Text

Issuance of Amendments Nos. 202 and 185 Regarding End State Revision from Hot Shutdown to Cold Shutdown for Several Technical Specifications
	ML19346E463
Person / Time
Site:	Vogtle
Issue date:	01/30/2020
From:	John Lamb; Plant Licensing Branch II
To:	Gayheart C; Southern Nuclear Operating Co
	Lamb J
References
	EPID L-2019-LLA-0148
	Download: ML19346E463 (29)
	v • d • e

January 30, 2020 Ms. Cheryl A. Gayheart Regulatory Affairs Director Southern Nuclear Operating Co., Inc.

3535 Colonnade Parkway Birmingham, AL 35243

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2, ISSUANCE OF AMENDMENT NOS. 202 AND 185, REGARDING END STATE REVISION FROM HOT SHUTDOWN TO COLD SHUTDOWN FOR SEVERAL TECHNICAL SPECIFICATIONS (EPID L-2019-LLA-0148)

Dear Ms. Gayheart:

The Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 202 to Renewed Facility Operating License No. NPF-68 and Amendment No. 185 to Renewed Facility Operating License No. NPF-81 for the Vogtle Electric Generating Plant (VEGP), Units 1 and 2, respectively. The amendments consist of changes to the License and Technical Specifications (TSs) in response to your application dated July 9, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19190A309), as supplemented by letter dated October 17, 2019 (ADAMS Accession No. ML19290H597).

The amendments revise the actions of TS 3.7.8, Nuclear Service Cooling Water (NSCW)

System, TS 3.8.1, AC Sources-Operating, TS 3.8.4, DC Sources - Operating, TS 3.8.7, Inverters - Operating, and TS 3.8.9, Distribution Systems - Operating. The amendments modify action end states for the subject TSs in conditions where more than one safety-related train is inoperable or the electrical power system is significantly degraded. Specifically, if the related required action statements are not met, then instead of requiring the plant to achieve Hot Shutdown (i.e., Mode 4), the end state of Cold Shutdown (i.e., Mode 5) is required.

By letter dated May 31, 2016 (ADAMS Accession No. ML16130A577), the NRC approved license Amendment Nos. 179 and 160 for VEGP, Units 1 and 2, respectively, to implement Technical Specifications Task Force (TSTF) traveler TSTF-432, Revision 1, Change in Technical Specifications End States (WCAP-16294), allowing a plant shutdown to hot conditions instead of cold conditions. By letter dated August 8, 2017 (ADAMS Accession No. ML15127A669), the NRC approved license Amendment Nos. 188 and 171 for VEGP, Units 1 and 2, respectively, to permit the use of Risk-Informed Completion Times (RICTs). The updated TS pages issued with Amendment Nos. 188 and 171 incorporating the RICT TS changes resulted in unintended consequences. The RICT TS changes allowed a Hot Shutdown end state instead of a Cold Shutdown end state following a loss of function condition for Component Cooling Water, NSCW, and electrical distribution systems, and following a significant degradation of the electrical power systems. The current amendments change this to require the plant to achieve Cold Shutdown (i.e., Mode 5) where more than one safety-related train is

C.

inoperable or the electrical power system is degraded significantly, if the related required action statements are not met.

A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commissions biweekly Federal Register notice.

Sincerely,

/RA/

John G. Lamb, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-424 and 50-425

Enclosures:

1. Amendment No. 202 to NPF-68

2. Amendment No. 185 to NPF-81

3. Safety Evaluation cc: Listserv

SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA DOCKET NO. 50-424 VOGTLE ELECTRIC GENERATING PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 202 Renewed License No. NPF-68

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment to the Vogtle Electric Generating Plant, Unit 1 (the facility) Renewed Facility Operating License No. NPF-68 filed by the Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated July 9, 2019, as supplemented by letter dated October 17, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations as set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-68 is hereby amended to read as follows:

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 202, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 30 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to License No. NPF-68 and the Technical Specifications Date of Issuance: January 30, 2020

SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA DOCKET NO. 50-425 VOGTLE ELECTRIC GENERATING PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 185 Renewed License No. NPF-81

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment to the Vogtle Electric Generating Plant, Unit 2 (the facility) Renewed Facility Operating License No. NPF-81 filed by the Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated July 9, 2019, as supplemented by letter dated October 17, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations as set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-81 is hereby amended to read as follows:

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 185, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 30 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to License No. NPF-81 and the Technical Specifications Date of Issuance: January 30, 2020

ATTACHMENT TO VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 LICENSE AMENDMENT NO. 202 RENEWED FACILITY OPERATING LICENSE NO. NPF-68 DOCKET NO. 50-424 AND LICENSE AMENDMENT NO. 185 RENEWED FACILITY OPERATING LICENSE NO. NPF-81 DOCKET NO. 50-425 Replace the following pages of the Licenses and the Appendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages License License License No. NPF-68, page 4 License No. NPF-68, page 4 License No. NPF-81, page 3 License No. NPF-81, page 3 TSs TSs 3.7.8-2 3.7.8-2 3.8.1-6 3.8.1-6 3.8.1-7 3.8.1-7 3.8.4-2 3.8.4-2 3.8.4-3 3.8.4-3 3.8.7-2 3.8.7-2 3.8.7-3 3.8.9-2 3.8.9-2 3.8.9-3 3.8.9-3 (1)

Maximum Power Level Southern Nuclear is authorized to operate the facility at reactor core power levels not in excess of 3625.6 megawatts thermal (100 percent power) in accordance with the conditions specified herein.

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 202, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3)

Southern Nuclear Operating Company shall be capable of establishing containment hydrogen monitoring within 90 minutes of initiating safety injection following a loss of coolant accident.

(4)

(5)

(6)

(7)

(8)

(9)

(10)

Deleted Deleted Deleted Deleted Deleted Deleted Mitigation Stratem'. License Condition The licensee shall develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a)

Fire fighting response strategy with the following elements:

1.

Pre-defined coordinated fire response strategy and guidance

2.

Assessment of mutual aid fire fighting assets

3.

Designated staging areas for equipment and materials

4.

Command and control

5.

Training and response personnel (b)

Operations to mitigate fuel damage considering the following:

1.

Protection and use of personnel assets

2.

Communications

3.

Minimizing fire spread

4.

Procedures for Implementing integrated fire response strategy

5.

Identification of readily-available pre-staged equipment

6.

Training on integrated fire response strategy Renewed Operating License NPF-68 Amendment No. 202 (2)

Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia, pursuant to the Act and 10 CFR Part 50, to possess but not operate the facility at the designated location in Burke County, Georgia, in accordance with the procedures and limitations set forth in this license; (3)

Southern Nuclear, pursuant to the Act and 10 CFR Part 70, to receive, possess, and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (4)

Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40, and 70 to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5)

Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; (6)

Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as my be produced by the operation of the facility authorized herein.

C.

This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter 1 and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect, and is subject to the additional conditions specified or incorporated below.

(1) Maximum Power Level Southern Nuclear is authorized to operate the facility at reactor core power levels not in excess of 3625.6 megawatts thermal (100 percent power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 185, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

The Surveillance requirements (SRs) contained in the Appendix A Technical Specifications and listed below are not required to be performed immediately upon implementation of Amendment No. 74. The SRs listed below shall be Renewed Operating License NPF-81 Amendment No. 185

ACTIONS (continued)

CONDITION B.

Required Action and B.1 associated Completion Time of Condition A not AND met.

B.2 C.

NOTES----------

C.1

1. Not applicable when second NSCWtrain intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.

Two NSCW trains inoperable.

D.

Required Action and D.1 associated Completion Time of Condition C not AND met.

D.2 AND D.3 Vogtle Units 1 and 2 REQUIRED ACTION Be in MODE 3.

NO TE-------------

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE4.

NOTE-------------

LCO 3.0.3 and all other LCO Required Actions requiring entry into MODE 5 are suspended until the NSCW System is capable of supporting the decay heat removal function of one RHR loop.

Restore NSCW trains to OPERABLE status.

Be in MODE 3.

Be in MODE 4.

Be in MODE 5.

3.7.8-2 NSCW 3.7.8 COMPLETION TIME 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Amendment No. 202 (Unit 1)

Amendment No. 185 (Unit 2)

ACTIONS (continued)

CONDITION F.

One automatic load F.1 sequencer inoperable.

G.

Required Action and G.1 associated Completion Time of Condition A, B, AND C, D, E, or F not met.

G.2 H.

NOTES----------

H.1

1. Not applicable when three or more required AC sources intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.

Three or more required AC sources inoperable.

Vogtle Units 1 and 2 REQUIRED ACTION Restore automatic load sequencer to OPERABLE status.

Be in MODE 3.

NOTE-~-----~---

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE 4.

Restore required inoperable AC sources to OPERABLE status.

3.8.1-6 AC Sources - Operating 3.8.1 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR In accordance with the Risk Informed Completion Time Program

( continued)

Amendment No. 202 (Unit 1)

Amendment No. 185 (Unit 2)

ACTIONS (continued)

CONDITION REQUIRED ACTION I.

Required Action and 1.1 Be in MODE 3.

associated Completion Time of Condition H not AND met.

1.2 Be in MODE 5.

SURVEILLANCE REQUIREMENTS SR 3.8.1.1 SR 3.8.1.2 SURVEILLANCE Verify correct breaker alignment and indicated power availability for each required offsite circuit.

NOTES-----------------------

1.

Performance of SR 3.8.1.7 satisfies this SR.

2.

All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

3.

A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met.

Verify each DG starts from standby conditions and achieves steady state voltage ~ 4025 V and

4330 V, and frequency ~ 58.8 Hz and

$; 61.2 Hz.

AC Sources - Operating 3.8.1 COMPLETION TIME 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.8.1-7 Amendment No. 202 (Unit 1)

Amendment No. 185 (Unit 2)

ACTIONS (continued)

CONDITION B.

One DC electrical power 8.1 source inoperable due to inoperable battery C or D.

AND 8.2 C.

One DC electrical power C.1 source inoperable for reasons other than Condition A or B.

D.

Required Action and 0.1 Associated Completion Time of Condition A, B, or AND C not met.

D.2 Vogtle Units 1 and 2 REQUIRED ACTION Verify SAT available Restore DC electrical power source to OPERABLE status.

Restore DC electrical power source to OPERABLE status.

Be in MODE 3.

NO TE------------

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE 4.

DC Sources - Operating 3.8.4 COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR In accordance with the Risk Informed Completion Time Program 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours (continued) 3.8.4-2 Amendment No. 202 (Unit 1)

Amendment No. 185 (Unit 2)

ACTIONS (continued)

CONDITION REQUIRED ACTION DC Sources - Operating 3.8.4 COMPLETION TIME E.

NOTES-----~---

E.1 Restore at least one DC 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

1. Not applicable when electrical power source second DC electrical to OPERABLE status.

power source intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and

h.

Two DC electrical power sources inoperable.

F.

Required Action and F.1 Be in MODE 3.

associated Completion Time of Condition E not AND met.

F.2 Be in MODE 5.

SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.8.4.1 Verify battery terminal voltage is greater than or equal to the minimum established float voltage.

Vogtle Units 1 and 2 3.8.4-3 OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours FREQUENCY In accordance with the Surveillance Frequency Control Program (continued)

Amendment No. 202 (Unit 1)

Amendment No. 185 (Unit 2)

ACTIONS CONDITION B.

Required Action and associated Completion Time of Condition A not met.

C.

NOTES------~-

1. Not applicable when two or more inverters intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and

h.

Two or more required inverters inoperable.

D.

Required Action and associated Completion Time of Condition C not met.

Vogtle Units 1 and 2 B.1 AND B.2 C.1 D.1 AND D.2 REQUIRED ACTION Be in MODE 3.

-~----------NOTE----~--~---

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE4.

Restore required inverters to OPERABLE status.

Be in MODE 3.

Be in MODE 5.

Inverters - Operating 3.8.7 COMPLETION TIME 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours 3.8.7-2 Amendment No. 202 (Unit 1)

Amendment No. 185 (Unit 2)

SURVEILLANCE REQUIREMENTS SR 3.8.7.1 SURVEILLANCE Verify correct inverter voltage and alignment to required AC vital buses.

Vogtle Units 1 and 2 3.8.7-3 Inverters - Operating 3.8.7 FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 202 (Unit 1)

Amendment No. 185 (Unit 2)

ACTIONS (continued)

CONDITION C.

One or more DC C.1 electrical power distribution subsystems inoperable.

D.

Required Action and D.1 associated Completion Time of Condition A, B, or AND C not met.

D.2 E.

NOTES-----~~

E.1

1. Not applicable when two or more electrical power subsystems intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and

h.

Two or more electrical power distribution subsystems inoperable that result in a loss of safety function.

Vogtle Units 1 and 2 Distribution Systems - Operating 3.8.9 REQUIRED ACTION COMPLETION TIME Restore DC electrical 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months power distribution subsystems to OR OPERABLE status.

In accordance with the Risk Informed Completion Time Program Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

--~---------NOTE-~-~-------

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Restore electrical power 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months distribution subsystems to OPERABLE status to OR restore safety function.

In accordance with the Risk Informed Completion Time Program (continued) 3.8.9-2 Amendment No. 202 (Unit 1)

Amendment No. 185 (Unit 2)

ACTIONS (continued)

CONDITION REQUIRED ACTION F.

Required Action and F.1 Be in MODE 3.

associated Completion Time of Condition E not AND met.

F.2 Be in MODE 5.

SURVEILLANCE REQUIREMENTS SURVEILLANCE Distribution Systems - Operating 3.8.9 COMPLETION TIME 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours FREQUENCY SR 3.8.9.1 Verify correct breaker alignments and voltage to required AC, DC, and AC vital bus electrical power distribution subsystems.

In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.8.9-3 Amendment No. 202 (Unit 1)

Amendment No. 185 (Unit 2)

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 202 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-68 AND AMENDMENT NO. 185 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-81 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-424 AND 50-425

1.0 INTRODUCTION

By application dated July 9, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19190A309), as supplemented by letter dated October 17, 2019 (ADAMS Accession No. ML19290H597), Southern Nuclear Operating Company, Inc. (SNC, the licensee), requested changes to the Technical Specifications (TSs) for the Vogtle Electric Generating Plant (VEGP), Units 1 and 2.

The proposed amendments would revise the actions of TS 3.7.7, Component Cooling Water (CCW) System, TS 3.7.8, Nuclear Service Cooling Water (NSCW) System, TS 3.8.1, AC

[Alternating Current] Sources - Operating, TS 3.8.4, DC [Direct Current] Sources - Operating, TS 3.8.7, Inverters - Operating, and TS 3.8.9, Distribution Systems - Operating. With the supplemental information provided on October 17, 2019, the proposed revision to TS 3.7.7 was withdrawn by SNC.

The proposed amendments would modify action end states for the subject TSs in conditions where more than one safety-related train is inoperable or the electrical power system is significantly degraded. Specifically, if the related required action statements are not met, then instead of requiring the plant to achieve Hot Shutdown (i.e., Mode 4), the end state of Cold Shutdown (i.e., Mode 5) would be required.

By letter dated May 31, 2016 (ADAMS Accession No. ML16130A577), the U.S. Nuclear Regulatory Commission (NRC, the Commission) approved license Amendment Nos. 179 and 160 for VEGP, Units 1 and 2, respectively, to implement Technical Specifications Task Force (TSTF) traveler TSTF-432, Revision 1, Change in Technical Specifications End States (WCAP-16294), allowing a plant shutdown to hot conditions instead of cold conditions.

By letter dated August 8, 2017 (ADAMS Accession No. ML15127A669), the NRC approved license Amendment Nos. 188 and 171 for VEGP, Units 1 and 2, respectively, to permit the use of Risk-Informed Completion Times (RICTs). The updated TS pages issued with Amendment Nos. 188 and 171 incorporating the RICT TS changes resulted in unintended consequences.

The RICT TS changes allowed a Hot Shutdown end state instead of Cold Shutdown end state following a loss of function condition for CCW, NSCW, and electrical distribution systems, and following a significant degradation of the electrical power systems.

The supplemental letter dated October 17, 2019, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staffs original proposed no significant hazards consideration determination as published in the Federal Register on August 29, 2019 (84 FR 45547).

2.0 REGULATORY EVALUATION

For further details of the system design and operation, see the letter dated July 9, 2019.

2.1

System Design

2.1.1 NSCW System Design The NSCW system provides a heat sink for the removal of process and operating heat from safety-related components during a design-basis accident (DBA) or transient. During normal operation and a normal shutdown, the NSCW system also provides this function for various safety-related and non-safety-related components.

The NSCW system consists of two separate, 100-percent capacity, safety-related, cooling water trains. Each train consists of three 50-percent capacity pumps and various safety-and non-safety-related component heat exchangers, piping, valving, and instrumentation. The pumps and valves are remotely and manually aligned, except in the unlikely event of a loss-of-coolant accident (LOCA). The pumps are started automatically upon receipt of a safety injection (SI) signal, and all essential valves are aligned to their post-accident positions.

The NSCW supports the residual heat removal (RHR) system decay heat removal via the CCW system and the on-site emergency diesel generators (EDGs) in Modes 5 and 6. These safety-related functions are covered by TS limiting condition for operation (LCO) 3.7.8, which requires that two NSCW trains shall be operable in Modes 1, 2, 3, and 4.

The operability requirements for the NSCW system in Modes 5 or 6 are determined by the systems it supports. Both trains of RHR are required to be operable in Mode 5 with one RHR loop in operation in accordance with TS 3.4.8, RCS [Reactor Coolant System] Loops - MODE 5, Loops Not Filled, and in Mode 6 in accordance with TS 3.9.6, Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level.

One train of RHR is required to be operable in Mode 5 with secondary water level above the highest point of the steam generator U-tubes on at least two Steam Generators in accordance with TS 3.4.7, RCS Loops - MODE 5, Loops Filled, and one train of RHR is required to be operable and in operation in Mode 6 in accordance with TS 3.9.5, Residual Heat Removal (RHR) and Coolant Circulation - High Water Level. One EDG is required to be operable in Modes 5 and 6 in accordance with TS 3.8.2, AC Sources - Shutdown.

The principal safety-related function of the CCW system is the removal of residual and decay heat from the RHR system during a DBA or transient. The CCW system also transfers heat from the RHR system to the NSCW system during normal reactor shutdown and cooldown. The safety-related function of the CCW system is covered by TS 3.7.7 Component Cooling Water (CCW) System, which requires that two CCW trains shall be operable in Modes 1, 2, 3, and 4.

The operability requirements for the CCW system in Mode 5 or 6 are determined by the RHR system it supports. The CCW system serves as a barrier to the release of radioactive byproducts between the potentially radioactive systems it supports and the NSCW system, and thus, to the environment.

2.1.2 Alternating Current (AC) Sources The Class 1E AC electrical power distribution system and AC sources consist of the offsite power sources, preferred power sources, normal and alternates, and the onsite standby power sources, Train A and Train B EDGs. The AC electrical power system provides independent and redundant sources of power to the engineered safeguards features (ESF) system.

2.1.3 Direct Current (DC) Sources The station DC electrical power system provides the AC emergency power system with control power. It also provides both motive and control power to selected safety-related equipment and preferred AC vital bus power via inverters. There are four safety features 125 volts direct current (VDC) systems per unit.

2.1.4 Inverters Through the use of an inverter, the station batteries can provide AC electrical power to the vital buses. The inverters provide the preferred source for the reactor protection system, ESF actuation system, the nuclear steam supply system control and instrumentation, the post-accident monitoring system, and the safety-related radiation monitoring system. The station batteries ensure that an uninterruptible power source is available for these devices.

2.1.5 Electrical Distribution Systems The onsite Class 1E AC electrical power distribution systems are divided by train into two redundant and independent AC electrical power distribution subsystems. The DC and AC vital buses are divided into four channels of distribution, two channels of which are associated with each train. The AC electrical power subsystem for each train consists of a primary ESF 4.16 kV bus and secondary 480 and 120 V buses, distribution panels, motor control centers, and load centers.

2.2 Licensees Proposed Changes TS 3.7.7 Component Cooling Water (CCW) System In the license amendment request (LAR) dated July 9, 2019, SNC included proposed changes to the TS 3.7.7 required actions for the CCW system for an end state of Cold Shutdown (Mode

5) for two inoperable CCW trains. However, in its response to a request for additional information provided in Enclosure 1 to the letter dated October 17, 2019, SNC determined that the existing TS 3.7.7 action to remain in Hot Shutdown (Mode 4) where the steam generators (SGs) provide the removal of decay heat would be preferred with two inoperable CCW trains.

The licensee provided the following justification:

Per LCO 3.0.6, when a supported system LCO is not met solely due to a support system LCO not being met, the conditions and required actions associated with the supported system are not required to be entered. However, if a loss of safety function exists per the safety function determination program (Specification 5.5.15), the appropriate conditions and required actions of the LCO in which the loss of safety function exists are required to be entered.

The supported emergency core cooling system (ECCS) LCOs affected by two inoperable CCW trains in Modes 1 2, 3, and 4 are LCO 3.5.2 and LCO 3.5.3 due to the inability of the RHR system to provide ECCS long term cooling. The actions of neither TS 3.5.2, ECCS - Operating, or TS 3.5.3, ECCS -

Shutdown, require cooldown to Mode 5 when both RHR subsystems are inoperable.

The decay heat removal function of the RHR system is not required in Mode 1, 2, or 3. The supported decay heat removal LCO affected by two inoperable CCW trains in Mode 4 is LCO 3.4.6, due to the inability for the RHR system to provide the decay heat removal function. The actions of TS 3.4.6, RCS Loops - MODE 4, do not require Mode 5 entry unless both RCS loops are inoperable concurrent with one or more RHR loops inoperable. As a result, a cooldown to Mode 5 is not currently required when two CCW trains are inoperable as long as one RCS loop is operable (i.e., an operable reactor coolant pump and an operable SG, including a means to provide feedwater and remove the decay heat). Based on this, SNC is hereby withdrawing the proposed change to TS 3.7.7 as requested in the July 9, 2019 license amendment request restoring the current end state of Mode 4 when two trains of CCW are not restored to operable status within the required completion time.

This safety evaluation acknowledges the withdrawal of proposed changes to TS 3.7.7.

2.3 Regulatory Requirements Section 50.90, Application for amendment of license, construction permit, or early site permit, of Title 10 of the Code of Federal Regulations (10 CFR) requires that whenever a holder of a license wishes to amend the license, including TSs in the license, an application for amendment must be filed, fully describing the changes desired. The regulation 10 CFR 50.92(a), Issuance of amendment, provides considerations for determinations on whether to issue an applied-for license amendment.

The regulation at 10 CFR 50.36(c)(2) requires that TSs contain LCOs, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the LCO can be met.

Appendix A, General Design Criteria [GDC] for Nuclear Power Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, provides, in part, the necessary design, fabrication, construction, testing, and performance requirements for structures, systems, and components important to safety.

Criterion 17, Electric power systems, states, in part, that an onsite electric power system and an offsite electric power system be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents.

The onsite electric power supplies, including the batteries, and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure.

Criterion 38, Containment heat removal, requires the provision of a containment heat removal system that will rapidly reduce containment pressure and temperature following any LOCA and maintain them at acceptably low levels.

Criterion 41, Containment atmosphere cleanup, requires that systems to control fission products, hydrogen, oxygen, and other substances which may be released into the reactor containment shall be provided as necessary to reduce, consistent with the functioning of other associated systems, the concentration and quality of fission products released to the environment following postulated accidents, and to control the concentration of hydrogen or oxygen and other substances in the containment atmosphere following postulated accidents to assure that containment integrity is maintained.

RG 1.93, Availability of Electric Power Sources, Revision 1 (ADAMS Accession No. ML090550661), describes operating procedures and restrictions acceptable to the NRC staff which should be implemented if the available electric power sources are less than the LCO.

3.0 TECHNICAL EVALUATION

3.1 NRC Staff Evaluation of TS 3.7.8 Proposed Changes The NRC staff reviewed the LAR dated July 9, 2019, as supplemented by letter dated October 17, 2019, and the content of SNCs proposed changes to TS 3.7.8.

The proposed changes to TS 3.7.8 would reverse the order of Conditions B and C, and add new Condition D.

Condition A remains unchanged; Existing Condition C, which currently applies when either the required action and completion time of existing Conditions A or B are not met, would be modified to apply only when Condition A is not met. Existing Condition C would be re-labeled as Condition B since it relates to Condition A; Existing Condition B would be re-labeled as Condition C. A Note that would allow an alternate end state of Mode 4 until the NSCW system is capable of supporting the decay heat removal function of one RHR loop would be added to re-labeled Condition C; and New Condition D would be added, which would apply when the required action and associated completion time of re-labeled Condition C are not met.

Proposed Condition B is revised to link its relevance to the failure to satisfy the Completion Time of Condition A. Condition A pertains to One NSCW train inoperable.

The NRC staffs SE dated March 29, 2010 (ADAMS Accession No. ML100770146),

pertaining to WCAP-16294-NP, Revision 0, evaluated the end state change pertaining to STS 3.7.8 in Section 3.1.23, TS 3.7.8 - Service Water System (SWS). The NRC staffs assessment concluded that:

Table 3.2.1 of this SE shows that cooldown to Mode 4, rather than cooling down to Mode 5, reduces overall risk of the shutdown process when a train of the SWS is inoperable. One SWS train will be operating when the unit enters Mode 4. Each train is designed to handle 100 percent of the heat loads during power operation and accident conditions. The heat loads will be significantly less in the shutdown modes and some accidents are less likely to occur. Therefore, sufficient defense-in-depth is maintained when the end state is changed from Mode 5 to Mode 4 provided LCO 3.0.4.a is not applicable for entry into Mode 4.

The NRC staff notes that WCAP-16294-NP, Revision 0, was intended to apply when only one train of a system is inoperable and proposed Condition B is consistent with this intent.

The WCAP-16294-NP and the NRC staffs SE served as the foundation for the NRC staffs approval of TSTF-432, Revision 1. Condition A and proposed Condition B of VEGP TS 3.7.8 are consistent with the direction of TSTF-432, Revision 1, and with the format of TS 3.7.8 (ADAMS Accession No. ML103360003).

The TS 3.7.8 Condition A and proposed Condition B satisfy the NRC staffs intent for the previously approved changes (i.e., Amendment Nos. 188 and 171) as detailed in the NRC staffs SE for those amendments. These changes were detailed in Section 1.2.3 Application of the RICT Program to Existing LCOs and Conditions of that SE.

Based on the above, the NRC staff finds that current Condition A and proposed Condition B of VEGP TS 3.7.8:

comply with the direction provided in TSTF-432, Revision 1; and continues to satisfy 10 CFR 50.36(c)(2)(i).

The licensee proposed adding new Condition D to TS 3.7.8. Condition D applies when the required actions of Condition C are not met within the Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or a licensee derived Risk Informed Completion Time, as appropriate. Condition C pertains to Two NSCW trains inoperable, and the RICT applies only when the specified constraints of VEGP TS 5.5.22, Risk Informed Completion Time Program, are satisfied.

Entry into proposed Condition D represents a TS loss of function (TS LOF), which encompasses those TS conditions with insufficient TS operable equipment to meet the specified safety function of the system. Section 3.1.2, Key Principle 2: Evaluation of Defense-in-Depth, of the NRC staffs SE for Amendment Nos. 188 and 171 states, in part:

SNC proposed a 24-hour instead of a 30-day backstop to be applied for TS LOF conditions. A 24-hour backstop upon loss of operability is consistent with the maximum acceptable CT in TSTF-426, Revise or Add Actions to Preclude Entry into LCO 3.0.3 - RITSTF [Risk-Informed TSTF] Initiatives 6b & 6c ADAMS (Reference 66). The TSTF-426 traveler supports extending the time before shutdown upon loss of TS operability from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months up to a maximum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months based on an in-depth evaluation on the impact of the loss of operability on the design basis and the development of additional, pre-identified defense-in-depth RMA [risk management actions] measures included in the TSs.

Accordingly, proposed Condition C, Note 2, specifies that VEGP TS 5.5.22 constraint e applies, which permits the use of the RICT during inoperability of all required trains of a system required to be operable if one or more trains are considered PRA Functional as defined in Section 2.3.1 of NEI 06-09. Also, a licensee derived RICT for proposed Condition C remains limited to a maximum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in accordance with VEGP TS 5.5.22 constraint e. No changes to the attributes of the Risk Informed Completion Time Program are being proposed in the subject LAR.

The submittal dated July 9, 2019, proposed a Required Action and an associated Completion Time for Condition D specifying Required Actions D.1 be in Mode 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , D.2 be in Mode 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and an endstate change D.3 be in Mode 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months for two inoperable NSCW trains (i.e., instead of a change to Mode 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months as contained in the existing TS Condition C).

The NRC staff requested additional information about the proposed endstate change to Mode 5 with two trains of NSCW inoperable and potentially PRA non-functional. The NRC staff noted that the proposed Condition D would direct the plant to attain MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months without the required support systems (i.e., NSCW) available to support this plant progression (ADAMS Accession No. ML19290H597).

In response, the licensee acknowledged that with both NSCW trains inoperable, the residual heat removal (RHR) system may be incapable of supporting the decay heat removal function when transitioning to Mode 5. With the RHR system incapable of supporting decay heat removal, no other practical means for conducting a cooldown to Mode 5 exists. In such a condition, it would be preferred that the unit remain in Mode 4 where the SGs provide the removal of decay heat. The licensee noted that the NSCW system supports multiple systems whose TS actions require Mode 5 entry when both trains of NSCW are inoperable.

Given this, the following Note was proposed to be added to proposed TS 3.7.8 Required Action C.1 for two NSCW trains inoperable:

LCO 3.0.3 and all other LCO Required Actions requiring entry into MODE 5 are suspended until the NSCW System is capable of supporting the decay heat removal function of one RHR loop.

Implementation of the proposed note would in effect result in an alternate end state of Mode 4 until the NSCW system can support the decay heat removal function of one RHR loop.

Furthermore, the proposed note would not remove the need in Mode 4 to restore an RHR subsystem to operable status while in this condition. If both trains of the NSCW system were inoperable, the LCO requirements for TS 3.5.3 ECCS - Shutdown with an Applicability of Mode 4 may not be met. Condition A of TS 3.5.3 would require immediate initiation of action to restore an ECCS RHR subsystem to OPERABLE status, which would necessitate restoring an NSCW subsystem as necessary to support the ECCS function. With both trains of the NSCW inoperable, the RHR pumps may be incapable of removing the required decay heat load via the RHR heat exchangers. When applying the proposed note, the LCO 3.0.3 requirement and all other TS action requirements to enter Mode 5 would be suspended due to the impracticality of Mode 5 entry in this configuration. TS 3.7.8 has an Applicability of MODES 1, 2, 3, and 4; therefore, the NSCW system is not required to be operable in Mode 5.

Furthermore, the proposed note would not suspend entry into Mode 5 until the NSCW system is restored to operable status. Instead the note suspends the cooldown to Mode 5 conditions until the NSCW system is restored as necessary to support the decay heat removal function of at least one RHR subsystem.

To this end, TS 3.4.7, RCS Loops - MODE 5, Loops Filled, with an Applicability of MODE 5 with RCS loops filled provides the requirements for the decay heat removal function of an RHR loop and ensures an operable RHR pump is capable of providing forced flow to an operable RHR heat exchanger prior to entry into Mode 5.

In addition, as part of the RAI response, Required Action D.2 to be in Mode 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months was also added to proposed Condition D. This addition is an intermediate Required Action between Mode 3 and Mode 5 of TS 3.7.8. The completion time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to reach Mode 4 is consistent with the time to reach Mode 4 in proposed Required Action B.2 of TS 3.7.8. In addition, the completion time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is consistent with other TS required actions to be in Mode 4.

Based on the above, the NRC staff finds that proposed Condition C and proposed Condition D of VEGP TS 3.7.8:

would comply with the guidance provided in NEI 06-09 Revision 0-A; and continues to satisfy 10 CFR 50.36(c)(2)(i).

The CCW and NSCW systems are designed to the applicable criteria of the 10 CFR Part 50, Appendix A, General Design Criteria for Nuclear Power Plants, as previously licensed and approved by the NRC. The proposed changes to TS 3.7.8 do not alter the design or operation of these systems and they continue to meet their applicable GDC.

The constraints imposed by TS 3.7.8, including the proposed changes, ensure that PRA functionality will be met any time a RICT is exercised, and that the plant will be operated in accordance with its design and licensing basis.

Based on the above, the NRC staff finds that the requirements of 10 CFR 50.36 continue to be met for the proposed changes to TS 3.7.8.

3.2 NRC Staff Evaluation of TSs 3.8.1, 3.8.4, 3.8.7, and 3.8.9 Proposed Changes The NRC staff reviewed information pertaining to the proposed electrical power systems TS conditions in the application, the VEGP Updated Final Safety Analysis Report (UFSAR), and applicable TS completion times, end states, and actions to verify that the capability of the affected electrical power systems to perform their safety functions is maintained.

By letter dated May 31, 2016 (ADAMS Accession No. ML16130A577), the NRC issued license Amendment Nos. 179 and 160 for VEGP, Units 1 and 2, respectively, to implement TSTF-432, Revision 1, allowing a plant shutdown to Hot Shutdown (MODE 4) instead of Cold Shutdown (MODE 5) based on a Westinghouse analysis summarized in WCAP-16294-NP-A.

On August 8, 2017 (ADAMS Accession No. ML15127A669), the NRC issued license Amendment Nos. 188 and 171 for VEGP, Units 1 and 2, respectively, to permit the use of RICT in accordance with NEI 06-09-A, Revision 0-A.

The NRC staff finds that the proposed changes to the TS 3.8.1, 3.8.4, 3.8.7, and 3.8.9 conditions and required actions are more restrictive than the existing conditions and required actions (i.e., the plant is to be placed in cold shutdown (MODE 5) within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , instead of hot shutdown (MODE 4) within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ). In MODE 5, the plant would be required to cooldown and depressurize to a condition such that the LCO does not apply (i.e., 200°F) with the minimum required electric power systems. Placing the plant in MODE 5 is consistent with the NRC staff positions provided in RG 1.93. Therefore, the NRC staff finds that the proposed license amendments, which modify action end states to cold shutdown (MODE 5) for the subject TSs in conditions where more than one safety-related train is inoperable, or the electrical power system is significantly degraded, are acceptable, because placing the unit in cold shutdown (MODE 5) is considered a safe condition, as most design-basis accidents and transients either cannot physically occur during cold shutdown or would have significantly reduced plant impact and occur much less frequently due to the reduced temperatures and pressures in the plant.

Based on the above, the NRC staff concludes that the proposed TS changes provide reasonable assurance that the licensee will continue to comply with the requirements of 10 CFR Part 50, Appendix A, GDC 17, 38, and 41, and 10 CFR 50.36(c)(2).

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Georgia State official was notified on October 15, 2019, of the proposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration (84 FR 45547 dated August 29, 2019), and there has been no public comment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: Roy Mathew, NRR/EEOB Eric Lysiak, NRR/EEOB Steve Jones, NRR/SCPB David Nold, NRR/SCPB John Lamb, NRR/DORL Date: January 30, 2020

ML19346E463

via email OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DSS/SCPB/BC NRR/DE/EEOB/BC NAME JLamb KGoldstein BWittick*

DWilliams (A)*

DATE 10/18/2019 12/17/2019 12/06/2019 09/30/2019 OFFICE NRR/DSS/STSB/BC OGC - NLO NRR/DORL/LPL2-1/BC NRR/DORL/LPL2-1/PM NAME VCusumano*

JWachutka*

MMarkley JLamb DATE 12/19/2019 01/9/2020 01/15/2020 01/30/2020

v t e Letter Sequence Approval
EPID:L-2019-LLA-0148, TSTF-432 (Approved, Closed)
Initiation Request, Request, Request, Request Acceptance Administration Meeting Questions 19 September 2019 Answers 17 October 2019 Results Approval Other:
MONTHYEAR2019-08-02 [Table View]

ML19346E463

Text

SUBJECT:

Dear Ms. Gayheart:

Enclosures:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

System Design

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

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