ML20069A003

COL Docs - FW: Request for 2nd Psm on Thurs. March 19, 2020 - Request for Exemption to 10CFR52, Appendix D (Compliance with Tier 1 plant-specific DCD)

ML20069A003
Person / Time
Site:	Vogtle
Issue date:	03/09/2020
From:	NRC
To:	NRC/NRR/DNRL
References
Download: ML20069A003 (20)

Text

From:

Rankin, Jennivine Sent:

Monday, March 9, 2020 6:49 AM To:

Vogtle PEmails

Subject:

FW: RE: Request for 2nd PSM on Thurs. March 19, 2020 - Request for Exemption to 10CFR52, Appendix D (Compliance with Tier 1 plant-specific DCD)

Attachments:

Draft Tier 1 Plant-Specific DCD Exemption Request.pdf For discussion at 3/19 pre-submittal meeting.

From: Agee, Stephanie Y. <SYAGEE@southernco.com>

Sent: Friday, March 06, 2020 2:40 PM To: Rankin, Jennivine <Jennivine.Rankin@nrc.gov>

Cc: Chamberlain, Amy Christine <ACCHAMBE@southernco.com>; Amundson, Theodore Edwin

<X2TAMUNS@southernco.com>; Arafeh, Yasmeen N. <YNARAFEH@southernco.com>; Santos, Cayetano

<Cayetano.Santos@nrc.gov>; Humphrey, Mark Phillips <MPHUMPHR@southernco.com>

Subject:

[External_Sender] RE: Request for 2nd PSM on Thurs. March 19, 2020 - Request for Exemption to 10CFR52, Appendix D (Compliance with Tier 1 plant-specific DCD)

Hi Jennie, Attached is our DRAFT Exemption request that we would like to discuss during a pre-submittal meeting on March 19th. To assist with the pre-submittal discussion, I will be sending a presentation to you next week. Please let me know if the staff can support this topic.

I appreciate your help!

Stephanie Agee ND Licensing Supervisor Nuclear Development Regulatory Affairs Southern Nuclear Operating Company a Southern Company 205-992-7556 From: Humphrey, Mark Phillips <MPHUMPHR@southernco.com>

Sent: Wednesday, March 4, 2020 10:41 AM To: Rankin, Jennivine <Jennivine.Rankin@nrc.gov>; Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Chamberlain, Amy Christine <ACCHAMBE@southernco.com>; Agee, Stephanie Y.

<SYAGEE@southernco.com>; Amundson, Theodore Edwin <X2TAMUNS@southernco.com>; Arafeh, Yasmeen N. <YNARAFEH@southernco.com>; Grant, Eddie <X2EDGRAN@SOUTHERNCO.COM>

Subject:

Request for 2nd PSM on Thurs. March 19, 2020 - Request for Exemption to 10CFR52, Appendix D (Compliance with Tier 1 plant-specific DCD)

Jennie/ Tanny -

In addition to the planned pre-submittal meeting for the ITAAC 195 LAR, SNC requests that the Staff support a 2nd PSM on March 19, 2020. The topic for the 2nd PSM is a Request for Exemption from the requirements of 10 CFR Part 52, Appendix D, to maintain and comply with the Tier 1 plant-specific DCD after the completion of the initial test phase of the project. This exemption request was discussed during a VRG earlier this year.

In support of a March 19, 2020 PSM for the Exemption Request, SNC can submit draft enclosures by Friday, March 6, 2020. Following, a PowerPoint presentation to be used during the PSM can be provided the week of March 9, 2020. Due to the current caution on air travel, SNC proposes this topic also be discussed via teleconference. We propose this to be the 2nd topic on the March 19th agenda, as the ITAAC 195 LAR PSM is anticipated to require less discussion because of a measure of alignment gained during the Feb. 13, 2020 technical exchange.

Thanks for considering this 2nd PSM for March 19, 2020. We look forward to your response.

Respectfully, Mark P. Humphrey Licensing Supervisor Nuclear Development Southern Nuclear 3535 Colonnade Parkway Birmingham, AL 35243 O: 205.992.6452 C: 205.215.5152 mphumphr@southernco.com From: Rankin, Jennivine <Jennivine.Rankin@nrc.gov>

Sent: Wednesday, March 4, 2020 5:52 AM To: Humphrey, Mark Phillips <MPHUMPHR@southernco.com>; Santos, Cayetano

<Cayetano.Santos@nrc.gov>

Subject:

RE: Request for PSM on Thurs. March 19, 2020 - LAR to Address ITAAC 195 Non-Material Issue EXTERNAL MAIL: Caution Opening Links or Files Good morning Mark -

The staff is able to support a 3/19 PSM for this LAR. We are looking forward to receiving the draft tomorrow and the discussion.

Thanks, Jennie

From: Humphrey, Mark Phillips <MPHUMPHR@southernco.com>

Sent: Monday, March 02, 2020 1:28 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Rankin, Jennivine <Jennivine.Rankin@nrc.gov>

Subject:

[External_Sender] Request for PSM on Thurs. March 19, 2020 - LAR to Address ITAAC 195 Non-Material Issue Hi Tanny - I left a phone message on this topic and am following up by email in case you are travelling this week.

SNC is requesting a pre-submittal meeting on Thursday, March 19, 2020 to discuss a planned LAR to address a non-material change needed to ITAAC 195 (Transportable Debris). The proposed LAR would be the first using the streamlined format for LARs addressing non-material ITAAC issues, as discussed with the staff on February 13, 2020.

In support of the proposed PSM, SNC can provide a draft of the LAR enclosures on or before Thursday, March 5, 2020. We believe this PSM can effectively take place via teleconference but could support a face to face meeting if the staff prefers.

We look forward to your response.

Respectfully, Mark P. Humphrey Licensing Supervisor Nuclear Development Southern Nuclear 3535 Colonnade Parkway Birmingham, AL 35243 O: 205.992.6452 C: 205.215.5152 mphumphr@southernco.com

Hearing Identifier:

Vogtle_COL_Docs_Public Email Number:

542 Mail Envelope Properties (MN2PR09MB489173537C43AD9D4A964EDC98FE0)

Subject:

FW: RE: Request for 2nd PSM on Thurs. March 19, 2020 - Request for Exemption to 10CFR52, Appendix D (Compliance with Tier 1 plant-specific DCD)

Sent Date:

3/9/2020 6:48:56 AM Received Date:

3/9/2020 6:49:01 AM From:

Rankin, Jennivine Created By:

Jennivine.Rankin@nrc.gov Recipients:

"Vogtle PEmails" <Vogtle.PEmails@nrc.gov>

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MN2PR09MB4891.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 5517 3/9/2020 6:49:01 AM image001.gif 2058 Draft Tier 1 Plant-Specific DCD Exemption Request.pdf 739194 Options Priority:

Normal Return Notification:

No Reply Requested:

No Sensitivity:

Normal Expiration Date:

Southern Nuclear Operating Company ND-20-0244 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Exemption Request:

10 CFR Part 52, Appendix D Tier 1 Plant-Specific DCD Requirements (This Enclosure consists of 15 pages, including this cover page) ting Plant (VEGP) Units 3 and 4 GP) Units 3 Exemption on Request:

Request:

52, Appendix D Tier x D Tie 1 Plant 1 Plant-Specific DCD Specific DCD R

ND-20-0244 Exemption Request: 10 CFR Part 52, Appendix D Tier 1 Plant-Specific DCD Requirements Page 2 of 15 Table of Contents 1.0 PURPOSE

2.0 BACKGROUND

3.0 TECHNICAL JUSTIFICATION OF ACCEPTABILITY 4.0 JUSTIFICATION FOR EXEMPTION 4.1 This exemption is authorized by law 4.2 This exemption will not present an undue risk to the health and safety of the public 4.3 The exemption is consistent with the common defense and security 4.4 Special circumstances are present 5.0 RISK ASSESSMENT 6.0 PRECEDENT EXEMPTIONS 7.0 SIGNIFICANT HAZARDS DETERMINATION AND ENVIRONMENTAL CONSIDERATIONS

9.0 REFERENCES

Draft sk to the health and safety to the health and s ommon defense and security defense and security t

S DS DETERMINATION AND ENVIRONMENTA ATION AND ENVIRONM CES ES

ND-20-0244 Exemption Request: 10 CFR Part 52, Appendix D Tier 1 Plant-Specific DCD Requirements Page 3 of 15 1.0 PURPOSE In accordance with the provisions of 10 CFR 52.7, Specific Exemptions, and § 50.12, Specific Exemptions, Southern Nuclear Operating Company (SNC) requests an exemption from the requirements of 10 CFR Part 52, Appendix D, regarding requirements to maintain a Tier 1 plant-specific Design Control Document (DCD) during the operating phase of a Combined License (COL). The requested exemption would permit SNC to designate the Tier 1 plant-specific DCD as historical information, no longer update the Tier 1 plant-specific DCD, nor evaluate future changes to Tier 2 plant-specific DCD information for impact to Tier 1 information. The exemption request does not involve changes to Tier 2 plant-specific DCD requirements. The exemption request also does not involve the generic design control document defined in the appendix. The definitions for plant-specific DCD and Tier 1 as defined in 10 CFR Part 52, Appendix D, are provided below:

Plant-specific DCD means the document maintained by an applicant or licensee who references this appendix consisting of the information in the generic DCD as modified and supplemented by the plant-specific departures and exemptions made under Section VIII of this appendix.

Tier 1 means the portion of the design-related information contained in the generic DCD that is approved and certified by this appendix (Tier 1 information). The design descriptions, interface requirements, and site parameters are derived from Tier 2 information. Tier 1 information includes:

1. Definitions and general provisions;

2. Design descriptions;

3. Inspections, tests, analyses, and acceptance criteria (ITAAC);

4. Significant site parameters; and

5. Significant interface requirements.

Specifically, SNC is requesting an exemption from 10 CFR Part 52, Appendix D, paragraph III.B, which requires compliance with Tier 1, paragraph VIII.B.5.a, which requires departures from Tier 2 information that involve Tier 1 information receive prior NRC approval, and paragraph X.A.2, which requires a licensee who references the appendix to maintain the plant-specific DCD for the term of the license.

The exemption is necessary because an underlying purpose of the Tier 1 plant-specific DCD will be obviated at the end of the initial testing phase for each VEGP Unit. In addition, it is not anticipated that additional AP1000 nuclear power plants will be licensed and complete construction in the foreseeable future; therefore, the benefits of maintaining standardization of VEGP 3&4 with the AP1000 design certification have been significantly reduced.

Not maintaining the Tier 1 DCD will allow SNC to realize efficiencies by simplifying the Tier 2 plant-specific DCD change process and will allow Draft r

D as h uate future ch future ch mation matio. The exemp

. The exem D requirements.

requirements. The exe Th trol document defined in the document defined in t ap r 1 as defined in 10 CFR Part 52, Ap efined in 10 CFR Part 5 ocument maintained by an applicant or licen y an applicant or licen isting of the information in the generic DCD a e information in the gene plant-specific departures and exemptions cific departures and exempt dix.

rtion of the design sign-related information conta ed information ved and certified by this appendix (Tier ertified by this appendix (Tier 1 in 1 in terface requirements, and site parameters rements, and site parameters ier 1 information includes:

ation in ons and general provisions; ns and general provisio sign descriptions; ign descriptions; Inspections, tests, analyses, and acceptance Inspections, tests, analyses, and accep

4. Significant site parameters; and

4. Significant site parameters; a

5. Significant interface requirements.

5. Significant interface requirem cally, SNC is requesting an cally, SNC is requesting III.B, which requires III.B, which require artures from Tier artures from Tie and parag and parag n the n th

ND-20-0244 Exemption Request: 10 CFR Part 52, Appendix D Tier 1 Plant-Specific DCD Requirements Page 4 of 15 SNC to effectively merge administrative change processes and procedures with other SNC operating reactors.

2.0 BACKGROUND

10 CFR Part 52 was first issued on April 18, 19891 in part to encourage standardization of nuclear power plant design and to provide for the early resolution of safety and environmental issues in licensing proceedings. The original version of 10 CFR Part 52 provided for procedures to be followed to apply for the certification of a nuclear power plant design and provided information to be submitted for NRC review and approval but did not specify the level of design detail to be provided in order for NRC staff to be able to complete their review and approval other than the phrase essentially complete nuclear power plant design. The statements of consideration (SOCs) expanded the definition of essentially complete to mean - includes all structures, systems, and components which can affect safe operation of the plant except for site-specific elements such as the service water intake structure and the ultimate heat sink. Consequently, initial design certification applications did not meet the NRCs expectations for level of detail and after several interactions between the industry and the NRC, the industry proposed a multi-tier approach to design certification.

In SECY-90-377 [ADAMS Accession Number ML003707889] the NRC approved a two-tier approach, which contained the following attributes:

Tier 1 Tier 1 will include information developed during the conceptual phase, such as design criteria and bases and certain information developed during the preliminary and detailed design phases, such as the following:

o System and key component descriptions o

Functional and performance requirements for plant systems o

Simplified electrical single-line diagrams o

Simplified piping and instrumentation drawings (P&IDs) o General arrangement drawings o

Inspection, test, analysis, and acceptance criteria (ITAAC)

Typical design products that provide the information to be included in Tier 1 are further defined in Attachments B and C to Appendix A. In developing the Tier 1 requirements, the staff sought to standardize design details to the maximum extent practical, considering the procurement and design reconciliation process.

Tier 1 information will be certified by the rulemaking process and will not be changed without previous NRC approval (through an amendment rulemaking, an exemption pursuant to 10 CFR 52.63, or a waiver pursuant to 10 CFR 2.758) for 1 54 Federal Register Vol. 73 15372, April 18, 1989 Draft early original versio nal r the certification o r the certification bmitted for NRC review a mitted for NRC rev e provided in order for NRC sta ovided in order for NR other than the phrase essentially han the phrase essen atements of consideration (SOCs) expand consideration (SOCs) expand to mean - includes all structures, system ncludes all structures, system e operation of the plant except for site of the plant except for

-specific ake structure and the ultimate heat sink. C re and the ultimate heat s pplications did not meet the NRCs expectat did not meet the NRCs expect interactions between the industry and the between the industry and the approach to design certification.

o design certification

[ADAMS Accession Number ML00370788 ccession Number ML003707 ach, which contained the following attributes:

ontained the following attributes:

r 1 1

r D

Tier Tier 1 will include information developed d 1 will include information dev as design criteria and bases and certa as design criteria and bases and c preliminary and detailed design phase preliminary and detailed design phas o

System and key compone ey co o

Functional and perform d per o

Simplified electrical Simplified electrica Simplified piping Simplified piping General arran General arran

pection, pection

ND-20-0244 Exemption Request: 10 CFR Part 52, Appendix D Tier 1 Plant-Specific DCD Requirements Page 5 of 15 the life of a facility referencing a design certification. An amendment to a certified design will affect all licensees referencing the certified design. Any combined license (COL) applicant or licensee may apply for an exemption affecting that one license only. Further, a contested COL proceeding could result in a rule waiver affecting that COL. 10 CFR 52.63 requires that in its review of proposed changes to Tier 1, the NRC examine the effect on standardization and the resulting safety benefits from the change. The staff will use existing guidelines, including NUREG-CR3568 Tier 2 Tier 2 will include information demonstrating how Tier 1 criteria are implemented in the design and will be of sufficient detail for the staff to make its safety determination as to the adequacy of the design as described in Tier 1. 10 CFR Part 52 does not address changes to uncertified information in the application for design certification (Tier 2) between design certification and COL issuance.

Because Tier 2 forms a basis for the staff's safety determination, the staff believes that Tier 2 should not undergo any changes before COL without previous NRC approval. Therefore, the staff proposes that the design certification itself require that any changes to Tier 2 information before the issuance of a COL be processed in a similar manner as Tier 1 changes (through an amendment rulemaking, an exemption, or a rule waiver pursuant to 10 CFR 2.758). 10 CFR Part 52 is not clear concerning changes to Tier 2 material during construction of a facility (after COL). 10 CFR 52.63(b)(2) invokes 10 CFR 50.59 for making changes to the uncertified portion of the application by a licensee only. Because Section 50.59 applies only to a licensee authorized to operate (see 10 CFR 52.83 and 10 CFR 50.59), 10 CFR Part 52 is best read to say that Tier 2 may be changed pursuant to 10 CFR 50.59 only after operation is permitted in accordance with 10 CFR 52.103. It is widely recognized throughout the industry that a certain amount of flexibility will be needed to finalize the design and construct the facility. To provide this flexibility, the staff proposes that a change process paralleling that of 10 CFR 50.59 be incorporated into the COL for making changes to Tier 2 information between COL issuance and operation. Changes to Tier 2 information after COL may be subject to hearing before operation if, as discussed in Section 52.103, acceptance criteria have not been met. Market forces such as the cost of redesign and the possibility for adjudication are major disincentives for changing Tier 2 design information and will help to preserve standardization. Although strong at the time of certification, the force associated with the cost of redesign will diminish over the life of the certification as technology advances.

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acility (after COL). 10 CFR 52.63(b)(2) invo lity (after COL). 10 CFR 52.63(b)(2) invo changes to the uncertified portion of the appli hanges to the uncertified port Section 50.59 applies only to a licensee Section 50.59 applies only to a 52.83 and 10 CFR 50.59), 10 52.83 and 10 CFR 50.59 CCFR FR Part P

changed pursuant to 10 CFR 50 to 10 CFR 50 accordance with 10 CFR 52.103.

accordance with 10 CFR that a certain amount of flex that a certain amount of construct the facility. To pro construct the facility. To p cess paralleling that o cess paralleling that es to es to Tier Tier 2 2

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ND-20-0244 Exemption Request: 10 CFR Part 52, Appendix D Tier 1 Plant-Specific DCD Requirements Page 6 of 15 The basis for the two-tiered approach is further defined in the SOCs for the AP1000 Design Certification Rule. They state:

The terms Tier 1, Tier 2, Tier 2*, and COL action items (license information) are defined in this appendix because these concepts were not envisioned when 10 CFR part 52 was developed. The design certification applicants and the NRC used these terms in implementing the two-tiered rule structure that was proposed by representatives of the nuclear industry after issuance of 10 CFR part 52. Therefore, appropriate definitions for these additional terms are included in this appendix. The nuclear industry representatives requested a two-tiered structure for the DCRs to achieve issue preclusion for a greater amount of information than was originally planned for the DCRs, while retaining flexibility for design implementation. The Commission approved the use of a two-tiered rule structure in its staff requirements memorandum (SRM), dated February 14, 1991, on SECY-90-377, Requirements for Design Certification Under 10 CFR Part 52, dated November 8, 1990. This document and others are available in the Regulatory History of Design Certification (see section IV, Availability of Documents, of this Statement of Consideration (SOC)).

The Tier 1 portion of the design-related information contained in the DCD is certified by this appendix and, therefore, is subject to the special backfit provisions in paragraph VIII.A of this appendix. An applicant who references this appendix is required to incorporate by reference and comply with Tier 1, under paragraphs III.B and IV.A.1 of this appendix. This information consists of an introduction to Tier 1, the system based and non-system based design descriptions and corresponding ITAAC, significant interface requirements, and significant site parameters for the design. The design descriptions, interface requirements, and site parameters in Tier 1 were derived from Tier 2 but may be more general than the Tier 2 information. The NRC staffs evaluation of the Tier 1 information is provided in section 14.3 of the FSER.

Changes to or departures from the Tier 1 information must comply with section VIII.A of this appendix The Tier 1 design descriptions serve as commitments for the lifetime of a facility referencing the design certification. The ITAAC verifies that the as-built facility conforms with the approved design and applicable regulations. Under 10 CFR 52.103(g), the Commission must find that the acceptance criteria in the ITAAC are met before authorizing operation. After the Commission has made the finding required by 10 CFR 52.103(g), the ITAAC do not constitute regulatory requirements for licensees or for renewal of the COL. However, subsequent modifications to the facility must comply with the design descriptions in the plant-specific DCD unless changes are made under the change process in section VIII of this appendix. The Tier 1 interface requirements are the most significant of the interface requirements for systems that are wholly or partially outside the scope of the standard design.

Tier 1 interface requirements were submitted in response to 10 CFR 52.47(a)(1)(vii) and must be met by the site-specific design features of a Draft dust or these ry representa epresenta ve issue preclusio ve issue preclus nally planned for the D ally planned for ntation. The Commission app tion. The Commissio in its staff requirements memo s staff requirements m 91, on SECY ECY-90 90-377, Requirements Requirement CFR Part 52, dated November 8, 1990. T 2, dated November 8, 1990. T available in the Regulatory History of De e Regulatory History of De IV, Availability of Documents, of this Statem ility of Documents, of n of the designn-related information contained related information containe his appendix and, x and, therefore, is subject to t therefore, is subject to n paragraph VIII.A of this appendix. An appli VIII.A of this appendix. An app ndix is required to incorporate by reference ired to incorporate by referenc paragraphs III.B and IV.A.1 of this appendix.

II.B and IV.A.1 of this appendix n introduction to trodu Tier Tier 1 1

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, the system based an

, the system based an escriptions and corresponding ITAAC, sign escriptions and corresponding ITAAC, sig and significant site parameters for the d and significant site parameters interface requirements, and site paramete interface requirements, and site para but b

may be more general than the e general than th evaluation of the Tier er 1 1

r information information Changes to or departures from Changes to or departure section VIII.A o sectio f this appendi ppen x Tier Tier 1 design descr 1 design desc referencing the referencing the onforms wit onforms w 103(g 103(

ND-20-0244 Exemption Request: 10 CFR Part 52, Appendix D Tier 1 Plant-Specific DCD Requirements Page 7 of 15 facility that references this appendix. An application that references this appendix must demonstrate that the site parameters (both Tier 1 and Tier 2) are met at the proposed site (refer to paragraph III.D of this SOC).

3.0 TECHNICAL JUSTIFICATION OF ACCEPTABILITY The underlying purpose of 10 CFR Part 52, Appendix D, is to provide for standardization of nuclear power plant design and to provide for the early resolution of safety and environmental issues in licensing proceedings regarding the AP1000 design. To address the issue of level of detail required for the NRC to meet its safety review objectives, Appendix D employs a two-tier approach and defines the plant-specific Design Control Document (DCD) as containing both Tier 1 information that is approved and certified by the NRC and Tier 2 information that is approved by the NRC but not certified. Tier 1 information is to contain the following:

1. Definitions and general provisions;

2. Design descriptions;

3. Inspections, tests, analyses, and acceptance criteria (ITAAC);

4. Significant site parameters; and

5. Significant interface requirements.

Design descriptions, site parameters, and interface requirements are derived from Tier 2 information. The VEGP 3 and 4 Tier 1 Plant-Specific DCD is arranged into the following sections:

1. Introduction 1.1 Definitions 1.2 General Provisions 1.3 Figure Legend 1.4 List of Acronyms and Abbreviations

2. System Based Design Descriptions and ITAAC

3. Non-system Based Design Descriptions and ITAAC

4. Interface Requirements

5. Site Parameters The proposed exemption would allow SNC to no longer comply with and maintain the Tier 1 plant-specific DCD and make changes to Tier 2 information under paragraph VIII.B.5.b and c without consideration of involvement with Tier 1 information. Because it is not anticipated that additional AP1000 nuclear power plants will be licensed and complete construction in the foreseeable future, the benefits of maintaining Draft early arding the ng the NRC to mee the NRC to me pproach and defines th proach and defin ng both Tie both r 1 information tha 1 informatio mation that is approved by the NR that is approved by t the following:

g:

sions; alyses, and acceptance criteria (ITAAC);

acceptance criteria (ITAAC);

arameters; and terface requirements.

irements.

ptions, site parameters, and interface requirem arameters, and interface require The VEGP 3 and 4 Tier nd 4 Ti 1 Plant-Specific DC Specific DC

. Introduction Introdu 1.1 Definitions 1

1.2 General Provisions 1.2 General Provisions 1.3 Figure Legend 1.3 Figu List of Acronyms and List of Acronyms and Based Design Based Design Base Base

ND-20-0244 Exemption Request: 10 CFR Part 52, Appendix D Tier 1 Plant-Specific DCD Requirements Page 8 of 15 standardization of VEGP 3 and 4 with the AP1000 design certification have been significantly reduced and create a burden instead of the intended benefit and therefore standardization is no longer needed. Because safety and environmental issues have been resolved during the AP1000 certification process and the VEGP 3 and 4 licensing process, there is no need to continue to maintain Tier 1 information. Because all ITAAC will have been completed when this exemption request will be put into effect (after the 10 CFR 52.103(g) finding and power accession testing complete (LC 2.D(5)(d)) for each unit), there is no need to continue to maintain ITAAC. To ensure changes to Tier 2 design information receive prior NRC approval as appropriate, changes to the Tier 2 plant-specific DCD will be subject to the provisions of paragraphs VIII.B.5.b and VIII.B.5.c.

The following paragraphs address the technical justification for not maintaining Tier 1 information for each section of the Tier 1 plant-specific DCD.

==

Introduction:==

Section 1.1, Definitions, defines terms that are applicable to design descriptions and associated ITAAC. Because the design descriptions contained in the Tier 1 plant-specific DCD are derived from design descriptions contained in the Tier 2 plant-specific DCD and changes to Tier 2 information are subject to paragraph VIII.B.5.b and c and the Tier 2 information must be maintained in accordance with paragraph X.A.1, the underlying purpose of the rule to maintain information contained in Tier 1 is maintained.

Definitions related to ITAAC will not be relevant after the 103(g) Commission finding because ITAAC are only used during the construction phase of the project.

Section 1.2, General Provisions, describes how items in Tier 1 are to be interpreted as they apply to design descriptions and ITAAC. These provisions are consistent with guidance or interpretations that would be applied to interpretation of Tier 2 information.

General provisions related to ITAAC will not be relevant after the 103(g) Commission finding because ITAAC are only used during the construction phase of the project. In addition, it is not expected that general provisions would change over the remainder of the license.

Section 1.3, Figure Legend, is provided for information and is not considered Tier 1 information.

Section 1.4, List of Acronyms and Abbreviations, is provided for information and are not considered Tier 1 information.

System Based Design Descriptions and ITAAC:

System based design description information is derived from the VEGP Updated Final Safety Analysis Report (UFSAR) (VEGP 3 and 4 plant-specific DCD) and the Physical Draft mplet C. To ens T

appropriate, ch appropriate, ch visions of paragraph visions of paragr chnical justification for not maintain justification for not ma 1 plant-specific DCD.

ific DCD efines terms that are applicable to design s that are applicable to design ecause the design descriptions contained sign descriptions cont rived from design descriptions contained in t design descriptions contained in s to Tier 2 information are subject to paragrap ormation are subject to paragra ation must be maintained in accordance be maintained in accordance purpose of the rule to maintain information co pose of the rule to maintain information co ns related to ITAAC will not be relevant aft s related to ITAAC will not be relevant a use ITAAC are only used during the constructi se ITAAC are only used during the ection 1.2, ection 1 General Provisions visions, describes ho cribes h they apply to design descriptions and ITA hey apply to design descriptions and ITA dance or interpretations that would b dance or interpretations that w ral provisions related to ITAAC ral provisions related to ITA ecause ITAAC are only u ecause ITAAC are only s not expected that s not expected tha Le Le

ND-20-0244 Exemption Request: 10 CFR Part 52, Appendix D Tier 1 Plant-Specific DCD Requirements Page 9 of 15 Security Plan. An exemption from complying with Tier 1 would allow SNC to make changes to Tier 2 design description information under the provisions of 10 CFR Part 52, Appendix D, paragraph B.5 and 10 CFR 50.54(p) for changes to the Physical Security Plan, which would provide assurance that matters of regulatory importance would require prior NRC approval before the change could be implemented. As a result, an underlying purpose of Tier 1 to bring changes important to the NRC for prior approval would be maintained.

System based ITAAC will be completed before the exemption request is implemented and are not required to be maintained or complied with after the 10 CFR 52.103(g)

Commission finding. Consequently, compliance with ITAAC will not be affected by this exemption request.

Non-System Based Design Descriptions and ITAAC:

Section 3.1, Emergency Response Facilities, design description information is derived from commitments contained in the SNC Standard Emergency Plan (SEP), and the SEP Annex for VEGP Units 3 and 4 (emergency plan). The emergency plan is incorporated by reference into the VEGP Units 3 and 4 UFSAR. Changes to the emergency plan are subject to the provisions of 10 CFR 50.54(q) which would provide assurance that matters of regulatory importance would require prior NRC approval before the change could be implemented. As a result, an underlying purpose of Tier 1 to bring changes important to the NRC for prior approval would be maintained.

Section 3.2, Human Factors Engineering, design description information is derived from VEGP 3 and 4 UFSAR, Chapter 18, Human Factors Engineering. The programmatic elements of the human factors engineering program derive from regulatory guidance in NUREG-0711, Human Factors Engineering Program Review Model. An exemption from complying with Tier 1 would allow SNC to make changes to Tier 2 design description information under the provisions of 10 CFR Part 52, Appendix D, paragraph B.5, which would provide assurance that matters of regulatory importance would require prior NRC approval before the change could be implemented. As a result, an underlying purpose of Tier 1 to bring changes important to the NRC for prior approval would be maintained.

Section 3.3, Buildings, design description information is derived from the VEGP UFSAR (VEGP 3 and 4 plant-specific DCD) and the Physical Security Plan. An exemption from complying with Tier 1 would allow SNC to make changes to Tier 2 design description information under the provisions of 10 CFR Part 52, Appendix D, paragraph B.5 and 10 CFR 50.54(p) for changes to the Physical Security Plan, which would provide assurance that matters of regulatory importance would require NRC approval before the change could be implemented. As a result, an underlying purpose of Tier 1 to bring changes important to the NRC for prior approval would be maintained.

Draft exemption req exemption req lied with after the 1 lied with after the ce with ITAAC will not be a with ITAAC will no ions and ITAAC:

AAC:

se Facilities, design description information

, design description n the SNC Standard Emergency Plan (SEP),

Standard Emergency Plan (

nd 4 (emergency plan). The emergency plan ency plan). The emergency pla EGP Units 3 and 4 UFSAR.

d 4 UFSAR. Changes to the e Changes to the sions of 10 CFR 50.54(q) which would pr 0 CFR 50.54(q) which would ory importance would require prior NRC app ce would require prior NRC ap mented. As a result, an underlying purpose s a result, an underlying purpos the NRC for prior approval would be maintain ior approval would be maintain n 3.2, 3.2, Human Factors Engineering Human Factors Engineerin, design de GP 3 and 4 UFSAR, Chapter 18, P 3 and 4 UFSAR, Chapter 18, Human F Hum lem ements of the human factors engineering p ents of the human factors engineering NUREG NUREG-0711, Human Factors Engineering ors Engineerin mplying with Tier 1 would allow SNC mplying with Tier 1 would allow ation under the provisions of 1 ation under the provisions ovide assurance that mat ovide assurance that m fore the change co fore the change co g changes im g changes im s

ND-20-0244 Exemption Request: 10 CFR Part 52, Appendix D Tier 1 Plant-Specific DCD Requirements Page 10 of 15 Section 3.4, Initial Test Program, design description requires SNC to implement an initial test program which involves preoperational tests (prior to fuel load) and startup tests (during and after fuel load). Because the initial test program for VEGP Units 3 and 4 will be completed before the requested exemption will be put into effect, compliance with the initial test program requirements will not be affected by this exemption request.

Section 3.5, Radiation Monitoring, design description information is derived from the VEGP UFSAR (VEGP 3 and 4 plant-specific DCD). An exemption from complying with Tier 1 would allow SNC to make changes to Tier 2 design description information under the provisions of 10 CFR Part 52, Appendix D, paragraph B.5, which would provide assurance that matters of regulatory importance would require prior NRC approval before the change could be implemented. As a result, an underlying purpose of Tier 1 to bring changes important to the NRC for prior approval would be maintained.

Section 3.6, Reactor Coolant Pressure Boundary Leak Detection, design description information is derived from VEGP 3 and 4 UFSAR (VEGP 3 and 4 plant-specific DCD),

Subsection 5.2.5, Detection of Leakage Through Reactor Coolant Pressure Boundary.

An exemption from complying with Tier 1 would allow SNC to make changes to Tier 2 design description information under the provisions of 10 CFR Part 52, Appendix D, paragraph B.5, which would provide assurance that matters of regulatory importance would require prior NRC approval before the change could be implemented. As a result, an underlying purpose of Tier 1 to bring changes important to the NRC for prior approval would be maintained.

Section 3.7, Design Reliability Assurance Program, design description describes a Design Reliability Assurance Program (D-RAP) that will be performed during the detailed design and equipment specification phase prior to initial fuel load. Because the D-RAP will not be used after the implementation of the requested exemption, compliance with D-RAP requirements will not be affected by this exemption request.

Interface Requirements:

No Tier 1 interfaces were identified for the AP1000 standard plant design.

Site Parameters:

A comparison of the AP1000 site parameters to the VEGP units 3 and 4 site is contained in VEGP 3 and 4 UFSAR Table 2.0-201, Comparison of AP1000 DCD Site Parameters and Vogtle Electric Generating Plant Units 3 & 4 Site Characteristics. Because a deviation from the AP1000 site parameters would be considered a deviation from a design standard, it would require prior NRC approval before the deviation could be implemented. As a result, an underlying purpose of Tier 1 to bring changes important to the NRC for prior approval would be maintained.

orm exempti x

esign descripti esign descript paragraph B.5, whi paragraph B.5, w ance would require prior ce would require As a result, an underlying purpose esult, an underlying pu rior approval would be maintained.

val would be maintaine ssure Boundary Leak Detection Leak Dete

, design des esign de P 3 and 4 UFSAR FSAR (VEGP 3 and 4 plant (VEGP 3 and 4

-spe of Leakage Through Reactor Coolant Pressu Through Reactor Coolant P ying with Tier 1 would allow SNC to make c r 1 would allow SNC to make c rmation under the provisions of 10 CFR Pa the provisions of 10 C ch would provide assurance that matters of ovide assurance that matters o or NRC approval before the change could be i val before the change could be purpose of Tier 1 to bring changes important t Tier 1 to bring changes important aintained.

n 3.7, n 3.7, Design Reliability Assurance Progra Design Reliability Assura sign Reliability Assurance Program (D ign Reliability Assurance Program (D-R

-RAP) t design and equipment specification phase pr esign and equipment specification phase p will not be used after the implementation will not be used after the implem AP requirements will not be affected AP requirements will not be af Requirements:

Requir aces were ide aces were ide

ND-20-0244 Exemption Request: 10 CFR Part 52, Appendix D Tier 1 Plant-Specific DCD Requirements Page 11 of 15 4.0 JUSTIFICATION FOR EXEMPTION 10 CFR 50.12, and § 52.7 state that the NRC may grant exemptions from the requirements of the regulations provided four conditions are met: 1) the exemption is authorized by law [§50.12(a)(1)]; 2) the exemption will not present an undue risk to the health and safety of the public [§50.12(a)(1)]; 3) the exemption is consistent with the common defense and security [§50.12(a)(1)]; 4) special circumstances are present

[§50.12(a)(2).

The requested exemption satisfies the criteria for granting specific exemptions, as described below.

4.1 This exemption is authorized by law The NRC has authority under 10 CFR 52.7 and § 50.12 to grant exemptions from the requirements of NRC regulations. Specifically, 10 CFR 52.7 and § 50.12 state that the NRC may grant exemptions from the requirements of 10 CFR Part 52 upon a proper showing. No law exists that would preclude the changes covered by this exemption request. Additionally, granting of the proposed exemption does not result in a violation of the Atomic Energy Act of 1954, as amended, or the Commissions regulations.

Accordingly, this requested exemption is authorized by law, as required by 10 CFR 50.12(a)(1).

4.2 This exemption will not present an undue risk to the health and safety of the public SNC is proposing an exemption from 10 CFR Part 52, Appendix D, section III.B that requires compliance with Tier 1, paragraph VIII.B.5.a that requires departures from Tier 2 information that involve Tier 1 information receive prior NRC approval, and paragraph X.A.2 that requires a licensee who references the appendix to maintain the plant-specific DCD for the term of the license. The proposed exemption would permit SNC to designate the plant-specific Tier 1 information as historical information, no longer update Tier 1 Plant-Specific DCD, nor evaluate future changes to Tier 2 plant-specific information for impact to Tier 1 information as required by paragraph VIII.B.5.a.

The proposed exemption does not introduce any new industrial, chemical, or radiological hazards that would present a public health or safety risk, nor does it modify or remove any design or operational controls or safeguards intended to mitigate any existing on-site hazards. Furthermore, the proposed exemption would not allow for a new fission product release path, result in a new fission product barrier failure mode, or create a new sequence of events that would result in fuel cladding failures. Accordingly, this proposed exemption will not endanger life or r granting spec r granting spec FR 52.7 and § 50.12 to grant exemptions fr

§ 50.12 to grant exemptions fr

s. Specifically, 10 10 CFR CFR 52.7 and § 50.12 sta 52.7 and § 50.12 st ons from the requirements of 10 e requirements of 10 CFR Part 5 exists that would preclude the changes cov would preclude the chang ditionally, granting of the proposed exemption anting of the proposed exemptio Atomic Energy Act of 1954, as amended, o y Act of 1954, as amended, o this requested exemption is authorized by la ted exemption is authorized by 1).

exemption will not present an undue risk exemption will not present a ublic ublic SNC is SNC proposing an exemption from 10 xemption from 10 requires compliance with Tier 1, parag requires compliance with Tier Tier 2 information that involve Tier Tier 2 information that involv agraph X.A.2 that requires a agraph X.A.2 that require ant ant-specific DCD for the specific DCD for th NC to designat NC to designa no longer u no longer u speci spec

ND-20-0244 Exemption Request: 10 CFR Part 52, Appendix D Tier 1 Plant-Specific DCD Requirements Page 12 of 15 property, as it does not present an undue risk from any existing or proposed equipment or systems.

4.3 The exemption is consistent with the common defense and security The proposed exemption would permit SNC to designate plant-specific Tier 1 information as historical information, no longer update the Tier 1 plant-specific DCD, nor evaluate future changes to Tier 2 plant-specific information for impact to Tier 1 plant-specific information.

The proposed exemption does not make any changes to the design, construction, or operation of any security-related SSCs, nor does it change any Security procedures.

Accordingly, this proposed exemption is consistent with the common defense and security. Therefore, the requested exemption from the requirements of 10 CFR Part 52, Appendix D, regarding requirements to maintain a Tier 1 plant-specific DCD during the operating phase of a COL would not endanger life or property or the common defense and security.

4.4 Special circumstances are present 10 CFR 50.12(a)(2) lists six special circumstances for which an exemption may be granted. Pursuant to the regulation, it is necessary for one of these special circumstances to be present in order for the NRC to consider granting an exemption request. The requested exemption meets the special circumstances of 10 CFR 50.12(a)(2)(ii). That subsection defines special circumstances as when Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule.

Specifically, SNC is requesting an exemption from 10 CFR Part 52, Appendix D, paragraph III.B, which requires compliance with Tier 1, paragraph VIII.B.5.a, which requires departures from Tier 2 information that involve Tier 1 information receive prior NRC approval, and paragraph X.A.2, which requires a licensee who references the appendix to maintain the Tier 1 plant-specific DCD for the term of the license.

The underlying purpose of 10 CFR Part 52, Appendix D, is to provide for standardization of nuclear power plant design and to provide for the early resolution of safety and environmental issues in licensing proceedings regarding the AP1000 design. Because the underlying purpose of the Tier 1 plant-specific DCD will be obviated at the end of the construction phase for each VEGP Unit (10 CFR 53.103(g) finding for each Unit) and it is not anticipated that additional nuclear power plants will be licensed and complete construction during the remaining duration of the current AP1000 design certification, the benefits of standardization will not be realized.

Draft nform changes to the design changes to the de r does it change any Securi oes it change any S is consistent with the common de sistent with the comm exemption from from the requirements of the requirements of equirements to maintain a o maintain a Tier 1 pp r

lant lant-specifi specif f a COL would not endanger life or proper ndanger life or proper rity.

es are present nt

2) lists six special circumstances for which special circumstances for whic uant to the regulation, it is necessary fo regulation, it is necessary fo ces to be present in order for the NRC to esent in order for the NRC to con co The requested exemption meets the spec d exemption meets the spec (a)(2)(ii). That subsection defines special cir a)(2)(ii). That subsection defines special cir the regulation in the particular circumstanc the regulation in the particular c purpose of the rule or is not necessary to ach purpose of the rule or is not necessary t Specifically, SNC is requesting an exe Specifically, SNC is requesting an ex paragraph paragra III.B, which requires com quire quires departures from Tier 2 quires departures from Tie NRC approval, and parag NRC approval, and para endix to maintain the endix to maintain th ng purpo ng purp of n of n

ND-20-0244 Exemption Request: 10 CFR Part 52, Appendix D Tier 1 Plant-Specific DCD Requirements Page 13 of 15 Therefore, special circumstances are present, as the particular circumstances discussed in this request are not necessary to achieve the underlying purpose of the rule.

5.0 RISK ASSESSMENT A risk assessment was not determined to be applicable to address the acceptability of this proposal.

6.0 PRECEDENT EXEMPTIONS None.

7.0 SIGNIFICANT HAZARDS DETERMINATION AND ENVIRONMENTAL CONSIDERATIONS The proposed exemption has been evaluated against the criteria of 10 CFR 51.21, Criteria for and identification of licensing and regulatory actions requiring environmental assessments, and has been determined to meet the categorical exclusion criteria of 10 CFR 51.22, Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review, as described below, which evaluates the change against the criteria of 10 CFR 51.22(c)(25).

The requested exemption, which seeks to change requirements for compliance with and maintenance of the Tier 1 plant-specific Design Control Document (DCD), does not make any changes to the facility or operating procedures and:

i)

Does not involve a significant hazards consideration [10 CFR 51.22(c)(25)(i)]. The standards set forth in 10 CFR 50.92(c) were used to determine whether the requested exemption involved a significant hazards consideration:

(1) Does the proposed licensing action involve a significant increase in the probability or consequences of an accident previously evaluated?

Response

No.

The proposed exemption from the requirements of 10 CFR Part 52, Appendix D, paragraph III.B that requires compliance with Tier 1, paragraph VIII.B.5.a that requires departures from Tier 2 information that involve Tier 1 information receive prior NRC approval, and paragraph X.A.2 that requires a licensee who references the appendix to maintain the Tier 1 plant-specific Design Control Document (DCD) for the term of the license does not alter the design, function, or operation of any plant equipment.

Therefore, granting this exemption would not involve a significant increase in the probability or consequences of an accident previously evaluated.

Draft ON AND ENVIRONMENTAL D ENVIRONMENTAL een evaluated against the criteria of 10 d against the criteria of 10 CF C

f licensing and regulatory actions requiring en nd regulatory actions req n determined to meet the ed to meet the categorical exclu categorical ex for categorical exclusion; identification rical exclusion; identification ligible for categorical exclusion or othe categorical exclusion or o ew, as described below, which evaluates cribed below, which evaluates t R 51.22(c)(25).

25).

sted exemption, which seeks to change requir d exemption, which seeks to change requir ance of the Tier 1 nce of the Tier plant ant-s

-specific Design Co pec e any changes to the facility or operating proce any changes to the facility or operat

)

Does not involve a significant hazards c Does not involve a significant hazards standards set forth in 10 standards set forth in 10 CFR C

50.92 9

requested exemption involved a sign requested exemption involved Does Does the proposed licens the proposed lice obability or conseque obability or consequ se:

se:

No.

No.

D d e d

ND-20-0244 Exemption Request: 10 CFR Part 52, Appendix D Tier 1 Plant-Specific DCD Requirements Page 14 of 15 (2) Does the proposed licensing action create the possibility of a new or different kind of accident from any accident previously evaluated?

Response

No.

The requested exemption does not alter the design, function, or operation of any plant equipment. The requested exemption does not create any new failure mechanisms, malfunctions, or accident initiators.

Therefore, granting this exemption does not create the possibility of a new or different kind of accident from any accident previously evaluated.

(3) Does the proposed licensing action involve a significant reduction in a margin of safety?

Response

No.

The requested exemption does not affect a structure, system, or component (SSC), SSC design function, or method of performing or controlling a design function. Maintenance of the Tier 1 plant-specific DCD requirements are not related to or used to establish the design bases of an SSC nor are they considered in the safety analyses. Furthermore, the requested exemption does not exceed or alter a design basis or safety limit.

Therefore, granting this exemption does not involve a significant reduction in a margin of safety.

Therefore, it is concluded that the proposed exemption does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of no significant hazards consideration is justified.

ii)

Does not involve a significant change in the types or significant increase in the amounts of any effluents that may be released offsite [10 CFR 51.22(c)(25)(ii)]. The requested exemption does not alter the design, function, or operation of any plant equipment. There are no changes to effluent types, plant radiological or non-radiological effluent release quantities, any effluent release path, or the functionality of any design or operational features credited with controlling the release of effluents during plant operation or construction.

Therefore, it is concluded that the proposed exemption does not involve a significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

iii) Does not involve a significant increase in individual or cumulative public or occupational radiation exposure [10 CFR 51.22(c)(25)(iii)]. There are no changes to plant radiation zones, nor any change to controls required under 10 CFR Part 20 which preclude a significant increase in occupational radiation exposure.

Draft create the po create the po t previously evaluated t previously evalua on involve a significant red involve a significan on does not affect a structure, system, or t affect a structure, sy unction, or method of performing or contro method of performing or co ance of the Tier 1 plant Tier 1 plant-specific DCD requ specific DCD requ sed to establish the design bases of an sh the design bases n the safety analyses. Furthermore, the requ analyses. Furthermore, the req d or alter a design basis or safety limit.

esign basis or safet efore, granting this exemption does not invo this exemption does not invo argin of safety.

rgin of safety.

Therefore, it is concluded that the proposed e herefore, it is concluded that the prop haza hazards consideration under the standa rds consideration under the stand accordingly, a finding of no significant h accordingly, a finding of no significant Does not involve a significant ch Does not involve a significan ounts of any effluents that m ounts of any effluents that sted exemption does n sted exemption does nt. There are n nt. There are gical effluen gical effluen of any of any nts nts

ND-20-0244 Exemption Request: 10 CFR Part 52, Appendix D Tier 1 Plant-Specific DCD Requirements Page 15 of 15 Therefore, it is concluded that the proposed exemption does not involve a significant increase in individual or cumulative public or occupational radiation exposure.

iv) Does not involve a significant construction impact [10 CFR 51.22(c)(25)(iv)]. The requested exemption does not alter the materials or methods of constructing or testing of any SSCs. No change to the construction of the facility is being made as a result of this exemption.

Therefore, it is concluded that the proposed exemption does not involve a significant construction impact.

v) Does not involve a significant increase in the potential for or consequences from radiological accidents [10 CFR 51.22(c)(25)(v)]. The requested exemption does not alter the design, function, or operation of any plant equipment. There are no changes to plant radiation zones, nor any change to controls required under 10 CFR Part 20 which preclude a significant increase in occupational radiation exposure.

Therefore, it is concluded that the proposed exemption does not involve a significant increase in the potential for or consequences from radiological accidents.

vi) Involves requirements of an administrative nature related to maintenance of the Tier 1 plant-specific DCD and reporting Tier 1 plant-specific DCD departures.

[10 CFR 51.22(c)(25)(vi)(I)].

Accordingly, the proposed exemption meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(25). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this exemption.

8.0 CONCLUSION

The requested exemption would permit SNC to designate the Tier 1 plant-specific DCD as historical information and no longer update the Tier 1 plant-specific DCD nor evaluate future changes to Tier 2 plant-specific DCD information for impact to Tier 1 information.

The exemption is necessary to allow SNC to effectively and efficiently integrate licensing document change processes with existing SNC operating reactor change processes.

The exemption request meets the requirements of 10 CFR 52.7, Specific Exemptions, and § 50.12, Specific Exemptions, in that the requested exemption is authorized by law, the exemption will not present an undue risk to the health and safety of the public, the exemption is consistent with the common defense and security; and special circumstances are present.

9.0 REFERENCES

None Draft ion does n

the potential for or cons he potential for or 25)(v)]

v)]. The requested exempt

. The requested e on of any plant equipment. The any plant equipment.

nor any change to controls required change to controls required a significant increase in occupational ra t increase in occupational ra that the proposed exemption does not involv posed exemption does not i l for or consequences from radiological accid equences from radiological accid ents of an administrative dministrat nature natur related elated to to ma c DCD and nd reporting Tier reporting Tier 1 plant ant-spec spe 22(c)(25)(vi)((I( )])]

I..

, the proposed exemption meets the eli he proposed exemption meets the eli set forth in 10 set forth in 10 CFR 51.22(c)(25). Therefore 51.22(c)(25). Therefor onmental impact statement or environmenta nmental impact statement or env nnection with the issuance of this nection with the issuance of exemption.

exempti CONCLUSION CONCL equested exemption would perm equested exemption would ical information ical info andd no lon no l ges to ges to Tier T

2 p 2 p r

lant lant-s n is necessary n is necessary e process e proces