Text

Proposed Tech Specs 3.8.2.1 & 3.8.3.1 Supporting 125 Vdc Vital Instrumentation & Control Power Sys Circuit Breakers Replacement
	ML20080K186
Person / Time
Site:	McGuire, Mcguire
Issue date:	02/23/1995
From:	; DUKE POWER CO.
To:	;
Shared Package
ML20080K181	List: ML20080K178; ML20080K186;
References
	NUDOCS 9502280411
	Download: ML20080K186 (17)
	v • d • e

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PROPOSED CHANGES l

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l 9502280411 950223 PDR ADOCK 05000369 P PDR . . _

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l ELECTRICAL POWER SYSTEMS ;

3/4.8.2 D.C. SOURCES l

. OPERATING LIMITING CONDITION FOR OPERATION 3.8.2.1 The following D.C. channels shall be~ OPERABLE and energized:

a. Channel I consisting of 125-Volt D.C. Bus No. EVDA, 125-Volt D.C. Battery Bank No. EVCA and a full-capacity charger,*#

b. Channel 2 consisting of 125-Volt D.C. Bus No. EVDB, 125-Volt D.C. Battery. Bank No. EVCB and a full-capacity charger,*#

c. Channel 3 consisting of 125-Volt D.C. Bus No. EVDC,125-Volt D.C.' Battery Bank No. EVCC and a full-capacity charger,"#.and

d. Channel 4 consisting of 125-Volt D.C. Bus No. EVDD, 125-Volt D.C. Battery Bank No. EVCD and a full-capacity charger,*#

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION: (Units 1 and 2)

a. With one 125-volt D.C. bus inoperable or not energized, restore the inoperable bus to OPERABLE and energized status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or be-in at least HOT STANDBY.within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. With one 125-volt D.C. battery and/or its normal and standby chargers inoperable or not energized, either:

1. Restore the inoperable battery and/or charger to OPERABLE and .

energized status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or be in at least HOT STANDBY l within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the follow- '

ing 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months , or

2. Energize the associated bus with an OPERABLE battery bank via OPERABLE tie breakers within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ; operation may then continue for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from time of initial loss of-OPERABILITY, otherwise, be in at least HOT STANDBY within the 4 next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following I 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . ,

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A vital bus may be disconnected from its D.C. source for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for the purpose of performing an equalizing charge on its associated battery bank provided the vital busses associated w k. the other battery banks are OPERABLE and energized.

periodsC ' battery b nk replapement on the affecteo cnannei may De f# bur dered OP ABLE prov' ed a te orary ba ry is conf red t full apacity rger and nnecte o the re ective bus 11 li

ing cond' lons for op tion, ac

n stat nts, an urveillanc requir ents perta' ing to

--) the rmanent b teries all be ntained fo ..the tem orary batt during periods of battery bank r placement.

McGUIRE - UNITS 1 and 2 3/4 8-11 Amendment No. 121 (Unit 1)

L- (sa 2 m) Amendment No. 103 (Uni 2)

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During periods of station modification associated with battery, i main and tie breaker replacement only, the loads of a DC bus may be energized from a same train DC bus via temporary cables and breakers connecting to the same train DC bus directly and i bypassing the de-energized DC bus. A one time allowable outage time up to 112 hours0.0013 days 0.0311 hours 1.851852e-4 weeks 4.2616e-5 months is granted for each DC bus, one at a time, to allow for replacement of these breakers. Footnote

shall not ;

be applied to any of the busses during the 112 hour0.0013 days 0.0311 hours 1.851852e-4 weeks 4.2616e-5 months perioda L

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ELECTRICAL POWER SYSTEMS 3/4.8.3 ONSITE POWER DISTRIBUTION U OPERATING LIMITING CONDITION FOR OPERATION 3.8.3.1 The following A.C. electrical busses and inverters shall be OPERABLE

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and energized with tie breakers open both between redundant busses within the j unit and between the two units: !

a. 4160-Volt Emergency Bus ETA, x

b. 4150-Volt Emergency Bus ETB,

c. 600-Volt Emergency Bus ELXA, l

d. 600-Volt Emergency Bus ELXB, '

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e. 600-Volt Emergency Bus ELXC,

f. 600-Volt Emergency Bus ELXD, i

g. 120-Volt A.C. Vital Bu EKVAenergizedfromInverterMEVIA connected to D.C. Chan 11,*M V

h. 120-Volta.C.VitalBushEKVBenergizedfromInverter EVIB connectedtoD.C. Channel 2,*p

i. 120-Volt A.C. Vital Bus EKV6n'ergizedfromInverter EVIC cennected to D.C. Channe 3,*Phnd i j. 120-Volt A.C. Vital Bus EKVD EVID connected to D.C. Channe 4..*$energizedfromInverter r l

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I APPLICABILITY: MODES 1, 2, 3, and 4. '

l ACTION: . '

a. With less than the above complement of A.C. busses OPERABLE and energized, restore the inoperable busses to OPERABLE and energized status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or be in at least HOT STANOBY within the next ,

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLO SHUT 00WN.within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b.

l With one inverter inoperabie, energize the associated A.C. Vital Bus within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ; restore the inoperable inverter to OPERABLE and l energized status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be jn at-least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS l

4.8.3.1 The specified A.C. busses and inverters shall be determined energized in the required manner at least once per 7 days by verifying correct breaker 411gnment and indicated voltage on the busses.

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An inverter may be disconnected from its D.C. source for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for the purpose of performing an equalizing charge cn its associated battery bank provided: (1) its vital bus is OPERABLE and :nargized, and (2) the vital busses associated with the other battery banks are OPERABLE and energized. ,

An inverter may be disconnected from its D.C. source for up to 72 hcurs i provided the conditions of ACTION b. of Specification 3.8.2.1 are satisfied. ,

ficGUIRE - UNITS 1 and 2 3/4 8-16 k fNo p f.A f

During periods of station modification associated with battery, main and tie breaker replacement only, two channel related inverters may be energized from a same train DC bus via temporary cables and breakers connecting to the same train DC bus directly and bypassing the associated de-energized DC bus. A one time allowable outage time up to 112 hours0.0013 days 0.0311 hours 1.851852e-4 weeks 4.2616e-5 months is granted for each DC bus, one at a time, to allow for replacement of these breakers.

Footnote

shall not be applied to any of the busses during the 112 hour0.0013 days 0.0311 hours 1.851852e-4 weeks 4.2616e-5 months period.

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6 ATTACHMENT 2 TECHNICAL JUSTIFICATION l

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U.S. Nuclear Regulatory Commission Attachment 2 February 23, 1995 Page 1/3 i Technical Justifications Figure 1 attached at the end of Attachment 2 shows a composite !

one-line diagram of the 125 VDC and 120 VAC Vital Instrumentation .

and Control Power Systems. The 125 VDC Vital Instrumentation and !'

Control Power System (reference McGuire FSAR, section 8.3.2.1.4) provides power to nuclear safety related instrumentation and ;

control loads requiring an uninterrupted power source to maintain safe reactor status during normal plant operation, a loss of offsite power (LOOP), design basis events, and a LOOP concurrent l with design basis events. This is a four- channel shared system !

between Units 1 and 2, with a spare charger which can be l connected to these four channels, one or two at a time. This i system is required to provide sufficient power to safety related :

systems and components needed to mitigate the consequences of 7 design basis events. Should a loss of a battery charger or AC ,

power source occur, a single battery is capable of supplying two channels for a period of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months while maintaining sufficient -

terminal voltage. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period is based on a conservative .

estimate of the time required to restore power to the battery chargers. 125 VDC bus voltage indicat*.on, alarms (DC bus ;

undervoltage, DC bus positive / negative ground, DC channel trouble) and computer points for each channel are provided in the ;

control room. The DC channel trouble alarm includes inputs from '

positions of the charger's input and output breakers, battery output breaker, distribution center's main incoming breaker and tie breaker, as well as undervoltage relays for the DC and AC panelboards.

l In July 1991, the NRC finished a functional inspection of the l electrical distribution system at McGuire. Based on the EDSFI j l results, there is a concern that the present breaker arrangement i

can result in a trip of both the battery breaker (which has an l instantaneous trip) and the main incoming breaker (which also has l an instantaneous trip) if a fault occurs on one of the 125 VDC panelboards.

By letters dated September 27, 1991, December 12, 1991 a,nd August 26, 1994, McGuire Nuclear Station committed to have these breakers replaced in 1995 with a better coordinated design to eliminate the above concern.

i A modification is planned to replace the battery circuit breaker (600A), distribution center main incoming circuit breaker (600A),

and tie circuit breaker (400A) for each of the 4 channels of the 125 VDC Vital Instrumentation and Control Power System. The battery circuit breaker will ba replaced with a non-fusible j switch (600A), and the distribt. ion center main incoming circuit breaker will be replaced with a fusible switch (600A). The tie circuit breaker will be replaced with either the battery or main incoming breaker previously removed (these breakers are capable l

U.S. Nuclear Regulatory Commission Attachment 2 February 23, 1995 Page 2/3 >

of being set at a higher instantaneous overcurrent setting than the existing tie breaker). The new arrangement will use a fusible switch which has a greater. time delay than the present ,

main incoming breaker, thereby allowing enough time for the individual breakers on the 125 VDC panelboards or the panelboard-feeder breaker to trip on a fault' condition, so that the entire distribution center (EVDA, EVDB, EVDC or EVDD) . will not be lost .

as a result of a fault on a panelboard. '

The proposed TS changes are for allowing the use of temporary !

cables and breakers to connect the loads of a vital IX: bus (EVDA, EVDB, EVDC or EVDD) to a same train vital DC bus while the vital ['

DC bus is de-energized for replacement of the battery, main and tie circuit breakers. The proposed TS changes are also for allowing a one time outage time up to 112 hours0.0013 days 0.0311 hours 1.851852e-4 weeks 4.2616e-5 months for each vital DC i bus for completion of all tasks associated with the replacement l of these breakers. The proposed 112 hours0.0013 days 0.0311 hours 1.851852e-4 weeks 4.2616e-5 months are extended from the j 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months currently allowed by TS 3.8.2.1 ACTION b.2 for two DC !

busses to be cross-tied together. Within this proposed 112 i hours, the expected time for implementation is 88 hours0.00102 days 0.0244 hours 1.455026e-4 weeks 3.3484e-5 months and the ,

additional 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are requested for contingencies that may arise during installation. To minimize the use of the 88 hours0.00102 days 0.0244 hours 1.455026e-4 weeks 3.3484e-5 months , the following steps will beLtaken:

1/ As much work as possible will be performed prior to entering '

l TS time.

i 2/ Work will be in progress 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day with various parts of the implementation proceeding simultaneously.

3/ DC panelboard circuit breakers for temporary alignment have been previously installed by minor modifications.

l l 4/ Spare circuit breakers and switches will be available.

l 5/ Possibility of unacceptable battery degradation will be eliminated by monitoring battery voltage periodically throughout installation and having a spare charger ,

available. ;

During modification installation, all inputs to the DC channel i trouble alarm, except those from the DC and AC panelboard !

undervoltage relays, are isolated so that an undervoltage condition in a panelboard can be immediately detected. The ;

temporary configuration, as described above, is technically compatible with the cross-tie configuration allowed by TS 3.8.2.1 l ACTION b.2.

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. .i U.S. Nuclear Regulatory Commission Attachment 2 February 23, 1995 Page 3/3 Since four identical channels are involved, only one channel is used in the following explanation. (

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To replace the battery, main and tie breakers in channel B (see i Figure 1), the modification is generally described as follows j (the actual implementation-is carried out in accordance with !

implementation procedures): Inverters lEVIB and 2EVIB and DC l panelboards 1EVDB and 2EVDB are energized from DC distribution center EVDD via temporary cables and breakers. DC distribution f center EVDB is de-energized. The battery, main and tie breakers ,

are replaced. Channel B is then restored to its normal configuration, with DC panelboards lEVDB and 2EVDB, and inverters lEVIB and 2EVIB energized by DC distribution center EVDB. t The proposed deletion of the existing # sign in TS 3.8.3.1, items a through j, is purely an administrative change to avoid ;

confusion with the proposed footnote # in TS 3.8.3.1 and TS 3.8.2.1.

i The proposed deletion of the existing footnote #.in TS 3.8.2.1 is purely an administrative change to remove this note because the battery replacement modifications are complete. f s

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U.S. MRC l

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i ATTACHMENT 3 SAFETY EVALUATION 1

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l l U.S. Nuclear Regulatory Commission Attachment 3 February 23, 1995 Page 1/2 -

Safety Evaluation: i i

The 125 VDC Vital Instrumentation and Control Power System .

provides power to nuclear safety related instrumentation and l control loads requiring an uninterrupted power source to maintain l safe reactor status during normal plant operation, a loss of l offsite power (LOOP), design basis events, and a LOOP concurrent with design basis events. This is a four-channel shared system between Units 1 and 2, with a spare charger which can be ;

l connected to these four channels, one or two at a time. This

! system is required to provide sufficient power to safety related j systems and components needed to mitigate the consequences of [

l design basis events. Should a loss of a battery charger or AC !

power source occur, a single battery is capable of supplying two channels for a period of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months while maintaining sufficient '

terminal voltage. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period is based on a conservative estimate of the time required to restore power to the battery chargers. 125 VDC bus voltage indication, alarms (DC bus undervoltage, DC bus positive / negative ground, DC channel l trouble) and computer points for each channel are provided in the l control room. The DC channel trouble alarm includes inputs from positions of the charger's input and output breakers, battery l output breaker, distribution center's main incoming breaker and tie breaker, as well as undervoltage relays for the DC and AC panelboards. Indication of the specific condition responsible t for initiating the channel trouble alarm is provided on the local alarm module located in the battery room.

A modification is planned to replace the battery circuit breaker (600A), distribution center main incoming circuit breaker (600A), !

and tie circuit breaker (400A) for each of the 4 channels of the 125 VDC Vital Instrumentation and Control Power System. The battery circuit breaker will be replaced with a non-fusible switch (600A), and the distribution center main incoming circuit breaker will be replaced with a fusible switch (600A). The tie -

circuit breaker will be replaced with either the battery or main incoming breaker previously removed (these breakers are capable of being set at a higher instantaneous overcurrent setting than the existing tie breaker). The new arrangement will use a fusible switch which opens at a later point than the present main incoming breaker, thereby allowing enough time for the individual breakers on the 125 VDC panelboards to trip on a fault condition, so that the entire distribution center (EVDA, EVDB, EVDC or EVDD) ;

will not be lost on trip of the main incoming breaker. '

i The use of temporary cables and breakers to facilitate the de-energization of a vital bus and connection of its loads to its same train vital bus for breaker replacement does not technically i violate the applicable technical specifications since the intent of these technical specifications is to have uninterrupted power to the loads normally connected to this de-energized bus. The

U..S. Nuclear Regulatory Commission Attachment 3 February 23, 1995 Page 2/2 1

proposed TS changes do not involve a significant relaxatior i limiting conditions for operation. Even though the propose !

changes involve a relaxation in outage time (112 hours0.0013 days 0.0311 hours 1.851852e-4 weeks 4.2616e-5 months vs. 72 !

hours), they are accompanied by compensatory conditions: 1/ no ,

equalizing charge on any of the three OPERABLE battery banks is !'

allowed during this time, 2/ all inputs to the DC. channel trouble alarm except those from the associated DC and AC panelboard undervoltage relays will be blocked during this time so that an undervoltage condition on any of the DC and AC panelboards during this period will be detected, 3/ a temporary portable charger will be available for charging the INOPERABLE battery during this period if needed, 4/ work done on the opposite train will be ,

minimized during this period, and 5/ installation of the modification will be carried out in accordance with I implementation procedures. Thus a commensurate level of safety is maintained.

l At no point during this modification is power lost to the DC and

j AC panelboards. A normal plant procedure is used to transfer ;

power for the AC panelboards back and forth between their. ,

inverters and their alternate regulated AC power supplies (1KRP l and 2KRP). Instrumentation as described above remains valid.to t l detect an undervoltage condition in the vital DC and AC ,

panelboards being temporarily connected to their same train power 6

source. Temporary cables and breakers meet all applicable safety !

class lE and seismic 'equirements. Temporary cabling will ;

l satisfy cable separation criteria. There will be no degradation of distribution centers and panelboards as a result of temporary i breakers being installed in them. :

i Based on the above evaluation, it is concluded that the proposed l TS changes do not compromise the safety of any system. The proposed changes do not affect any accident previously analyzed nor create any possible new accidents, and does not compromise in any way the safety of the public.

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ATTACHMENT 4 NO SIGNIFICANT HAZARDS CONSIDERATION i

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1 U.S. Nuclear Regulatory Commission Attachment 4 February 23, 1995 Page 1/3 >

No Significant Hazards Considerations As required by 10 CFR 50.91, this analysis is provided concerning whether the requested amendments involve significant hazards considerations, as defined by 10 CFR 50.92. Standards for determination that an amendment request involves no significant hazards considerations are if operation of the facility in accordance with the requested amendment would not: 1) Involve a.

significant increase in the probability or consequences of an accident previously evaluated; or 2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or 3) Involve a significant reduction in a margin of safety. .

The proposed TS changes are needed to allow replacement of the battery circuit breaker (600A), distribution center main incoming circuit breaker (600A), and tie circuit breaker (400A) for each of the 4 channels of the 125 VDC Vital Instrumentation and Control Power System thus increasing reliability of safety related DC power source. The battery circuit breaker will be replaced with a non-fusible switch (600A), and the. distribution center main incoming circuit breaker will be replaced with a ,

fusible switch (600A). The tie circuit breaker will be replaced I with either the battery or main incoming breaker previously removed (these breakers are capable of being set at a higher instantaneous overcurrent setting than the existing tie breaker).

The new arrangement will use a fusible switch which opens at a later point than the present main incoming breaker, thereby allowing enough time for the individual breakers on the 125 VDC panelboards to trip on a fault condition, so that the entire distribution center (EVDA, EVDB, EVDC or EVDD) will not be lost l

due to tripping of the main incoming breaker.

l In 48 FR 14870, the Commission has set forth examples of i

amendments that are considered likely to involve significant hazards considerations. Example iii describes a change which involves a significant relaxation in limiting conditions for operation not accompanied by compensatory changes, conditions, or actions that maintain a commensurate level of safety. The requested mmendment is not similar to example.iii above in that the proposed changes do not involve a significant relaxation in limiting conditions for operation. Even though the proposed changes involve a relaxation in outage time (112 hours0.0013 days 0.0311 hours 1.851852e-4 weeks 4.2616e-5 months vs. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ), they are accompanied by compensatory conditions: 1/ no equalizing charge on any of the three OPERABLE battery banks is allowed during this time,.2/ all inputs to the DC channel trouble alarm except those from the associated DC and AC panelboard

, undervoltage relays will be blocked during this time so that an j undervoltage condition on any of the DC and AC panelboards during this period will be detected, 3/ a temporary portable charger

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l U.S. Nuclear Regulatolf Commission Attachment 4 February 23, 1995 Page 2/3 l l

will be available for charging,the INOPERABLE battery during this 1 period if needed, 4/ work done on the opposite train will be l

. minimized during this period, and 5/ installation of the modification will be carried out in accordance with implementation procedures. Thus a commensurate level of safety is maintained. l Criterion 1 Operation of the facility in accordance with the requested amendments will not involve a significant increase in the probability or consequences of an accident previously evaluated.

At no point during this temporary modification is power lost to the DC and AC panelboards. A normal plant procedure is used to transfer power for the AC panelboards back and forth between their inverters and their alternate regulated AC power supplies (lKRP and 2KRP). All inputs to the DC channel trouble alarm except those from the associated DC and AC panelboard undervoltage relays will be blocked during the 112 hour0.0013 days 0.0311 hours 1.851852e-4 weeks 4.2616e-5 months temporary modification period so that an undervoltage condition on any of the DC and AC panelboards during this period will be detected immediately. Temporary cabling will satisfy cable separation criteria., Temporary cables and breakers meet all applicable safety class 1E and seismic requirements. There will be no degradation of distribution centers and panelboards as a result of temporary breakers being installed in them.

Criterion 2 Operation of the facility in accordance with the requested amendments will not create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed TS changes will not create the possibility for an accident or malfunction of a different type than any previously evaluated. No new failure modes are being created by the proposed TS changes.

Criterion 3 Operation of the facility in accordance with the requested amendments will not involve a significant reduction in a margin of safety. The proposed TS changes will not reduce the margin of ;

safety as described in the bases for any Technical Specifications. The bases for Tech. Specs. 3/4.8.2 and 3/4.8.3 (minimum specified independent and redundant A.C and D.C. power sources and distribution systems to supply safety-related equipment for safe shutdown and mitigation / control of accident conditions) will not be impacted by these proposed TS changes.

The proposed TS changes will not reduce the margin of safety i since the temporary cables and breakers meet all applicable safety class 1E and seismic requirements. The use of temporary

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U.S. Nuclear Regulatory Commission Attachment 4 February 23, 1995 Page 3/3 cables and breakers to facilitate the de-energization of a vital bus and connection of its loads to its same train vital bus for breaker replacement does not technically violate the applicable technical specifications since the intent of these technical specifications is to have uninterrupted power to the loads normally connected to this de-energized bus. Instrumentation during the temporary modification period remains valid to i immediately detect an undervoltage condition in the affected DC l and AC panelboards. l Based on the preceding analyses, Duke Power concludes that the l requested amendments do not involve a significant hazards consideration. i l

Environmental Impact Analysis

! The proposed Technical Specification amendment has been reviewed i l -against the criteria of 10 CFR 51.22 for environmental j l considerations. The proposed amendment does not involve a significant hazards consideration, nor increase the types and ;

amounts of effluents that may.be released offsite, nor increase l individual or cumulative occupational radiation exposures. '

Therefore, the proposed amendment meets the criteria given in 10 CFR 51.22 (c) (9) for a categorical exclusion from the requirement ,

for an Environmental Impact Review.

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ML20080K186

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