ML22152A123

Issuance of Amendment No. 271 Request for Exception from Certain Primary Containment Leak Rate Testing Requirements

ML22152A123
Person / Time
Site:	Cooper
Issue date:	07/18/2022
From:	Thomas Wengert Plant Licensing Branch IV
To:	Dent J Nebraska Public Power District (NPPD)
Wengert T, NRR/DORL/LPLIV, 415-4037
References
EPID L-2021-LLA-0129
Download: ML22152A123 (14)

Text

July 18, 2022 Mr. John Dent, Jr.

Vice President and Chief Nuclear Officer Nebraska Public Power District 72676 648A Avenue P.O. Box 98 Brownville, NE 68321

SUBJECT:

COOPER NUCLEAR STATION - ISSUANCE OF AMENDMENT NO. 271 RE:

REQUEST FOR EXCEPTION FROM CERTAIN PRIMARY CONTAINMENT LEAK RATE TESTING REQUIREMENTS (EPID L-2021-LLA-0129)

Dear Mr. Dent:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 271 to Renewed Facility Operating License No. DPR-46 for Cooper Nuclear Station (Cooper). The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated July 20, 2021.

The amendment revises Cooper TS 5.5.12, Primary Containment Leakage Rate Testing Program, to allow for an exception to a leak testing requirement of the program. Specifically, the amendment extends the allowance to not vent and drain pathways during the Type A test, which have been Type B or C tested within the previous 24 calendar months of the Type A test, from 24 calendar months to 30 calendar months.

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

Sincerely,

/RA/

Thomas J. Wengert, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298

Enclosures:

1. Amendment No. 271 to DPR-46

2. Safety Evaluation cc: Listserv

NEBRASKA PUBLIC POWER DISTRICT DOCKET NO. 50-298 COOPER NUCLEAR STATION AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 271 Renewed License No. DPR-46

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Nebraska Public Power District (the licensee),

dated August 19, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations 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 amended by 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. DPR-46 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 271, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3.

The license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. DPR-46 and the Technical Specifications Date of Issuance: July 18, 2022 Jennifer L.

Dixon-Herrity Digitally signed by Jennifer L. Dixon-Herrity Date: 2022.07.18 09:38:15 -04'00'

ATTACHMENT TO LICENSE AMENDMENT NO. 271 RENEWED FACILITY OPERATING LICENSE NO. DPR-46 COOPER NUCLEAR STATION DOCKET NO. 50-298 Replace the following pages of the Renewed Facility Operating License No. DPR-46 and Appendix A Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Renewed Facility Operating License REMOVE INSERT Technical Specifications REMOVE INSERT 5.0-17 5.0-17 5.0-18 5.0-18 5.0-19 5.0-19

Amendment No. 271 (5) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by operation of the facility.

C. This license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; 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 The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2419 megawatts (thermal).

(2) Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 271, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Physical Protection The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: Cooper Nuclear Station Safeguards Plan, submitted by letter dated May 17, 2006.

NPPD shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The NPPD CSP was approved by License Amendment No. 238 as supplemented by changes approved by License Amendments 244 and 249.

(4) Fire Protection NPPD shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment request dated April 24, 2012 (and supplements dated July 12, 2012, January 14, 2013, February 12, 2013, March 13, 2013, June 13, 2013, December 12, 2013, January 17, 2014, February 18, 2014, and April 11, 2014), and as approved in the safety evaluation dated April 29, 2014.

Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if

Programs and Manuals 5.5 5.5 Programs and Manuals (continued)

Cooper 5.0-17 Amendment No. 271 5.5.12 Primary Containment Leakage Rate Testing Program (continued)

5.

Exemption from Section III.B of 10CFR Part 50, Appendix J, Option B, to allow the contribution from Main Steam Pathway (Main Steam lines and Main Steam inboard drain line) leakage to be excluded from the sum of the leakage rates from Type B and Type C tests (September 14, 2009).

6.

Exception to NEI 94-01, Industry Guideline for Implementing Performance-Based Option of 10 CFR 50, Appendix J, to allow testing of Type C Residual Heat Removal heat exchanger relief valves and their associated Type B testable discharge flange tests at the same frequency as the visual examination, seat leakage testing, and set pressure testing performed for these valves under the requirements of the Inservice Testing Program per 10 CFR 50.55a(f).

7.

Exception to NEI 94-01, Rev. 0, lndustry Guideline for lmplementing Performance-Based Option of 10 CFR Part 50, Appendix J, Section 8.0 and Section 9.2.1, to allow that pathways which are Type B or C tested within the previous 30 calendar months of the Type A test, need not be vented or drained during the Type A test.

b.

The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 58.0 psig. The containment design pressure is 56.0 psig.

c.

The maximum allowable containment leakage rate, La, at Pa, shall be 0.635% of containment air weight per day.

d.

Leakage Rate acceptance criteria are:

1.

Containment leakage rate acceptance criterion is 1.0 La. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are, <0.60 La for the Type B and C tests and 0.75 La for Type A tests.

2.

Air lock testing acceptance criteria are:

a.

Overall air lock leakage rate is 12 scfh when tested at Pa.

b.

Overall air lock leakage rate is 0.23 scfh when tested at 3.0 psig.

e.

The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program.

f.

The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program.

Programs and Manuals 5.5 5.5 Programs and Manuals (continued)

(continued)

Cooper 5.0-18 Amendment No. 271 5.5.13 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Filter (CREF) System, CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of either (a) 5 rem whole body or its equivalent to any part of the body for the duration of the loss-of-coolant accident, or (b) 5 rem total effective dose equivalent (TEDE) for the duration of the fuel handling accident. The program shall include the following elements:

a.

The definition of the CRE and CRE boundary.

b.

Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.

c.

Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors,"

Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0. No exceptions to Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0, are proposed.

d.

Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by the CREF System, operating at the flow rate required by the Ventilation Filter Testing Program, at a Frequency of 24 months. The results shall be trended and used as part of the periodic assessment of the CRE boundary.

e.

The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

Programs and Manuals 5.5 5.5 Programs and Manuals Cooper 5.0-19 Amendment No. 271 5.5.13 Control Room Envelope Habitability Program (continued)

f.

The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered air inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

5.5.14 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a.

The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b.

Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c.

The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 271 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-46 NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298

1.0 INTRODUCTION

By application dated July 20, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21202A200), Nebraska Public Power District (the licensee) requested a change to the technical specifications (TSs) for Cooper Nuclear Station (Cooper).

The proposed change would revise Cooper TS 5.5.12, Primary Containment Leakage Rate Testing Program, to allow for an exception to a leak rate testing requirement of the program.

Specifically, the licensee requested to extend the allowance to not vent and drain pathways during the Type A test that have been previously Type B or C tested from 24 calendar months to 30 calendar months prior to the Type A test.

1.1 Background

In its application dated July 20, 2021, the licensee stated that Cooper is currently on a 24-month refueling cycle, and that most of the Title 10 of the Code of Federal Regulations (10 CFR)

Part 50, Appendix J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors, Types B and C tests are performed during refueling outages, with a select few Type B and C tests performed prior to the outages. The licensee also stated that it plans to perform a Type A test near the end of refueling outage RE32, which is scheduled for the fall of 2022. The licensee added that the Types B and C testing that is not on an extended frequency under Option B, Performance-Based Requirements, of Appendix J, will be tested during refueling outage RE32 (or pre-outage).

The licensee further stated that these Types B and C tests will meet the 24-calendar month requirement of Nuclear Energy Institute (NEI) 94-01, Revision 0, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J (ML11327A025).

However, any Types B and C testing on an extended frequency that was tested during the previous refueling outage (RE31) in the fall of 2020 (or pre-outage), would not meet the 24-calendar month requirement of NEI 94-01, Revision 0. The time period would be approximately 24-26 months prior to the Type A test.

In the license amendment request (LAR), the licensee explained that, without this exception, it would have to reperform the Types B and C tests that were performed during RE31 in RE32 to be in compliance with the 24-calendar month criterion. The licensee noted that this would involve approximately 78 Types B and C tests, 41 of which are Type B and 37 of which are Type C. The licensee stated that these tests would result in additional scheduling concerns, resources required, and approximately 300 millirem of additional radiological dose during refueling outage RE32 without a compensating increase in safety.

2.0 REGULATORY EVALUATION

2.1

System Description

The Cooper Updated Safety Analysis Report (USAR), Revision 30 (ML21130A114), describes the primary containment as a General Electric Mark I pressure suppression system design housing the reactor vessel, the reactor coolant recirculation loops, and other branch connections of the reactor primary system. The primary containment consists of a drywell, a suppression chamber (torus) that stores a large volume of water (suppression pool), a connecting vent system between the drywell and the suppression pool, isolation valves, a primary containment isolation system, and a vacuum relief system. Additional equipment, including portions of the emergency core cooling system, is located within the primary containment and provides services to the primary containment.

In the event of a process system piping failure within the drywell, reactor water and steam will be released into the drywell gas space. The resulting increased drywell pressure forces a mixture of air, steam, and water through the vent system into the suppression pool. The steam condenses rapidly in the suppression pool, resulting in rapid pressure reduction in the drywell.

Air transferred during reactor blowdown to the suppression chamber pressurizes the chamber and subsequently is vented to the drywell through the vacuum relief system as the pressure in the drywell drops below that in the suppression chamber. Steam remaining in the drywell can be condensed by the containment spray system, as described in Cooper USAR section IV-8.5.3, Containment Cooling Subsystems.

Cooling systems are provided to remove heat from the suppression pool to provide for continuous cooling of the primary containment under the postulated design-basis accident conditions for which the primary containment is assumed to be functional. Isolation valves are provided to ensure containment of radioactive materials within the primary containment, which might be released from the reactor to the containment during an accident. Other service equipment is provided to maintain the containment within its design parameters during normal operation.

2.2 The Licensees Proposed TS Changes In the LAR, the licensee proposed to change Cooper TS 5.5.12 by adding a new exception 7 to the description of the guidance used. TS 5.5.12 currently states, in part:

a.

A program shall establish the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, Performance-

Based Containment Leak-Test Program, dated September 1995, as modified by the following exceptions:

TS 5.5.12.a is modified by six exceptions. The licensees proposed change would add a seventh exception which would state:

7.

Exception to NEI 94-01, Rev. 0, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J, Section 8.0 and Section 9.2.1, to allow that pathways which are Type B or C tested within the previous 30 calendar months of the Type A test, need not be vented or drained during the Type A test.

2.3 Regulatory Requirements The regulation in 10 CFR 50.36(c)(5), Administrative controls, requires, in part, the inclusion of administrative controls in TSs that are necessary to assure operation of the facility in a safe manner.

Appendix J to 10 CFR Part 50, identifies three types of required tests: (1) Type A tests, which are intended to measure the primary containment overall integrated leakage rate; (2) Type B tests, which are intended to detect local leaks and to measure leakage across pressure-containing or leakage limiting boundaries (other than valves) for primary containment penetrations; and (3) Type C tests, which are intended to measure containment isolation valve leakage rates. The regulation in 10 CFR Part 50, Appendix J, was revised, effective October 26, 1995,1 to allow licensees to choose containment leakage testing under either Option A, Prescriptive Requirements, or Option B, Performance-Based Requirements. Option B requires that test intervals for Types A, B, and C testing be determined by using a performance-based approach.

License Amendment No. 180, dated March 3, 2000 (ML003690276), approved the implementation of 10 CFR Part 50, Appendix J, Option B, for Cooper. The amendment added TS 5.5.12, Primary Containment Leakage Rate Testing Program, to require Type A, B and C testing in accordance with Regulatory Guide (RG) 1.163, Performance-Based Containment Leak-Test Program, dated September 1995 (ML003740058). RG 1.163 specifies a method acceptable to the U.S. Nuclear Regulatory Commission (NRC or the Commission) for complying with Option B by approving the use of NEI 94-01, Revision 0, and American Nuclear Standards Institute/American Nuclear Society Standard ANSI/ANS - 56.8-1994, Containment System Leakage Testing Requirements.

2.4 Regulatory Guidance NEI 94-01, Revision 0, contains an allowance that for planning and scheduling purposes, or as low as reasonably achievable (ALARA) considerations, pathways which are Type B or C tested within the previous 24 calendar months need not be vented or drained during the Type A test.

The as-found and as-left leakage rates from those tests are added to the Type A results to provide an indication of overall containment leakage. The 24-calendar month criterion was approved because most plants were operating on an 18-month refueling cycle. The 24 calendar months allowed the use of leak test results from the previous refueling outage. Cooper is 1 Federal Register Notice, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors Final Rule (60 FR 49495-49505, September 26, 1995).

currently on a 24-month refueling cycle such that the benefit of this allowance is greatly reduced. The licensee stated that allowing pathways that have been Type B or C tested within the previous 30 calendar months to not be vented or drained during the Type A test would restore this benefit, reducing outage resources and radiological dose.

NEI 94-01, Revision 0, section 9.2.1, Pretest Inspection and Test Methodology, states, in part:

For planning and scheduling purposes, or ALARA considerations, licensees may want to consider not venting and draining additional penetrations that are capable of local leakage rate testing. It should be noted that the Type B or C tests performed on those pathways must test all of its containment barriers. This includes bonnets, packings, flanged joints, threaded connections, and compression fittings. If the Type B or C test pressurizes any of the pathways containment barriers in the reverse direction, it must be shown that test results are not affected in a nonconservative manner by directionality. The As-found and the As-left leakage rate for all pathways that are not drained and vented must be determined by Type B and Type C testing within the previous 24 calendar months of the time that the Type A test is performed and must be added to the Type A leakage rate UCL [upper confidence limit] to determine the overall La

[maximum allowable Type A test leakage rate at Pressure Pa] surveillance acceptance criteria in accordance with the definition in ANSI/ANS 56.8-1994.

NEI 94-01, Revision 3-A, dated July 2012 (ML12221A202), revised the Type A test standard exclusion period for previously performed Types B and C tests to 30 calendar months.

NEI 94-01, Revision 3-A, was approved by an NRC staff safety evaluation (SE) dated May 8, 2012 (ML12221A202). Additionally, NEI 94-01, Revision 3-A, section 2.0, Purpose and Scope, states, in part, that:

This guideline delineates the basis for a performance-based approach for determining Type A, Type B, and Type C containment leakage rate surveillance testing frequencies. It does not address how to perform the tests because these details can be found in existing documents (e.g., ANSI/ANS-56.8-2002)... and this document, NEI 94-01. Where differences exist, NEI 94-01, Revision 3-A takes precedence.

ANSI/ANS-56.8-2002, section 3.2.5(4) states:

[T]he venting and draining requirements are optional for pathways that have been Type B or Type C tested within the previous 30 calendar months of the time that the Type A test is performed or during the same cycle in which the Type A test is performed (before or after). The latest as-left MNPLR [minimum pathway leakage rate] for those penetrations that have not been vented and drained shall be added to the measured Type A leakage rates UCL for comparison against the acceptance criteria.

3.0 TECHNICAL EVALUATION

The licensee stated that License Amendment No. 180 authorized the licensee to use 10 CFR Part 50, Appendix J, Option B provisions for Types A, B, and C tests for Cooper. The NRC staff finds that the 24 calendar months requirement in Cooper TS 5.5.12, was based on NEI 94-01, Revision 0, and that the 24-month requirement was extended to 30 calendar months in

section 8.0 of NEI 94-01, Revision 3-A. The NRC SE for NEI 94-01, Revision 3-A, stated, in part: The NRC staff reviewed NEI TR [Topical Report] 94-01, Revision 3, and determined that it describes an acceptable approach for implementing the optional performance-based requirements of Option B to 10 CFR Part 50, Appendix J, as modified by the conditions and limitations summarized in section 4.0 of this SE.

Summary of Technical Evaluation This proposed license amendment does not change the test frequencies themselves, only how long measured Type B or C test results for isolated penetrations could be added to the Type A test measured leakage, instead of measuring actual leakage through all penetrations as part of the integrated Type A test. The change is consistent with previously approved NEI 94-01, Revision 3-A. Therefore, the NRC staff concludes that allowing the 24 calendar month exclusion for Types B and C tested penetrations to extend beyond the 24 calendar month period (up to a 30 calendar month period) will have a negligible impact on containment integrity and is therefore, acceptable. Based on the discussions above, the NRC staff finds that the proposed changes to TS 5.5.12 assure continued operation of the facility in a safe manner and therefore, the requirements of 10 CFR 50.36(c)(5) and 10 CFR Appendix J will continue to be met.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Nebraska State official was notified of the proposed issuance of the amendment on May 26, 2022. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves 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 amendment involves no significant hazards consideration published in the Federal Register on October 5, 2021 (86 FR 55012), and there has been no public comment on such finding. Accordingly, the amendment meets 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 amendment.

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 Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: N. Chien J. Ma Date: July 18, 2022

ML22152A123

• by email OFFICE NRR/DORL/LPL4/PM*

NRR/DORL/LPL4/LA NRR/DEX/ESEB/BC*

NAME TWengert PBlechman JColaccino (BLehman for)

DATE 6/6/2022 6/9/2022 6/17/2022 OFFICE NRR/DSS/SCPB/BC(A)*

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NRR/DORL/LPL4/PM NAME RHarper JDixon-Herrity TWengert DATE 6/29/2022 7/13/2022 7/18/2022