ML23310A292
| ML23310A292 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  (NPF-091) |
| Issue date: | 12/07/2023 |
| From: | Cayetano Santos NRC/NRR/VPOB |
| To: | Coleman J Southern Nuclear Operating Co |
| References | |
| EPID L-2023-LLA-0075, LAR 23-007, RG-1.163 | |
| Download: ML23310A292 (15) | |
Text
December 7, 2023 Ms. Jamie M. Coleman, Director Regulatory Affairs Southern Nuclear Operating Company, Inc.
3535 Colonnade Parkway, Bin-N-274-EC Birmingham, AL 35243
SUBJECT:
VOGTLE ELECTRIC GENERATING PLANT, UNIT 3 - ISSUANCE OF AMENDMENT FOR EXCEPTION TO REGULATORY GUIDE 1.163, LAR 23-007 (EPID NO. L-2023-LLA-0075)
Dear Ms. Coleman:
In response to your application dated May 25, 2023, the U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 196 to Combined License (COL) No. NPF-91 for Vogtle Electric Generating Plant (VEGP) Unit 3. The amendment revises Technical Specification (TS) 5.5.8, Containment Leakage Rate Testing Program, to permit an exception to Regulatory Guide (RG) 1.163, Performance-Based Containment Leak-Test Program. This exception allows the first periodic Type A integrated leak rate test (ILRT) for VEGP Unit 3 to be performed prior to the earlier of initial Mode 4 entry for Cycle 2 and midnight on May 31, 2025.
A copy of the related Safety Evaluation, which includes the staffs evaluation of the amendment, is enclosed. The notice of issuance of the amendment documents included in this letter will be published in the Federal Register.
J. Coleman In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 2, Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access and Management System (ADAMS).
ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html.
Sincerely, Cayetano G. Santos Jr., Senior Project Manager Vogtle Project Office Office of Nuclear Reactor Regulation Docket Nos.: 52-025
Enclosures:
1.
Amendment No. 196 to VEGP Unit 3 COL 2.
Safety Evaluation cc: Listserv Cayetano G.
Santos Digitally signed by Cayetano G. Santos Date: 2023.12.07 12:38:16 -05'00'
- via e-mail NRO-002 OFFICE NRR/VPO/PM NRR/VPO/LA NRR/DSS/STSB/BC NRR/DSS/SCPB/BC NAME CSantos RButler* (KGoldstein for)
SMehta*
BWittick*
DATE 11/03/23 11/07/2023 11/15/23 11/15/23 OFFICE NRR/DEX/EMIB/BC NRR/DRA/ARCB/BC NRC/OGC NRR/VPO/D NAME SBailey*
KHsueh*
Aghosh Naber LNist DATE 11/08/23 11/16/23 12/01/23 12/07/23 OFFICE NRR/VPO/PM NAME CSantos (s)
DATE 12/07/23 SOUTHERN NUCLEAR OPERATING COMPANY, INC.
GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MEAG POWER SPVM, LLC MEAG POWER SPVJ, LLC MEAG POWER SPVP, LLC CITY OF DALTON, GEORGIA VOGTLE ELECTRIC GENERATING PLANT, UNIT 3 DOCKET NO.52-025 AMENDMENT TO FACILITY COMBINED LICENSE Amendment No. 196 License No. NPF-91
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Southern Nuclear Operating Company (SNC),
dated May 25, 2023, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I; B.
The facility will be constructed and 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 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 Appendix A, Technical Specifications, of the facility Combined License as indicated in the attachment to this license amendment. Paragraph 2.D(8) of facility Combined License No. NPF-91 is hereby amended to read as follows:
(8)
Incorporation The Technical Specifications and Environmental Protection Plan in Appendices A and B, respectively, of this license, as revised through Amendment No. 196, are hereby incorporated into this license.
3.
This license amendment is effective as of the date of its issuance and shall be implemented within 30 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Lauren A. Nist, Director Vogtle Project Office Office of Nuclear Reactor Regulation
Attachment:
Page 7 of the facility Combined License and affected pages of Appendix A of the facility Combined License Date of Issuance: December 7, 2023 Lauren A.
Nist Digitally signed by Lauren A. Nist Date: 2023.12.07 12:51:11 -05'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 196 TO FACILITY COMBINED LICENSE NO. NPF-91 DOCKET NO.52-025 Replace the following pages of the facility Combined License No. NPF-91 with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Facility Combined License No. NPF-91 REMOVE INSERT 7
7 Appendix A to facility Combined License No. NPF-91 REMOVE INSERT 5.5-8 5.5-8
7 Amendment No. 196 (7)
Reporting Requirements (a)
Within 30 days of a change to the initial test program described in UFSAR Section 14, Initial Test Program, made in accordance with 10 CFR 50.59 or in accordance with 10 CFR Part 52, Appendix D,Section VIII, Processes for Changes and Departures, SNC shall report the change to the Director of NRO, or the Directors designee, in accordance with 10 CFR 50.59(d).
(b)
SNC shall report any violation of a requirement in Section 2.D.(3),
Section 2.D.(4), Section 2.D.(5), and Section 2.D.(6) of this license within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Initial notification shall be made to the NRC Operations Center in accordance with 10 CFR 50.72, with written follow up in accordance with 10 CFR 50.73.
(8)
Incorporation The Technical Specifications and Environmental Protection Plan in Appendices A and B, respectively, of this license, as revised through Amendment No. 196, are hereby incorporated into this license.
(9)
Technical Specifications The technical specifications in Appendix A to this license become effective upon a Commission finding that the acceptance criteria in this license (ITAAC) are met in accordance with 10 CFR 52.103(g).
(10)
Operational Program Implementation SNC shall implement the programs or portions of programs identified below, on or before the date SNC achieves the following milestones:
(a)
Environmental Qualification Program implemented before initial fuel load; (b)
Reactor Vessel Material Surveillance Program implemented before initial criticality; (c)
Preservice Testing Program implemented before initial fuel load; (d)
Containment Leakage Rate Testing Program implemented before initial fuel load; (e)
- 1.
The fire protection measures in accordance with Regulatory Guide (RG) 1.189 for designated storage building areas (including adjacent fire areas that could affect the storage area) implemented before initial receipt
Technical Specifications Programs and Manuals 5.5 VEGP Units 3 and 4 5.5 - 8 Amendment No. 196 (Unit 3)
Amendment No. 181 (Unit 4) 5.5 Programs and Manuals 5.5.8 Containment Leakage Rate Testing Program a.
A program shall be established to implement 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 exception: for Unit 3 only, the specified Frequency for the first periodic Type A test shall be the earlier of a) initial MODE 4 entry for Unit 3 Cycle 2 and b) 2400 hours0.0278 days <br />0.667 hours <br />0.00397 weeks <br />9.132e-4 months <br /> on May 31, 2025.
b.
The calculated peak containment internal pressure for the design basis loss of coolant accident, Pa, is 58.1 psig. The containment design pressure is 59 psig.
c.
The maximum allowable primary containment leakage rate, La, at Pa, shall be 0.10% of primary 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 Type C tests and 0.75 La for Type A tests; 2.
Air lock testing acceptance criteria are:
i.
Overall air lock leakage rate is 0.05 La when tested at Pa, ii.
For each door, leakage rate is 0.01 La when pressurized to 10 psig.
e.
The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program.
f.
Nothing in these Technical Specifications shall be construed to modify the testing Frequencies required by 10 CFR 50, Appendix J.
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 196 TO THE COMBINED LICENSE NO. NPF-91 SOUTHERN NUCLEAR OPERATING COMPANY, INC.
GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MEAG POWER SPVM, LLC MEAG POWER SPVJ, LLC MEAG POWER SPVP, LLC CITY OF DALTON, GEORGIA VOGTLE ELECTRIC GENERATING PLANT, UNIT 3 DOCKET NO.52-025
1.0 INTRODUCTION
By letter dated May 25, 2023 (Agencywide Documents Access and Management System Accession No. ML23145A265), the Southern Nuclear Operating Company (the licensee or SNC) requested that the Nuclear Regulatory Commission (NRC) amend Vogtle Electric Generating Plant (VEGP), Unit 3 Combined License (COL) Number NPF-91. License Amendment Request (LAR)23-007 proposed a revision to COL Appendix A, Technical Specification (TS) 5.5.8, Containment Leakage Rate Testing Program, to permit an exception to Regulatory Guide (RG) 1.163, Performance-Based Containment Leak-Test Program, (ML003740058). This exception would allow, for VEGP Unit 3, the specified frequency for the first periodic Type A integrated leak rate test (ILRT) to be performed prior to the earlier of initial Mode 4 entry for Unit 3 Cycle 2 and midnight on May 31, 2025.
2.0 REGULATORY EVALUATION
2.1 Regulatory Requirements Regulations in 10 CFR Part 52, Appendix D, VIII.C.6 state that after issuance of a license, Changes to the plant-specific TS will be treated as license amendments under 10 CFR 50.90.
The regulation in 10 CFR 50.90 addresses applications for amendment of license, construction permit, or early site permit. The proposed LAR requires changes in the TS; therefore, in accordance with 10 CFR 50.90, an LAR is required to be submitted for NRC approval.
The NRC regulatory requirements related to the content of the TSs are contained in 10 CFR 50.36, Technical specifications. The regulations in 10 CFR 50.36(c)(5),
Administrative controls, state, in part:
Technical specifications will include items in the following categories:...
Administrative controls. Administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.
Section 50.54(o) of 10 CFR requires primary reactor containments for water cooled power reactors be subject to the requirements set forth in Appendix J to 10 CFR Part 50, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors. Appendix J to 10 CFR Part 50 includes two options: Option A - Prescriptive Requirements, and Option B - Performance-Based Requirements, either of which may be chosen by a licensee for meeting the requirements of the Appendix. SNC adopted 10 CFR Part 50, Appendix J, Option B for VEGP Unit 3.
The testing requirements in 10 CFR Part 50, Appendix J ensure that (a) leakage through containments or systems and components penetrating containments does not exceed allowable leakage rates specified in the TS, and (b) integrity of the containment structure is maintained during the service life of the containment.
Option B of 10 CFR Part 50, Appendix J, specifies performance-based requirements and criteria for preoperational and subsequent leakage rate testing. These requirements are met by performing Type A tests to measure the containment system overall integrated leakage rate; Type B pneumatic tests to detect and measure local leakage rates across pressure-retaining leakage-limiting boundaries, such as penetrations; and Type C pneumatic tests to measure containment isolation valve leakage rates. After the preoperational tests, these tests are required to be conducted at periodic intervals based on the historical performance of the overall containment system (for Type A tests) and based on the safety significance and historical performance of each penetration boundary and isolation valve (for Type B and C tests) to ensure integrity of the overall containment system as a barrier to fission product release.
The leakage rate test results must not exceed the allowable leakage rate (La) with margin, as specified in the TS. Option B also requires that a general visual inspection of the accessible interior and exterior surfaces of the containment system, for structural deterioration that may affect the containment leak-tight integrity, must be conducted prior to each Type A test and at a periodic interval between tests.
Section V.B.3 of 10 CFR Part 50, Appendix J, Option B, requires that the RG or other implementation document used by a licensee to develop a performance-based leakage-testing program must be included, by general reference, in the plant TSs. Furthermore, the submittal for TS revisions must contain justification, including supporting analyses, if the licensee chooses to deviate from methods approved by the Commission and endorsed in a RG.
2.2 Regulatory Guidance RG 1.163, dated September 1995, states that NEI 94-01, Revision 0, dated July 26, 1995, Industry Guideline for Implementing Performance Based Option of 10 CFR 50, Appendix J, [ML11327A025] prepared by the Nuclear Energy Institute, provides methods acceptable to the NRC staff for complying with the provisions of Option B in Appendix J to 10 CFR Part 50, subject to four identified considerations.
The Updated Final Safety Analysis Report (UFSAR) for VEGP Units 3 and 4 (ML23165A215) states in Appendix 1A that VEGP Unit 3 conforms with the September 1995 version of RG 1.163 and thus conforms to NEI 94-01, Revision 0.
NEI 94-01, Revision 0, Section 9.2.2, Initial Test Intervals, states the following:
A preoperational Type A test shall be conducted prior to initial reactor operation.
If initial reactor operation is delayed longer than 36 months after completion of the preoperational Type A test, a second preoperational Type A test shall be performed prior to initial reactor operations.
The first periodic Type A test shall be performed within 48 months after the successful completion of the last preoperational Type A test. Periodic Type A tests shall be performed at a frequency of at least once per 48 months, until acceptable performance is established in accordance with Section 9.2.3. The interval for testing should begin at initial reactor operation. Each test interval begins upon completion of a Type A test and ends at the start of the next test.
If the test interval ends while primary containment integrity is either not required or it is required solely for shutdown activities, the test interval may be extended indefinitely. However, a successful Type A test shall be completed prior to entering the operating mode requiring primary containment integrity.
Regulatory Issue Summary (RIS) 2008-27, Staff Position on Extension of the Containment Type A Test Interval Beyond 15 Years Under Option B of Appendix J to 10 CFR Part 50 (ML080020394), states that licensees who determine the due date for a Type A test using the definition in Section 9.2.2 of NEI 94-01 gains limited flexibility by being able to commence the test no later than the last day of the month in which it becomes due, without seeking NRC approval.
3.0 TECHNICAL EVALUATION
3.1 Description of VEGP Unit 3 containment The containment is a free-standing steel pressure vessel surrounded by a reinforced concrete shield building. The containment vessel, including all its penetrations, is a low leakage steel vessel designed to contain radioactive material that may be released from the reactor core following a Design Basis Accident such that offsite radiation exposures are maintained within limits. The containment and shield building provide shielding from the fission products that may be present in the containment atmosphere following accident conditions.
The inner steel containment and its penetrations establish the leakage limiting boundary of the containment. The TS leakage rate Surveillance Requirements comply with 10 CFR Part 50, Appendix J, Option B, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors, Performance-Based Requirements, as modified by approved exemptions.
3.2 Licensees Proposed Changes The current TS 5.5.8a states:
A program shall be established to implement 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 approved exceptions.
With the proposed changes, the VEGP Unit 3 TS 5.5.8a would be revised as shown below.
Proposed additions are underlined and proposed deletions appear in strikeout.
A program shall be established to implement 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 approved the following exceptions: for Unit 3 only, the specified Frequency for the first periodic Type A test shall be the earlier of a) initial MODE 4 entry for Unit 3 Cycle 2 and b) 2400 hours0.0278 days <br />0.667 hours <br />0.00397 weeks <br />9.132e-4 months <br /> on May 31, 2025.
3.3 Reason for Proposed Change Section 2.3 of LAR 23-007 states the following.
The pre-operational integrated leak rate test (ILRT), or Type A test, was completed for VEGP Unit 3 on July 12, 2020. Initial reactor operation, as defined by imposing containment operability as required by Technical Specification 3.6.1, Containment, was achieved December 8, 2022, i.e., first entry into Mode 4. The result was that initial operation was 29 months after the initial preoperational Type A test. As such, the 36-month criteria in the first paragraph of NEI 94-01 Section 9.2.2 does not require a second pre-operational performance of the Type A test prior to July 2023 pursuant to this criterion.
However, the second paragraph of NEI 94-01 Section 9.2.2 requires the first periodic Type A test be performed within 48 months of the pre-operational Type A test.
With the additional flexibility from the [RIS 2008--27] provisions for conducting Type A tests, the 48-month criterion from July of 2020 would require that the first periodic Type A test be performed by the end of July 2024.
Section 2.3 of the LAR 23-007 also states:
At the time of performance of the pre-operational ILRT in July of 2020, the Unit 3 was scheduled for commercial operation in May of 2021, and a refueling outage would have then been scheduled in 2022 during which the first operational ILRT would be performed to meet this 48-month requirement. Due to delays in the startup of Unit 3, commercial operation was delayed until June of 2023 with the first refueling outage now scheduled for October 2024.
To meet the 48-month criterion and conduct the first periodic Type A test by July 2024 would require an unscheduled shutdown of Unit 3. In order to achieve the necessary fuel burnup for entering the first refueling outage, SNC is requesting an extension of the 48-month criterion for the first periodic Type A test. The requested exception represents a maximum extension of 10-months (from July 2024 to May 2025), with flexibility to schedule the refueling outage in the fall of 2024 or the spring of 2025.
3.4 Pre-Operational Leakage Rate Test Results Guidance in NEI 94-01 states, in part, that Type A, Type B, and Type C tests should be performed using the technical methods and techniques specified in ANSI/ANS 56.8-1994, Containment System Leakage Testing Requirements. The pre-operational Type A test of the VEGP Unit 3 containment was completed using the ANSI/ANS-56.8-1994 mass point data analysis technique. The licensee provided the VEGP Unit 3 results for the initial pre-operational Type A test and the pre-operational Type B and C local leakage rate testing (LLRT), which are summarized below.
3.4.1 ILRT (Type A Test)
For VEGP Unit 3, TS 5.5.8 indicates that the peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 58.1 psig. TS 5.5.8 also specifies the maximum allowable primary containment leakage rate, La, at Pa, shall be 0.10 percent of the primary containment air weight per day.
In Section 3 of the LAR, the licensee provided a summary of the preoperational Type A ILRT results showing that the containment performance leakage rate was less than the maximum allowable leakage rate at a test pressure in excess of Pa. The results demonstrated an acceptable as-left leakage rate of 0.0285 percent of primary containment air weight per day
(%wt/day) when compared to the acceptance criterion of 0.075 %wt/day (i.e., 75% of the maximum allowable leakage rate, La of 0.10 %wt/day).
The NRC staff notes that the preoperational ILRT results have demonstrated ample margin with respect to the TS leakage rate acceptance criteria. Specifically, the pre-operational ILRT resulted in less than 40 percent (i.e., > 60 percent margin) of the allowable as-left leakage and less than 30 percent (i.e., > 70 percent margin) of the maximum allowed leakage. Therefore, the NRC staff finds that the pre-operational performance of the Type A test has substantial margin relative to the acceptance criterion to support a conclusion that exceeding the performance criterion of La would be unlikely with implementation of the proposed extension of the first periodic ILRT.
3.4.2 LLRT (Type B and C Testing)
The VEGP Unit 3 Appendix J, Type B and C leakage rate test program requires testing of electrical penetrations, airlocks, hatches, flanges, and containment isolation valves within the scope of the program as required by 10 CFR 50, Appendix J, Option B and TS 5.5.8.
The NRC staff reviewed the pre-operational local leak rate summary provided in Section 3 of the LAR. For VEGP Unit 3, the combined Type B and C leakage acceptance criterion is 0.60 La or 120,400 standard cubic centimeters per minute (sccm). Therefore, 1.0 La equals 200,667 sccm.
The preoperational local leak rate tests resulted in a total value of 29,480 sccm. The NRC staff finds that the Type B and C preoperational test results show a large amount of margin between the total leakage and the respective TS leakage rate acceptance criteria, which demonstrates the leak tightness of the Type B and C tested components. Specifically, the preoperational Type B and C leakage summation was less than 15 percent of their overall 1.0 La value and less than 25 percent of 0.6 La.
As discussed in NUREG-1493, Performance-Based Leak-Test Program (ML20098D498),
Types B and C tests can identify the vast majority of all potential leakage paths in an ILRT.
Therefore, the performance results of the pre-operational Type B and C tests at VEGP Unit 3 further provide a high degree of assurance that containment integrity will be maintained during the requested extended period until the first periodic ILRT.
3.5 Technical Conclusions Based on the preceding regulatory and technical evaluations, the NRC staff finds that SNC has adequately implemented its existing primary containment leakage rate testing program consisting of ILRT and LLRT. The results of the pre-operational ILRT and LLRT demonstrate acceptable performance with margin and support a conclusion that the structural and leak-tight integrity of the primary containment will remain adequate during the requested extension period for conducting the first periodic Type A test. The NRC staff finds that the risk insights considered are sufficient to support the evaluation of changes to the first periodic ILRT. Based on these findings, the staff concludes that the requirements of 10 CFR 50.54(o) and 10 CFR Part 50, Appendix J will continue to be met.
Based on the preceding regulatory and technical evaluations, the NRC staff also finds that proposed change to TS 5.5.8 to provide a one-time exception to RG 1.163 continues to ensure operation of the facility in a safe manner. Based on this finding, the staff concludes that the TS 5.5.8 proposed change will continue to meet 10 CFR 50.36(c)(5).
Therefore, the NRC staff finds that the proposed change to VEGP Unit 3 TS 5.5.8 regarding the containment leakage rate testing program is acceptable.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Georgia State official was notified of the proposed issuance of the amendments on November 7, 2023. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component 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 amendments involve no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on August 8, 2023 (88 FR 53537). 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. Therefore, the staff finds the changes proposed in this license amendment acceptable.
Principal Contributors:
Brian Lee, NRR Clinton Ashley, NRR Gurjendra Bedi, NRR Jerry Dozier, NRR Date: December 7, 2023