ML24159A470
| ML24159A470 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/17/2024 |
| From: | William Orders NRC/NRR/DORL/LPL4 |
| To: | Heflin A Arizona Public Service Co |
| Orders W, NRR/DORL/LPL4 | |
| References | |
| EPID L-2024-LLA-027 | |
| Download: ML24159A470 (1) | |
Text
July 17, 2024 Adam C. Heflin Executive Vice President/
Chief Nuclear Officer Mail Station 7605 Arizona Public Service Company P.O. Box 52034 Phoenix, AZ 85072-2034
SUBJECT:
PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 - ISSUANCE OF AMENDMENT NOS. 223, 223, AND 223 REGARDING REVISION TO TECHNICAL SPECIFICATIONS 3.5.1 and 3.5.2 USING RISK-INFORMED PROCESS FOR EVALUATIONS (EPID L-2024-LLA-0027)
Dear Adam Heflin:
The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 223 to Renewed Facility Operating License No. NPF-41, Amendment No. 223 to Renewed Facility Operating License No. NPF-51, and Amendment No. 223 to Renewed Facility Operating License No. NPF-74 for Palo Verde Nuclear Generating Station, Units 1, 2, and 3, respectively. The amendments consist of changes to the technical specifications (TSs) in response to your application dated March 8, 2024.
The amendments revise Conditions A and B of TS 3.5.1, Safety Injection Tanks (SITs) -
Operating, and TS 3.5.2, Safety Injection Tanks (SITs) - Shutdown, using the risk-informed process for evaluations (RIPE). Specifically, the proposed changes would modify the Completion Time for Condition B of TS Limiting Conditions for Operation (LCOs) 3.5.1 and 3.5.2 from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 10 days. Additionally, this change deletes the second case of Condition A of LCOs 3.5.1 and 3.5.2 (i.e., One SIT inoperable due to inability to verify level or pressure).
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/
William Orders, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-528, STN 50-529, and STN 50-530
Enclosure:
- 1. Amendment No. 223 to NPF-41
- 2. Amendment No. 223 to NPF-51
- 3. Amendment No. 223 to NPF-74
- 4. Safety Evaluation cc: Listserv
ARIZONA PUBLIC SERVICE COMPANY, ET AL.
DOCKET NO. STN 50-528 PALO VERDE NUCLEAR GENERATING STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 223 License No. NPF-41
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by the Arizona Public Service Company (APS or the licensee) on behalf of itself and the Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, Los Angeles Department of Water and Power, and Southern California Public Power Authority dated March 8, 2024, 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 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. NPF-41 is hereby amended to read as follows:
(2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 223, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed operating license. APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.
- 3.
This license amendment is effective as of the date of issuance and shall be implemented within 90 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Jennivine K. Rankin, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to Renewed Facility Operating License No. NPF-41 and the Technical Specifications Date of Issuance: July 17, 2024 Jennivine K.
Rankin Digitally signed by Jennivine K. Rankin Date: 2024.07.17 18:31:07 -04'00'
ARIZONA PUBLIC SERVICE COMPANY, ET AL.
DOCKET NO. STN 50-529 PALO VERDE NUCLEAR GENERATING STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 223 License No. NPF-51
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by the Arizona Public Service Company (APS or the licensee) on behalf of itself and the Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, Los Angeles Department of Water and Power, and Southern California Public Power Authority dated March 8, 2024, 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 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. NPF-51 is hereby amended to read as follows:
(2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 223, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed operating license. APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.
- 3.
This license amendment is effective as of the date of issuance and shall be implemented within 90 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Jennivine K. Rankin, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to Renewed Facility Operating License No. NPF-51 and the Technical Specifications Date of Issuance: July 17, 2024 Jennivine K.
Rankin Digitally signed by Jennivine K. Rankin Date: 2024.07.17 18:31:34 -04'00'
ARIZONA PUBLIC SERVICE COMPANY, ET AL.
DOCKET NO. STN 50-530 PALO VERDE NUCLEAR GENERATING STATION, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 223 License No. NPF-74
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by the Arizona Public Service Company (APS or the licensee) on behalf of itself and the Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, Los Angeles Department of Water and Power, and Southern California Public Power Authority dated March 8, 2024, 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 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. NPF-74 is hereby amended to read as follows:
(2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 223, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed operating license. APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.
- 3.
This license amendment is effective as of the date of issuance and shall be implemented within 90 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Jennivine K. Rankin, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to Renewed Facility Operating License No. NPF-74 and the Technical Specifications Date of Issuance: July 17, 2024 Jennivine K.
Rankin Digitally signed by Jennivine K. Rankin Date: 2024.07.17 18:32:02 -04'00'
ATTACHMENT TO LICENSE AMENDMENT NOS. 223, 223, AND 223 TO RENEWED FACILITY OPERATING LICENSE NOS. NPF-41, NPF-51, AND NPF-74 PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530 Replace the following pages of Renewed Facility Operating Licenses Nos. NPF-41, NPF-51, and NPF-74, and the 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 No. NPF-41 REMOVE INSERT 5
5 Renewed Facility Operating License No. NPF-51 REMOVE INSERT 6
6 Renewed Facility Operating License No. NPF-74 REMOVE INSERT 4
4 Technical Specifications REMOVE INSERT 3.5.1-1 3.5.1-1 3.5.2-1 3.5.2-1 Renewed Facility Operating License No. NPF-41 Amendment No. 223 (1)
Maximum Power Level Arizona Public Service Company (APS) is authorized to operate the facility at reactor core power levels not in excess of 3990 megawatts thermal (100% power), in accordance with the conditions specified herein.
(2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 223, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed operating license.
APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.
(3)
Antitrust Conditions This renewed operating license is subject to the antitrust conditions delineated in Appendix C to this renewed license.
(4)
Operating Staff Experience Requirements Deleted (5)
Post-Fuel-Loading Initial Test Program (Section 14, SER and SSER 2)*
Deleted (6)
Environmental Qualification Deleted (7)
Fire Protection Program APS shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility, as supplemented and amended, and as approved in the SER through Supplement 11, subject to the following provision:
APS may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
- The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.
Renewed Facility Operating License No. NPF-51 Amendment No. 223 (1)
Maximum Power Level Arizona Public Service Company (APS) is authorized to operate the facility at reactor core power levels not in excess of 3990 megawatts thermal (100% power) in accordance with the conditions specified herein.
(2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 223, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed operating license.
APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.
(3)
Antitrust Conditions This renewed operating license is subject to the antitrust conditions delineated in Appendix C to this renewed operating license.
(4)
Operating Staff Experience Requirements (Section 13.1.2, SSER 9)*
Deleted (5)
Initial Test Program (Section 14, SER and SSER 2)
Deleted (6)
Fire Protection Program APS shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility, as supplemented and amended, and as approved in the SER through Supplement 11, subject to the following provision:
APS may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
(7)
Inservice Inspection Program (Sections 5.2.4 and 6.6, SER and SSER 9)
Deleted
- The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.
Renewed Facility Operating License No. NPF-74 Amendment No. 223 (4)
Pursuant to the Act and 10 CFR Part 30, 40, and 70, APS to receive, possess, and use in amounts required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5)
Pursuant to the Act and 10 CFR Parts 30, 40, and 70, APS to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C.
This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1)
Maximum Power Level Arizona Public Service Company (APS) is authorized to operate the facility at reactor core power levels not in excess of 3990 megawatts thermal (100% power), in accordance with the conditions specified herein.
(2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 223, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed operating license.
APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.
(3)
Antitrust Conditions This renewed operating license is subject to the antitrust conditions delineated in Appendix C to this renewed operating license.
(4)
Initial Test Program (Section 14, SER and SSER 2)
Deleted (5)
Additional Conditions The Additional Conditions contained in Appendix D, as revised through Amendment No. 212, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Additional Conditions.
SITs-Operating 3.5.1 PALO VERDE UNITS 1,2,3 3.5.1-1 AMENDMENT NO. 209, 223 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.1 Safety Injection Tanks (SITs) - Operating LCO 3.5.1 Four SITs shall be OPERABLE.
APPLICABILITY:
MODES 1 and 2, MODES 3 and 4 with pressurizer pressure 1837 psia.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
One SIT inoperable due to boron concentration not within limits.
A.1 Restore SIT to OPERABLE status.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> B.
One SIT inoperable for reasons other than Condition A.
B.1 Restore SIT to OPERABLE status.
10 days C.
NOTES-----------
- 1. Not applicable when the second or a subsequent SIT intentionally made inoperable.
- 2. The following Section 5.5.20 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.
Two or more SITs inoperable for reasons other than Condition A.
C.1 Restore all but one SIT to OPERABLE status.
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> OR In accordance with the Risk Informed Completion Time Program
SITs - Shutdown 3.5.2 PALO VERDE UNITS 1,2,3 3.5.2-1 AMENDMENT NO. 118, 223 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.2 Safety Injection Tanks (SITs) - Shutdown LCO 3.5.2 Four SITs shall be OPERABLE with a borated water volume > 39%
wide range indication and < 83% wide range indication; OR Three SITS shall be OPERABLE with a borated water volume
> 60% wide range indication and < 83% wide range indication.
APPLICABILITY: MODES 3 and 4 with pressurizer pressure < 1837 psia.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
One required SIT inoperable due to boron concentration not within limits.
A.1 Restore required SIT to OPERABLE status.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> B.
One required SIT inoperable for reasons other than Condition A.
B.1 Restore required SIT to OPERABLE status.
10 days C.
Inoperability of the required SIT was discovered but not restored while in ITS 3.5.1, "SITs Operating" OR Required Action and associated Completion Time of Condition A or B not met.
C.1 Be in MODE 5.
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> D.
Two or more required SITs inoperable.
D.1 Enter LCO 3.0.3.
Immediately
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 223, 223, AND 223 TO RENEWED FACILITY OPERATING LICENSE NOS. NPF-41, NPF-51, AND NPF-74 ARIZONA PUBLIC SERVICE COMPANY, ET AL.
PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530
1.0 INTRODUCTION
By application dated March 8, 2024 (Reference 1), Arizona Public Service Company (APS, the licensee) submitted a license amendment request (LAR) requesting changes to the technical specifications (TSs) for Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (Palo Verde).
The proposed amendments would modify Conditions A and B of TS 3.5.1, Safety Injection Tanks (SITs) - Operating, and TS 3.5.2, Safety Injection Tanks (SITs) - Shutdown, using the risk-informed process for evaluations (RIPE). Specifically, the proposed changes would modify the Completion Time (CT) for Condition B of TS Limiting Conditions for Operation (LCOs) 3.5.1 and 3.5.2 from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 10 days. Additionally, this change deletes the second case of Condition A of LCOs 3.5.1 and 3.5.2 (i.e., One SIT inoperable due to inability to verify level or pressure).
2.0 REGULATORY EVALUATION
2.1 Background
The Palo Verde reactor coolant system (RCS) incorporates four SITs with one SIT connected to each of the RCS cold legs. The SITs are partially filled with borated water and passively inject to the RCS when RCS pressure decreases below the SIT pressure. The SITs are pressurized with nitrogen and no operator action is required to deliver the contents of the SITs to the RCS. The SITs isolation valves are normally open with power removed to prevent inadvertent closure, and two discharge check valves in series prevent backflow into each SIT. If a SIT isolation valve is closed, it will receive an automatic safety injection actuation signal to open.
The SITs provide makeup to the RCS during the initial phase (i.e., blowdown) of a loss-of-coolant accident (LOCA) and RCS makeup inventory for the refill phase immediately following blowdown. The addition of the SITs inventory to the RCS during the blowdown phase ensures that heat from the reactor vessel and reactor core continues to be transferred to the reactor coolant. During the refill phase, reactor coolant has vacated the core through steam
flashing and loss of inventory out through the break. The balance of the SITs inventory is available to assist in filling voids in the reactor vessel and core and establish ongoing reflood of the core with the addition of safety injection water from the high pressure and low pressure safety injection systems.
Palo Verde TS LCO 3.5.1 requires Four SITs to be OPERABLE such that three SITS are assured to be available to deliver their contents to the reactor core during the blowdown phase.
The Palo Verde LOCA analysis assumes that the contents of one SIT is lost through the break.
Therefore, the SITs are designed, sized, and configured such that three SITs are adequate to partially recover the core before significant clad melting or zirconium water reaction can occur following a LOCA, based on conservative analysis criteria in Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix K, ECCS [Emergency Core Cooling System]
Evaluation Models. However, Probabilistic Risk Assessment (PRA) Study 13-NS-B106, At-Power PRA System Study for the Safety Injection Systems, specifies only two SITs be capable to deliver their contents to the reactor core to prevent core melt following a large break LOCA. PRA Study 13-NS-B106, also states that the SITs are not required for a small break LOCA unless there is a coincident failure of both high pressure safety injection (HPSI) trains.
Palo Verde TS LCO 3.5.2 ensures that conditions are established such that the minimum required cumulative SIT volume (assuming the contents of one SIT is lost out through the break) is available to accomplish the SITs core cooling safety function following a LOCA. These operability requirements ensure compliance with the ECCS acceptance criteria of 10 CFR 50.46, Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors. Continued compliance with the acceptance criteria contained in 10 CFR 50.46(b), with respect to the proposed change regarding SIT operability, also ensures that the general ECCS requirements in 10 CFR Part 50, Appendix A, General Design Criterion (GDC) 35, are met.
2.2 Changes to TS 3.5.1 and TS 3.5.2 The licensees proposed changes to the Palo Verde TSs would modify Conditions A and B of TSs 3.5.1 and 3.5.2. Specifically, the proposed changes would modify the Completion Time for Condition B of TS LCOs 3.5.1 and 3.5.2 from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 10 days. Additionally, this change deletes the second case of Condition A of LCOs 3.5.1 and 3.5.2 (i.e., One SIT inoperable due to inability to verify level or pressure).
2.3 Regulatory Requirements The regulations in 10 CFR 50.36, Technical specifications, state that the TSs will include items in five specific categories. These categories include: (1) safety limits, limiting safety system settings, and limiting control settings; (2) LCOs; (3) surveillance requirements; (4) design features; and (5) administrative controls. In particular, 10 CFR 50.36(c)(2)(i) states, in part:
Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.
The regulations in 10 CFR 50.46 include the following specific criteria that are applicable to the proposed TS change:
(b)(1) Peak cladding temperature. The calculated maximum fuel element cladding temperature shall not exceed 2200°F [degrees Fahrenheit].
(b)(2) Maximum cladding oxidation. The calculated total oxidation of the cladding shall nowhere exceed 0.17 times the total cladding thickness before oxidation. As used in this subparagraph total oxidation means the total thickness of cladding metal that would be locally converted to oxide if all the oxygen absorbed by and reacted with the cladding locally were converted to stoichiometric zirconium dioxide. If cladding rupture is calculated to occur, the inside surfaces of the cladding shall be included in the oxidation, beginning at the calculated time of rupture. Cladding thickness before oxidation means the radial distance from inside to outside the cladding, after any calculated rupture or swelling has occurred but before significant oxidation. Where the calculated conditions of transient pressure and temperature lead to a prediction of cladding swelling, with or without cladding rupture, the unoxidized cladding thickness shall be defined as the cladding cross-sectional area, taken at a horizontal plane at the elevation of the rupture, if it occurs, or at the elevation of the highest cladding temperature if no rupture is calculated to occur, divided by the average circumference at that elevation. For ruptured cladding the circumference does not include the rupture opening.
(b)(3) Maximum hydrogen generation. The calculated total amount of hydrogen generated from the chemical reaction of the cladding with water or steam shall not exceed 0.01 times the hypothetical amount that would be generated if all of the metal in the cladding cylinders surrounding the fuel, excluding the cladding surrounding the plenum volume, were to react.
(b)(4) Coolable geometry. Calculated changes in core geometry shall be such that the core remains amenable to cooling.
The regulation in 10 CFR Part 50, Appendix A, GDC 35, requires that the ECCS will perform the safety function to transfer heat from the reactor core following any loss of reactor coolant at a rate that such that:
(1) fuel and clad damage that could interfere with continued effective core cooling is prevented and (2) clad metal-water reaction is limited to negligible amounts.
2.4 Regulatory Guidance Palo Verde submitted the proposed LAR for review using RIPE as described in the U.S. Nuclear Regulatory Commissions (NRCs or the Commissions) Guidelines for Characterizing the Safety Impact of Issues (SIC), Revision 2 (Reference 2). The Office of Nuclear Reactor Regulation (NRR) temporary staff guidance (TSG) document TSG-DORL-2021-01, Revision 3 (Reference 3) provides the framework and guidance for NRR staff to implement the streamlined processing of LARs submitted under the RIPE. Use of this guidance is limited to issues for which the safety impact associated with an issue addressed by a TS LAR can be modeled using
PRA. The NRCs review is streamlined in that RIPE is based on the application of pre-existing risk-informed criteria that allow for review and disposition of the submittal with minimal resources.
RIPE, as described in the SIC, is available to licensees that have a technically acceptable PRA and have established an integrated decisionmaking panel (IDP). For the purposes of RIPE, having a technically acceptable PRA must be demonstrated by having an approved and implemented license amendment for Technical Specifications Task Force (TSTF) Traveler TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF [Risk-Informed TSTF] Initiative 4b (Reference 4) or TSTF-425 Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b (Reference 5). Under RIPE, an IDP may be established by having an approved and implemented 10 CFR 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors, amendment or by establishing a RIPE IDP, as documented in the Nuclear Energy Institute (NEI) guidance, NEI Guidelines for the Implementation of the Risk-Informed Process for Evaluations Integrated Decision-Making Panel (Reference 6). Licensees that have implemented an NRC-approved amendment to adopt TSTF-505 or TSTF-425 and have established an IDP can leverage these initiatives to perform safety impact characterizations using RIPE. Licensees may then request licensing actions with the expectation that the NRC staff will use a streamlined review process if the issue is characterized as having a minimal safety impact.
Changes made under RIPE are reviewed by the NRC staff in a manner consistent with the principles of risk-informed decision-making (RIDM) outlined in Regulatory Guide (RG) 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis (Reference 7), which includes ensuring that the proposed change meets current regulations (unless an exemption is requested), is consistent with the defense-in-depth philosophy, maintains sufficient safety margins, is consistent with the Commissions Safety Goal Policy Statement, and includes performance monitoring strategies.
For RIPE, as described in the SIC, all of the following must apply in order to characterize an issue as having a minimal safety impact:
The issue contributes less than 1 x 10-7/year to core damage frequency (CDF);
The issue contributes less than 1 x 10-8/year to large early release frequency (LERF);
The issue has no safety impact or minimal safety impact in accordance with the SIC; and Cumulative risk is assessed based on plant-specific CDF and LERF. Cumulative risk is acceptable for the purposes of this guidance if baseline risk remains less than 1 x 10-4/year for CDF and less than 1 x 10-5/year for LERF once the impact of the proposed change is incorporated into baseline risk.
The safety impact must be characterized as none or minimal for the LAR to qualify for the NRC streamlined RIPE review. In addition, the RIPE LAR must include defense-in-depth and safety margin considerations assessed by the IDP.
3.0 TECHNICAL EVALUATION
The current Condition A in TSs 3.5.1 and 3.5.2 describes the condition where one SIT is inoperable due to boron concentration not within limits or an inability to verify SIT level or
pressure. Required Action A.1 requires restoration of the SIT to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The current Condition B in TSs 3.5.1 and 3.5.2 describes the condition where one SIT is inoperable for reasons other than Condition A. Required Action B.1 requires restoration of the SIT to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The licensee described the proposed changes to the TS in section 3.1 of the LAR enclosure. The licensee proposed deleting the second portion of the Condition A description as well as increasing the CT of Required Action B.1 from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 10 days. In section 3.2 of the LAR enclosure, the licensee provided the following justification for the deletion of the second portion of the Condition A description:
Eliminating the case for level and/or pressure instrumentation issues simplifies the Control Room staff response by removing the need to diagnose or troubleshoot instrumentation issues related to SIT level and pressure to determine if Condition A or B should be entered.
The NRC staff notes that by proposing the deletion of the second part of the Condition A description, along with proposing to extend the Condition B CT, the licensee is proposing extending the CT for the situation when one SIT is inoperable due to an inability to verify SIT level or pressure from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 10 days. The licensee justified the proposed extension on page 36 of attachment 1 of the LAR enclosure, which states in part:
Since the second case of Condition A of LCOs 3.5.1 and 3.5.2 is bounded by Condition B of LCOs 3.5.1 and 3.5.2, deleting the second case of Condition A does not affect the adverse impacts noted in the responses, corresponding risk increase, or the assessed safety impact of the proposed change to extend the completion time to 10 days. As such, the assessment for extending the Completion Time for Condition B of LCOs 3.5.1 and 3.5.2 from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 10 days bounds the deletion of the second case of Condition A of LCOs 3.5.1 and 3.5.2 obviating the need to be addressed separately.
The NRC staff reviewed the licensees justification and determined that deletion of the second, very specific inoperability condition description in Condition A is acceptable because the general language in the Condition B description will include situations where a SIT is inoperable because of the inability of operators to verify level or pressure. In the sections of this evaluation preceding and following this section, the NRC staff reviewed the proposed increased CT for all cases of one SIT being inoperable besides those due to boron concentration not within limits.
For the reasons summarized in section 3.7 of this safety evaluation, the NRC staff determined that increasing the CT from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 10 days is acceptable.
3.1 Conformance with RIPE Minimal Safety Impact Criteria The licensee considered the RIPE screening questions contained in sections 4.1 and 4.2 of the NRCs SIC, Revision 2, and concluded that the requested amendments involve adverse safety impacts, but that these impacts had a minimal impact on safety. Considerations for each of the five RIPE screening questions are discussed below.
3.1.1 Does the issue result in an adverse impact on the frequency of occurrence of an accident initiator or result in a new accident initiator?
Safety significant initiators and associated operating modes involving the SITs were evaluated in attachment 1 of the LAR enclosure. The NRC staff has determined that the proposed TS changes would not result in an adverse impact of the frequency of occurrence of an accident
initiator or result in a new accident initiator. In each case reviewed, the licensee determined that no transients or accidents were initiated by the SITs or initiated by a single, inoperable SIT. The evaluation also noted that external hazard frequencies are not reduced or increased by a plant-initiated change. The NRC staff reviewed the licensees consideration of this screening element and agrees with the licensees conclusion of no adverse impact given the passive function of the SITs, the fact that the proposed change is consistent with the Palo Verde PRA success criteria and does not alter the way the SITs are utilized in the plant.
3.1.2 Does the issue result in an adverse impact on the availability, reliability, or capability of SSCs or personnel relied upon to mitigate a transient, accident, or natural hazard?
The licensees review of this RIPE screening element determined that there was no adverse impact on the availability, reliability, or capability of personnel. However, an impact could result regarding the availability of systems, structures, and components (SSCs) relied upon to mitigate a transient, accident, or natural hazard. The adverse impact arises from the proposed change to extend the CT for Condition B of LCOs 3.5.1 and 3.5.2 from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 10 days. The proposed extended CT has the potential to increase the duration that one of the required SITs is inoperable, which could have an adverse impact on availability of the required SITs to mitigate a LOCA.
LCOs 3.5.1 and 3.5.2 assist in ensuring that the fuel cladding criteria associated with 10 CFR 50.46 and 10 CFR Part 50, Appendix A, GDC 35, remain satisfied following a LOCA.
The proposed TS change would increase the time that a required SIT could be unavailable. In this condition, core recovery could be delayed until the low-pressure safety injection (LPSI) and HPSI pumps are able to deliver sufficient flow to reflood the core, resulting in a challenge to the ECCS criteria contained in 10 CFR 50.46. PRA Study 13-NS-B106 specifies PRA acceptance criteria that only two SITs must be capable of delivering their contents to the reactor core to prevent core melt following a large break LOCA. PRA Study 13-NS-B106, also states that the SITs are not required for a small break LOCA unless there is a coincident failure of both HPSI trains. The proposed TS CT change will not alter the current TS LCOs 3.5.1 and 3.5.2 Condition B requirement for three operable SITs or change operability requirements for the safety injection pumps. The impact was determined to be not more than minimal because the proposed TS change will continue to require that three SITs remain operable. In addition, the licensee presented historical plant operating experience demonstrating high reliability of the SITs.
The NRC staff reviewed the licensees consideration of this screening element and concluded that the evaluation supported a conclusion of a not more than minimal adverse impact for this screening element. The SITs are passively actuated and do not rely on any operator actions to perform their safety function, precluding impact on the availability, reliability, or capability of personnel. While the proposed CT extension from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 10 days increases the allowed unavailability of one inoperable SIT, the Palo Verde PRA acceptance criteria and ECCS acceptance criteria associated with 10 CFR 50.46 and GDC 35 will continue to be met with the three remaining operable SITs.
3.1.3 Does the issue result in an adverse impact on the consequences of an accident sequence?
The evaluation for adverse impact on the consequences of an accident sequence described in attachment 1 of the LAR enclosure, determined that the proposed TS changes do not result in a more than minimal increase in the consequences of a risk significant accident sequence. The NRC staff reviewed the licensees consideration of this screening element and concluded that
the determination of not more than minimal adverse impact is reasonable given that the Palo Verde PRA success criteria is maintained, and dose consequences remain unchanged.
3.1.4 Does the issue result in an adverse impact on the capability of a fission product barrier?
The licensees review of this RIPE screening criteria determined that the proposed change could result in a potential adverse impact on a fission product barrier, specifically the fuel cladding. LCOs 3.5.1 and 3.5.2 assist in ensuring that the fuel cladding criteria associated with 10 CFR 50.46 and GDC 35 remain satisfied following a LOCA. As discussed in section 3.1.2 of this SE, the proposed TS change would increase the time that a required SIT could be unavailable. In this condition, core recovery could be delayed until the LPSI and HPSI pumps are able to deliver sufficient flow to reflood the core, resulting in a challenge to the ECCS acceptance criteria contained in 10 CFR 50.46. However, the adverse impact was determined to be not more than minimal because PRA Study 13-NS-B106 specifies PRA acceptance criteria that only two SITs must be capable of delivering their contents to the reactor core to prevent core melt following a large break LOCA. The proposed TS CT change will not alter the current TS LCOs 3.5.1 and 3.5.2 Condition B requirement for three operable SITs. Therefore, the Palo Verde PRA success criteria requirement of two available SITs following a LOCA, assuming the contents of one SIT is lost out of the break, will be maintained, and the ECCS acceptance criteria associated with 10 CFR 50.46 and GDC 35 will continue to be satisfied.
The NRC staff reviewed the licensees consideration of this screening element and concluded that the impact on the capability of a fission product barrier would not be more than minimal since the proposed TS change would not conflict with the Palo Verde PRA success criteria, and the ECCS acceptance criteria associated with 10 CFR 50.46 and GDC 35 will continue to be satisfied for the SITs.
3.1.5 Does the issue result in an adverse impact on defense-in-depth capability or impact in safety margin?
The ECCS includes a diverse design with active and passive subsystems, with the four SITs included in the passive portion of the system. The evaluation in attachment 1 of the LAR enclosure provided a detailed assessment of the seven considerations used to assess the impact on defense-in-depth described in section C.2.1.1.2, Considerations for Evaluating the Impact of the Proposed Licensing Basis Change on Defense in Depth, of RG 1.174. The licensees evaluation of this RIPE screening element determined that there was a potential adverse impact on defense-in-depth capability or safety margin associated with the proposed TS changes, but that the adverse impact was not more than minimal.
The NRC staff reviewed the licensees consideration of this screening element and concluded that the licensees evaluation demonstrated that the adverse impact on defense-in-depth and safety margin was not more than minimal. The Palo Verde plant design consists of robust layers of defense that are preserved and will remain effective to mitigate severe accidents. The SITs are passively actuated and do not rely on any operator actions to perform their safety function and no new operator actions are proposed such that there are no new human errors introduced and there is not an over-reliance on programmatic controls. In addition, the proposed TS change will continue to require that three SITs remain operable per current TS LCOs 3.5.1 and 3.5.2 Condition B requirements and, therefore, two SITs will be capable of delivering their contents to the reactor core. Therefore, the proposed change maintains the capability of the ECCS to meet the Palo Verde PRA success criteria and the ECCS acceptance criteria associated with 10 CFR 50.46 and GDC 35.
3.2 Implementation of an IDP The licensee has been approved to adopt 10 CFR 50.69 by letter dated October 10, 2018 (Reference 8). The licensee established a multi-disciplinary IDP to evaluate the proposed amendments to modify the CT for Condition B of TS LCOs 3.5.1 and 3.5.2 from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 10 days and delete the second case of Condition A of LCOs 3.5.1 and 3.5.2 (i.e., One SIT inoperable due to inability to verify level or pressure). The IDP membership was comprised of plant personnel experienced in operations, design and systems engineering, safety analysis, licensing, and PRA risk assessment. Therefore, the NRC staff concludes that Palo Verde utilized an acceptable IDP in support of the proposed LAR per the RIPE guidance. The IDP deliberated the five adverse safety impact screening questions contained in the SIC and concluded that the proposed amendments result in no more than a minimal safety impact. The RIPE LAR documents the incorporation of the IDPs comments in the LAR. The IDP evaluation is included in attachment 3 of the LAR enclosure.
3.3 Use of an Acceptable/Approved PRA Model The NRC staff approved the Palo Verde risk-informed completion time license amendments by letters dated May 29, 2019, and February 10, 2020 (References 9 and 10, respectively),
consistent with NEI 06-09, Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines, in lieu of TSTF-505 since at the time the NRC had temporarily suspended approval of TSTF-505. The Palo Verde PRA model used to support the risk-informed completion time program includes internal and external events, fires, and seismic hazards. Subsequently, implementation of the TSTF-505 license amendments and license conditions was completed. Therefore, the NRC staff concludes that PVNGS utilized a technically acceptable PRA model in support of the proposed exemption request per the RIPE guidance.
3.4 Evaluation of PRA Results The licensee calculated the probability of an individual SIT failing to inject water into the RCS and incorporated this result into a plant-specific risk assessment utilizing the Palo Verde at-power PRA model. RCS pipe stresses are significantly reduced during lower shutdown modes. However, the at-power initiating event frequencies for large break LOCA and small break LOCA were used to quantify the risk impact of having one SIT inoperable for 10 days to provide a bounding conservative analysis for Modes 3 and 4. In addition, an operating experience review was performed that determined a worst-case SIT maintenance frequency of 1.22 entries per year (1.22/year) into Conditions A and B of LCOs 3.5.1 and 3.5.2. The risk increase was determined to be 1.13 x 10-8/year for CDF and 1.17 x 10-10/year for LERF. These results satisfy the RIPE criteria of contributing less than 1 x 10-7/year to CDF and 1 x 10-8/year to LERF. The addition of the calculated increase in risk associated with extending the allowed outage times of Condition B of LCOs 3.5.1 and 3.5.2 from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 10 days and deleting the second case (i.e., One SIT inoperable due to an inability to verify level or pressure) from Condition A of LCOs 3.5.1 and 3.5.2, does not alter the Palo Verde baseline risk of 6.11 x 10-5/year for CDF and 9.65 x 10-6/year for LERF. Therefore, cumulative risk for Palo Verde remains less than the RIPE criteria of 1.0 x 10-4/year for CDF and 1.0 x 10-5/year for LERF. The NRC staff concludes that these results satisfy the RIPE criteria for no more than a minimal increase in risk for the proposed amendments.
3.5 Evaluation of the Need for Risk Management Actions Evaluation of the RIPE screening questions and the PRA results discussed above confirm that the proposed amendments result in a minimal safety impact. Therefore, the guidance in the SIC states that risk management actions should be considered. In section 4.4, Plant Specific Risk Assessment Results, of the enclosure to the LAR, the licensee determined that, based on the minimal risk impact, no new risk management actions were required to off-set the risk increase.
The NRC staff reviewed the licensees consideration of the risk management actions and concluded that no new risk management actions are required.
3.6 Assessment of Performance Monitoring Strategies The licensees LAR concluded that no specific performance monitoring strategies are required.
However, the Palo Verde ECCS system, including the SITs, are monitored under the regulation in 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants, which requires that unacceptable performance is addressed and corrected.
Section 4.4 of the LAR enclosure indicates that ongoing, emergent, and future maintenance work activities are assessed via operations and work management processes. In addition, section 4.2, Technical Adequacy of the Probabilistic Risk Assessment, of the LAR enclosure, notes that Palo Verde implements a process to ensure that the PRA model reflects the as-built, as-operated plant, including both regularly scheduled and interim model updates. The NRC staff concludes that existing regulations and plant processes will assure acceptable performance monitoring of the SITs such that the finding of minimal safety impact of the proposed TS change will remain valid.
3.7 Technical Conclusion Based on its review of the LAR, the NRC staff finds that the licensee has demonstrated that the proposed amendments are low risk, represents minimal safety impact, and maintains adequate defense-in-depth and safety margins. Therefore, the NRC staff finds that the proposed changes to the Palo Verde TSs to modify the CT for Condition B of TS LCOs 3.5.1 and 3.5.2 from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 10 days and to delete the second case of Condition A of LCOs 3.5.1 and 3.5.2 (i.e.,
One SIT inoperable due to inability to verify level or pressure) are acceptable.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Arizona State official was notified of the proposed issuance of the amendments on July 1, 2024. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change requirements with respect to 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 amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, published in the Federal Register on May 14, 2024 (89 FR 41998), and there has been no public comment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b),
no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
7.0 REFERENCES
- 1.
Horton, T., Arizona Public Service Company, letter to U.S. Nuclear Regulatory Commission, Palo Verde Nuclear Generating Station Units 1, 2, and 3 Docket Nos.
STN 50-528, 50-529, and 50-530 Renewed Operating License Number NPF-41, NPF-51 and NPF-74 License Amendment Request to Revise Technical Specifications 3.5.1 and 3.5.2 using Risk-Informed Process for Evaluations, dated March 8, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24068A252).
- 2.
U.S. Nuclear Regulatory Commission Guidelines for Characterizing the Safety Impact of Issues, Revision 2, May 2022 (ML22088A135).
- 3.
U.S. Nuclear Regulatory Commission, NRR Temporary Staff Guidance Risk-Informed Process for Evaluations, TSG-DORL-2021-01, Revision 3, September 18, 2023 (ML23122A014).
- 4.
Technical Specifications Task Force, Transmittal of TSTF-505, Revision 1, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b Errata, dated June 14, 2011, and Proposed Revision to the Model Application for TSTF-505, Revision 1, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, dated January 31, 2012 (Package ML120330410).
- 5.
Technical Specifications Task Force Transmittal of TSTF-425, Revision 3, Relocate Surveillance Frequencies to Licensee Control-RITSTF Initiative 5b, Improved Standard Technical Specifications Change Traveler TSTF-425, Revision 3, dated March 18, 2009 (Package ML090850642).
- 6.
Nuclear Energy Institute, NEI Guidelines for the Implementation of the Risk-Informed Process for Evaluations Integrated Decision-Making Panel, August 2020 (ML20245E147).
- 7.
U.S. Nuclear Regulatory Commission, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, Regulatory Guide 1.174, Revision 3, January 2018 (ML17317A256).
- 8.
Orenak, M. D., U.S. Nuclear Regulatory Commission, letter to R. Bement, Arizona Public Service Company, Palo Verde Nuclear Generating Station, Units 1, 2, and 3 - Issuance of Amendment Nos. 207, 207, and 207, to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors, dated October 10, 2018 (ML18243A280).
- 9.
Lingam, S.P., U.S. Nuclear Regulatory Commission, letter to R. Bement, Arizona Public Service Company, Palo Verde Nuclear Generating Station, Units 1, 2, and 3 - Issuance of Amendment Nos. 209, 209, and 209 RE: Adoption of Risk-Informed Completion Times in Technical Specifications (CAC Nos. MF6576, MF6577, and MF6578; EPID L-2015-LLA-0001), dated May 29, 2019 (ML19085A525).
- 10.
Lingam, S.P., U.S Nuclear Regulatory Commission, letter to M. Lacal, Arizona Public Service Company, Palo Verde Nuclear Generating Station, Units 1, 2, and 3 - Issuance of Amendment Nos. 211, 211, and 211 to Extend Implementation Date for Amendment Nos. 209, 209, and 209 Associated with Initiative 4b that Permit the Use of Risk-Informed Completion Times on the Technical Specifications (EPID L-2019-LLA-0289), dated February 10, 2020 (ML20016A458).
Principal Contributors: John Hughey, NRR Michelle Kichline, NRR Date: July 17, 2024
- concurrence via email NRR-058 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA*
NRR/DRA/APOB/BC*
NRR/DSS/STSB/BC*
NAME WOrders PBlechman AZoulis SMehta DATE 6/11/2024 6/11/2024 6/7/2024 6/13/2024 OFFICE OGC - NLO*
NRR/DORL/LPL4/BC*
NRR/DORL/LPL4/PM*
NAME STurk JRankin WOrders DATE 7/1/2024 7/17/2024 7/17/2024