ML14350B285

Issuance of Amendment No. 299, Revise Technical Specification 6.5.16, Containment Leakage Rate Testing Program, for Requirements for Containment Building Emergency Escape Air Lock Doors

ML14350B285
Person / Time
Site:	Arkansas Nuclear
Issue date:	01/22/2015
From:	Andrea George Plant Licensing Branch IV
To:	Entergy Operations
George A
References
TAC MF3383
Download: ML14350B285 (14)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 22, 2015 Vice President, Operations Arkansas Nuclear One Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802

SUBJECT:

ARKANSAS NUCLEAR ONE, UNIT NO. 2 - ISSUANCE OF AMENDMENT RE:

CONTAINMENT BUILDING EMERGENCY ESCAPE AIR LOCK TESTING REQUIREMENTS (TAC NO. MF3383)

Dear Sir or Madam:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 299 to Renewed Facility Operating License No. NPF-6 for Arkansas Nuclear One, Unit No. 2. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated January 21, 2014, as supplemented by letters dated March 17 and September 24, 2014.

The amendment would revise the TS 6. 5.16 requirements for the local leak test required for the containment building emergency escape air lock doors, in that it would require a seal contact verification in lieu of the current seal pressure test to verify leak tightness. The associated exemption is addressed under separate correspondence dated January 13, 2015.

A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely, Andrea E. George, Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-368

Enclosures:

1. Amendment No. 299 to NPF-6

2. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ENTERGY OPERATIONS, INC.

DOCKET NO. 50-368 ARKANSAS NUCLEAR ONE. UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 299 Renewed License No. NPF-6

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

A. The application for amendment by Entergy Ope:-ations, Inc. (the licensee), dated January 21, 2014, as supplemented by letters dated March 17 and September 24, 2014, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's 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 Commission's regulations; D. The issuance of this license 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 Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

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-6 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 299, are hereby incorporated in the renewed 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 90 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Eric R. Oesterle, Acting Chief Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. NPF-6 Technical Specifications Date of Issuance: January 22, 2015

ATTACHMENT TO LICENSE AMENDMENT NO. 299 RENEWED FACILITY OPERATING LICENSE NO. NPF-6 DOCKET NO. 50-368 Replace the following pages of the Renewed Facility Operating License No. NPF-6 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.

Operating License REMOVE INSERT Technical Specifications REMOVE INSERT 6-18 6-18

3 (4) EOI, pursuant to the Act and 10 CFR Parts 30, 40 and 70 to receive, possess and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5) EOI, pursuant to the Act and 10 CFR Parts 30, 40 and 70 to receive, possess, and use in amounts as 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 (6) EOI, pursuant to the Act and 10 CFR Parts 30 and 70 to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed license shall be deemed to contain and is subject to 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; 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 EOI is authorized to operate the facility at steady state reactor core power levels not in excess of 3026 megawatts thermal. Prior to attaining this power level EOI shall comply with the conditions in Paragraph 2.C.(3).

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 299, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications.

Exemptive 2nd paragraph of 2.C.2 deleted per Amendment 20, 3/3/81.

(3) Additional Conditions The matters specified in the following conditions shall be completed to the satisfaction of the Commission within the stated time periods following issuance of the renewed license or within the operational restrictions indicated.

The removal of these conditions shall be made by an amendment to the renewed license supported by a favorable evaluation by the Commission.

2.C.(3)(a) Deleted per Amendment 24, 6/19/81.

Renewed License No. NPF-6 Amendment No. 299 Revised by letter dated July 18, 2007

ADMINISTRATIVE CONTROLS 6.5.16 Containment Leakage Rate Testing Program 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 NEI 94-01, Revision 2-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," dated October 2008. The next Type A test performed after the November 30, 2000 Type A test shall be performed no later than November 30, 2015.

In addition, the containment purge supply and exhaust isolation valves shall be leakage rate tested prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days.

The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa. is 58 psig.

The maximum allowable containment leakage rate, La, shall be 0.1% of containment air weight per day at Pa.

Leakage rate acceptance criteria are:

a. Containment leakage rate acceptance criteria is::; 1.0 La. During the first unit startup following each test performed 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.

b. Air lock acceptance criteria are:

1. Overall air lock leakage rate is::; 0.05 La when tested at:::: Pa.

2. Leakage rate for each Personnel Air Lock door is::; 0.01 La when pressurized to:::: 10 psig.

3. A seal contact check for each Emergency Escape Air Lock door, consisting of a verification of continuous contact between the seals and the sealing surfaces.

The provisions of Specification 4.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.

The provisions of Specification 4.0.3 are applicable to the Containment Leakage Rate Testing Program.

ARKANSAS- UNIT 2 6-18 Amendment No. ~.~.2-92. 299

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 299 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-6 ENTERGY OPERATIONS, INC.

ARKANSAS NUCLEAR ONE, UNIT NO. 2 DOCKET NO. 50-368

1.0 INTRODUCTION

By letter dated January 21, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14021A085), as supplemented by letters dated March 17 and September 24, 2014 (ADAMS Accession Nos. ML14077A139 and ML14268A317, respectively},

Entergy Operations, Inc. (Entergy, the licensee}, submitted a license amendment request (LAR) proposing changes to the Technical Specifications (TSs) for Arkansas Nuclear One, Unit 2 (AN0-2). The amendment would modify TS 6.5.16, "Containment Leakage Rate Testing Program," to require a seal contact verification in lieu of a seal pressure test with respect to the emergency escape air lock doors.

Concurrent with this LAR, in the application dated January 21, 2014, the licensee also submitted a request for an exemption from certain requirements 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," associated with the proposed testing protocol. The U.S. Nuclear Regulatory Commission (NRC) staff addressed this exemption request in separate correspondence dated January 13, 2015 (ADAMS Accession No. ML14346A240).

The supplemental letter dated September 24, 2014, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register on April15, 2014 (79 FR 21296).

2.0 REGULATORY EVALUATION

The regulations in 10 CFR 50.54(o) state that primary reactor containments of water-cooled power reactors are subject to the requirements set forth in Appendix J to 10 CFR Part 50.

Option B, "Performance Based Requirements," of Appendix J to 10 CFR Part 50, requires the licensee to perform local leakage rate tests (LLRTs), termed as Type B tests. Type B tests are Enclosure 2

primarily intended to detect local leaks and to measure leakage across each pressure-containing or leakage-limiting boundary for primary reactor containment penetrations.

Specifically, a between-the-seals pressure test is required for the emergency escape air lock doors.

The regulations in 10 CFR 50.36 (c)(3), "Surveillance requirements," state that surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

The regulations in 10 CFR 50.36 (c)(5), "Administrative controls," state that administrative controls are the provisions relating to organization and management, procedures, record keeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. Each licensee shall submit any reports to the Commission pursuant to approved technical specifications as specified in 10 CFR 50.4.

3.0 TECHNICAL EVALUATION

3.1 Emergency Escape Air Lock In its letter dated January 21, 2014, the licensee provided the following description of the AN0-2 containment building emergency escape air lock:

The air lock consists of a steel cylinder with circular doors at each end interlocked so that only one door can be open at any time. The air lock is designed to withstand all Containment Building conditions with either door or both doors closed. The doors open towards the interior of Containment Building and the door directly in contact with the Containment Building atmosphere is designated as the inner door. The air lock performs two functions: (1) [it is]

capable of sealing and maintaining Containment Building integrity during accident conditions (verified by local leak rate testing (LLRT) and by Integrated Leak Rate Testing (ILRT)), and (2) [it is] capable of providing the Occupational Safety and Health Administration (OSHA) required emergency personnel egress from the Containment Building.

Double gaskets or seals are provided to seal each door. The seal material currently in use is an ethylene-propylene-diamine-monomer (EPDM), which is the vendor recommended material. The air lock barrel may be pressurized to test its leak tightness without pressurizing the Containment Building. The Emergency Escape Air Lock doors each have two latching pins centered at the top and bottom of the door (corresponding to 12 o'clock and 6 o'clock positions). The Emergency Escape Air Lock door latching pins serve only to position the door against the stationary bulkhead. The doors rely on the increase in containment pressure during a postulated event to provide sufficient closing force to produce an effective seal. The two latching pins alone do not provide an adequate circumferential closing force to allow meaningful door between-the-seals pressure testing.

3.2 NRC Staff Evaluation During a design basis accident, rising containment building pressure will apply forces to seal the inner air lock door. If the inner door seal leaks, the air lock barrel (area between inner and outer doors) will be pressurized and further seal the outer door. There are three types of containment leakage testing to assure that the containment and all containment penetration seals perform their required safety function. Type A testing, also known as integrated leak rate testing (ILRT, involves pressurizing the entire containment building to measure the overall leakage rate from containment. The second and third, which are both Type B testing, consist of the barrel pressure test to verify the sealing capability of the outer door, and the between-the-seals test to ensure the sealing of both inner and outer doors. Type B tests are intended to detect local leaks and to measure leakage across pressure containing or leakage-limiting boundaries, other than valves, for containment building penetrations.

Both of the licensee's air lock inner and outer doors are designed to open inward toward the containment interior. During the barrel pressure test, the pressure applied to the outer door will be in the same direction as that postulated during an accident, and will further seat that door on its seal. However, the pressure applied to the inner air lock door during the barrel pressure test is in the opposite direction of accident pressure, and acts to unseat the inner door. Therefore, a strongback test clamp is required to be installed on the inner door to simulate accident pressure inside containment prior to testing. Furthermore, applying test pressure without a strong back installed on the inner door would damage the door and its latching mechanism, resulting in substantial leakage. Therefore, by design, a strong back must be installed on the inner door, which acts to hold the inner door closed, prior to performance of the barrel test. No strong backs are utilized on either door during performance of the ILRT. The ILRT pressurizes the entire containment interior, applying pressure to the inner door in the accident direction. The barrel and outer door would experience pressure forces only if the inner door seals exhibited some amount of leakage.

In a request for additional information (RAI) dated August 11, 2014 (ADAMS Accession No. ML14218A602), the NRC staff requested details regarding the between-the-seals tests in order to have a comprehensive understanding for the cause of test failures and efforts being taken by the licensee to improve the test. In its supplemental letter dated September 24, 2014, the licensee stated that the between-the-seals test on a given air lock door is required after each door opening, except when the air lock is being used for multiple entries. The licensee also stated that during the test, the annulus between the door seals (two seals in series for each door) is pressurized, and a mass flowmeter is used to measure the door seal leakage. The licensee performed the test with the strong back installed on the inner door because the pressure as applied during a between-the-seals test was in the opposite direction of accident pressure and acted to "lift" the inner door off its seating surface.

In recent years, the licensee has performed maintenance and modification activities on the air lock doors. In the RAI dated August 11, 2014, the NRC staff requested information regarding whether the licensee had evaluated seal design, seal material, seal shape, and seal operation conditions to address the test failure. In its response, by letter dated September 24, 2014, the licensee stated that the seals are replaced every refueling outage. The licensee also stated that the seal material currently in use is EPDM, which is the vendor recommended and qualified material. The seals are a square cross-section shape design formed in a continuous circle to fit

the bulk head frame seal channel. By design of the channel, the seal shape is limited. In addition, each door is designed with a "nose/sealing bar" that provides a continuous protrusion into the flat-faced seal for improved sealing contact. These features prevent seal design changes without extensive changes to the design and hardware of the hatch.

The licensee performed some trial between-the-seals tests without a strongback installed on the inner air lock door. The licensee stated that it found that when the annulus between the door seals pressurized to pressures as low as 12 pounds per square inch gauge (psig) without the door strongback installed, the test pressure dissipated rapidly, indicating that a full pressure test would fail to meet acceptance criteria and 10 CFR 50, Appendix J, Option B requirements. The licensee has taken efforts to improve the test without the use of a strong back. These efforts have produced conflicted results. Given this, the licensee has investigated the potential of substantial modifications to the air lock doors in order to meet the current seal pressure test requirements and OSHA requirements. Beyond the many components previously replaced, along with spring upgrades to help alleviate the excessive force now needed to operate the doors, the licensee has determined complete door replacement (retrofit) would be necessary to resolve the aforementioned issues. Vendor proposals for options such as an "0" ring seal design with a 3-pin latching configuration, or a gear reduction design for the opening and closing mechanism for the doors, have been received and the associated cost study has been completed, resulting in a high estimated cost. While these options would improve the ability to increase sealing forces, there is insufficient evidence as to whether such modification(s) would ensure future success with respect to between-the-seal pressure testing.

The vendor has clearly stated that the AN0-2 design does not support testing without the use of a strongback and, to meet leak rate limits, the air lock's latching mechanism must generate a high latch contact such that it will maintain a residual compressive load on the gasket greater than the unseating effect produced by the test pressure. Adjustment and/or modification of the latch in this manner defeats the purpose of the emergency escape air lock since excessive human force would be required to open the air lock door in an emergency situation. In its application, the licensee describe two situations which have occurred since 2008, where difficult operation of the door created personnel hazards: (1) after an individual became trapped in the air lock due to being unable to open the door, a torque amplifying device has been installed to assist personnel in door opening/closing, and (2) during the fall 2012 outage, the outer door required mechanical agitation to open and it was noted that the 3/4-inch stainless steel latch pins were bent. Based on efforts to date, the licensee has concluded that attempting to apply excessive closing torque to the door in order to overcome the original design characteristics is inappropriate.

Past TS surveillance testing for the emergency escape air lock has shown that testing with strong backs in place is successful; however, the pressure applied by the strong backs, or the pressure applied to the outer door during the overall air lock pressure test, can cause door seals to take a set that reflects the shape of the seal grooves. With strong backs installed or test pressure applied by the air lock barrel, the male portion of the door seal (the seal bead) can be pressed into the seal. The seal will remain in this compressed condition for the entire test period, causing the seal to take a set in the seal groove of the air lock bulkhead. After completion of an overall air lock barrel pressure test, both doors must be opened to verify proper seal contact with the door seal bead in order to ensure that the seals rebound to the pre-test condition. During the seal contact check, a seal adjustment may be required after

testing because the force of the strong backs on a given door and/or the force due to the air lock barrel test pressure on the outer door can draw the seal bead on the doors further into the seal groove than what would occur under normal door closure forces.

In its application, the licensee provided information on how the seal contact check is performed.

The proposed seal contact check consists of applying chalk or other viable medium on the door seal face and then closing and reopening the air lock door, which results in a pattern in chalk (or other medium) that is representative of the door seal bead mating with the seal. If the chalk (or other medium) pattern does not show adequate 360-degree contact, the seals are adjusted in the area of the gap and a final seal contact check is performed to verify seal surface integrity.

The practice of verifying acceptable seal contact following performance of the overall air lock leak test and the acceptance criteria for this verification have been incorporated into the plant maintenance procedures.

In its application, the licensee stated that the performance of the door seal contact check, as a precursor to the full pressure test, has led to the successful completion of subsequent emergency escape air lock full pressure tests since the procedural practice began. In the RAI dated August 11, 2014, the NRC staff requested the licensee to provide test results to show the effectiveness of the seal contact check. In its RAI response by letter dated September 24, 2014, the licensee provided the pressure test results following seal contact checks during refueling outages from 2008 (2R19) to 2014 (2R23). The licensee stated, in its RAI response, that the results indicate that performance of the seal contact check is instrumental in the successful completion of subsequent leak testing. In addition, in its application, the licensee stated that no ILRT in that period has failed because of emergency escape air lock door seal leakage.

In summary, the licensee has made numerous attempts to consistently perform the between-the-seals test without the use of a strong back, including modifications and maintenance to the door. However, the design of the door and the seal configuration is the cause of the test failure.

Since the seals are implanted into the stationary bulkhead frame, applying test pressure between the seals will act to push the inner door away from the stationary bulkhead and lift the door off of its contact position with the seals, causing excessive leakage, even at low test pressures. The air lock door design configuration does not present other options for performing between-the-seals testing such that forces would not be applied to the inner door in the opposite direction of accident pressure.

As an alternative to the between-the-seals pressure test required by the TSs for verification of door seal functionality, the licensee has proposed a door seal contact verification. This seal performance verification is completed following the full pressure air lock test, after the removal of the inner door strong back, and just prior to final closure of the air lock doors. The requested TS changes would not affect compliance with the present requirement to perform a full pressure emergency escape air lock test each refueling outage.

Based on information provided by the licensee, and the evaluations above, the NRC staff concludes that the seal contact verification test will provide reasonable assurance that the air lock doors continue to fulfill their design function using a seal contact check in lieu of the current seal pressure test.

3.3 Revisions toTS 6.5.16. "Containment Leakage Rate Testing Program" Current TS 6.5.16 states, in part, that

b. Air lock acceptance criteria are:

1. Overall air lock leakage rate is s 0.05 La when tested at~ Pa.

2. Leakage rate for each door is s 0.01 La when pressurized to

~ 10 psig.

Revised TS 6.5.16 would state, in part, that

b. Air lock acceptance criteria are:

1. Overall air lock leakage rate iss 0.05 La when tested at~ Pa.

2. Leakage rate for each Personnel Air Lock door iss 0.01 La when pressurized to ~ 10 psig.

3. A seal contact check for each Emergency Escape Air Lock door, consisting of a verification of continuous contact between the seals and the sealing surfaces.

The NRC staff has reviewed these TS changes and concludes, based on the approved exemption from Appendix J to 10 CFR Part 50 between-the-seals pressure test requirement for the air lock doors and the above evaluation, that the TS 6.5.16 revisions are consistent with the proposed testing protocol and are, therefore, acceptable.

3.4 Exemption to Regulations As explained in Section 2.0 above, the regulations in Appendix J to 10 CFR Part 50 require a between-the-seals pressure test for the containment building emergency air lock doors. The design of the air lock doors at AN0-2, are such that a between-the-seals pressure test does not provide meaningful results, because the test pressure serves to unseat the inner air lock door (since, for the inner door, between-the-seals test pressure is in the opposite direction of postulated accident containment pressure) and allow leakage in excess of the acceptance criteria. Therefore, a plant-specific exemption is needed to permit the use of a seal contact check in lieu of the seal pressure test. The exemption dated January 13, 2015, is issued separately from, but with support from this safety evaluation and amendment.

3.5 Summary of Technical Evaluation The purpose of between-the-seals testing is to verify the seal integrity after an Emergency Escape Air Lock door is opened. Alternatively, the seal contact check and adjustment (if necessary) performed on the door seals, can fulfill this purpose and ensure the door is sealing

properly and performing its design basis function. Based on this evaluation, the NRC staff concludes that the licensee's proposal to perform seal contact check instead of the between-the-seals leak rate testing on the emergency escape air lock door seals is acceptable. The NRC staff further concludes that the revised TS 6.5.16 is consistent with the proposed change, and is, therefore, acceptable.

The regulation at 10 CFR 50.36(a)(1) states: "A summary statement of the bases or reasons for such specifications ... shall also be included in the application, but shall not become part of the technical specifications." The licensee may make changes to the TS Bases without prior NRC staff review and approval in accordance with TS 6.5.14, "Technical Specifications (TS) Bases Control Program." Accordingly, along with the proposed TS changes, the licensee also submitted TS Bases changes corresponding to the proposed TS changes. The NRC staff determined that these TS Bases changes are consistent with the proposed TS changes and provide the purpose for each requirement in the specification consistent with the Commission's "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors,"

dated July 22, 1993 (58 FR 39132).

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Arkansas State official was notified of the proposed issuance of the amendment. The Arkansas 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 amendment involves no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on April15, 2014 (79 FR 21296). 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 Commission's 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 Contributor: S. Peng, NRR/DSS/SCVB Date: January 22, 2015

ML143508285 *via memo OFFICE NRR/DORULPL4-1/PM NRR/DORLILPL4-1/LA NRR/DSS/STSB/BC NRR/DSS/SCVB/BC NAME A George JBurkhardt REIIiott RDennig*

DATE 12/23/14 12/23/14 12/31/14 10/31/14 OFFICE OGC- NLO NRR/DORLILPL4-1/BC(A) NRR/DORLILPL4-1/PM NAME BHarris EOesterle AGeorge DATE 1/9/15 1/14/15 1/22/15