ML18289A432

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James A. Fitzpatrick Nuclear Power Plant Issuance of Amendment No. 323 Revision to the Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6
ML18289A432
Person / Time
Site: FitzPatrick Exelon icon.png
Issue date: 11/28/2018
From: Booma Venkataraman
Plant Licensing Branch 1
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
Venkataraman B, NRR/DORL/LPL1
References
EPID L-2018-LLA-0032
Download: ML18289A432 (30)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 28, 2018 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT-ISSUANCE OF AMENDMENT NO. 323 RE: REVISION TO THE EMERGENCY ACTION LEVEL SCHEMES PURSUANT TO NEI 99-01, REVISION 6 (EPID L-2018-LLA-0032)

Dear Mr. Hanson:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 323 to Renewed Facility Operating License No. DPR-59 for the James A. FitzPatrick Nuclear Power Plant (FitzPatrick).

The amendment consists of changes to the FitzPatrick emergency plan in response to your application dated January 31, 2018, as supplemented by letter dated July 12, 2018. The amendment revises the emergency plan by changing the emergency action level schemes to those based on the Nuclear Energy lnstitute's (NEl's) guidance in NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," dated November 2012, which was endorsed by the Commission by letter dated March 28, 2013. A copy of the related Safety Evaluation is also enclosed.

Notice of Issuance will be included in the Commission's biweekly Federal Register notice. Docket No. 50-333

Enclosures:

Sincerely, {~r Booma Venkataraman, Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

1. Amendment No. 323 to Renewed DPR-59 2. Safety Evaluation cc: Listserv UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON FITZPATRICK, LLC EXELON GENERATION COMPANY, LLC DOCKET NO. 50-333 JAMES A. FITZPATRICK NUCLEAR POWER PLANT AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 323 Renewed License No. DPR-59 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that: A. The application for amendment by Exelon Generation Company, LLC (the licensee) dated January 31, 2018, as supplemented by letter dated July 12, 2018, 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 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, by Amendment No. 323, Renewed Facility Operating License No. DPR-59 is hereby amended to authorize revision to the Emergency Plan as set forth in the licensee's application dated January 31, 2018, as supplemented by letter dated July 12, 2018, and evaluated in the NRC staff's safety evaluation enclosed with this amendment.

3. This license amendment is effective as of the date of its issuance and shall be implemented on or before December 31, 2019. FOR THE NUCLEAR REGULATORY COMMISSION Ho K. Nieh, Director Office of Nuclear Reactor Regulation Date of Issuance:

November 28, 201 8 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 323 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-59 EXELON FITZPATRICK, LLC EXELON GENERATION COMPANY, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333

1.0 INTRODUCTION

By application dated January 31, 2018 (Reference 1 ), as supplemented by letter dated July 12, 2018 (Reference 2), Exelon Generation Company, LLC (Exelon, the licensee) requested U.S. Nuclear Regulatory Commission (NRC, the Commission) approval of changes to revise the James A. FitzPatrick Nuclear Power Plant (FitzPatrick)

Emergency Plan. The proposed amendment would revise the emergency action level (EAL) scheme to one based on the Nuclear Energy Institute (NEI) document NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," dated November 2012 (Reference 3). Revision 6 of NEI 99-01 was endorsed by the NRC in a letter dated March 28, 2013 (Reference 4). The supplemental letter dated July 12, 2018, provided additional information that clarified the application, but did not expand the scope of the application as originally noticed, and did not change the NRC staff's proposed no significant hazards consideration determination as published in the Federal Register on July 17, 2018 (83 FR 33267).

2.0 REGULATORY EVALUATION

The applicable regulations and guidance for the emergency plans are provided in Sections 2.1 and 2.2 below. 2.1 Regulations Title 10 of the Code of Federal Regulations (10 CFR) Section 50.47, "Emergency plans," sets forth emergency plan requirements for nuclear power reactors.

Section 50.47(b) of 10 CFR establishes the planning standards that the onsite and offsite emergency response plans must meet for the NRC staff to make a finding that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

Planning Enclosure 2 Standard (4) of this section requires that onsite and offsite emergency response plans meet the following standard:

A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.

Section 50.47(b)(4) of 10 CFR requires the use of a standard emergency classification and action level scheme, ensuring that implementation methods are relatively consistent throughout the industry for a given reactor and containment design, but permits site-specific design considerations and preferences.

Section IV.B of Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," to 10 CFR Part 50, states, in part: The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the plant boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring.

By June 20, 2012, for nuclear power reactor licensees, these action levels must include hostile action that may adversely affect the nuclear power plant. Section IV.B.2 of Appendix E to 1 O CFR Part 50 states, in part: A licensee desiring to change its entire emergency action level scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change. 2.2 Guidance The EAL development guidance was initially established in Generic Letter (GL) 79-50, "Emergency Plans Submittal Dates," dated October 10, 1979 (Reference 5). This guidance was subsequently revised in NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," dated November 1980 (Reference 6), which was endorsed by NRC Regulatory Guide (RG) 1.101, Revision 2, "Emergency Planning and Preparedness for Nuclear Power Reactors," dated October 31, 1981 (Reference 7), as an approach acceptable to the NRC for the development of an EAL scheme. As industry and regulatory experience was gained with the implementation and use of EAL schemes, the industry issued revised EAL scheme development guidance to reflect lessons learned, many of which have been provided to the NRC for review and endorsement as generic (i.e., non-site-specific)

EAL development guidance.

Most recently, the industry developed NEI 99-01, Revision 6, which the NRC staff endorsed by letter dated March 28, 2013, as acceptable generic EAL scheme development guidance.

Although the EAL development guidance contained in NEI 99-01, Revision 6, is generic and may not be entirely applicable for some non-passive, large light-water reactor designs, it bounds the most typical accident and event scenarios for which emergency response is necessary in a format that allows for industry standardization and consistent regulatory oversight.

Licensees may choose to develop site-specific EAL schemes using NEI 99-01, Revision 6, with appropriate site-specific alterations as applicable.

NRC Regulatory Issue Summary (RIS) 2003-18, "Use of NEI 99-01, 'Methodology for Development of Emergency Action Levels'," Revision 4, dated October 8, 2003, including Supplements 1 and 2 (Reference 8), also provides guidance for developing or changing a standard EAL scheme. In addition, this RIS, and its supplements, provide recommendations to assist licensees, consistent with Section IV.B.2 of Appendix E to 10 CFR Part 50, in determining whether to seek prior NRC approval of deviations from the guidance.

In summary, the NRC staff considers NEI 99-01, Revision 6, as an acceptable method to develop site-specific EALs that meet the requirements of Section IV.B of Appendix E to 10 CFR Part 50, and planning standard 10 CFR 50.47(b)(4), with the understanding that licensees may want to develop EALs that differ from the guidance document as allowed in RG 1.101. 2.3 NRC Staff Review In its application dated January 31, 2018, as supplemented by letter dated July 12, 2018, the licensee proposes to revise the current FitzPatrick EAL scheme to one based on NEI 99-01, Revision 6. Additionally, the licensee submitted the proposed EAL scheme, the technical basis containing an evaluation and rationale for each proposed EAL change, and a comparison matrix providing a line-by-line comparison of the proposed initiating conditions, mode applicability, and EAL wording to that found in NEI 99-01, Revision 6. The comparison matrix also includes a description of global changes applicable to the EAL scheme and a justification for any differences or deviations from NEI 99-01, Revision 6. The application states that the licensee used the terms "difference" and "deviation" as defined in RIS 2003-18, as supplemented, when comparing its proposed site-specific EALs to the generic EALs in NEI 99-01, Revision 6. The NRC staff reviewed the application, as supplemented, and verified that the proposed EAL scheme is consistent with the guidance provided in NEI 99-01, Revision 6, to assure that the proposed EAL scheme meets the requirements of Section IV.B of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4).

The NRC staff reviewed the proposed site-specific EAL scheme, technical basis, comparison matrix, and all additional information provided in the licensee's application and supplemental letters. The NRC staff found that both the current and proposed EALs have modifications from the NEI 99-01, Revision 6, guidance due to the specific plant design and licensee preference.

The NRC staff reviewed the application, as supplemented, and verified that the instrumentation and setpoints derived for this proposed EAL scheme are consistent with the overall EAL scheme development guidance, address the site-specific implementation strategies provided, and are consistent with a standard EAL scheme. Although the EALs must be site-specific, the NRC staff reviewed the proposed EALs for the following key characteristics of an effective EAL scheme to ensure:

  • Consistency, including standardization of intent, if not in actual wording (i.e., the EALs would lead to similar decisions under similar circumstances at different plants);
  • Human factors engineering and user friendliness;
  • Potential for emergency classification level upgrade only when there is an increasing threat to public health and safety;
  • Ease of upgrading and downgrading the emergency classification level;
  • Thoroughness in addressing issues regarding the completeness and accuracy of Appendix 1 to NUREG-0654 (i.e., the EALs are unambiguous and are based on site-specific indicators);
  • Technical completeness for each classification level;
  • Logical progression in classification for multiple events; and
  • The use of objective and observable values. The NRC staff verified that the proposed EAL scheme uses objective and observable values; is worded in a manner that addresses human factors engineering and user friendliness concerns; follows logical progressions for escalating events; and allows for event downgrading and upgrading based upon the potential risk to the public health and safety. The NRC staff verified that risk assessments were appropriately used to set the boundaries of the emergency classification levels and ensure that all EALs that trigger the declaration of an emergency classification are in the same range of relative risk. In addition, the NRC staff verified that the proposed EAL scheme is technically complete for each classification level, accurate, and consistent with EAL schemes implemented at similarly designed plants. To aid in understanding the nomenclature used in this safety evaluation, the following conventions are used: the first letter signifies the EAL Recognition Category; the second letter signifies the emergency classification level, and the number is the applicable number from the site-specific EAL scheme.
  • The scheme's generic information is organized by Recognition Category in the following order: o A or R -Abnormal Radiation Levels/Radiological Effluent, o C -Cold Shutdown/Refueling System Malfunction, o E -Independent Spent Fuel Storage Installation, o F -Fission Product Barrier, o H -Hazards and Other Conditions Affecting Plant Safety, and o S or M -System Malfunction.
  • The emergency classification levels are: o U -Notification of Unusual Event (UE), o A-Alert, o S -Site Area Emergency (SAE), and o G -General Emergency (GE). An EAL set refers to EALs within an EAL Recognition Category that include an escalation path for one or more classification levels. Not all EAL Recognition Categories require an EAL set. This safety evaluation uses the numbering system from the proposed site-specific EAL scheme; however, the numbering system from the generic EAL scheme development guidance contained in NEI 99-01, Revision 6, is also annotated in [brackets]

to aid in cross-referencing the site-specific EAL numbering convention with that of the guidance.

3.0 TECHNICAL

EVALUATION

3.1 Recognition

Category 'R' -Abnormal Radiation Levels/Radiological Effluent 3.1.1 FitzPatrick EAL Set RU1/RA1/RS1/RG1

[AU1/AA1/AS1/AG1]

The intent of this EAL set is to ensure that an emergency classification is declared upon site-specific indications of a release of radioactivity (gaseous or liquid). In recognition of the lower possible radioactivity concentrations, the assessment of liquid releases is limited to the UE and Alert classification levels. This set provides for accident assessments using pre-calculated values based on assumed conditions, real-time parameters, and field monitoring results. The NRC staff reviewed the licensee's evaluation and justification for plant-specific EAL changes associated with this set and determined that the progression from a UE to a GE classification level is appropriate and consistent with EAL scheme development guidance.

  • RU 1 -This EAL addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release).
  • RA 1 -This EAL addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1 percent of the U.S. Environmental Protection Agency (EPA) early phase protective action guides (PAGs) (Reference 9).
  • RS1 -This initiating condition addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10 percent of the EPA early phase PAGs.
  • RG1 -This initiating condition addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA early phase PAGs. The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications. Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.1.2 FitzPatrick

EAL Set RU2/RA2/RS2/RG2

[AU2/AA2/AS2/AG2]

The intent of this EAL set is to ensure that an emergency classification is declared upon site-specific indications of potential or actual damage to an irradiated fuel assembly or multiple assemblies.

It addresses a lowering of water level over irradiated fuel or fuel uncovery (i.e., level below the top of the fuel), and a spectrum of fuel handling accidents that result in mechanical damage to irradiated fuel (e.g., a dropped fuel assembly).

Some of these EALs rely on the spent fuel pool water level instrumentation required by NRC Order EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012 (Reference 10). The NRC staff reviewed the licensee's evaluation and justification for plant-specific EAL changes associated with this set and determined that the progression from a UE to a GE classification level is appropriate and consistent with EAL scheme development guidance.

  • RU2 -This EAL addresses a decrease in water level above irradiated fuel sufficient to cause elevated radiation levels.
  • RA2 -This EAL addresses events that have caused imminent or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the spent fuel pool (SFP).
  • RS2 -This EAL addresses a significant loss of SFP water inventory control and makeup capability leading to imminent fuel damage and addresses NRC Order EA-12-051.
  • RG2 -This EAL addresses a significant loss of SFP water inventory control and makeup capability leading to a prolonged uncovery of irradiated fuel. The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 1 O CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable. 3.1.3 FitzPatrick EAL RA3 [AA3] The intent of this EAL is to ensure that an emergency classification is declared when elevated radiation levels in certain plant rooms and areas are sufficient enough to preclude or impede personnel from performing actions necessary to maintain normal plant operation or to perform a normal plant cooldown and shutdown.

This includes equipment in the control room and the central alarm station. The Alert classification level is primarily intended to ensure that the plant emergency response organization (ERO) is activated to support the control room in removing the impediment to normal access, as well as assisting in quantifying potential damage to the fuel. Indications of increasing radiation levels at the plant are bounded by Recognition Category 'F', as well as EALs RS1 and RG1. The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, logical progression, and instrumentation and setpoints for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for* this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.2 Recognition

Category 'C' -Cold Shutdown/Refueling System Malfunction

3.2.1 FitzPatrick

EAL Set CU6/CA6/CS6/CG6

[CU1/CA1/CS1/CG1]

The intent of this EAL set is to ensure an emergency classification is declared upon a loss of reactor pressure vessel (RPV) and/or reactor coolant system (RCS) inventory.

The NRC staff reviewed the licensee's evaluation and justification for plant-specific EAL changes associated with this set and determined that the progression from a UE to a GE classification level is appropriate and consistent with EAL scheme development guidance.

  • CU6 -This EAL addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor RPV/RCS level concurrent with indications of reactor coolant leakage.
  • CA6 -This EAL addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel in the RPV/RCS (i.e., a precursor to a challenge to the fuel clad barrier).
  • CS6 -This EAL addresses a significant and prolonged loss of RPV/RCS inventory control and makeup capability leading to imminent fuel damage.
  • CG6 -This EAL addresses the inability to restore and maintain RPV/RCS level above the top of active fuel with containment challenged.

The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.2.2 FitzPatrick

EAL Set CU1/CA1 [CU2/CA2]

The intent of this EAL set is to ensure that an emergency classification is declared upon a loss of available alternating current (AC) power to emergency power electrical busses. The NRC staff reviewed the licensee's evaluation and justification for plant-specific EAL changes associated with this set and determined that the progression from a UE to an Alert classification level is appropriate and consistent with EAL scheme development guidance.

The SAE and GE classification levels for this specific accident progression are bounded by EALs RS1 and RG1.

  • CU1 -This EAL describes a significant degradation of offsite and onsite AC power sources, such that any additional single failure would result in a loss of all AC power to safety systems.
  • CA 1 -This EAL addresses a loss of all AC power that compromises the performance of all safety systems requiring electric power, including those necessary for emergency core cooling, containment heat removal/pressure control, irradiated fuel heat removal, and the ultimate heat sink. The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, logical progression, and ease of upgrading/downgrading for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.2.3 FitzPatrick

EAL Set CU5/CA5 [CU3/CA3)

The intent of this EAL set is to ensure that an emergency classification is declared based on the inability to maintain control of decay heat removal. The NRC staff reviewed the licensee's evaluation and justification for plant-specific EAL changes associated with this set and determined that the progression from a UE to an Alert classification level is appropriate and consistent with EAL scheme development guidance.

The SAE and GE classification levels for this specific accident progression are bounded by EALs RS1 and RG1.

  • CU5 -This EAL addresses an unplanned increase in RCS temperature above the Technical Specification cold shutdown temperature limit, or the inability to determine RCS temperature and level.
  • CA5 -This EAL addresses conditions involving a loss of decay heat removal capability, or an addition of heat to the RCS in excess of that which can currently be removed. The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, logical progression, and ease of upgrading/downgrading for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR50.47(b)(4).

The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.2.4 FitzPatrick

EAL CU3 [CU4) The intent of this EAL is to ensure that an emergency classification is declared upon a loss of vital direct current (DC) power, which compromises the ability to monitor and control operable safety systems. This EAL is primarily intended to ensure that key ERO members and offsite response organizations (OROs) are aware of the event, resources necessary to respond to the event are mobilized, and any necessary compensatory measures are promptly implemented. The Alert, SAE, and GE classification levels for a protracted loss of vital DC power are bounded by EALs CA6, CA5, CS6, CG6, RA1, RS1, and RG1. The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, formatting, logical progression, and instrumentation and setpoints for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.2.5 FitzPatrick

EAL CU4 [CU5] The intent of this EAL is to highlight the importance of emergency communications by ensuring that an emergency classification is declared if normal communication methods for onsite and offsite personnel, or with OROs, including the NRC, are lost. This EAL is primarily intended to ensure that key ERO members and OROs are aware of the loss of communications capabilities, the resources necessary to restore communications are mobilized, and compensatory measures are promptly implemented.

Considering that a loss of emergency communications capability would not involve an actual or potential substantial degradation to the level of safety of the plant, no escalation path is necessary for this EAL. The communication methods derived for this EAL are consistent with the overall EAL scheme development guidance.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance.

The NRG staff verified that the numbering, sequencing, formatting, and logical progression for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 GFR 50.47(b)(4).

The NRG staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRG staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable. 3.2.6 FitzPatrick EAL CA2 [CA6] The intent of this EAL is to ensure that an emergency classification is declared when hazardous events lead to potential damage to safety systems. The hazardous events of interest include, but are not limited to, an earthquake, flooding, high winds, tornado strike, explosion, fire, or any other hazard applicable for the site. This EAL is primarily intended to ensure that the site ERO is activated to support the control room in understanding the event impacts and restoring affected safety system equipment to service. Indications of hazard-induced damage to components containing radioactive materials are bounded by EALs CS6, CG6, RS1, and RG1. As described in NUREG-0654/FEMA-REP-1, Revision 1, and the endorsed guidance in NEI 99-01, Revision 6, an Alert class exists when "[e]vents are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels." The endorsed guidance in NEI 99-01, Revision 6, is intended to ensure that an Alert should be declared only when an actual or potential substantial degradation of the level of safety of the plant has occurred as a result of a hazardous event. However, there may be cases where a hazardous event only causes damage to a single safety system component or a single safety system train. Additionally, an Alert classification should not be made if the damage from the hazardous event is limited to a safety system component or a safety system train that was inoperable or out of service prior to the event occurring.

The licensee is proposing that an Alert classification will be made when a hazardous event results in indications of degraded performance to one train of a safety system, with either indications of degraded performance on a second safety system train or visible damage to a second safety system train, such that the operability or reliability of the second safety system train is a concern. Although different from the endorsed guidance in NEI 99-01, Revision 6, the NRC staff finds that this change is acceptable, considering that the endorsed guidance in NEI 99-01, Revision 6, is intended to ensure that an Alert should be declared only when an actual or potential substantial degradation of the level of safety of the plant has occurred as a result of a hazardous event. The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, and logical progression for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 1 O CFR Part 50. Therefore, the NRC staff finds this EAL acceptable. 3.3 Recognition Category 'E' -Independent Spent Fuel Storage Installation

3.3.1 FitzPatrick

EAL E-HU1 [E-HU1] This EAL applies to an event that results in damage to the confinement boundary of a storage cask containing irradiated fuel. An independent spent fuel storage installation does not have an accident progression that would lead to a GE. This EAL is primarily intended to ensure that key ERO members and OROs are aware of the cask damage, resources necessary to respond to the event are mobilized, and protective measures, if warranted, are promptly implemented.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, and logical progression for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.4 Recognition

Category 'F' -Fission Product Barrier Matrix 3.4.1 FitzPatrick EAL Set FA1/FS1/FG1

[FA1/FS1/FG1]

The intent of this EAL set is to ensure that an emergency classification is declared upon a loss or potential loss of one or more fission product barriers.

This EAL set uses plant condition based thresholds as triggers within a particular logic configuration needed to reflect a loss or potential loss of a fission product barrier. Non-passive, large light-water reactors in the United States have three fission product barriers:

fuel cladding, the RCS, and primary containment.

Licensees are to develop thresholds that provide EAL decisionmakers input into making an event declaration based upon degradation of one or more of these fission product barriers.

There are numerous triggers used as logic inputs to decide on the appropriate classification based upon the number of loss and/or potential loss indicators that are triggered for each barrier. These indicators are redundant with other similar indicators in Recognition Categories

'R' and 'S'. The NRC staff reviewed the licensee's evaluation and justification for plant-specific EAL changes associated with this set and determined that the logic used to determine the appropriate emergency classification is consistent with the generic EAL scheme development guidance in NEI 99-01, Revision 6. Additionally, the staff determined that the progression from an Alert to a GE classification level is appropriate and consistent with EAL scheme development guidance.

  • FA1 -Any Loss or any Potential Loss of either the Fuel Clad or RCS barrier.
  • FS 1 -Loss or Potential Loss of any two barriers.
  • FG1 -Loss of any two barriers, and Loss or Potential Loss of the third barrier. The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.5 Recognition

Category 'H' -Hazards and Other Conditions Affecting Plant Safety 3.5.1 FitzPatrick EAL Set HU1/HA1/HS1

[HU1/HA1/HS1/HG1]

The intent of this EAL set is to ensure that an emergency classification is declared based upon a security-related event. This EAL set was developed in accordance with the guidance from NRC Bulletin 2005-02, "Emergency Preparedness and Response Actions for Security-Based Events," dated July 18, 2005 (Reference 11 ), and RIS 2006-12, "Endorsement of Nuclear Energy Institute Guidance 'Enhancements to Emergency Preparedness Programs for Hostile Action"' (Reference 12), dated July 19, 2006, for licensees to implement, regardless of the specific version of the generic EAL scheme development guidance used, or if the particular licensee developed its EAL scheme using an alternative approach.

Based upon lessons learned from the implementation and use of this EAL set, particularly the insights gained from combined security and emergency preparedness drills, FitzPatrick is proposing to not develop EAL [HG1] as provided in NEI 99-01, Revision 6. EAL HG1 of NEI 99-01, Revision 6, addresses a hostile action that results in the loss of physical control of the facility.

Such an action can reasonably be expected to exceed EPA early phase PAG exposure levels offsite for more than the immediate site area, which is the criteria for EAL HG? in NEI 99-01, Revision 6. Therefore, in NEI 99-01, Revision 6, EAL HG1 is bounded by the EAL HG?. Additionally, any event that could result in a radiological release in excess of EPA early phase PAGs would be bounded by EALs AG1 or AG2 in NEI 99-01, Revision 6. The NRC staff verified that the licensee's EALs RG1, RG2, and HG? bound the events addressed by EAL HG1 in NEI 99-01, Revision 6. The NRC staff also reviewed the licensee's evaluation and justification for plant-specific EAL changes associated with this set and determined that the progression from a UE to a SE classification level is appropriate and consistent with EAL scheme development guidance.

  • HU1 -This EAL addresses events that pose a threat to plant personnel or safety system equipment.
  • HA 1 -This EAL addresses the occurrence of a hostile action within the Owner Controlled Area or notification of an aircraft attack threat.
  • HS 1 -This EAL addresses the occurrence of a hostile action within the Protected Area. The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.5.2 FitzPatrick

EAL HU4 [HU2] The intent of this EAL is to ensure that an emergency classification is declared based upon a seismic event that results in accelerations at the plant site greater than specified for an operating basis earthquake.

This EAL is primarily intended to ensure that key ERO members and OROs are aware of the earthquake magnitude at the site and that post-event damage assessments are promptly implemented. This EAL is considered part of an EAL set containing EALs CA2 and MA5, depending on the operating mode applicable at the time of the event. Indications of earthquake-induced damage to components containing radioactive materials are bounded by Recognition Category 'F', as well as EALs RA1, RS1, or RG1. The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, logical progression, and instrumentation and setpoints for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications. Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.5.3 FitzPatrick

EAL HU6 [HU3] The intent of this EAL is to ensure that an emergency classification is declared based upon the effects that natural or technological hazard events may have on the facility that are considered to be precursors to a more significant event or condition or have potential impacts that warrant emergency notification to local, State, and Federal authorities.

Specific hazards addressed include:

  • Tornado strike within the protected area;
  • Internal room or area flooding requiring electrical isolation of a safety system component;
  • Movement of personnel within the protected area impeded due to an offsite event involving hazardous materials;
  • A hazardous event that results in onsite conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles, and
  • Other site-specific events. This EAL is primarily intended to ensure that key ERO members and OROs are aware of the hazardous event affecting the site, and post-event damage assessments are promptly implemented.

In addition, other site-specific events that may impact the effective implementation of the site emergency plan are considered.

This EAL is considered part of an EAL set containing EALs CA2 and MA5, depending on the operating mode applicable at the time of the event. Indications of hazard-induced damage to components containing radioactive materials are bounded by Recognition Category 'F', as well as EALs RA1, RS1, or RG1. The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance.

The NRG staff verified that the numbering, sequencing, formatting, and logical progression for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable. 3.5.4 FitzPatrick EAL HU3 [HU4] The intent of this EAL is to ensure that an emergency classification is declared based upon the effect that a fire may have on the facility, which would be indicative of a potential degradation of the level of safety of the plant. This EAL is primarily intended to ensure that key ERO members and OROs are aware of the fire, and post-event damage assessments are promptly implemented. This EAL is considered part of an EAL set containing EALs CA2 and MA5, depending on the operating mode applicable at the time of the event. Indications of a protracted fire involving radioactive materials are bounded by Recognition Category 'F', as well as EALs RS1 and RG1. The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, and logical progression for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.5.5 FitzPatrick

EAL HA5 [HA5) The intent of this EAL is to ensure that an emergency classification is declared based upon the effect that toxic, corrosive, asphyxiating, or flammable gases may have on the facility, which precludes or impedes access to equipment necessary to maintain normal plant operation or required for a normal plant cooldown and shutdown.

This EAL is primarily intended to ensure that the site ERO is activated to support the control room in removing the impediment to normal access to the affected area or room. Indications of a protracted loss of access to equipment necessary for normal plant operations, cooldown, or shutdown are bounded by Recognition Category 'F', as well as EALs RS1 and RG1. The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, and formatting for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications. Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.5.6 FitzPatrick

EAL Set HA2/HS2 [HA6/HS6]

The intent of this EAL set is to ensure that an emergency classification is declared based upon a control room evacuation with the inability to control critical plant systems remotely.

The NRC staff reviewed the licensee's evaluation and justification for plant-specific EAL changes associated with this set and determined that the progression from an Alert to an SAE classification level is appropriate and consistent with EAL scheme development guidance.

The GE classification level for this specific accident progression is bounded by Recognition Category 'F', as well as EAL RG1.

  • HA2 -This EAL addresses an evacuation of the control room that results in transfer of plant control to alternate locations outside the control room.
  • HS2 -This EAL addresses an evacuation of the control room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, and ease of upgrading/downgrading for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 1 O CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.5.7 FitzPatrick

EAL Set HU7/HA7/HS7/HG7

[HU7/HA7/HS7/HG7]

The intent of this EAL set is to provide decisionmakers with an escalating emergency classification to consider when, in their judgment, entry into the site's emergency plan and mobilization of the licensee's ERO and ORO is warranted.

The NRC staff reviewed the licensee's evaluation and justification for plant-specific EAL changes associated with this set and determined that the progression from a UE to a GE classification level is appropriate and consistent with EAL scheme development guidance.

  • HU? -This EAL addresses unanticipated conditions not explicitly addressed elsewhere but, in the judgement of Emergency Director, warrants declaration of an emergency due to conditions existing that are believed to fall under the emergency classification level description for a UE.
  • HA7 -This EAL addresses unanticipated conditions not explicitly addressed elsewhere but, in the judgement of Emergency Director, warrants declaration of an emergency due to conditions existing that are believed to fall under the emergency classification level description for an Alert.
  • HS7 -This EAL addresses unanticipated conditions not explicitly addressed elsewhere but, in the judgement of Emergency Director, warrants declaration of an emergency due to conditions existing that are believed to fall under the emergency classification level description for an SAE.
  • HG7 -This EAL addresses unanticipated conditions not explicitly addressed elsewhere but, in the judgement of Emergency Director, warrants declaration of an emergency due to conditions existing that are believed to fall under the emergency classification level description for a GE. The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, and ease of upgrading/downgrading for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.6 Recognition

Category 'M' -System Malfunction

3.6.1 FitzPatrick

EAL Set MU1/MA1/MS1/MG1

[SU1/SA1/SS1/SG1]

The intent of this EAL set is to ensure that an emergency classification is declared based upon a loss of available AC power sources to the emergency busses. The NRC staff reviewed the licensee's evaluation and justification for site-specific changes associated with this EAL set and determined that the progression from a UE to a GE classification level is appropriate and consistent with EAL scheme development guidance.

  • MU1 -This EAL addresses a prolonged loss of offsite AC power.
  • MA 1 -This EAL describes a significant degradation of offsite and onsite AC power sources, such that any additional single failure would result in a loss of all AC power to safety systems. '
  • MS1 -This EAL addresses a loss of all AC power that compromises the performance of all safety systems requiring electric power, including those necessary for emergency core cooling, containment heat removal/pressure control, irradiated fuel heat removal, and the ultimate heat sink.
  • MG1 -This EAL addresses a prolonged loss of all power sources to AC emergency buses. The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47{b)(4).

The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.6.2 FitzPatrick

EAL Set MU4/MA4 [SU2/SA2]

The intent of this EAL set is to ensure that an emergency classification is declared based upon the effect that an unplanned loss of available indicators in the control room has on the facility.

The NRC staff reviewed the licensee's evaluation and justification for plant-specific EAL changes associated with this set and determined that the progression from a UE to an Alert classification level is appropriate and consistent with EAL scheme development guidance.

The SAE and GE classification levels for this specific accident progression are bounded by Recognition Category 'F', as well as EALs RS 1 and RG 1.

  • MU4 -This EAL addresses the difficulty associated with monitoring normal site conditions without the ability to obtain safety system parameters from within the control room.
  • MA4 -This EAL addresses the difficulty associated with monitoring rapidly changing plant conditions during a transient without the ability to obtain safety system parameters from within the control room. The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.6.3 FitzPatrick

EAL RU3 [SU3] The intent of this EAL is to ensure that an emergency classification is declared when RCS activity is greater than Technical Specification allowable limits. This EAL is primarily intended to ensure that key ERO members are aware of the elevated reactor coolant activity and support the control room in implementation of appropriate response measures.

Escalation of the emergency classification is bounded by Recognition Category 'F', as well as EALs RA 1, RS 1, and RG1. The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, logical progression, and instrumentation and setpoints for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.6.4 FitzPatrick

EAL MU6 [SU4] The intent of this EAL is to ensure that an emergency classification is declared when the plant has indications of RCS leakage. By design, the indications for this EAL are redundant to corresponding indicators for a loss or potential loss of fission product barriers, as well as radiation monitoring, to ensure reactor and/or fission product barrier events are recognized.

This EAL is primarily intended to ensure that key ERO members are aware of the RCS leakage and support the control room in implementation of appropriate response measures.

Escalation of the emergency classification is bounded by Recognition Category 'F', as well as EALs RA 1, RS1, and RG1. The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, logical progression, and instrumentation and setpoints for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.6.5 FitzPatrick

EAL Set MU3/MA3/MS3

[SU5/SA5/SS5]

The intent of this EAL set is to ensure that an emergency classification is declared based upon the effect that a failure of the reactor protection system (RPS) may have on the plant. The NRC staff reviewed the licensee's evaluation and justification for plant-specific EAL changes associated with this set and determined that the progression from a UE to an SAE classification level is appropriate and consistent with EAL scheme development guidance.

The GE classification level for this event is bounded by Recognition Category 'F', as well as EAL RG1.

  • MU3 -This EAL addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor control consoles or a subsequent automatic trip is successful in shutting down the reactor.
  • MA3 -This EAL addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and subsequent operator manual actions taken at the reactor control consoles to shut down the reactor are also unsuccessful.
  • MS3 -This EAL addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, all subsequent operator actions to manually shut down the reactor are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core and/or the RCS. The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.6.6 FitzPatrick

EAL MU7 [SU6] The intent of this EAL is to highlight the importance of emergency communications by ensuring that an emergency classification is declared if normal communication methods for onsite and offsite personnel, or with OROs including the NRC, are lost. It is primarily intended to ensure that key ERO members, OROs, and the NRC are aware of the loss of communications capabilities, the resources necessary to restore communications are mobilized, and compensatory measures are promptly implemented.

Considering that a loss of emergency communications capability would not involve an actual or potential substantial degradation to the level of safety of the plant, no escalation path is necessary for this EAL. The communication methods derived for this EAL are consistent with the overall EAL scheme development guidance.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, and logical progression for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.6. 7 FitzPatrick EAL Set MS2/MG2 [SS8/SG8]

The intent of this EAL set is to ensure that an emergency classification is declared when a loss of DC power occurs, as this condition compromises the ability of the licensee to monitor and control safety systems. The NRC staff reviewed the licensee's evaluation and justification for plant-specific EAL changes associated with this set and determined that the progression from an SAE to a GE classification level is appropriate and consistent with EAL scheme development guidance.

  • MS2 -This EAL addresses a loss of Vital DC power, which compromises the ability to monitor and control safety systems.
  • MG2 -This EAL addresses a concurrent and prolonged loss of both AC and Vital DC power. The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.6.8 FitzPatrick

EAL MAS [SA9] The intent of this EAL is to ensure that an emergency classification is declared when a hazardous event leads to potential damage to safety systems needed for the current operating mode. The hazardous events of interest include, but are not limited to, an earthquake, flooding, high winds, tornado strike, explosion, fire, or any other hazard applicable for FitzPatrick.

This EAL is primarily intended to ensure that the plant ERO is activated to support the control room in understanding the event impacts and restoring affected safety system equipment to service. Indications of hazard-induced damage to components containing radioactive materials are bounded by Recognition Category 'F', as well as EALs RS1 and RG1. As described in NUREG-0654/FEMA-REP-1, Revision 1, and the endorsed guidance in NEI 99-01, Revision 6, an Alert class exists when "[e]vents are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels." The endorsed guidance in NEI 99-01, Revision 6, is intended to ensure that an Alert should be declared only when an actual or potential substantial degradation of the level of safety of the plant has occurred as a result of a hazardous event. However, there may be cases where a hazardous event only causes damage to a single safety system component or a single safety system train. Additionally, an Alert classification should not be made if the damage from the hazardous event is limited to a safety system component or a safety system train that was inoperable or out of service prior to the event occurring.

The licensee is proposing that an Alert classification will be made when a hazardous event results in indications of degraded performance to one train of a safety system with either indications of degraded performance on a second safety system train or visible damage to a second safety system train, such that the operability or reliability of the second safety system train is a concern. Although different from the endorsed guidance in NEI 99-01, Revision 6, this change is acceptable, considering that the endorsed guidance in NEI 99-01, Revision 6, is intended to ensure that an Alert should be declared only when an actual or potential substantial degradation of the level of safety of the plant has occurred as a result of a hazardous event. The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance.

The NRC staff verified that the numbering, sequencing, formatting, logical progression, and instrumentation and setpoints for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above), and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3. 7 NRC Staff Review Summary The NRC staff has reviewed the technical bases for the proposed EAL scheme, the modifications from NEI 99-01, Revision 6, and the licensee's evaluation of the proposed changes. The licensee chose to modify its proposed EAL scheme from the generic EAL scheme development guidance provided in NEI 99-01, Revision 6, in order to adopt a format that is better aligned with how it currently implements its EALs, as well as with site-specific writer's guides and preferences.

The NRC staff verified that these modifications do not alter the intent of any specific EAL within a set, recognition category, or within the entire EAL scheme described in NEI 99-01, Revision 6. Thus, the proposed changes meet the requirements in Appendix E to 10 CFR Part 50 and planning standard 10 CFR 50.47(b).

The NRC staff determined that the proposed EAL scheme uses objective and observable values, is worded in a manner that addresses human factors engineering and user friendliness concerns, follows logical progressions for escalating events, and allows for event downgrading or upgrading based upon the potential risk to the public health and safety. Risk assessments were appropriately used to set the boundaries of the emergency classification levels and ensure that all EALs that trigger an emergency classification are in the same range of relative risk. In addition, the NRC staff determined that the proposed EAL scheme is technically complete and consistent with EAL schemes implemented at similarly designed plants. The NRC staff verified that the instrumentation and setpoints derived for this proposed EAL scheme are consistent with the overall EAL scheme development guidance, address the site-specific implementation strategies provided, and are consistent with a standard EAL scheme. Based on its review, the NRC staff finds that the licensee's proposed EAL scheme is acceptable and provides reasonable assurance that the licensee can and will take adequate protective measures in the event of a radiological emergency.

Specifically, the staff concludes that the licensee's proposed EAL scheme and site-specific EAL technical basis document provided by letter dated January 31, 2018, as supplemented by letter dated July 12, 2018, are acceptable for implementation.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the New York State official was notified of the proposed issuance of the amendment on October 16, 2018. 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 amendment involves no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on July 17, 2018 (83 FR 33267). 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. 7.0 1. 2. 3. 4. REFERENCES Letter from Exelon Generation Company, LLC, to U.S. Nuclear Regulatory Commission, "License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, 'Development of Emergency Action Levels for non-Passive Reactors,"'

dated January 31, 2018 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML 18037A782).

Letter from Exelon Generation Company, LLC, to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information

-License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, 'Development of Emergency Action Levels for Non-Passive Reactors,"'

dated July 12, 2018 (ADAMS Accession No. ML 18194A252).

NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," dated November 2012 (ADAMS Package Accession No. ML 13091A209).

Thaggard, M., U.S. Nuclear Regulatory Commission, letter to Susan Perkins-Grew, Nuclear Energy Institute, "U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 6, dated November, 2012 (TAC No. D92368)," dated March 28, 2013 (ADAMS Accession No. ML 12346A463). 5. U.S. Nuclear Regulatory Commission, Generic Letter 79-50, "Emergency Plans Submittal Dates," dated October 10, 1979 (ADAMS Accession No. ML031320278).

6. U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," NUREG-0654/FEMA-REP-1, Revision 1, dated November 1980 (ADAMS Accession No. ML040420012).
7. U.S. Nuclear Regulatory Commission, "Emergency Planning and Preparedness for Nuclear Power Reactors," Regulatory Guide 1.101, Revision 2, October 31, 1981 (ADAMS Accession No. ML090440294);

Revision 3, August 31, 1992 (ADAMS Accession No. ML003740302);

and Revision 4, dated July 31, 2003 (ADAMS Accession No. ML032020276).

8. U.S. Nuclear Regulatory Commission, Regulatory Issue Summary 2003-18, "Use of NEl-99-01, 'Methodology for Development of Emergency Action Levels,' Revision 4, Dated January 2003," dated October 8, 2003, including Supplement 1 dated July 13, 2004, and Supplement 2 dated December 12, 2005 (ADAMS Accession Nos. ML032580518, ML041550395, and ML051450482, respectively).
9. U.S. Environmental Protection Agency, "PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incidents," dated January 2017 (ADAMS Accession No. ML 17044A073).
10. Leeds, E. and Johnson, M., U.S. Nuclear Regulatory Commission, letter to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, NRC Order EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Effective Immediately}," dated March 12, 2012 (ADAMS Accession No. ML 12056A044).
11. U.S. Nuclear Regulatory Commission, Bulletin 2005-02, "Emergency Preparedness and Response Actions for Security-Based Events," dated July 18, 2005 (ADAMS Accession No. ML051740058).
12. U.S. Nuclear Regulatory Commission, Regulatory Issue Summary 2006-12, "Endorsement of Nuclear Energy Institute Guidance 'Enhancements to Emergency Preparedness Programs for Hostile Action,"'

dated July 19, 2006 (ADAMS Accession No. ML072670421

). Principal Contributor:

R. Hoffman, NSIR Date: November 2 8, 201 8

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT-ISSUANCE OF AMENDMENT NO. 323 RE: REVISION TO THE EMERGENCY ACTION LEVEL SCHEMES PURSUANT TO NEI 99-01, REVISION 6 (EPID L-2018-LLA-0032)

DATED NOVEMBER 28, 2018 DISTRIBUTION:

Public PM File Copy RidsACRS_MailCTR RidsNrrDorl RidsNrrOd RidsN rrDorl Lpl 1 RidsNrrDssSrxb RidsNrrDssStsb RidsNrrLALRonewicz RidsNrrPMFitzPatrick RidsRgn1 MailCenter RHoffman, NSIR MAbramovitz, NSIR RidsNsirDpr ADAMS A ccess1on N ML 18289A432

  • b f t o.: ,ysa e I f y eva ua 10n memo OFFICE NRR/DORL/LPL 1/PM NRR/DORL/LPL 1/LA NSIR/DPR/RLB/BC*

NAME BVenkataraman LRonewicz JAnderson DATE 10/16/2018 11/01/2018 09/13/2018 OFFICE NRR/DORL/LPL 1/BC NRR/DORL/D NRR/D NAME JDanna CErlanger HNieh (MEvans for) DATE 11/09/2018 11/16/2018 11/28/2018 OFFICIAL RECORD COPY **b *1 1y e-ma1 OGC-NLO**

AGhosh 10/31/2018 NRR/DORL/LPL 1/PM BVenkataraman 11/28/2018