Text

Issuance of Amendment Nos. 210, 210, and 210, to Revise Technical Specifications to Adopt Traveler TSTF-529, Revision 4,Clarify Use and Application
	ML19309F304
Person / Time
Site:	Palo Verde
Issue date:	12/18/2019
From:	Siva Lingam; Plant Licensing Branch IV
To:	Bement R; Arizona Public Service Co
	Lingam S, 301-415-1564
References
	EPID L-2018-LLA-0725
	Download: ML19309F304 (29)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 18, 2019 Mr. Robert S. Bement Executive Vice President Nuclear/

Chief Nuclear Officer Mail Station 7602 Arizona Public Service Company P.O. Box 52034 Phoenix, AZ 85072-2034

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 - ISSUANCE OF AMENDMENT NOS. 210, 210, and 210 TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE (TSTF) TRAVELER TSTF-529, REVISION 4, "CLARIFY USE AND APPLICATION RULES" (EPID L-2018-LLA-0725)

Dear Mr. Bement:

The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment Nos. 210, 210, and 210, to Renewed Facility Operating License Nos. NPF-41, NPF-51, and NPF-74 for the Palo Verde Nuclear Generating Station (Palo Verde), Units 1, 2, and 3, respectively. The amendments requested changes to the technical specifications (TSs) in response to your application dated December 27, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18361A845).

The amendments revise the TS requirements in Section 1.3, "Completion Times," and Section 3.0, "Limiting Condition for Operation (LCO) Applicability" and Section 3.0, "Surveillance Requirement (SR) Applicability." Specifically, these changes clarify and expand the use and application of the Palo Verde's TS usage rules and are consistent with NRG-approved Technical Specifications Task Force (TSTF) Traveler TSTF-529, Revision 4, "Clarify Use and Application Rules," dated February 29, 2016 (ADAMS Accession No. ML16062A271 ), which was approved by the NRC by letter dated April 21, 2016 (ADAMS Accession No. ML16060A441 ).

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

Sincerely,

~ eJ>* ~

Siva P. Lingam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-528, STN 50-529, and STN 50-530

Enclosures:

1. Amendment No. 210 to NPF-41

2. Amendment No. 210 to NPF-51

3. Amendment No. 210 to NPF-74

4. Safety Evaluation cc: Listserv

UNITED STATE~

NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555-0001 ARIZONA PUBLIC SERVICE COMPANY, ET AL.

DOCKET NO. STN 50-528 PALO VERDE NUCLEAR GENERATING STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 210 License No. NPF-41

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

A. The application for amendment by the Arizona Public Service Company (APS or the licensee) on behalf of itself and the Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, Los Angeles Department of Water and Power, and Southern California Public Power Authority (collectively, the licensees) dated December 27, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's 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, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Renewed Facility Operating License No. NPF-41 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 210, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed operating license. APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

3. This license amendment is effective as of the date of issuance and shall be implemented within 90 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

, ~B~~~~7 ** j Jennifer L. D1xon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. NPF-41 and Technical Specifications Date of Issuance: December 1 8, 2 o1 9

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ARIZONA PUBLIC SERVICE COMPANY, ET AL.

DOCKET NO. STN 50-529 PALO VERDE NUCLEAR GENERATING STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 210 License No. NPF-51

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

A The application for amendment by the Arizona Public Service Company (APS or the licensee) on behalf of itself and the Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, Los Angeles Department of Water and Power, and Southern California Public Power Authority (collectively, the licensees) dated December 27, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's 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 2

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Renewed Facility Operating License No. NPF-51 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 210, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed operating license. APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

3. This license amendment is effective as of the date of issuance and shall be implemented within 90 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION f--~Y~

Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. NPF-51 and Technical Specifications Date of Issuance: December 1 8, 2 O1 9

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ARIZONA PUBLIC SERVICE COMPANY, ET AL.

DOCKET NO. STN 50-530 PALO VERDE NUCLEAR GENERATING STATION, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 210 License No. NPF-74

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

A. The application for amendment by the Arizona Public Service Company (APS or the licensee) on behalf of itself and the Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, Los Angeles Department of Water and Power, and Southern California Public Power Authority (collectively, the licensees) dated December 27, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's 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 3

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Renewed Facility Operating License No. NPF-74 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 210, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed operating license. APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

3. This license amendment is effective as of the date of issuance and shall be implemented within 90 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

.~£)c1k>411 9 tJ u" Jennifer L. Dixon-Herrity, Chief

.I Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. NPF-74 and Technical Specifications Date of Issuance: December 1 8, 2 O1 9

ATTACHMENT TO LICENSE AMENDMENT NOS. 210,210, AND 210 TO RENEWED FACILITY OPERATING LICENSE NOS. NPF-41, NPF-51, AND NPF-74 PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530 Replace the following pages of the Renewed Facility Operating License Nos. NPF-41, NPF-51, and NPF-74, and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Renewed Facility Operating License No. NPF-41 REMOVE INSERT 5 5 Renewed Facility Operating License No. NPF-51 REMOVE INSERT 6 6 Renewed Facility Operating License No. NPF-74 REMOVE INSERT 4 4 Technical Specifications REMOVE INSERT 1.3-1 1.3-1 1.3-2 1.3-2 1.3-3 1.3-3 3.0-2 3.0-2 3.0-4 3.0-4

(1) Maximum Power Level Arizona Public Service Company (APS) is authorized to operate the facility at reactor core power levels not in excess of 3990 megawatts thermal (100% power), in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 210, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed operating license.

APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

(3) Antitrust Conditions This renewed operating license is subject to the antitrust conditions delineated in Appendix C to this renewed license.

(4) Operating Staff Experience Requirements Deleted (5) Post-Fuel-Loading Initial Test Program (Section 14. SER and SSER 2)*

Deleted

. (6) Environmental Qualification Deleted (7) Fire Protection Program APS shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility, as supplemented and amended, and as approved in the SER through Supplement 11, subject to the following provision:

APS may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Renewed Facility Operating License No. NPF-41 Amendment No. 210

( 1) Maximum Power Level Arizona Public Service Company (APS) is authorized to operate the facility at reactor core power levels not in excess of 3990 megawatts thermal (100% power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 210, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed operating license.

APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

(3) Antitrust Conditions This renewed operating license is subject to the antitrust conditions delineated in Appendix C to this renewed operating license.

(4) Operating Staff Experience Requirements (Section 13.1.2, SSER 9f Deleted (5) Initial Test Program (Section 14, SER and SSER 2)

Deleted (6) Fire Protection Program APS shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility, as supplemented and amended, and as approved in the SER through Supplement 11, subject to the following provision:

APS may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(7) lnservice Inspection Program (Sections 5.2.4 and 6.6, SER and SSER 9)

Deleted

The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Renewed Facility Operating License No. NPF-51 Amendment No. 210

(4) Pursuant to the Act and 10 CFR Part 30, 40, and 70, APS to receive, possess, and use in amounts required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, APS to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level Arizona Public Service Company {APS) is authorized to operate the facility at reactor core power levels not in excess of 3990 megawatts thermal (100% power), in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 210, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed operating license.

APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

(3) Antitrust Conditions This renewed operating license is subject to the antitrust conditions delineated in Appendix C to this renewed operating license.

(4) Initial Test Program (Section 14, SER and SSER 2)

Deleted (5) Additional Conditions The Additional Conditions contained in Appendix D, as revised through Amendment No. 209, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Additional Conditions.

Renewed Facility Operating License No. NPF-74 Amendment No. 210

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met.

Specified with each stated Condition are Required Action(s) and Completion Time(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time.

For example, LCO 3.8.1, "AC Sources - Operating," Required Action 8.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

(continued)

PALO VERDE UNITS 1,2,3 1.3-1 AMENDMENT NO. 447 210

Completion Times 1.3 1.3 Completion Times DESCRIPTION Required Actions must be completed prior to the expiration of the (continued) specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.

Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

However, when a subsequent train, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met.

The subsequent inoperability:

a. Must exist concurrent with the first inoperability; and

b. Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; or

b. The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

(continued)

PALO VERDE UNITS 1,2,3 1.3-2 AMENDMENT NO. 497 210

Completion Times 1.3 1.3 Completion Times (continued)

DESCRIPTION The above Completion Time extension does not apply to a (continued) Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ,"

where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery ... "

EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action and associated Completion Time not B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months met.

Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

The Required Actions of Condition B are to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . A total of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is allowed for reaching MODE 3 and a total of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (not 42 hours4.861111e-4 days 0.0117 hours 6.944444e-5 weeks 1.5981e-5 months ) is allowed for reaching MODE 5 from the time that Condition B was entered. If MODE 3 is reached within 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months , the time allowed for reaching MODE 5 is the next 33 hours3.819444e-4 days 0.00917 hours 5.456349e-5 weeks 1.25565e-5 months because the total time allowed for reaching MODE 5 is 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

If Condition B is entered while in MODE 3, the time allowed for reaching MODE 5 is the next 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

(continued)

PALO VERDE UNITS 1,2,3 1.3-3 AMENDMENT NO. 447 210 I

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 b. After performance of a risk assessment addressing (continued) inoperable systems and components, consideration of the results, detei'mtnation of the acceptability of entering the MOOE or other specified condition In the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated In the Individual Specifications); or *

c. When an allowance is stated In the Individual value, parameter, or other Specification.

This Specification shall not prevent changes In MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared Inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate Its OPERABILliY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY. -

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed rn accordance with Specification 5.5.15, "Safetr Function Determination Program (SFOP)." If a loss o safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO In which the loss of safety function exists are required to be entered.

(continued)

PALO VERDE UNITS 1,2,3 3.0-2 AMENDMENT NO . .ffii, 210

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMEN'f (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions In the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a SurveHlance. whether such failure Is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveftlance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. SurveHlances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR Is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per ..." basis, the above Frequency extension applies to each performance after the initial performance.

Exceetions to this Specification are stated in the individual Specifications.

SR 3.0.3 If It is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever Is greater. This delay period Is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when perfonned. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk Impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

(continued)

PALO VERDE UNITS 1,2,3 3 . 0-4 AMENDMENT NO. 444, 210

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 210,210, AND 210 TO RENEWED FACILITY OPERATING LICENSE NOS. NPF-41, NPF-51, AND NPF-74 ARIZONA PUBLIC SERVICE COMPANY, ET AL.

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530

1.0 INTRODUCTION

By application dated December 27, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18361A845), Arizona Public Service Company (the licensee) requested changes to the technical specifications (TSs) for Palo Verde Nuclear Generating Station (Palo Verde), Units 1, 2 and 3.

The amendments propose changes to the TS requirements in Section 1.3, "Completion Times,"

and Section 3.0, "Limiting Condition for Operation (LCO) Applicability" and Section 3.0, "Surveillance Requirement (SR) Applicability." Specifically, these changes clarify and expand the use and application of the Palo Verde's TS usage rules and are consistent with the U.S.

Nuclear Regulatory Commission (NRC)-approved Technical Specifications Task Force (TSTF) Traveler TSTF-529, Revision 4, "Clarify Use and Application Rules," dated February 29, 2016 (ADAMS Accession No. ML16062A271 ), which was approved by the NRC by letter dated April 21, 2016 (ADAMS Accession No. ML16060A441 ).

2.0 REGULATORY EVALUATION

2.1 Background Palo Verde TS Section 1.3, "Completion Times," currently describes completion times as follow:

The completion time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO. Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

Enclosure 4

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time of discovery of the situation that required entry into the Condition.

Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition.

LCO 3.0.1 through LCO 3.0.8 establish the general requirements applicable to all specifications and apply at all times, unless otherwise stated. Similarly, SR 3.0.1 through SR 3.0.4 establish the general requirements for surveillances that are applicable to all specifications and apply at all times, unless otherwise stated.

2.2 Description of TS Changes The proposed change will revise Palo Verde TS Section 1.3, "Completion Times," and Section 3.0, "Limiting Condition for Operation (LCO) Applicability" and Section 3.0, "Surveillance Requirement (SR) Applicability." The proposed changes are described in more detail below.

2.2.1 Proposed Changes to "Time of Discovery" Palo Verde TS Section 1.3, "Description," currently states, in part, the following (with emphasis added):

The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

Palo Verde TS Section 1.3, "Description," also currently states, in part, the following (with emphasis added on "time of'):

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time of discovery of the situation that required entry into the Condition.

The licensee's proposed changes to Palo Verde TS Section 1.3 would delete "time of' from the previous statements and read as follows:

The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

[... ]

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.

The adequacy of this change is discussed in Section 3.1.1.1 of this safety evaluation (SE).

2.2.2 Proposed Addition to "Completion Times" The licensee proposed to add the following paragraph to Palo Verde TS Section 1.3 of the TSs under

Description:

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered.

The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action B.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

This change is evaluated in Section 3.1.1.2 of this SE.

2.2.3 Proposed Addition of "Unless Otherwise Specified" Palo Verde TS Section 1.3, "Description," currently states the following (with emphasis added):

The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS

Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

The licensee proposed to add a new second paragraph starting with the following sentence to Palo Verde TS Section 1.3 under

Description:

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered.

In addition, the licensee proposed adding the phrase "unless otherwise specified" to the following two statements to Palo Verde TS Section 1.3 (with emphasis added):

When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.

and The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

This change is evaluated in Section 3.1.1.3 of this SE.

2.2.4 Proposed Changes to LCO 3.0.4 Palo Verde TS LCO 3.0.4 currently states, in part:

When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c. When an allowance is stated in the individual value, parameter, or other Specification.

The licensee proposed to clarify LCO 3.0.4.b. by placing the statement regarding exceptions in parenthesis and replacing the last comma with a semicolon. The proposed TS LCO 3.0.4 would state, in part, the following:

When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This change is evaluated in Section 3.1.2 of this SE.

2.2.5 Proposed Changes to TS SR 3.0.3 Palo Verde SR 3.0.3 currently states the following:

If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

The licensee proposed to add the underlined language to Palo Verde SR 3.0.3:

If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed.

A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

This change is evaluated in Section 3.1.3 of this SE.

2.3 Regulatory Requirements, Licensing Information, Guidance Documents The NRC staff considered the following regulatory requirements, guidance, and licensing information during its review of the proposed changes:

Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(c) requires TSs to include the categories of LCOs and SRs.

Paragraph 50.36(c)(2) of 10 CFR states that "Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met. When a limiting condition for operation of any process step in the system of a fuel reprocessing plant is not met, the licensee shall shut down that part of the operation or follow any remedial action permitted by the technical specifications until the condition can be met."

Paragraph 50.36(c)(3) of 10 CFR states 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 NRC staff's guidance for review of the TSs is in NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition," Chapter 16, Revision 3, "Technical Specifications," dated March 2010 (ADAMS Accession No. ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared standard technical specifications (STSs) (NUREG-1430 to NUREG-1434, ADAMS Accession Nos.

ML12100A177, ML12100A222, ML12102A165, ML12104A192 and ML12104A195, respectively) for each of the light-water reactor nuclear steam supply systems and associated balance-of-plant equipment systems. Accordingly, the NRC staff's review includes consideration of whether the proposed TSs are consistent with the current STS in NUREG-1432, "Standard Technical Specifications Combustion Engineering Plants,"

. as modified by NRG-approved TSTF Travelers such as TSTF-529, Revision 4. Special attention is given to TS provisions that depart from the reference technical specifications and NRG-approved TSTF Travelers to determine whether proposed differences are justified by uniqueness in plant design or other considerations so that 10 CFR 50.36 is

met. In addition, the guidance states that comparing the change to previous STSs can help clarify the TS intent.

3.0 TECHNICAL EVALUATION

During the review of TSTF-529, Revision 4, the NRC staff considered the guidance on the regulatory requirements described in Section 2.3 of this SE. Additionally, the NRC staff evaluated the proposed changes to the Palo Verde TSs against what is required to be in the TSs under 10 CFR 50.36.

3.1 Requested Changes 3.1.1 Proposed Changes to Section 1.3, "Completion Times" 3.1.1.1 Proposed Changes to "Time of Discovery" The only mention of the term "time of discovery" in relation to completion times is in Palo Verde TS Section 1.3 (quoted in Section 2.2.1 of this SE). Throughout the Palo Verde TSs, the term "discovery" is used to describe the point in time that it is recognized that the requirements of an LCO are not met. For example, TS LCO 3.0.2 states in part that "Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6."

The proposed change to Palo Verde TS Section 1.3 would delete "time of' from the previous statements. The NRC staff finds the proposed change acceptable because it makes Section 1.3 consistent with the language used throughout the rest of the TSs. The change is editorial and has no effect on the requirements currently in the TSs. Therefore, the NRC staff finds the proposed change acceptable.

3.1.1.2 Proposed Addition to "Completion Times" The licensee also proposed to add the following paragraph to Section 1.3 of the Palo Verde's TS under

Description:

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered.

The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action 8.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

The operating shift crew is responsible for overall control of facility operation. As part of that responsibility, the operating shift crew must be aware of the status of the plant and condition of structures, systems and components. This includes status of degraded or nonconforming conditions that may affect plant operation. The phrase "and an ACTIONS Condition is entered" in the above proposed insertion, is necessary to accommodate circumstances in which LCO 3.0.6 allows an LCO to not be met without entry into the Conditions. In those circumstances, a completion time does not begin. In addition, an example is added to the proposed insertion in order to explain the concept presented.

The NRC staff finds the proposed change acceptable since it clarifies senior reactor operators' responsibilities and the allowances of LCO 3.0.6, and therefore, provides a consistent application of the Palo Verde TS required actions and associated completion times.

3.1.1.3 Proposed Addition of "Unless Otherwise Specified" The phrase, "unless otherwise specified," in Palo Verde TS Section 1.3, refers to those instances in which TS LCOs define the start of the completion time as different from "discovery."

For example, Palo Verde TS 3.8.1, "AC Sources - Operating," Required Action 8.2, requires declaring the required feature(s) supported by the inoperable diesel generator inoperable when its redundant required feature(s) are inoperable. The completion time states, "4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case, the completion time does not begin until the conditions in the completion time are satisfied.

As discussed in Section 2.2.3 of this SE, the licensee proposed to add a new second paragraph starting with the following sentence to Palo Verde TS Section 1.3 under Description (with emphasis added):

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered.

In addition, the licensee proposed adding the phrase "unless otherwise specified" to the following two statements in Palo Verde TS Section 1.3 (with emphasis added):

When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.

and The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

The addition of the phrase "unless otherwise specified" acknowledges that there are instances, as indicated in the individual TSs, when the completion time does not start at discovery. These exceptions are varied, such as when a required action note, or SR note provides an alternative time to perform specific tasks, such as testing, without starting the completion time. While utilizing the note, should a condition be applicable for any reason not addressed by the note, the

completion time begins. Should the time allowance in the note be exceeded, the completion time begins at that point as well.

The NRC staff finds the proposed changes acceptable since it clarifies that there are exceptions, and, therefore, provides a consistent application of the Palo Verde TS required actions and associated completion times.

3.1.2 Proposed Changes to LCO 3.0.4 As stated in Section 2.2.4 of this SE, the current Palo Verde TS LCO 3.0.4 contains three options, (LCO 3.0.4.a, b, and c). LCO 3.0.4.a ends with a semicolon and LCO 3.0.4.b ends with a comma followed by the word "or."

LCO 3.0.4.b statement: "After performance of a risk assessment ... stated in the individual Specifications, or," could lead to operator misinterpretation. Operators could misapply this statement by believing the "or" applies to the phrase regarding exceptions and that LCO 3.0.4.a, b, and c apply concurrently.

The licensee proposed to clarify this sentence by placing the statement regarding exceptions in parenthesis, deleting the semicolon after the word "appropriate," and replacing the ending comma with a semicolon. The proposed TS LCO 3.0.4.b would state the following: "After performance of a risk assessment ... if appropriate (exceptions to this Specification are stated in the individual Specifications); or."

The NRC staff finds that the change is editorial since it does not change the requirements currently in the TSs. The NRC staff finds the proposed change is acceptable since it removes potential for misapplication of LCO 3.0.4 allowances, and therefore, provides a consistent application of the Palo Verde TS required actions.

3.1.3 Proposed Changes to SR 3.0.3 The NRC staff has typically interpreted SR 3.0.3, which is quoted in Section 2.2.5 of this SE, as inapplicable to SRs that have never been performed (e.g. never performed the SRs or not adequately performed the SRs). This is because the allowance provided by SR 3.0.3 is based on the fact that the SR was satisfactorily met in the past and the most probable result of performing the SR is the verification of conformance with the requirements. Therefore, there is reasonable expectation the SR will be met when performed.

However, the NRC staff recognizes that there are instances in which an SR may not have been performed in the past, but the licensees may have a reasonable expectation the SR will be met when performed. For example, an SR requires testing of a relay contact. A licensee identifies that the relay contact has never been tested as required in accordance with a particular SR.

The licensee, however, concludes there is a reasonable expectation the SR will be met when performed because the subject relay contact has been tested by another SR or historical operation of the subject relay contact has been successful.

The delay period allowed by Palo Verde SR 3.0.3 offers adequate time to complete SRs that have been missed. In addition, this delay period permits the completion of an SR before complying with required actions or other remedial measures that might preclude completion of the SR. The NRC staff finds the application of the delay period allowed by Palo Verde SR 3.0.3

acceptable for use on SRs that have never been performed as long as licensees can provide an adequate determination of reasonable expectation the SR will be met when performed.

The licensee's proposed changes to Palo Verde SR 3.0.3, states the following (the new sentence reflecting the inclusion of SRs that have never been performed is underlined):

If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

Additionally, for the NRC's information, the licensee provided revisions to the TS Bases. These revisions included, in part, language, consistent with TSTF-529, Revision 4 (ADAMS Accession No. ML16060A440), -regarding SR 3.0.3 that explains how the licensee will determine that there is a reasonable expectation that a SR will be met. Notably, there should be consideration of factors such as the period of time since the surveillance was last performed, or whether the surveillance, or a portion thereof, has ever been performed, and any other indications, tests, or activities that might support the expectation that the surveillance will be met when performed.

Also, the TS Bases indicated that a rigorous evaluation for surveillances that have not been performed for a long period or that have never been performed, should be documented in sufficient detail and provide a high degree of confidence that the equipment is operable.

The proposed change, which expands the scope of Palo Verde TS SR 3.0.3 to SRs that have never been performed, is acceptable because it requires the licensee to have a reasonable expectation the SR will be met when performed. The proposed change is also consistent with plant safety since it could prevent unnecessary shutdowns by providing adequate time to complete SRs that have never been performed, but are likely to achieve satisfactory results. In addition, although the TS Bases are not part of the license, the TS Bases explanation of the "reasonable expectation" determination will be subject to control by the TS Bases Control Program required by TS 5.5.14. Therefore, the staff finds the change meets the 10 CFR 50.36(c)(3) requirement relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, the facility operation will be within safety limits, and that LCOs will be met.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Arizona State official was notified of the proposed issuance of the amendment on October 31, 2019. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and changes SRs. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, published in the Federal Register on February 12, 2019 (84 FR 3506), and there has been no public comment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b ), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: C. Tilton, NRR Date: December 18, 2019

ML19309F304 *b e-mail OFFICE NRR/DORULPL4/PM N RR/DORULPL4/LA NRR/DSS/STSB/BC

OGG (NLO)*

NAME Slingam PBlechman VCusumano MWoods DATE 11/12/19 11/12/19 11/5/19 12/18/19 OFFICE NRR/DORULPL4/BC NRR/DORULPL4/PM NAME JDixon-Herrity Slingam DATE 12/18/19 12/18/19

v t e Letter Sequence Approval
EPID:L-2018-LLA-0725, TSTF-529 (Approved, Closed)
Initiation Request Acceptance Administration Questions Answers Results Approval, Approval Other:
MONTHYEAR2019-01-25 [Table View]

ML19309F304

Text

SUBJECT:

Dear Mr. Bement:

Enclosures:

Attachment:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

Description:

Description:

3.0 TECHNICAL EVALUATION

Description:

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

Navigation menu

Search