ML19337D035
| ML19337D035 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/28/2020 |
| From: | Marshall M Plant Licensing Branch 1 |
| To: | Bryan Hanson Exelon Generation Co |
| Marshall M, NRR/DORL/LPLI, 415-2871 | |
| References | |
| EPID L-2019-LLA-0102 | |
| Download: ML19337D035 (26) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 28, 2020 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:
CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 333 AND 311 RE: DELETION OF E-BAR DEFINITION AND REVISION TO REACTOR COOLANT SYSTEM SPECIFIC ACTIVITY TECHNICAL SPECIFICATIONS (EPID L-2019-LLA-0102)
Dear Mr. Hanson:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 333 to Renewed Facility Operating License No. DPR-53 and Amendment No. 311 to Renewed Facility Operating License No. DPR-69 for the Calvert Cliffs Nuclear Power Plant, Units 1 and 2. These amendments consist of changes to the technical specifications (TSs) in response to your application dated May 6, 2019 (Agencywide Documents Access and Management System Accession No. ML19127A076).
These amendments revise TS requirements relating to reactor coolant system activity limits.
Specifically, the TS limits on reactor coolant system gross specific activity are based on a new dose equivalent xenon -133 definition that replaces the current E-Bar average disintegration energy definition, and the dose equivalent iodine -131 definition is revised to allow the use of committed effective dose equivalent dose conversion factors.
A copy of our related safety evaluation is enclosed. Notice of issuance will be included in the Commission's biweekly Federal Register notice.
Docket Nos. 50-317 and 50-318
Enclosures:
- 1. Amendment No. 333 to DPR-53
- 2. Amendment No. 311 to DPR-69
- 3. Safety Evaluation cc: Listserv Michael L. Marshall, Jr., Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, 0.C. 20555-0001 EXELON GENERATION COMPANY. LLC DOCKET NO. 50-317 CALVERT CLIFFS NUCLEAR POWER PLANT. UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 333 Renewed License No. DPR-53
- 1.
The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Exelon Generation Company, LLC (Exelon, the licensee) dated May 6, 2019, 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 1 O 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 1 O CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.2. of Renewed Facility Operating License No. DPR-53 is hereby amended to read as follows:
- 2.
Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 333, are hereby incorporated into this license. Exelon Generation shall operate the facility in accordance with the Technical Specifications.
- 3.
This license amendment is effective as of the date of its issuance and shall be implemented within 90 days.
Attachment:
Changes to the Renewed Facility Operating License and Technical Specifications FOR THE NUCLEAR REGULATORY COMMISSION L}cw~~
JameS{'. G. Danna, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance:
February 2 8, 2 o 2 o
ATTACHMENT TO LICENSE AMENDMENT NO. 333 CALVERT CLIFFS NUCLEAR POWER PLANT. UNIT 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-53 DOCKET NO. 50-317 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.
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Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Pages 1.1-2 1.1-3 3.4.15-1 3.4.15-2 3.4.15-3 3.4.15-4 Insert Pages 1.1-2 1.1-3 3.4.15-1 3.4.15-2 3.4.15-3 (4)
Exelon Generation pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use, in amounts as required, any byproduct, source, and 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)
Exelon Generation pursuant to the Act and 10 CFR Parts 30 and 70 to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C.
This license is deemed to contain and is subject to the conditions set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act, and the rules, regulations, and orders of the Commission, now or hereafter applicable; and is subject to the additional conditions specified and incorporated below:
(1)
(2)
Maximum Power Level Exelon Generation is authorized to operate the facility at steady-state reactor core power levels not in excess of 2737 megawatts-thermal in accordance with the conditions specified herein.
Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 333, are hereby incorporated into this license. Exelon Generation shall operate the facility in accordance with the Technical Specifications.
(a)
For Surveillance Requirements (SRs) that are new, in Amendment 227 to Facility Operating License No. DPR-53, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 227. For SRs that existed prior to Amendment 227, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the Surveillance was last performed prior to implementation of Amendment 227.
(3)
Additional Conditions The Additional Conditions contained in Appendix C as revised through Amendment No. 327 are hereby incorporated into this license. Exelon Generation shall operate the facility in accordance with the Additional Conditions.
(4)
Secondary Water Chemistry Monitoring Program Exelon Generation shall implement a secondary water chemistry monitoring program to inhibit steam generator tube degradation. This program shall include:
Amendment No. 333
1.1 Definitions CHANNEL FUNCTIONAL TEST CORE OPERATING LIMITS REPORT {COLR)
DOSE EQUIVALENT I-131 CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 Definitions 1.1 indication and status to other indications or status derived from independent instrument channels measuring the same parameter.
A CHANNEL FUNCT!ONAL TEST shall be:
Analog Channels - the injection of a simulated signal into the channel as close to the primary sensor as practicable to verify OPERABILITY of all devices in the channel required for channel OPERABILITY.
Bistable Channels - the injection of a simulated signal into the channel sensor to verify OPERABILITY of all devices in the channel required, for channel OPERABILITY.
The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping or total channel steps.
The COLR is the unit specific document that provides cycle specific parameter limits for the current reload cycle. These cycle specific parameter limits shall be determined for each reload cycle in accordance with Specification 5.6.5.
Plant operation within these limits is addressed in individual Specifications.
DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries per gram) that alone would produce the same dose when inhaled as the combined activities of iodine isotopes of I-131, I-132, I-33, I-134, and I-135 actually present. The determination DOSE EQUIVALENT I-131 shall be performed using Committed Effective Dose Equivalent {CEDE) dose conversion factors from Table 2.1 of EPA Federal Guidance Report No. 11.
1.1-2 Amendment No. 333 Amendment No. 311
1.1 Definitions DOSE EQUIVALENT XE-133 ENGINEERED SAFETY FEATURE (ESF) RESPONSE TIME INSERVICE TESTING PROGRAM La CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 Definitions 1.1 DOSE EQUIVALENT XE-133 shall be that concentration of Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-85, Kr-87, Kr-88, Xe-131m, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138 actually present. If a specific noble gas nuclide is not detected, it should be assumed to be present at the minimum detectable activity. The determination of DOSE EQUIVALENT XE-133 shall be performed using effective dose conversion factors for air submersion listed in Table III.1 of EPA Federal Guidance Report No. 12, 1993, "External Exposure to Radionuclides in Air, Water, and Soil."
The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable.
The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.
In lieu of measurement, response time may be.verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.
The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.SSa(f).
The maximum allowable containment leakage rate, La, shall be 0.16% of containment air weight per day at the calculated peak containment pressure (Pa).
1.1-3 Amendment No. 333 Amendment No. 311
3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.15 RCS Specific Activity CS Specific Activity 3.4.15 LCO 3.4.15 RCS DOSE EQUIVALENT I-131 and DOSE EQUIVALENT XE-133 specific activity shall be within limits.
APPLICABILITY: MODES 1, 2, 3, and 4 ACTIONS CONDITION A.
DOSE EQUIVALENT I-131
> 0.5 µCi/gm.
CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 REQUIRED ACTION
NOTE-----------
LCO 3.0.4.c is applicable.
A.1 A.2 Verify DOSE EQUIVALENT I-131
- 30 µCi/gm.
Restore DOSE EQUIVALENT I-131 to within limit.
3.4.15-1 COMPLETION TIME Once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 48 hours Amendment No. 333 Amendment No. 311
ACTIONS (continued)
CONDITION REQUIRED ACTION
-- --- - -----NOTE- -- --- - ----
B.
DOSE EQUIVALENT LCO 3.0.4.c is applicable.
XE-133 > 630 µcl/gm.
B.l Restore DOSE EQUIVALENT XE-133 to within limit.
C.
Required Action and C.l Be in MODE 3 associated Completion Time of Condition A or B not met.
QR AND DOSE EQUIVALENT I -131 C.2 Be in MODE 5
> 30 µcl/gm.
SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.4.15.1 Verify reactor coolant DOSE EQUIVALENT XE-133 specific activity~ 630 µCi/gm.
CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 3.4.15-2 CS Specific Activity 3.4.15 COMPLETION TIME 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> 6 hours 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 333 Amendment No. 311
SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE cs Specific Activity 3.4.15 FREQUENCY SR 3.4.15.2 Verify reactor coolant DOSE EQUIVALENT I-131 In accordance specific activity~ 0.5 µCi/gm.
with the Surveillance Frequency Control Program SR 3.4.15.3 Deleted CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 3.4.15-3 Between 2 and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after THERMAL POWER change of
~ 15% RTP within a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period Amendment No. 333 Amendment No. 311
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 EXELON GENERATION COMPANY, LLC DOCKET NO. 50-318 CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 311 Renewed License No. DPR-69
- 1.
The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Exelon Generation Company, LLC (Exelon, the licensee) dated May 6, 2019, 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.
- 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. DPR-69 is hereby amended to read as follows:
- 2.
Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 311, are hereby incorporated into this license. The licensee shall operate the facility in accordance with the Technical Specifications.
- 3.
This license amendment is effective as of the date of its issuance and shall be implemented within 90 days.
Attachment:
Changes to the Renewed Facility Operating License and Technical Specifications FOR THE NUCLEAR REGULATORY COMMISSION
("-\\
C)evv'V~
Jamk G. Danna, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance:
February 28, 2020
ATTACHMENT TO LICENSE AMENDMENT NO. 311 CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT 2 RENEWED FACILITY OPERATING LICENSE NO. DPR-69 DOCKET NO. 50-318 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.
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Calvert Cliffs Nuclear Power Plant, Unit 2, uses the same Appendix A as Calvert Cliffs Nuclear Power Plant, Unit 1. Accordingly, the Unit 1 Renewed Facility Operating License has been updated with the following pages, which are applicable to both Units 1 and 2.
Remove Pages 1.1-2 1.1-3 3.4.15-1 3.4.15-2 3.4.15-3 3.4.15-4 Insert Pages 1.1-2 1.1-3 3.4.15-1 3.4.15-2 3.4.15-3 (4)
Exelon Generation pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use, in amounts as required, any byproduct, source, and 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)
Exelon Generation pursuant to the Act and 10 CFR Parts 30 and 70 to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C.
This license is deemed to contain and is subject to the conditions set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act, and the rules, regulations, and orders of the Commission, now or hereafter applicable; and is subject to the additional conditions specified and incorporated below:
(1)
Maximum Power Level Exelon Generation is authorized to operate the facility at steady-state reactor core power levels not in excess of 2737 megawatts-thermal in accordance with the conditions specified herein.
(2)
Technical Specifications (3)
(4)
The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 311, are hereby incorporated into this license. The licensee shall operate the facility in accordance with the Technical Specifications.
(a)
For Surveillance Requirements (SRs) that are new, in Amendment 201 to Facility Operating License No. DPR-69, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 201. For SRs that existed prior to Amendment 201, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the Surveillance was last performed prior to implementation of Amendment 201.
Less Than Four Pump Operation The licensee shall not operate the reactor at power levels in excess of five (5) percent of rated thermal power with less than four (4) reactor coolant pumps in operation. This condition shall remain in effect until the licensee has submitted safety analyses for less than four pump operation, and approval for such operation has been granted by the Commission by amendment of this license.
Environmental Monitoring Program If harmful effects or evidence of irreversible damage are detected by the biological monitoring program, hydrological monitoring program, and the Amendment No. 311
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 333 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-53 AMENDMENT NO. 311 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-69 EXELON GENERATION COMPANY, LLC CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-317 AND 50-318
1.0 INTRODUCTION
By application dated May 6, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19127A076), Exelon Generation Company, LLC (the licensee) submitted a license amendment request to change the Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (Calvert Cliffs), Technical Specifications (TSs).
The proposed changes would revise TS requirements relating to reactor coolant system (RCS) activity limits. The changes are based upon Technical Specifications Task Force (TSTF)
Traveler 490 (TSTF-490), Revision 0, "Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec," dated September 13, 2005 (ADAMS Accession No. ML052630462). The changes would replace the current TS limits on RCS gross specific activity with a new limit on RCS noble gas specific activity. The noble gas specific activity limit would be based on a new dose equivalent xenon (Xe)-133 (DEX) definition that replaces the current E-Bar (E) average disintegration energy definition. The current dose equivalent iodine (1)-131 (DEi) definition would be revised to allow the use of committed effective dose equivalent (CEDE) dose conversion factors (DCFs ).
By letter dated September 13, 2005 (ADAMS Accession No. ML052630462), the TSTF submitted TSTF-490 for U.S. Nuclear Regulatory Commission (NRC or the Commission) staff review. The notice of availability for TSTF-490 was published in the Federal Register on March 19, 2007 (72 FR 12838), signifying NRC approval of TSTF-490.
2.0 REGULATORY EVALUATION
The NRC staff evaluated the impact of the proposed changes as they relate to the radiological consequences of affected design-basis accidents (DBAs) that use the RCS inventory as the source term. The source term assumed in radiological analyses should be based on the activity associated with either the projected fuel damage or the maximum RCS TS values, whichever maximizes the radiological consequences. The limits on RCS specific activity ensure that the offsite doses are appropriately limited for accidents that are based on releases from the RCS with no significant amount of fuel damage.
The steam generator tube rupture (SGTR) accident typically does not result in fuel damage; therefore, the radiological consequence analyses are generally based on the release of primary coolant activity at maximum TS limits. For accidents that result in fuel damage, the additional dose contribution from the initial activity in the RCS is not normally evaluated and is considered to be insignificant in relation to the dose consequence resulting from the release of fission products from the damaged fuel.
For licensees using the alternative source term (AST) in their dose consequence analyses, the NRC staff uses the regulatory guidance provided in NUREG-0800, Revision 0, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition" (SRP), Section 15.0.1, "Radiological Consequence Analyses Using Alternative Source Terms,"
dated July 2000 (ADAMS Accession No. ML003734190), and the methodology and assumptions stated in Regulatory Guide (RG) 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," dated July 2000 (ADAMS Accession No. ML003716792). Licensees using the AST are evaluated against the dose criteria specified in Title 10 of the Code of Federal Regulations ( 10 CFR) Section 50.67, "Accident source term."
The NRC staff's evaluation is based upon the following regulations, RGs, and standards:
10 CFR 50.36(a)(1 ), which requires an applicant for an operating license to include in the application proposed TSs in accordance with the requirements of 10 CFR 50.36 and include a "summary statement of the bases or reasons for such specifications, other than those covering administrative controls." However, per 10 CFR 50.36(a)(1 ), these TS bases "shall not become part of the technical specifications."
10 CFR 50.36(b ), which requires that each license authorizing reactor operation include TSs derived from the analyses and evaluation included in the safety analysis report and amendments thereto.
10 CFR 50.36(c), which requires that TS include certain items. Per 10 CFR 50.36(c)(2)(i),
the TSs must include limiting conditions for operation (LCOs), which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. That provision also requires that when an LCO of a nuclear reactor is not met, the licensee must shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met.
10 CFR 50.36(c)(3), which requires that TSs include surveillance requirements (SRs),
which 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 LCOs will be met.
10 CFR 50.67, which states that any licensee that was initially authorized to operate prior to January 10, 1997, and who seeks to revise its current accident source term in its design-basis radiological consequence analyses, must apply for a license amendment under 10 CFR 50.90.
The regulation in 10 CFR 50.67(b)(2) states that the NRC may issue the amendment only if the applicant's analysis demonstrates with reasonable assurance that:
(i)
An individual located at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release, would not receive a radiation dose in excess of 0.25 Sv (25 rem) total effective dose equivalent (TEDE).
(ii)
An individual located at any point on the outer boundary of the low population zone, who is exposed to the radioactive cloud resulting from the postulated fission product release (during the entire period of its passage), would not receive a radiation dose in excess of 0.25 Sv (25 rem) total effective dose equivalent (TEDE).
(iii)
Adequate radiation protection is provided to permit access to and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 0.05 Sv (5 rem) total effective dose equivalent (TEDE) for the duration of the accident.
RG 1.183, which provides guidance to licensees on performing evaluations and re-analyses in support of the implementation of an alternative source term.
NUREG-0800, SRP Section 15.0.1, which provides guidance for an application for the initial implementation of an alternative source term at operating power reactors and subsequent license amendment requests from these plants.
The NRC staffs guidance for review of TSs in Section 16, "Technical Specifications," of NUREG-0800, Revision 3, dated March 2010.
The NRC staff also considered relevant information in the Calvert Cliffs Updated Final Safety Analysis Report, which describes the DBAs and evaluation of their radiological consequences.
3.0 TECHNICAL EVALUATION
The NRC staff evaluated the licensee's application to determine if the proposed changes are consistent with the guidance, regulations, and licensing information discussed in Section 2.0 of this safety evaluation and TSTF-490, Revision 0. In determining whether an amendment to a license will be issued, the Commission is guided by the considerations that govern the issuance of initial licenses to the extent applicable and appropriate. In making its determination as to whether to amend the license, the NRC staff considered those regulatory requirements that are automatically conditions of the license through 10 CFR 50.54.
The regulation at 10 CFR 50.36(a)(1) states, in part: "A summary statement of the bases or reasons for such specifications... shall also be included in the application but shaJI not become part of the technical specifications." Accordingly, along with the proposed TS changes, the licensee also submitted proposed TS Bases changes that correspond to the proposed TS changes for information only.
3.1 TSTF-490 Background The primary coolant specific activity level is used in DBA analyses to determine the radiological consequences of accidents that involve the release of primary coolant activity with no substantial amount of.fuel damage. For events that also include significant amounts of fuel damage, the contribution from the initial activity in the primary coolant is considered insignificant and is not normally evaluated.
The maximum allowable primary coolant specific activity is governed by TSs. Due to the importance of iodine in the dose consequence analyses, a separate limit is specified for the iodine isotopes. This limit is specified in units of DEi, which is the normalized quantity of 1-131 that would result in the same dose consequence as the combination of the major isotopes of iodine present in the primary coolant. The TSs for DEi include both an equilibrium long-term limit, as well as a higher maximum allowable short-term limit, to account for iodine spiking.
The Calvert Cliffs TSs definition of DEi is based on thyroid DCFs. The numerical determination of DEi is dependent on the relative quantities of the isotopes of iodine present in the RCS and on the DCFs used in the calculation. The TS definition of DEi lists the acceptable source for the thyroid DCFs to be used in the determination of DEi. The DCFs used in the determination of DEi are consistent with the DCFs used in the dose consequence analyses.
For plants implementing an AST methodology pursuant to 10 CFR 50.67, thyroid and whole-body doses are not reported. Instead, doses are reported as TEDE. TEDE is defined as the summation of the CEDE from inhalation and the deep dose equivalent from external exposure. RG 8.40, "Methods for Measuring Effective Dose Equivalent from External Exposure," dated July 2010 (ADAMS Accession No. ML100610534), states that licensees are encouraged to use the effective dose equivalent (EDE) in place of the deep dose equivalent in situations in which doses are calculated rather than measured with personnel dosimetry.
Therefore, in dose consequence analyses using the AST, the appropriate definition for TEDE would be the summation of the CEDE and the EDE. The EDE is equivalent to the whole-body dose that is calculated for plants using Technical Information Document (TID)-14844,
- U.S. Atomic Energy Commission (AEC), "Calculation of Distance Factors for Power and Test Reactor Sites," dated March 23, 1962 (ADAMS Accession No. ML021720780), in their dose consequence analysis. RG 1.195, "Methods and Assumptions for Evaluating Radiological Consequences of Design Basis Accidents at Light-Water Nuclear Power Reactors" (ADAMS Accession No. ML031490640), Subsection 4.1, assumption 4.1.4, states that whole-body doses should be calculated assuming submergence in a semi-infinite cloud with appropriate credit for attenuation by body tissue. Table 111.1 of the U.S. Environmental Protection Agency (EPA)
"Federal Guidance Report No. 12: External Exposure to Radionuclides in Air, Water, and Soil" (FGR) provides external DCFs acceptable to the NRC staff. The factors in the column headed "effective" yield doses correspond to the whole-body dose. The use of effective DCFs as a surrogate for whole-body DCFs is appropriate because of the uniform body exposure associated with semi-infinite cloud dose modeling.
It is appropriate for those plants using the AST methodology to use a definition of DEi based on the CEDE DCFs instead of thyroid DCFs. During Calvert Cliffs' conversion to the AST they included a revision to their TS definition of DEi so that it references the TEDE inhalation DCFs from U.S. EPA "Federal Guidance Report No. 11: Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion."
A second limit is used to govern the non-iodine radioisotopes in the RCS. This limit has traditionally been based on an evaluation of the average beta and gamma disintegration energy of the total non-iodine activity in the RCS, which is referred to as E. The Calvert Cliffs TSs define E as the average sum of the beta and gamma energies in mega electron volts per disintegration for isotopes, other than iodines, with half-lives greater than 15 minutes, making up at least 95 percent of the total non-iodine activity in the coolant. The RCS non-iodine specific activity limit is then expressed as the quantity 100 divided by E in units of micro curies per gram
(µCi/gm). In OBA dose consequence analyses, based on releases from the RCS with no significant fuel damage, the concentration of noble gas activity in the coolant is derived from that level associated with 1 percent fuel clad defects. Operating experience has indicated that depending on the isotopes used to calculate E and the actual degree of fuel clad defects, the routinely calculated value of E may not be an effective indicator of the level of noble gas activity relative to the levels used in the OBA dose consequence analyses on which the limit is based.
3.2 Technical Evaluation of TSTF-490 TS Changes 3.2.1 Revision to the Definition of DEi The list of acceptable DCFs for use in the determination of DEi includes the following:
Table Ill of TID-14844, AEC, 1962, "Calculation of Distance Factors for Power and Test Reactor Sites."
Table E-7 of RG 1.109, Revision 1, dated 1977.
International Commission of Radiological Protection (ICRP) 30, 1979, pages 192-212, table titled "Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity."
Committed dose equivalent or CEDE dose conversion factors from Table 2.1 of EPA Federal Guidance Report No. 11.
Table 2.1 of EPA FGR No. 11, 1988, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion."
The licensee proposes to use the CEDE DCFs from Table 2.1 of EPA FGR No. 11 to determine DEi such that Calvert Cliffs TS 1.1 definition of "DOSE EQUIVALENT 1-131" will state:
DOSE EQUIVALENT 1-131 shall be that concentration of 1-131 (microcuries per gram) that alone would produce the same dose when inhaled as the combined activities of iodine isotopes 1-131, 1-132, 1-133, 1-134, and 1-135 actually present.
The determination DOSE EQUIVALENT 1-131 shall be performed using Committed Effective Dose Equivalent (CEDE) dose conversion factors from Table 2.1 of EPA Federal Guidance Report No. 11.
The proposed change updates DEi so that it will result in an LCO that more closely relates the iodine RCS activity limits to the dose consequence analyses that form their bases. The NRC staff finds the change to be acceptable from a radiological dose perspective.
3.2.2 Deletion of the Definition of E and the Addition of a New Definition for DEX The new definition for DEX is similar to the definition for DEi. The determination of DEX will be performed in a similar manner to that currently used in determining DEi, except that the calculation of DEX is based on the acute dose to the whole body and considers the noble gases krypton (Kr)-85m, Kr-85, Kr-87, Kr-88, Xe-131m, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138, which are significant in terms of contribution to whole-body dose. Some noble gas isotopes are not included due to low concentration, short half-life, or small DCF. The calculation of DEX would use either the average gamma disintegration energies for the nuclides or the effective dose conversion factors from Table 111.1 of EPA FGR No. 12. Using this approach, the limit on the amount of noble gas activity in the primary coolant would not fluctuate with variations in the calculated values of I::. If a specified noble gas nuclide is not detected, the new definition states that it should be assumed that the nuclide is present at the minimum detectable activity. This will result in a conservative calculation of DEX.
When E is determined using a design-basis approach in which it is assumed that 1.0 percent of the power is being generated by fuel rods having cladding defects, and it is also assumed that there is no removal of fission gases from the letdown flow, the value of I:: is dominated by Xe-133. The other nuclides have relatively small contributions. However, during normal plant operation, there are typically only a small amount of fuel clad defects, and the radioactive nuclide inventory can become dominated by tritium and corrosion and/or activation products, resulting in the determination of a value of I:: that is very different than would be calculated using the design-basis approach. Because of this difference, the accident dose analyses become disconnected from plant operation, and the LCO becomes essentially meaningless. This difference also results in a TS limit that can vary during operation as different values for I:: are determined.
This proposed change will implement an LCO that is consistent with the whole-body radiological consequence analyses that are sensitive to the noble gas activity in the primary coolant but not to other non-gaseous activity currently captured in the E definition. TS LCO 3.4.15 specifies the limit for reactor coolant gross activity of the RCS as 100/E µCi/gm. The current I:: definition includes radioisotopes that decay by the emission of both gamma and beta radiation. The current Condition C of TS LCO 3.4.15 would rarely, if ever, be entered for exceeding 100/1::,
since the calculated value is very high (the denominator is very low) if beta emitters such as tritium are included in the determination, as required by the I:: definition.
The following TS Section 1.1 definition "!::-AVERAGE DISINTEGRATION ENERGY" is deleted:
I:: shall be the average (weighted in proportion to the concentration of each radionuclide in the reactor coolant at the time of sampling) of the sum of the average beta and gamma energies per disintegration (in Mev) for isotopes, other than iodines, with half lives > 15 minutes, making up at least 95% of the total non-iodine activity in the coolant.
The new definition "DOSE EQUIVALENT XE-133," replaces the above E-AVERAGE DISINTEGRATION ENERGY definition. The added definition for DEX states:
DOSE EQUIVALENT XE-133 shall be that concentration of Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-85, Kr-87, Kr-88, Xe-131m, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138 actually present. If a specific noble gas nuclide is not detected, it should be assumed to be present at the minimum detectable activity. The determination of DOSE EQUIVALENT XE-133 shall be performed using effective dose conversion factors for air submersion listed in Table 111.1 of EPA Federal Guidance Report No. 12, 1993, "External Exposure to Radionuclides in Air, Water, and Soil."
The licensee's proposed deletion of the above-stated definition for E and addition of a new definition for DEX in TS 1.1 is acceptable from a radiological dose perspective, since it will result in an LCO that more closely relates the non-iodine RCS activity limits to the dose consequence analyses that form their bases.
3.2.3 Revision of TS 3.4.15, "RCS Specific Activity" TS LCO 3.4.15 is modified to specify that iodine specific activity in terms of DEi and noble gas specific activity in terms of DEX shall be within limits. Currently, the limiting indicators are not explicitly identified in the LCO, but instead defined in current Condition A and SR 3.4.15.1 for reactor coolant gross non-iodine activity and in current Condition A and SR 3.4.15.2 for iodine specific activity.
The proposed change replaces "The specific activity of the reactor coolant," with "RCS DOSE EQUIVALENT 1-131 and DOSE EQUIVALENT XE-133 specific activity," such that the modified TS LCO 3.4.15 states, "RCS DOSE EQUIVALENT 1-131 and DOSE EQUIVALENT XE-133 specific activity shall be within limits." This proposed change modifies the TS LCO so that it is easier to read because the limiting indicators are explicitly stated in the LCO. The NRC staff finds that this proposed change provides clarity and is acceptable.
3.2.4 TS 3.4.15 Applicability TS 3.4.15 applicability is modified to include all of Mode 3 and Mode 4. It is necessary for the LCO to apply during Modes 1 through 4 to limit the potential radiological consequences of an SGTR that may occur during these modes. In Mode 5, with the RCS loops filled, the steam generators are specified as a backup means of decay heat removal by natural circulation. In this mode, however, due to the reduced temperature of the RCS, the probability of a OBA involving the release of significant quantities of RCS inventory is greatly reduced. Therefore, monitoring of RCS specific activity is not required. In Mode 5, with the RCS loops not filled, and in Mode 6, the steam generators are not used for decay heat removal, the RCS and steam generators are depressurized, and primary to secondary leakage is minimal. Therefore, the monitoring of RCS specific activity is not required. The proposed change to modify the TS 3.4.15 applicability to include all of Mode 3 and Mode 4 is necessary to limit the potential radiological consequences of an SGTR that may occur during these modes, and is, therefore, acceptable from a radiological dose perspective.
3.2.5 TS 3.4.15 Condition A TS 3.4.15 Required Action A.1 is revised to remove the reference to Figure 3.4.15-1, "Reactor Coolant DOSE EQUIVALENT 1-131 Specific Activity Limit versus Percent of RATED THERMAL POWER [RTP] With Reactor Coolant Specific Activity~ 0.5 µCi/gm DOSE EQUIVALENT 1-131,"
and insert a limit of less than or equal to the site-specific DEi spiking limit, which is 30 µCi/gm.
The curve contained in Figure 3.4.15-1 was provided by the AEC in a June 12, 1974 letter from the AEC on the subject entitled "Proposed Standard Technical Specifications for Primary Coolant Activity." The radiological dose consequence analysis for the SGTR accident takes into account the pre-accident iodine spike and does not consider the elevated RCS iodine specific activities permitted by Figure 3.4.15-1 for operation at power levels below 80 percent RTP.
Instead, the pre-accident iodine spike analyses assume a DEi concentration 60 times higher than the corresponding long-term equilibrium value, which corresponds to the specific activity limit associated with 100 percent RTP operation. It is acceptable that TS 3.4.15 Required Action A.1 is based on the short-term site-specific DEi spiking limit to be consistent with the assumptions contained in the radiological consequence analyses.
When the DEi limit of 0.5 µCi/gm is exceeded, TS 3.4.15 Required Action A.2 completion time allows 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> to restore DEi to within its limit. The licensee proposes to revise TS 3.4.15 Required Action A.2 completion time from 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. This change is a deviation from TSTF-490 becauseTSTF-490 did not modify the Standard Technical Specification 3.4.16 Required Action A.2 completion time, which is 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. The licensee's proposed change aligns the Calvert Cliffs TS 3.4.15 Required Action A.2 completion time with the Standard Technical Specification 3.4.16 Required Action A.2 completion time. This is a more restrictive change because it reduces the time allowed to restore DEi to within its limit. The proposed change is acceptable since it is expected that if there were an iodine spike, the normal coolant iodine concentration would be restored within this time period. In addition, there is a low probability of an SGTR occurring during this time period.
3.2.6 TS 3.4.15 Condition C Revision to Include Action for DEX Limit TS 3.4.15 Condition C is replaced with a new Condition B for DEX not within limits. This change is made to be consistent with the change to the TS 3.4.15 LCO, which requires the DEX specific activity to be within limits, as discussed above in Section 3.2.3. The DEX limit is site-specific, and the numerical value of 630 µCi/gm is contained in new TS Condition B and revised SR 3.4.15.1. The site-specific limit of 630 µCi/gm DEX is established based on the maximum accident analysis RCS activity corresponding to 1 percent fuel clad defects with sufficient margin to accommodate the exclusion of those isotopes based on low concentration, short half-life, or small dose conversion factors. The primary purpose of TS 3.4.15 LCO on RCS specific activity and its associated conditions is to support the dose analyses for DBAs. The whole-body dose is primarily dependent on the noble gas activity, not the non-gaseous activity currently captured in the E definition.
The completion time for new TS 3.4.15 required action B.1 requires restoration of DEX to within the limit in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. This is consistent with the proposed completion time for TS 3.4.15 Required Action A.1 for DEi. The radiological consequences for the SGTR accident demonstrate that the calculated thyroid doses are generally a greater percentage of the applicable acceptance criteria than the calculated whole-body doses. It then follows that the completion time for noble gas activity being out of specification in new Required Action B.1 should be at least as great as the completion time for iodine specific activity being out of specification in revised Required Action A.2. Therefore, the completion time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> for new Required Action B.1 is acceptable from a radiological dose perspective because it is expected that if there were an xenon spike in the normal coolant, iodine concentration would be restored within this time period. In addition, there is a low probability of an SGTR occurring during this time period.
A note is also added to the new Required Action B.1 that states LCO 3.0.4.c is applicable. This note would allow entry into a mode or other specified condition in the LCO applicability when LCO 3.4.15 is not being met and is the same note that is currently stated for Required Actions A.1 and A.2. The proposed note would allow entry into the applicable modes from Mode 4 (hot shutdown} to Mode 1 (power operation} while the DEX limit is exceeded and the DEX is being restored to within its limit. This mode change is acceptable due to the significant conservatism incorporated into the DEX specific activity limit, the low probability of an event occurring that is limiting due to exceeding the DEX specific activity limit. and the ability to restore transient specific excursions while the plant remains at, or proceeds to, power operation.
3.2. 7 TS 3.4.15 Condition B TS 3.4.15 Condition B is re-lettered to Condition C and revised to include new Condition B (DEX not within limit) if the required action and associated completion time of Condition B is not met.
This is consistent with new Condition B, which now provides the same completion time for both components of RCS specific activity, as discussed above in the revision to Condition C (new Condition B}. The revision to Condition B (also referred to as new Condition C} also replaces the limit on DEi from the deleted Figure 3.4.15-1 with a site-specific value of> 30 µCi/gm. This change makes new Condition C consistent with the changes made to TS 3.4.15 Required Action A.1.
The proposed change to new TS 3.4.15 Required Action C.1 deletes the requirement for average RCS temperature to be less than 500 degrees Fahrenheit and adds a new Required Action C.2, which requires the plant to be in Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. These changes are consistent with the changes made to the TS 3.4.15 applicability. The revised LCO is applicable throughout all of Modes 1 through 4 to limit the potential radiological consequences of an SGTR that may occur during these modes. In Mode 5 (cold shutdown), with the RCS loops filled, the steam generators are specified as a backup means of decay heat removal by natural circulation.
In this mode, however, due to the reduced temperature of the RCS, the probability of a OBA involving the release of significant quantities of RCS inventory is greatly reduced. Therefore, monitoring of RCS specific activity is not required. In Mode 5, with the RCS loops not filled, and Mode 6 (refueling}, the steam generators are not used for decay heat removal, the RCS and steam generators are depressurized, and primary to secondary leakage is minimal. Therefore, the monitoring of RCS specific activity is not required.
A new TS 3.4.15 Required Action C.2 completion time of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> is added for the plant to reach Mode 5. This completion time is reasonable, based on operating experience, to reach Mode 5 from full power conditions in an orderly manner and without challenging plant systems, and the value of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> is consistent with other TSs, which have a completion time to reach Mode 5. Based on all the above, the new Condition C, its associated required actions, and their completion times, are acceptable.
3.2.8 SR 3.4.15.1 DEX Surveillance The change would replace the current SR 3.4.15.1 surveillance for RCS gross specific activity with a surveillance to verify that the site-specific reactor coolant DEX specific activity is s 630 µCi/gm. This change provides a surveillance for the new LCO limit added to TS 3.4.15 for DEX. The revised SR 3.4.15.1 surveillance requires performing a gamma isotopic analysis as a measure of the noble gas specific activity of the reactor coolant in accordance with the surveillance frequency control program. This measurement is the sum of the degassed gamma activities and the gaseous gamma activities in the sample taken. The surveillance provides an indication of any increase in the noble gas specific activity. The results of the surveillance on DEX allow proper remedial actions to be taken before reaching the LCO limit under normal operating conditions, and is, therefore, acceptable.
3.2.9 SR 3.4.15.2 DEi Surveillance As described in Section 3.2.4 above, the applicability requirement of LCO 3.4.15 is Modes 1, 2, 3, and 4. Currently, a note exists in SR 3.4.16.2, which states, "Only required to be performed in MODE 1." The proposed change deletes this note. The licensee stated that deleting this note provides continued assessment of RCS activity for the modes of applicability since DEi will no longer be limited to Mode 1 operation. Therefore, the DEi surveillance is required to be met during all modes of applicability (Modes 1, 2, 3, and 4 ). Calvert Cliffs TS SR 3.0.1 states that SRs shall be met during the modes or other specified conditions in the applicability for individual LCOs, unless otherwise stated in the SR. The proposed change is in accordance with SR 3.0.1 and requires sampling DEi during plant conditions when isotopic spiking and fuel failures are more likely, and the DEi limit could be exceeded; therefore, the deletion of the note in SR 3.4.15.2 is acceptable.
3.2.10 SR 3.4.16.3 Deletion The current SR 3.4.15.3 that required the determination of E is deleted. TS 3.4.15 LCO on RCS specific activity supports the dose analyses for DBAs in which the whole-body dose is primarily dependent on the noble gas concentration, not the non-gaseous activity currently captured in the E definition. With the elimination of the limit for RCS gross specific activity and the addition of the new LCO limit for noble gas specific activity, this SR to determine E. is no longer required; therefore, the deletion of SR 3.4.15.3 is acceptable.
3.3 Technical Evaluation Conclusion
The NRC staff reviewed the licensee's changes to revise the Calvert Cliffs TSs to be consistent with TSTF-490 and make associated changes, which include replacing the current specific activity of the reactor coolant limits with limits on RCS DEi and DEX specific activity. The NRC staff reviewed the proposed changes to (1) delete the reactor coolant gross activity limit, its associated conditions, required actions, and SRs, (2) delete the determination of E, and (3) add a new DEX limit, its associated conditions, required actions, and SRs, and has concluded that the changes are consistent with the methodology used to analyze the radiological consequences of the SGTR accident. The NRC staff finds with reasonable assurance that the licensee's estimates of the TEDE from postulated DBAs comply with the acceptance criteria in RG 1.183 and SRP 15.0.1 and the radiation dose limits in 10 CFR 50.67.
The NRC staff reviewed the proposed changes and determined that changes to the TSs meet the standards for TSs in 10 CFR 50.36(b) and 10 CFR 50.36(c). The proposed SRs assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met and satisfy 10 CFR 50.36(c)(3). Additionally, the changes to the TSs were reviewed for technical clarity and consistency with customary terminology and format in accordance with SRP Chapter 16. The NRC staff concludes that the proposed TS changes meet the requirements stated in 10 CFR 50.36 and are acceptable.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Maryland State official was notified of the proposed issuance of the amendments on February 13, 2020. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component 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, and there has been no public comment on such finding published in the Federal Register on July 2, 2019 (84 FR 31634). 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: Kristy Bucholtz Date: February 28, 2020
ML19337D035 OFFICE NRR/DORL/LPL 1/PM NRR/DORL/LPL 1/LA NAME MMarshall LRonewicz DATE 12/23/2019 12/19/2019 E
OGC-NLO*
NRR/DORL/LPL 1 /BC RAugustus JDanna 02/13/2020 02/24/2020