ML25086A296
| ML25086A296 | |
| Person / Time | |
|---|---|
| Site: | Catawba, Harris, Robinson  |
| Issue date: | 06/02/2025 |
| From: | Natreon Jordan NRC/NRR/DORL/LPL2-2 |
| To: | Gibby S Duke Energy |
| References | |
| EPID L-2024-LLA-0077 | |
| Download: ML25086A296 (1) | |
Text
June 2, 2025 Shawn Gibby Vice President Nuclear Engineering Duke Energy 525 S. Tryon St.
Charlotte, NC 28202
SUBJECT:
CATAWBA NUCLEAR STATION, UNIT NOS. 1 AND 2; SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1; AND H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 - ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-234-A, REVISION 1 ADD ACTION FOR MORE THAN ONE [D]RPI INOPERABLE, (EPID L-2024-LLA-0077)
Dear Shawn Gibby:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment Nos. 321 and 317 to Renewed Facility Operating License Nos. NPF-35 and NPF-52 for the Catawba Nuclear Station, Unit Nos. 1 and 2 (CNS), respectively; Amendment No. 203 to Renewed Facility Operating License No. NPF-63 for the Shearon Harris Nuclear Power Plant, Unit No. 1 (HNP); and Amendment No. 281 to Renewed Facility Operating License No. DPR-23 for the H. B. Robinson Steam Electric Plant, Unit No. 2 (RNP). The amendments are in response to your application dated May 23, 2024.
The proposed amendments would revise TS 3.1.7, Rod Position Indication at CNS and RNP and TS 3.1.3.2, Position Indication Systems - Operating at HNP, to add a new Condition for more than one inoperable rod position indicator per rod group, and revise the Actions Notes and to clarify the wording of current Actions. TS requirements would be re-lettered to account for the revisions and additions. Current CNS and RNP TS would be modified to reflect that the verification of the position of the rods with inoperable position indicators can be done indirectly by using movable in-core detectors. These changes are consistent with NRC-approved Technical Specification Task Force (TSTF) Traveler TSTF-234, Revision 1, Add Action for More Than One [D]RPI Inoperable (Agencywide Documents Access and Management System (ADAMS) Accession No. ML040580468).
A copy of the related SE is also enclosed. Notice of issuance will be included in the Commissions monthly Federal Register notice.
Sincerely,
/RA/
Natreon Jordan, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 50-413, 50-414, 50-400, and 50-261
Enclosures:
- 1. Amendment No. 321 to License No. NPF-35
- 2. Amendment No. 317 to License No. NPF-52
- 3. Amendment No. 203 to License No. NPF-63
- 4. Amendment No. 281 to License No. DPR-23
- 5. Safety Evaluation cc: Listserv DUKE ENERGY CAROLINAS, LLC NORTH CAROLINA ELECTRIC MEMBERSHIP CORPORATION DOCKET NO. 50-413 CATAWBA NUCLEAR STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 321 Renewed License No. NPF-35 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment filed by Duke Energy Carolinas, LLC (the licensee), dated May 23, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations as set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations set forth in 10 CFR Chapter I; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
2.
Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment, and Paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-35 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 321, which are attached hereto, are hereby incorporated into this renewed operating license. Duke Energy Carolinas, LLC shall operate the facility in accordance with the Technical Specifications.
3.
This license amendment is effective as of its date of issuance and shall be implemented within 120 days of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION David Wrona, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to Renewed Facility Operating License No. NPF-35 and Technical Specifications Date of Issuance: June 2, 2025 DAVID WRONA Digitally signed by DAVID WRONA Date: 2025.06.02 09:02:35 -04'00' DUKE ENERGY CAROLINAS, LLC NORTH CAROLINA MUNICIPAL POWER AGENCY NO. 1 PIEDMONT MUNICIPAL POWER AGENCY DOCKET NO. 50-414 CATAWBA NUCLEAR STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 317 Renewed License No. NPF-52 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment to the Catawba Nuclear Station, Unit 2 (the facility) Renewed Facility Operating License No. NPF-52 filed by the Duke Energy Carolinas, LLC (the licensee), dated May 23, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations as set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations set forth in 10 CFR Chapter I; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
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-52 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 317, which are attached hereto, are hereby incorporated into this renewed operating license. Duke Energy Carolinas, LLC shall operate the facility in accordance with the Technical Specifications.
3.
This license amendment is effective as of its date of issuance and shall be implemented within 120 days of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION David Wrona, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to Renewed Facility Operating License No. NPF-52 and Technical Specifications Date of Issuance: June 2, 2025 DAVID WRONA Digitally signed by DAVID WRONA Date: 2025.06.02 09:02:59 -04'00'
ATTACHMENT AMENDMENT NO. 321 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-35 AMENDMENT NO. 317 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-52 CATAWBA NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-413 AND 50-414 Renewed Facility Operating License Nos. NPF-35 and NPF-52 Replace the following pages of the Renewed Facility Operating Licenses with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Insert NPF-35, page 4 NPF-35, page 4 NPF-52, page 4 NPF-52, page 4 Appendix A to Renewed Facility Operating License Nos. NPF-35 and NPF-52 Replace the following pages of the Appendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Insert TS 3.1.7-1 TS 3.1.7-1 TS 3.1.7-2 TS 3.1.7-2 TS 3.1.7-3 Renewed License No. NPF-35 Amendment No. 321 (2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 321, which are attached hereto, are hereby incorporated into this renewed operating license. Duke Energy Carolinas, LLC shall operate the facility in accordance with the Technical Specifications.
(3)
Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21(d), as revised on December 16, 2002, describes certain future activities to be completed before the period of extended operation. Duke shall complete these activities no later than December 6, 2024, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.
The Updated Final Safety Analysis Report supplement as revised on December 16, 2002, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71 (e)(4),
following issuance of this renewed operating license. Until that update is complete, Duke may make changes to the programs described in such supplement without prior Commission approval, provided that Duke evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.
(4)
Antitrust Conditions Duke Energy Carolinas, LLC shall comply with the antitrust conditions delineated in Appendix C to this renewed operating license.
(5)
Fire Protection Program Duke Energy Carolinas, LLC shall implement and maintain in effect all provisions of the approved fire protection program that complies with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated September 25, 2013; as supplemented by letters dated January 13, 2015; January 28, 2015; February 27, 2015; March 30, 2015; April 28, 2015; July 15, 2015; August 14, 2015; September 3, 2015; December 11, 2015; January 7, 2016; March 23, 2016; June 15, 2016; August 2, 2016; September 7, 2016; and, January 26, 2017, as approved in the SE dated February 8, 2017. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c),
the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
Renewed License No. NPF-52 Amendment No. 317 (2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 317, which are attached hereto, are hereby incorporated into this renewed operating license. Duke Energy Carolinas, LLC shall operate the facility in accordance with the Technical Specifications.
(3) Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21(d), as revised on December 16, 2002, describes certain future activities to be completed before the period of extended operation. Duke shall complete these activities no later than December 6, 2024, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.
The Updated Final Safety Analysis Report supplement as revised on December 16, 2002, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71 (e)(4),
following issuance of this renewed operating license. Until that update is complete, Duke may make changes to the programs described in such supplement without prior Commission approval, provided that Duke evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.
(4) Antitrust Conditions Duke Energy Carolinas, LLC shall comply with the antitrust conditions delineated in Appendix C to this renewed operating license.
(5) Fire Protection Program Duke Energy Carolinas, LLC shall implement and maintain in effect all provisions of the approved fire protection program that complies with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated September 25, 2013; as supplemented by letters dated January 13, 2015; January 28, 2015; February 27, 2015; March 30, 2015; April 28, 2015; July 15, 2015; August 14, 2015; September 3, 2015; December 11, 2015; January 7, 2016; March 23, 2016; June 15, 2016; August 2, 2016; September 7, 2016; and, January 26, 2017, as approved in the SE dated February 8, 2017. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c),
the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
Rod Position Indication 3.1.7 Catawba Units 1 and 2 3.1.7-1 Amendment Nos. 321/317 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Rod Position Indication LCO 3.1.7 The Digital Rod Position Indication (DRPI) System and the Demand Position Indication System shall be OPERABLE.
APPLICABILITY:
MODES 1 and 2.
ACTIONS
NOTE----------------------------------------------------------
Separate Condition entry is allowed for each inoperable rod position indicator and each demand position indicator.
CONDITION REQUIRED ACTION COMPLETION TIME A.
One DRPI per group inoperable for one or more groups.
A.1 Verify the position of the rods with inoperable position indicators indirectly by using movable incore detectors.
OR A.2 Reduce THERMAL POWER to < 50% RTP.
Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 8 hours B.
More than one DRPI per group inoperable.
B.1 Place the control rods under manual control.
AND B.2 Monitor and Record RCS Tavg.
AND Immediately Once per 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (continued)
Rod Position Indication 3.1.7 ACTIONS (continued)
Catawba Units 1 and 2 3.1.7-2 Amendment Nos. 321/317 CONDITION REQUIRED ACTION COMPLETION TIME B.
(continued)
B.3 Verify the position of the rods with inoperable position indicators indirectly by using the movable incore detectors.
AND B.4 Restore inoperable position indicators to OPERABLE status such that a maximum of one DRPI per group is inoperable.
Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 24 hours C.
One or more rods with inoperable position indicators have been moved in excess of 24 steps in one direction since the last determination of the rod's position.
C.1 Verify the position of the rods with inoperable position indicators indirectly by using movable incore detectors.
OR C.2 Reduce THERMAL POWER to < 50% RTP.
4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 8 hours (continued)
Rod Position Indication 3.1.7 ACTIONS (continued)
Catawba Units 1 and 2 3.1.7-3 Amendment Nos. 321/317 CONDITION REQUIRED ACTION COMPLETION TIME D.
One demand position indicator per bank inoperable for one or more banks.
D.1.1 Verify by administrative means all DRPIs for the affected banks are OPERABLE.
AND D.1.2 Verify the most withdrawn rod and the least withdrawn rod of the affected banks are
< 12 steps apart.
OR D.2 Reduce THERMAL POWER to < 50% RTP.
Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 8 hours E.
Required Action and associated Completion Time not met.
E.1 Be in MODE 3.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.7.1 Verify each DRPI agrees within 12 steps of the group demand position for the full indicated range of rod travel.
Once prior to criticality after each removal of the reactor head DUKE ENERGY PROGRESS, LLC DOCKET NO. 50-400 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 203 Renewed License No. NPF-63 1.
The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Duke Energy Progress, LLC (the licensee),
dated May 23, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions 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 Commissions regulations.
D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
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-63 is hereby amended to read as follows:
(2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, as revised through Amendment No. 203, are hereby incorporated into this license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
3.
This license amendment is effective as of the date of its issuance and shall be implemented within 120 days of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION David Wrona, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Renewed Facility Operating License No. NPF-63 and Technical Specifications Date of Issuance: June 2, 2025 DAVID WRONA Digitally signed by DAVID WRONA Date: 2025.06.02 09:04:05 -04'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 203 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 RENEWED FACILITY OPERATING LICENSE NO. NPF-63 DOCKET NO. 50-400 Replace the following page of the Renewed Facility Operating License with the revised page.
The revised page is identified by amendment number and contains a marginal line indicating the area of change:
Remove Insert Page 4 Page 4 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 Insert 3/4 1-17 3/4 1-17 Renewed License No. NPF-63 Amendment No. 203 C.
This 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 Duke Energy Progress, LLC, is authorized to operate the facility at reactor Core power levels not in excess of 2948 megawatts thermal (100 percent rated core power) in accordance with the conditions specified herein.
(2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, as revised through Amendment No. 203, are hereby incorporated into this license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(3)
Antitrust Conditions Duke Energy Progress, LLC. shall comply with the antitrust conditions delineated in Appendix C to this license.
(4)
Initial Startup Test Program (Section 14)1 Any changes to the Initial Test Program described in Section 14 of the FSAR made in accordance with the provisions of 10 CFR 50.59 shall be reported in accordance with 50.59(b) within one month of such change.
(5)
Steam Generator Tube Rupture (Section 15.6.3)
Prior to startup following the first refueling outage, Carolina Power & Light Company* shall submit for NRC review and receive approval if a steam generator tube rupture analysis, including the assumed operator actions, which demonstrates that the consequences of the design basis steam generator tube rupture event for the Shearon Harris Nuclear Power Plant are less than the acceptance criteria specified in the Standard Review Plan, NUREG-0800, at 15.6.3 Subparts II (1) and (2) for calculated doses from radiological releases. In preparing their analysis Carolina Power &
Light Company* will not assume that operators will complete corrective actions within the first thirty minutes after a steam generator tube rupture.
1The 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.
- On April 29, 2013, the name of Carolina Power & Light Company (CP&L) was changed to Duke Energy Progress, Inc. On August 1, 2015, the name Duke Energy Progress, Inc. was changed to Duke Energy Progress, LLC.
SHEARON HARRIS - UNIT 1 3/4 1-17 Amendment No. 203 REACTIVITY CONTROL SYSTEMS POSITION INDICATION SYSTEMS - OPERATING LIMITING CONDITION FOR OPERATION 3.1.3.2 The Digital Rod Position Indication System and the Demand Position Indication System shall be OPERABLE and capable of determining the shutdown and control rod positions within +/- 12 steps.
APPLICABILITY: MODES 1 and 2.
ACTION:
- a.
With a maximum of one digital rod position indicator per bank inoperable either:
- 1.
Determine the position of the nonindicating rod(s) indirectly by the movable incore detectors at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and immediately after any motion of the nonindicating rod which exceeds 24 steps in one direction since the last determination of the rod's position, or
- 2.
Reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
- b.
With more than one digital rod position indicator per bank inoperable either:
1.a) Place the control rods under manual control immediately, and b) Monitor and record Reactor Coolant System average temperature (Tavg) at least once per hour, and c) Determine the position of the nonindicating rods indirectly by the movable incore detectors at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and immediately after any motion of the nonindicating rods which exceeds 24 steps in one direction since the last determination of the rod positions, and d) Restore the inoperable digital rod position indicators to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> such that a maximum of one digital rod position indicator per bank is inoperable, or
- 2.
Be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
- c.
With a maximum of one demand position indicator per bank inoperable either:
- 1.
Verify that all digital rod position indicators for the affected bank are OPERABLE and that the most withdrawn rod and the least withdrawn rod of the bank are within a maximum of 12 steps of each other at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, or
- 2.
Reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
SURVEILLANCE REQUIREMENTS 4.1.3.2 Each digital rod position indicator shall be determined to be OPERABLE by verifying that the Demand Position Indication System and the Digital Rod Position Indication System agree within 12 steps at the frequency specified in the Surveillance Frequency Control Program except during time intervals when the rod position deviation monitor is inoperable, then compare the Demand Position Indication System and the Digital Rod Position Indication System at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
DUKE ENERGY PROGRESS, LLC DOCKET NO. 50-261 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 281 Renewed License No. DPR-23 1.
The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment filed by Duke Energy Progress, LLC (the licenses), dated May 23, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions 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 Commissions regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
2.
Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment; and paragraph 3.B of Renewed Facility Operating License No. DPR-23 is hereby amended to read, in part, as follows:
B.
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 281 are hereby incorporated in the 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 120 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION David Wrona, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: June 2, 2025 DAVID WRONA Digitally signed by DAVID WRONA Date: 2025.06.02 09:04:45 -04'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 281 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 RENEWED FACILITY OPERATING LICENSE NO. DPR-23 DOCKET NO. 50-261 Replace the following page of Renewed Facility Operating License No. DPR-23 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.
Renewed Facility Operating License No. DPR-23 Remove Insert Page 3 Page 3 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 Insert 3.1-15 3.1-15 3.1-16 3.1-16 3.1-17 3.1-17 Renewed Facility Operating License No. DPR-23 Amendment No. 281 D.
Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or instrument and equipment calibration or associated with radioactive apparatus or components; E.
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 operation of the facility.
- 3.
This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations: 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Section 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 CFR Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
A.
Maximum Power Level The licensee is authorized to operate the facility at a steady state reactor core power level not in excess of 2339 megawatts thermal.
B.
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 281 are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.
(1)
For Surveillance Requirements (SRs) that are new in Amendment 176 to Final Operating License DPR-23, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 176. For SRs that existed prior to Amendment 176, 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 176.
Rod Position Indication 3.1.7 HBRSEP Unit No. 2 3.1-15 Amendment No. 281 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Rod Position Indication LCO 3.1.7 The Analog Rod Position Indication (ARPI) System and the Demand Position Indication System shall be OPERABLE.
NOTE --------------------------------------------------
Individual Rod Position Indicators may be outside their limits for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> following substantial rod movement.
APPLICABILITY:
MODES 1 and 2.
ACTIONS
NOTE-------------------------------------------------------------
Separate Condition entry is allowed for each inoperable rod position indicator and each demand position indicator.
CONDITION REQUIRED ACTION COMPLETION TIME A.
One ARPI per group inoperable for one or more groups.
A.1 Verify the position of the rods with inoperable position indicators indirectly by using movable incore detectors.
OR A.2 Reduce THERMAL POWER to 50% RTP.
Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 8 hours B.
More than one ARPI per group inoperable.
B.1 Place the control rods under manual control.
AND B.2 Monitor and Record RCS Tavg.
AND Immediately Once per 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (continued)
Rod Position Indication 3.1.7 HBRSEP Unit No. 2 3.1-16 Amendment No. 281 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B.
(continued)
B.3 Verify the position of the rods with inoperable position indicators indirectly by using the movable incore detectors.
AND B.4 Restore inoperable position indicators to OPERABLE status such that a maximum of one ARPI per group is inoperable.
Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 24 hours C.
One or more rods with inoperable position indicators have been moved in excess of 24 steps in one direction since the last determination of the rod's position.
C.1 Verify the position of the rods with inoperable position indicators indirectly by using movable incore detectors.
OR C.2 Reduce THERMAL POWER to 50% RTP.
4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 8 hours (continued)
Rod Position Indication 3.1.7 HBRSEP Unit No. 2 3.1-17 Amendment No. 281 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D.
One demand position indicator per bank inoperable for one or more banks.
D.1.1 Verify by administrative means all ARPIs for the affected banks are OPERABLE.
AND D.1.2
NOTE-----------
Only required to be met for bank positions < 200 steps.
Verify the position of each rod in the affected bank(s) is within 7.5 inches of the average of the individual rod positions in the affected bank(s).
AND D.1.3
NOTE-----------
Only required to be met for bank positions 200 steps.
Verify the position of each rod in the affected bank(s) is within 15 inches of the bank demand position.
OR D.2 Reduce THERMAL POWER to 50% RTP.
Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 8 hours E.
Required Action and associated Completion Time not met.
E.1 Be in MODE 3.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> SAFETY EVALUATION BY THE NUCLEAR REACTOR REGULATION RELATED TO DUKE ENERGY PROGRESS, LLC AND DUKE ENERGY CAROLINAS, LLC ADOPTION OF TSTF-234-A AT CATAWBA NUCLEAR STATION, SHEARON HARRIS NUCLEAR POWER PLANT, AND H.B.
ROBINSON STEAM ELECTRIC PLANT DOCKET NOS. 50-413, 50-414, 50-400, AND 50-261 EPID L-2024-LLA-0077
1.0 PROPOSED CHANGE
By letter to the U.S. Nuclear Regulatory Commission (NRC, the Commission) dated May 23, 2024, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24149A117), Duke Energy Progress, LLC and Duke Energy Carolinas, LLC (the licensee) submitted an application to amend the Technical Specifications (TSs) for the Catawba Nuclear Satiation, Units 1 and 2 (CNS), Shearon Harris Nuclear Power Plant, Unit 1 (HNP) and H. B. Robinson Steam Electric Plant, Unit 2 (RNP).
The proposed amendments would revise TS 3.1.7, Rod Position Indication at CNS and RNP and TS 3.1.3.2, Position Indication Systems - Operating at HNP, to add a new Condition for more than one inoperable rod position indicator per rod group, and revise the Actions Notes and to clarify the wording of current Actions. TS requirements would be re-lettered to account for the revisions and additions. Current CNS and RNP TS would be modified to reflect that the verification of the position of the rods with inoperable position indicators can be done indirectly by using movable incore detectors. These changes are consistent with NRC-approved Technical Specification Task Force (TSTF) Traveler TSTF-234, Revision 1 (TSFT-234), Add Action for More Than One [D]RPI Inoperable (ML040580468).
The licensee also included, in the license amendment request, its TS Bases changes for the proposed changes to the TSs. These changes were presented for information only.
2.0 REGULATORY EVALUATION
2.1
System Description
The licensee provided the following general description of the rod position indication systems in Section 2.1 of the LAR:
The axial position of shutdown rods and control rods are determined by two separate and independent systems: the Bank Demand Position Indication System (commonly called group step counters) and the Rod Position Indication (RPI) System.
The Bank Demand Position Indication System counts the pulses from the Rod Control System that move the rods. There is one step counter for each group of rods. Individual rods in a group all receive the same signal to move and should, therefore, all be at the same position indicated by the group step counter for that group. The Bank Demand Position Indication System is considered highly precise (+/- 1 step or +/- 5/8 inch). If a rod does not move one step for each demand pulse, the step counter will still count the pulse and incorrectly reflect the position of the rod.
The RPI System provides a highly accurate indication of actual control rod position, but at a lower precision than the step counters. This system is based on inductive analog signals from a series of coils spaced along a hollow tube with a center-to-center distance of 3.75 inches, which is 6 steps.
Detailed descriptions of each plants RPI system and associated nomenclature are contained in CNP UFSAR, Rev. 24, Section 7.7.1.3.2 (ML24296A046), RNP UFSAR, Rev. 30, Section 7.7.1.1.5 (ML23145A158), and HNP UFSAR, Amendment 65, Section 7.7.1.3.2 (ML23118A138), respectively.
2.2 Licensees Proposed Changes 2.2.1 CNP Changes Current TS 3.1.7, Action Notes, states:
Separate Condition entry is allowed for each inoperable rod position indicator per group and each demand position indicator per bank.
Revised TS 3.1.7, Action Notes, will state:
Separate Condition entry is allowed for each inoperable rod position indicator and each demand position indicator.
Current TS 3.1.7, Condition A, Required Action A.1, states:
Verify the position of the rods with inoperable position indicators by using movable incore detectors.
Revised TS 3.1.7, Condition A, Required Action A.1, will state:
Verify the position of the rods with inoperable position indicators indirectly by using movable incore detectors.
Current Condition B is re-lettered and Condition C and Required Action C.1, currently states:
Verify the position of the rods with inoperable position indicators by using movable incore detectors.
Revised TS 3.1.7, Condition C, Required Action C.1, will state:
Verify the position of the rods with inoperable position indicators indirectly by using movable incore detectors.
Conditions C and D are re-lettered as D and E, respectively, with no changes.
A new Condition B, More than one DRPI per group inoperable, with its associated Required Actions B.1, B.2, B.3, B.4 and associated Completion Times (CTs) are added, as shown below.
CONDITION REQUIRED ACTION COMPLETION TIME B. More than one DRPI per group inoperable.
B.1 Place the control rods under manual control.
AND Immediately B.2 Monitor and Record RCS Tavg.
AND Once per 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> B.3 Verify the position of the rods with inoperable position indicators indirectly by using the movable incore detectors.
AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> B.4 Restore inoperable position indicators to OPERABLE status such that a maximum of one DRPI per group is inoperable.
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 2.2.2 RNP Changes Current TS 3.1.7, Action Notes, states:
Separate Condition entry is allowed for each inoperable rod position indicator per group and each demand position indicator per bank.
Revised TS 3.1.7, Action Notes, will state:
Separate Condition entry is allowed for each inoperable rod position indicator and each demand position indicator.
Current TS 3.1.7, Condition A, Required Action A.1, states:
Verify the position of the rods with inoperable position indicators by using movable incore detectors.
Revised TS 3.1.7, Condition A, Required Action A.1, will state:
Verify the position of the rods with inoperable position indicators indirectly by using movable incore detectors.
Current Condition B is re-lettered and Condition C and Required Action C.1, currently states:
Verify the position of the rods with inoperable position indicators by using movable incore detectors.
Revised TS 3.1.7, Condition C, Required Action C.1, will state:
Verify the position of the rods with inoperable position indicators indirectly by using movable incore detectors.
Conditions C and D are re-lettered as D and E, respectively, with no changes to re-lettered Condition E.
Current Condition C (re-lettered Condition D) ends with an asterisk (*) and a footnote at the bottom of TS page 3.1-16 states:
- During Cycle 25, the condition of two demand position indicators per bank inoperable for one or more banks is allowed with a required action to restore one demand position indicator per bank and a completion time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
The asterisk at the end of Current Condition C (re-lettered Condition D) and the associated footnote will be deleted.
A new Condition B, More than one ARPI per group inoperable, with its associated Required Actions B.1, B.2, B.3, B.4 and associated Completion Times is added, as shown below.
CONDITION REQUIRED ACTION COMPLETION TIME B. More than one ARPI per group inoperable.
B.1 Place the control rods under manual control.
AND Immediately B.2 Monitor and Record RCS Tavg.
AND Once per 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> B.3 Verify the position of the rods with inoperable position indicators indirectly by using Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> CONDITION REQUIRED ACTION COMPLETION TIME the movable incore detectors.
AND B.4 Restore inoperable position indicators to OPERABLE status such that a maximum of one ARPI per group is inoperable.
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 2.2.3 HNP Changes A new ACTION b will be added as shown below:
- b.
With more than one digital rod position indicator per bank inoperable either:
- 1.
a) Place the control rods under manual control immediately, and b) Monitor and record Reactor Coolant System average temperature (Tavg) at least once per hour, and c) Determine the position of the nonindicating rods indirectly by the movable incore detectors at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and immediately after any motion of the nonindicating rods which exceeds 24 steps in one direction since the last determination of the rod positions, and d) Restore the inoperable digital rod position indicators to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> such that a maximum of one digital rod position indicator per bank is inoperable, or
- 2. Be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Current ACTION b will be re-lettered to ACTION c.
2.3 Applicable Regulations and Guidance Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36 requires TSs for nuclear reactors to include items in the following categories: (1) Safety limits, limiting safety system settings, and limiting control settings; (2) Limiting conditions for operation [LCOs];
(3) Surveillance requirements [SRs]; (4) Design features; and (5) Administrative controls. The regulation does not specify the particular requirements to be included in a plants TSs.
10 CFR 50.36(c)(2), Limiting conditions for operation [LCO], states, in part, (i) Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.
The NRC staffs guidance for TS format and content for Westinghouse plants is found in NUREG-1431, Standard Technical Specifications [STS], Westinghouse Plants. In adopting the STS or a TSTF traveler, licensees propose revisions to their licensed nuclear reactor facility TSs to: (1) incorporate revised NRC policy and guidance regarding the content and format of TSs, (2) clarify a specifications intent by revising ambiguous language and correcting editorial errors, and (3) enhance specifications to correct inadequacies.
The NRC approved TSTF-234 changes to NUREG 1431, Revision 1 on January 13, 1999 (ML20199E634). This traveler revised STS 3.1.8, Rod Position Indication by adding a new TS Action B to allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore inoperability of more than one RPI in a group.
3.0 TECHNICAL EVALUATION
TSTF-234 allows for more than one RPI to be inoperable for a maximum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, given that other indirect means of monitoring changes in rod position are available. This provides sufficient time to restore operability while minimizing shutdown transients during the time that the position indication is degraded.
In Section 1 of the LAR, the licensee stated the proposed changes are consistent with TSTF-234. In Section 2.2 of the LAR the licensee stated, consistent with TSTF-234, when more than one RPI per group is inoperable, the TSs will require that the control rods be placed under manual control, the reactor coolant system average temperature (RCS Tavg) be monitored and recorded hourly, and the rod position to be verified indirectly every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The proposed change requires the use of the movable incore detectors as an indirect means of monitoring changes in rod position in order to assure that the rod alignment and rod insertion LCOs are met, consistent with TSTF-234. In Section 2.3 of the LAR the licensee provided a discussion of each of the variations from the TSTF-234 changes each plant specific change would contain.
The NRC staff reviewed the proposed changes as well as the licensees justifications for the changes and variations from TSTF-234.
3.1 TSTF-234 changes The NRC staff determined the proposed changes are consistent with TSTF-234, which allows verification of core peaking factors and shutdown margin to satisfy the action requirements, providing the non-indicating rods have not been moved. The additional time to restore an inoperable RPI is appropriate because the proposed action would require that the control rods be under manual control, that the RCS Tavg be monitored and recorded hourly, and that rod position be verified indirectly every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, thereby assuring that the rod alignment and rod insertion LCOs are met. Therefore, the required shutdown margin will be maintained.
Given the alternate position monitoring requirement, and other indirect means of monitoring changes in rod position, a 24-hour CT to restore all but one RPI per group provides sufficient time to restore operability while minimizing shutdown transients during the time that the position indication system is degraded.
3.2 Variations from TSTF-234 The licensee cited 8 variations between the proposed changes and the approved traveler in Section 2.3 of the LAR. The differences are: 1) The specification numbers and names are different from the STS Section 3.1 specification numbers; 2) TSTF-234 contains the bracketed text [, or B.1, as applicable] in the Bases discussion for Condition C which was not adopted by the licensee; 3) RNP TS 3.1.7 Condition C contains a footnote which does not exist in STS 3.1.8; 4) HNP TS content and format follow the guidance of NUREG-0452, the precursor to NUREG-1431; 5) HNP TS uses the term bank instead of the term group used in NUREG-1431; 6) Unlike NUREG-1431, current HNP TSs do not have a default Action to be in MODE 3 when the required Action and associated CT are not met, so it is proposed, in this LAR, as an addition to HNP TS in a manner that follows the NUREG-0452 format; 7) Unlike NUREG-1431, current HNP TS do not contain a NOTE indicating that separate Condition entry is allowed; and 8) HNP TSs already state that rod position can be verified indirectly.
The NRC staff determined variation 1 is acceptable because the TS number and name differences do not affect the applicability of the TSTF-234 changes to CNP, RNP, or HNP TS.
The staff determined variation 2 is acceptable because it is not necessary to restate in the Bases that all applicable Conditions must be entered since this concept is enforced by TS usage rules.
The staff reviewed the proposed deletion described in variation 3. The staff determined the text proposed for deletion no longer affects TS requirements because it is expired. The staff determined the deletion is acceptable. Furthermore, the staff determined variation 3 is acceptable because the footnote is an expired cycle-specific TS requirement modification that does not affect the applicability of the TSTF-234 changes to RNP.
The staff determined variations 4 and 5 are differences which do not affect the applicability of the TSTF-234 changes to HNP TS and are acceptable.
The staff determined variation 6 is acceptable because it is necessary to adopt the concepts approved in TSTF-234 to the existing format and content of HNP TS.
The staff determined variation 7 is acceptable because HNP TS do not need a NOTE for separate condition entry to adopt the concepts approved in TSTF-234 to the existing format and content of HNP TS.
The staff determined variation 8 is acceptable since the HNP TS already allows indirect rod position verification as approved in TSTF-234.
3.3 Conclusion The NRC staff concludes that the requirements of 10 CFR 50.36(c)(2) will continue to be met at CNP, HNP, and RNP because the minimum performance level of equipment needed for safe operation of each of the facilities will be contained in the respective RPI LCOs, and the appropriate remedial measures are specified for each facility if the respective LCO is not met.
Based on the above, the proposed changes are acceptable to the staff.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the North Carolina and South Carolina State officials were notified of the proposed issuance of the amendments on April 29, 2025. The State officials had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 or change surveillance requirements. 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 previously issued a proposed finding that the amendments involve no significant hazards consideration published in the Federal Register on August 6, 2024 (89 FR 63989), 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). An amendment made editorial or corrective revisions and, thus, meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principle Contributor: M. Hamm, NRR Date of Issuance: June 2, 2025
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