ML050400005
| ML050400005 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 02/07/2005 |
| From: | Sean Peters NRC/NRR/DLPM/LPD2 |
| To: | Jamil D Duke Energy Corp |
| Peters S, NRR/DLPM, 415-1842 | |
| Shared Package | |
| ML050400007 | List: |
| References | |
| TAC MC5833 | |
| Download: ML050400005 (15) | |
Text
February 7, 2005 Mr. D. M. Jamil Vice President Catawba Nuclear Station Duke Energy Corporation 4800 Concord Road York, SC 29745
SUBJECT:
CATAWBA NUCLEAR STATION, UNIT 2 RE: ISSUANCE OF AMENDMENT (TAC NO. MC5833)
Dear Mr. Jamil:
The Nuclear Regulatory Commission has issued the enclosed Amendment No. 213 to Renewed Facility Operating License NPF-52 for the Catawba Nuclear Station, Unit 2. The amendment consists of changes to the Technical Specifications in response to your application dated February 5, 2005, as supplemented by letter dated February 7, 2005.
The amendment revises the system bypass leakage acceptance criterion for the charcoal adsorber in the 2B Auxiliary Building Filtered Ventilation Exhaust System train as listed in Technical Specification 5.5.11, Ventilation Filter Testing Program.
A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
/RA/
Sean E. Peters, Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-414
Enclosures:
- 1. Amendment No. 213 to NPF-52
- 2. Safety Evaluation cc w/encls: See next page
February 7, 2005 Mr. D. M. Jamil Vice President Catawba Nuclear Station Duke Energy Corporation 4800 Concord Road York, SC 29745
SUBJECT:
CATAWBA NUCLEAR STATION, UNIT 2 RE: ISSUANCE OF AMENDMENT (TAC NO. MC5833)
Dear Mr. Jamil:
The Nuclear Regulatory Commission has issued the enclosed Amendment No. 213 to Renewed Facility Operating License NPF-52 for the Catawba Nuclear Station, Unit 2. The amendment consists of changes to the Technical Specifications in response to your application dated February 5, 2005, as supplemented by letter dated February 7, 2005.
The amendment revises the system bypass leakage acceptance criterion for the charcoal adsorber in the 2B Auxiliary Building Filtered Ventilation Exhaust System train as listed in Technical Specification 5.5.11, Ventilation Filter Testing Program.
A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
/RA/
Sean E. Peters, Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-414
Enclosures:
- 1. Amendment No. 213 to NPF-52
- 2. Safety Evaluation cc w/encls: See next page DOCUMENT NAME: G:\\DLPM\\PDII-1\\Catawba\\AMD MC5833.wpd Package Number: ML050400007 Amendment Number: ML050400005 Tech Spec Number: ML050400114 NRR-058 OFFICE PDII-1/PM PDII-1/LA SPSB/SC IROB/SC OGC PDII-1/SC NAME SPeters CHawes RDennig TBoyce SCole JNakoski DATE 2/7/05 2/7/05 2/7/05 2/7/05 2/7/05 2/7/05 OFFICIAL RECORD COPY
SUBJECT:
CATAWBA NUCLEAR STATION, UNIT 2 RE: ISSUANCE OF AMENDMENT (TAC NOS. MC5833)
Date: February 7, 2005 DISTRIBUTION:
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Catawba Nuclear Station, Unit 2 Page 1 of 2 cc:
Mr. Lee Keller, Manager Regulatory Compliance Duke Energy Corporation 4800 Concord Road York, South Carolina 29745 Ms. Lisa F. Vaughn Duke Energy Corporation Mail Code - PB05E 422 South Church Street P.O. Box 1244 Charlotte, North Carolina 28201-1244 Ms. Anne Cottingham, Esquire Winston and Strawn 1400 L Street, NW Washington, DC 20005 North Carolina Municipal Power Agency Number 1 1427 Meadowwood Boulevard P.O. Box 29513 Raleigh, North Carolina 27626 County Manager of York County York County Courthouse York, South Carolina 29745 Piedmont Municipal Power Agency 121 Village Drive Greer, South Carolina 29651 Ms. Karen E. Long Assistant Attorney General North Carolina Department of Justice P.O. Box 629 Raleigh, North Carolina 27602 NCEM REP Program Manager 4713 Mail Service Center Raleigh, North Carolina 27699-4713 North Carolina Electric Membership Corp.
P.O. Box 27306 Raleigh, North Carolina 27611 Senior Resident Inspector U.S. Nuclear Regulatory Commission 4830 Concord Road York, South Carolina 29745 Mr. Henry Porter, Assistant Director Division of Waste Management Bureau of Land and Waste Management Dept. of Health and Environmental Control 2600 Bull Street Columbia, South Carolina 29201-1708 Mr. R.L. Gill, Jr., Manager Nuclear Regulatory Issues and Industry Affairs Duke Energy Corporation 526 South Church Street Mail Stop EC05P Charlotte, North Carolina 28202 Saluda River Electric P.O. Box 929 Laurens, South Carolina 29360 Mr. Peter R. Harden, IV, Vice President Customer Relations and Sales Westinghouse Electric Company 6000 Fairview Road 12th Floor Charlotte, North Carolina 28210 Ms. Mary Olson Director of the Southeast Office Nuclear Information and Resource Service 729 Haywood Road, 1-A P.O. Box 7586 Asheville, North Carolina 28802
Catawba Nuclear Station, Unit 2 Page 2 of 2 cc:
Mr. T. Richard Puryear Owners Group (NCEMC)
Duke Energy Corporation 4800 Concord Road York, South Carolina 29745 Mr. Richard M. Fry, Director Division of Radiation Protection NC Dept. of Environment, Health, and Natural Resources 3825 Barrett Drive Raleigh, North Carolina 27609-7721 Mr. Henry Barron Group Vice President, Nuclear Generation and Chief Nuclear Officer P.O. Box 1006-EC07H Charlotte, NC 28201-1006 Diane Curran Harmon, Curran, Spielbergy &
Eisenberg, LLP 1726 M Street, NW Suite 600 Washington, DC 20036
DUKE ENERGY CORPORATION 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. 213 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 Corporation, acting for itself, North Carolina Municipal Power Agency No. 1 and Piedmont Municipal Power Agency (licensees), dated February 5, 2005, as supplemented by letter dated February 7, 2005, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's 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 Commission's 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 Commission's regulations and all applicable requirements have been satisfied.
2.
Accordingly, the license is hereby amended by page 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. 213, which are attached hereto, are hereby incorporated into this license. Duke Energy Corporation 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 30 days of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION John A. Nakoski, Chief, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation
Attachment:
Technical Specification Changes Date of Issuance: February 7, 2005
ATTACHMENT TO LICENSE AMENDMENT NO. 213 RENEWED FACILITY OPERATING LICENSE NO. NPF-52 DOCKET NO. 50-414 Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contain marginal lines indicating the areas of change.
Remove Insert 5.5-14 5.5-14
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 213 TO RENEWED FACILITY OPERATING LICENSE NPF-52 DUKE ENERGY CORPORATION, ET AL.
CATAWBA NUCLEAR STATION, UNIT 2 DOCKET NOS. 50-414
1.0 INTRODUCTION
By letter dated February 5, 2005, as supplemented by letter dated February 7, 2005, Duke Energy Corporation, et al. (DEC, the licensee), submitted a request for changes to the Catawba Nuclear Station (Catawba), Unit 2, Technical Specifications (TS). The requested changes would revise the system bypass leakage acceptance criterion for the charcoal adsorber in the 2B Auxiliary Building Filtered Ventilation Exhaust System (ABFVES) train as listed in TS 5.5.11, Ventilation Filter Testing Program. Specifically, DEC requested that the acceptance criterion be changed from 0.05 percent to 0.2 percent for the remainder of the existing operating cycle.
2.0 REGULATORY EVALUATION
2.1 Background
The Catawba, Unit 2 ABFVES consists of two filter trains with fans, two 100 percent capacity heater/demister sections, associated ductwork, and a High Efficiency Particulate Air (HEPA) filter located upstream and downstream of the charcoal adsorber. During accident conditions, the two ABFVES trains will operate as two-100 percent capacity systems. The ABFVES operates in the continuous filtration mode to eliminate a single failure concern associated with operating in the filter bypass mode. DEC believes that operation in this manner increases the reliability and availability of the system.
The majority of the airflow passing through the ABFVES is unheated and the charcoal adsorber is continuously exposed to contaminants and water vapor. This exposure to contaminants and water vapor can affect the retention of R-11 that is utilized in the conduct of an in-place test of the charcoal adsorber. The result would be an increase in the penetration and bypass through the charcoal adsorber.
The ABFVES filters and adsorbs air exhausted from all potentially contaminated areas of the auxiliary building. These areas encompass the Emergency Core Cooling System (ECCS) and non-safety related systems. Upon receipt of a safety injection signal, the ABFVES isolates the non-safety related areas of the auxiliary building, and one train of the ABFVES exhausts air from the ECCS pump rooms.
The licensee would utilize the ABFVES in the event of a loss-of-coolant accident (LOCA) although it does not take credit for the ABFVES in the design basis LOCA radiological consequence analysis. DEC would also use the ABFVES to mitigate the consequences of a rod ejection accident. However, the licensee does take credit for the ABFVES in the calculation of the consequences of a rod ejection accident and for the program that determines the allowable Engineered Safety Feature (ESF) leakage rates.
For the analysis, where DEC took credit for the ABFVES, it assumed that the charcoal adsorber removes 95 percent of elemental iodine and 80 percent of the organic iodine. In addition, the analysis also assumes that the charcoal adsorber has 0.05 percent bypass.
2.2 Applicable Regulations Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix A, General Design Criterion GDC 19, Control Room, requires that adequate radiation protection be provided to permit access to and occupancy of the control room under accident conditions and for the duration of the accident without personnel radiation exposures in excess of 5 rem to the whole body, or its equivalent to any part of the body. 10 CFR 100.11, Determination of exclusion area, low population zone [LPZ] and population center distance, on the other hand, contains dose criteria for the establishment of an Exclusion Area Boundary (EAB) and an LPZ.
In order to meet the above regulatory requirements, licensees install dose mitigating systems, including the ABFVES in this case, and licensees perform evaluations of accident radiation doses. Regulatory guidance for system evaluation is provided in the form of regulatory guides (RG) and Standard Review Plans (SRP) sections. Specific guidance for ESF ventilation systems is provided in RG 1.52, Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants; SRP 6.4, Control Room Habitability System; and SRP 15.4.8, Spectrum of Rod Ejection Accidents (PWR).
3.0 TECHNICAL EVALUATION
3.1 Licensee Assessment DEC assessed the impact of the proposed TS change on the consequences of the LOCA and the rod ejection accident. Since the analyses do not credit the ABFVES for the LOCA, the proposed change has no effect on the LOCA dose consequences.
For the rod ejection accident at Catawba, Unit 2, one contributing pathway to its consequences is that associated with ESF leakage. The dose analysis credits the ABFVES for mitigating the release of ESF leakage. In the analysis, it was assumed that the ABFVES charcoal adsorber efficiencies were 95 percent for removal of elemental iodine and 80 percent for removal of organic iodine compounds. Consequently, DEC assumed that 5 percent of the elemental iodine and 20 percent of the organic iodine in the airflow penetrates or bypasses the ABFVES charcoal adsorbers. In the analysis, the current criterion of 0.05 percent for the Catawba, Unit 2 ABFVES penetration and bypass test was not incorporated into the analyses because its contribution was considered insignificant.
The present licensing basis analysis for this accident for Catawba, Unit 2 shows thyroid doses of 30.7 rem, 19.3 rem, and 8.7 rem for the EAB, LPZ, and control room operators, respectively.
The thyroid dose acceptance criteria for these locations is 75 rem at the EAB and LPZ. It is 30 rem for the control room operators.
For this proposed change to the in-place testing criterion, the licensee reviewed the control rod ejection analysis to determine its impact upon the radiological consequences. DEC assumed that the impact of the increase to 0.2 percent would apply to all contributing pathway doses from the control rod ejection. This assumption was made even though it was recognized that any increase in consequences should apply only to that portion which is treated by the ABFVES charcoal adsorbers. That would be the ESF leakage component.
DECs assessment of the impact of the change to 0.2 percent concluded that the change would have a greater impact upon the elemental iodine releases than upon the releases of the organic forms of iodine. The proposed change would result in an increase of 4 percent (5.2/5) for the elemental constituents and a change of 1 percent (20.2/20) for the organic constituent. DECs assessment applied the impact of a 4 percent increase in doses to individuals located at the LPZ and in the control room. The licensee did not apply the increase to the EAB because the EAB dose is limited to the consequences in the first two hours following the accident. Since ESF leakage would not occur within the first two hours following the accident, the EAB dose would be unaffected by the proposed change.
DEC found that a 4 percent increase in consequences would result in values that were less than the criterion of SRP Sections 15.4.8 and 6.4. Therefore, the licensee concluded that the change was acceptable.
3.2 NRC Staff Assessment The Nuclear Regulatory Commission (NRC) staff has assessed the proposed change to TS 5.5.11.b. Catawba, Units 1 and 2 have different in-place testing requirements because Unit 1 implemented the guidance of Generic Letter (GL) 83-13, Clarification of Surveillance Requirements for HEPA Filters and Charcoal Adsorber Units in Standard Technical Specifications on ESF Cleanup Systems, while Unit 2 implemented the guidance of RG 1.52, Revision 2. The GL was determined to be in error with respect to its guidance for in-place testing of charcoal adsorbers and HEPA filters, therefore, RG 1.52 remains the basis for in-place testing.
The NRC staff has assessed the impact of the proposed change upon the consequences associated with the control rod ejection accident. The resulting change in doses still results in consequences that meet the acceptance criteria presented in SRP Sections 15.4.8 and 6.4.
Therefore, the NRC staff finds that the radiological dose consequences are acceptable.
However, there is a concern on the part of the NRC staff that the failure to meet the acceptance criterion of TS 5.5.11.b may be attributed to the continuous operation of the ABFVES. This operation may be degrading the charcoal adsorber, creating a new bypass path, or further degrading an existing bypass leakage path. DEC reported the results of the laboratory tests for the 2B ABFVES train. In January 2005, the penetration was 0.63 percent, whereas two samples that were laboratory tested in February 2005 showed 0.42 percent and 0.34 percent, respectively. Based upon the laboratory testing acceptance criterion of 4 percent penetration and based upon the fact that the test results remain relatively constant, it would appear that any degradation of the charcoal adsorber due to the continuous operation of the ABFVES is minimal. Furthermore, the licensee has committed to conduct an in-place test within 90 days of the issuance of the amendment. This in-place test should provide additional information as to whether a bypass pathway may be developing or further degrading.
Based upon the fact that the change in radiological analyses consequences is minimal, the NRC staff has concluded that the proposed temporary change to TS 5.5.11.b is acceptable.
4.0 STATEMENT OF EMERGENCY CIRCUMSTANCES Title 10 of the Code of Federal Regulations (10 CFR) Section 50.91, Notice for public comment; State consultation, provides special exceptions for the issuance of amendments when the usual 30-day public notice cannot be met. One type of special exception is an emergency. An emergency can exist when the NRC staff and the licensee need to act quickly in order to prevent the derating or shutdown of a nuclear power plant. For a license amendment involving an emergency, the NRC may issue a license amendment involving no significant hazards consideration without prior notice and opportunity for a hearing or for public comment. In such a situation, the NRC will not publish a notice of proposed determination on no significant hazards consideration, but will publish a notice of issuance under 10 CFR 2.106, Notice of issuance, providing for an opportunity for a hearing and for public comment after issuance.
The licensee requested that the NRC issue this amendment on an emergency basis because the condition was not created by its failure to take timely action. DEC took the 2B ABFVES train out of service for routine maintenance on February 1, 2005. Following the maintenance, the licensee tested the train in accordance with TS 5.5.11.b, as required by the ventilation filter testing program (VFTP). The acceptance criterion for this TS is a penetration/bypass less than 0.05 percent.
The testing, completed on February 2, 2005, showed a penetration of 0.10 percent. DEC performed additional maintenance on the train and performed the testing again. This time, the results showed a 0.14 percent penetration. Because the licensee failed to meet the TS 5.5.11.b criterion, Catawba, Unit 2 entered into TS 3.7.12, Auxiliary Building Filtered Ventilation Exhaust System (ABFVES), required action A.1 on February 1, 2005, at 4:00 a.m. The Action Statement for TS 3.7.12 requires that two trains of ABFVES be restored to OPERABLE status within 7 days or be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The licensee is evaluating the test results and is in the process of obtaining additional equipment to perform further testing. However, if the investigation confirms the previous results, then the only potential corrective measures would be further modification and testing.
Since DEC does not believe that the 2B ABFVES train could be restored within 7 days if it performed these actions, it requested approval of an emergency TS change prior to February 8, 2005, at 4:00 a.m. to avoid shutting down Catawba, Unit 2.
DEC proposed the addition of a footnote to the TS 5.5.11.b acceptance criterion for the Catawba, Unit 2 ABFVES. This footnote would allow the penetration and bypass leakage criterion to be increased from 0.05 percent to 0.20 percent until the Spring 2006 refueling outage for Catawba, Unit 2. At that time, the 2B ABFVES train can be overhauled to restore the bypass leakage to 0.05 percent.
DEC has committed to perform another bypass leakage test of the 2B ABFVES train within 90 days following approval of this emergency TS change. The results of this test will be used to determine if additional actions are required during the current operating cycle.
The licensee could not have anticipated the need for a license amendment under these circumstances that would allow for the 30 day comment period. Additionally, the proposed amendment involves no significant hazards as specified in 10 CFR 50.92. On the basis of the above discussion, the NRC staff has determined that emergency circumstances exist and that the licensee used its best efforts to make a timely application and did not cause the emergency situation.
5.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION
DETERMINATION The Commission's regulations in 10 CFR 50.92(c) state that the Commission may make a final determination that a license amendment involves no significant hazards consideration, if operation of the facility, in accordance with the amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.
The amendment has been evaluated against the three standards in 10 CFR 50.92(c). In its analysis of the issue of no significant hazards consideration, as required by 10 CFR 50.91(a),
the licensee has provided the following:
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
No.
This license amendment request proposes an amendment to the VFTP TS requirements for the 2B ABFVES train. The ABFVES is in operation during normal plant operations. However, the ABFVES is not used in direct support of any phase of power generation or conversion or transmission, shutdown cooling, fuel handling operations, or processing of radioactive fluids. Therefore, it is not an accident initiator. No accident initiators are associated with the change proposed in this license amendment request.
For these reasons, operation of the facility in accordance with this proposed amendment does not involve a significant increase in the probability of any accident previously evaluated.
The changes proposed to the VFTP TS for the 2B ABFVES train will not result in a significant increase in any accident consequences. The change to the penetration value for the charcoal adsorber for the 2B ABFVES train is acceptable because the appropriate safety factors as delineated in the applicable regulatory guideline documents are still maintained. Therefore, the proposed amendment is determined to not result in a significant increase in accident consequences.
Operation of the facility in accordance with the proposed amendment does not involve a significant increase in the consequences of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
No.
This proposed amendment does not involve addition, removal, or modification of any plant system, structure, or component. This change will not affect the operation of any plant system, structure, or components as directed in plant procedures. Operation of the facility in accordance with this amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction in a margin of safety?
No.
Margin of safety is related to confidence in the ability of fission product barriers to perform their design functions following any of their design basis accidents. These barriers include the fuel cladding, the Reactor Coolant System, and the containment.
The performance of these barriers either during normal plant operations or following an accident will not be affected by the changes associated with the license amendment request.
The operation of the ABFVES either during normal plant operations or following an accident will not be affected by implementation of the amendment to its TS.
As described in section 4.0 of Attachment 3, an evaluation of radiological consequences of the design basis LOCA and rod ejection accident at Catawba Nuclear Station has been performed in support of this license amendment request. The input assumptions in the current analyses of record bound this proposed change and the radiological consequences are within the regulatory guideline values with significant margin.
The change proposed to the VFTP TS for the 2B ABFVES train will not result in a significant reduction in the margin of safety. This change is supported by regulatory guidance documents, and is consistent with existing system operation. Operation of the facility in accordance with the proposed amendment does not involve a significant reduction in the margin of safety.
The NRC staff has reviewed the licensee's analysis, and based on this review, has determined that the three standards of 10 CFR 50.92(c) are satisfied. Therefore, the NRC staff finds that the amendment request involves no significant hazards consideration.
6.0 STATE CONSULTATION
In accordance with the Commission's regulations, the South Carolina State official was notified of the proposed issuance of the amendments. The State official had no comments.
7.0 ENVIRONMENTAL CONSIDERATION
The amendments change requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the 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. 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) 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: Jack Hayes Date: February 7, 2005