ML082340629

Issuance of Amendments Regarding Removing Notes Associated with Amendment Nos. 230 and 221 Regarding an Alternate Method to Monitor Rod Position for a Rod with an Inoperable Analog Rod Position Indication During Specified.

ML082340629
Person / Time
Site:	Turkey Point
Issue date:	09/30/2008
From:	Mozafari B Plant Licensing Branch II
To:	Stall J Florida Power & Light Co
Mozafari B, NRR/ADRO/DORL, 415-2020
Shared Package
ML082340646	List: ML082340629 ML082720002
References
TAC MD9229, TAC MD9230
Download: ML082340629 (15)

Text

September 30, 2008 Mr. J. A. Stall Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420

SUBJECT:

TURKEY POINT UNITS 3 AND 4 - ISSUANCE OF AMENDMENTS REGARDING REMOVING NOTES ASSOCIATED WITH AMENDMENT NOS. 230 AND 221 REGARDING AN ALTERNATE METHOD TO MONITOR ROD POSITION FOR A ROD WITH AN INOPERABLE ANALOG ROD POSITION INDICATION DURING THE SPECIFIED FUEL CYCLES (TAC NOS. MD9229 AND MD9230)

Dear Mr. Stall:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 238 to Renewed Facility Operating License No. DPR-31 and Amendment No. 233 to Renewed Facility Operating License No. DPR-41 for the Turkey Point Plant, Units 3 and 4, respectively.

The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated September 5, 2007, as supplemented by letter dated September 8, 2008.

These amendments remove the notes associated with Turkey Point Unit 4 License Amendment No. 221 regarding the inoperability of the Unit 4 Rod Position Indication (RPI) system for control rod F-8 in Shutdown Bank B and the notes associated with Turkey Point Unit 3 Amendment No.

230 regarding the inoperability of the Unit 3 RPI system for control rod M-6 in Control Bank C.

The RPI system for control rod F-8 was repaired during the Unit 4 Cycle 22 refueling outage in spring 2005; thus the associated TS License Amendment No. 221 revisions are no longer required. Similarly, the RPI system for control rod M-6 was repaired in June 2007; thus, the associated TS License Amendment No. 230 revisions are no longer required.

J. Stall A copy of the related safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely,

/RA/

Brenda L. Mozafari, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251

Enclosures:

1. Amendment No. 238 to DPR-31

2. Amendment No. 233 to DPR-41

3. Safety Evaluation cc w/enclosures: See next page

ML082340629 TS Pages: ML082720002 Package: ML082340646 OFFICE LPL2-2/PM LPL2-2/PM LPL2-2/LA ITSB/BC OGC NLO LPL2-2/BC NAME TOrf BMozafari BClayton RElliott LSubin TBoyce DATE 8/26/08 8/26/08 8/26/08 9/8/06 9/16/09 9/22/08 OFFICE NRR LPL2-2/PM NAME ELeeds BMozafari DATE 09/24/08 09/24/08 Florida Power and Light Company TURKEY POINT PLANT cc:

Mr. Mano Nazar Senior Vice President Attorney General and Nuclear Chief Operating Officer Department of Legal Affairs Florida Power & Light Company The Capitol P.O. Box 14000 Tallahassee, Florida 32304 Juno Beach, FL 33408 Michael Kiley M. S. Ross, Managing Attorney Plant General Manager Florida Power & Light Company Turkey Point Nuclear Plant P.O. Box 14000 Florida Power and Light Company Juno Beach, FL 33408-0420 9760 SW. 344th Street Florida City, FL 33035 Marjan Mashhadi, Senior Attorney Florida Power & Light Company Olga Hanek, Licensing 801 Pennsylvania Avenue, NW. Florida Power and Light Company Suite 220 Turkey Point Nuclear Plant Washington, DC 20004 9760 SW. 344th Street Florida City, FL 33035 William Jefferson, Jr.

Site Vice President Don E. Grissette Turkey Point Nuclear Plant Vice President, Nuclear Operations, Florida Power and Light Company South Region 9760 SW. 344th Street Florida Power and Light Company Florida City, FL 33035 P.O. Box 14000 Juno Beach, FL 33408-0420 County Manager Miami-Dade County Abdy Khanpour 111 Northwest 1 Street, 29th Floor Vice President, Engineering Support Miami, Florida 33128 Florida Power & Light Company P.O. Box 14000 Senior Resident Inspector Juno Beach, FL 33408-0420 Turkey Point Nuclear Plant U.S. Nuclear Regulatory Commission Mark E. Warner 9762 SW. 344th Street Vice President, Nuclear Plant support Florida City, Florida 33035 Florida Power & Light Company P.O. Box 14000 Mr. William A. Passetti, Chief Juno Beach, FL 33408-0420 Department of Health Bureau of Radiation Control Peter Wells, Acting VP, Nuclear 2020 Capital Circle, SE, Bin #C21 Training and Performance Improvement Tallahassee, Florida 32399-1741 Florida Power & Light Company P.O. Box 14000 Mr. Craig Fugate, Director Juno Beach, FL 33408-0420 Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100

FLORIDA POWER AND LIGHT COMPANY DOCKET NO. 50-250 TURKEY POINT PLANT UNIT NO. 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 238 Renewed License No. DPR-31

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

A. The application for amendment by Florida Power & Light Company (the licensee) dated September 5, 2007, as supplemented by letter dated September 8, 2008, 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 3.B of Renewed Facility Operating License No. DPR-31 is hereby amended to read as follows:

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 238, are hereby incorporated into this renewed license. The Environmental Protection Plan contained in Appendix B is hereby incorporated into this renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Thomas H. Boyce, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Operating License and Technical Specifications Date of Issuance: September 30, 2008

FLORIDA POWER AND LIGHT COMPANY DOCKET NO. 50-251 TURKEY POINT PLANT UNIT NO. 4 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 233 Renewed License No. DPR-41

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

A. The application for amendment by Florida Power & Light Company (the licensee) dated September 5, 2007, as supplemented by letter dated September 8, 2008, 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 3.B of Renewed Facility Operating License No. DPR-41 is hereby amended to read as follows:

(B) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 233, are hereby incorporated in the license. The Environmental Protection Plan contained in Appendix B is hereby incorporated into the license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This licensee amendment is effective as of its date of issuance and shall be implemented within 60 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Thomas H. Boyce, Chief Plant Licensing Branch II-2 Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Operating License and Technical Specifications Date of Issuance: September 30, 2008

ATTACHMENT TO LICENSE AMENDMENT AMENDMENT NO. 238 RENEWED FACILITY OPERATING LICENSE NO. DPR-31 AMENDMENT NO. 233 RENEWED FACILITY OPERATING LICENSE NO. DPR-41 DOCKET NOS. 50-250 AND 50-251 Replace Page 3 of Renewed Operating License DPR-31 with the attached Page 3 Replace Page 3 of Renewed Operating License DPR-41 with the attached Page 3.

Replace the following pages of the Appendix A Technical Specifications with the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the area of change.

Remove pages Insert pages 3/4 1-17 3/4 1-17 3/4 1-18 3/4 1-18 3/4 1-20 3/4 1-20 3/4 1-20a 3/4 1-20a 3/4 1-21 3/4 1-21 3/4 1-25 3/4 1-25 3/4 1-26 3/4 1-26

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 238 TO FACILITY OPERATING LICENSE NO. DPR-31 AND AMENDMENT NO. 233 TO FACILITY OPERATING LICENSE NO. DPR-41 FLORIDA POWER AND LIGHT COMPANY TURKEY POINT NUCLEAR PLANT, UNIT NOS. 3 AND 4 DOCKET NOS. 50-250 AND 50-251

1.0 INTRODUCTION

By letter dated September 5, 2007, as supplemented by letter dated September 8, 2008, Florida Power & Light (licensee) requested U.S. Nuclear Regulatory Commission (NRC) approval of changes to the Turkey Point Units 3 and 4 Technical Specifications (TS). The proposed amendment removes the notes associated with Turkey Point Unit 4 License Amendment No. 221 regarding the inoperability of the Unit 4 Rod Position Indication (RPI) system for control rod F-8 in Shutdown Bank B and the notes associated with Turkey Point Unit 3 Amendment No. 230 regarding the inoperability of the Unit 3 RPI system for control rod M-6 in Control Bank C. The supplemental letter provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staffs original proposed no significant hazards consideration determination as published in the Federal Register.

On August 20, 2004, the NRC issued License Amendment 221 for Turkey Point Unit 4 which modified TS 3/4.1.3.1, "Movable Control Assemblies," TS 3/4.1.3.2, "Position Indication Systems-Operating," TS 3/4.1.3.5," Shutdown Rod Insertion Limit," to allow the use of an alternate method of determining rod position for control rod F-8 in Shutdown Bank B until the end of Cycle 21. The RPI system for control rod F-8 was repaired during the Unit 4 Cycle 22 refueling outage in Spring 2005; thus the associated TS License Amendment 221 revisions are no longer required.

On October 5, 2006, the NRC issued License Amendment 230 for Turkey Point Unit 3 which modified TS 3/4.1.3.1, "Movable Control Assemblies," TS 3/4.1.3.2, "Position Indication Systems-Operating," TS 3/4.1.3.6," Control Rod Insertion Limits," to allow the use of an alternate method of determining rod position for control rod M-6 in Control Bank C until the end of Cycle 22. The RPI system for control rod M-6 was repaired in June 2007; thus the associated TS License Amendment 230 revisions are no longer required.

2.0 REGULATORY EVALUATION

Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The licensee provides TSs in order to maintain the operational capability of structures, systems and components that are required to protect the health and safety of the public. The Commission=s regulatory requirements related to the content of the TS are contained in 10 CFR 50.36. The TS requirements will include the following categories: (1) safety limits, limiting safety systems settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls.

General Design Criterion (GDC) 13 in Appendix A to 10 CFR Part 50 requires that instrumentation and appropriate controls be provided to monitor and maintain the variables and systems within their prescribed operating ranges during normal operation, anticipated operational occurrences, and accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems.

3.0 TECHNICAL EVALUATION

The analog rod position indication (ARPI) system functions to monitor control rod position and, thereby, ensures control rod alignment and insertion limits are maintained. This is necessary to achieve the purpose of the rod control system, which is to ensure that acceptable power distributions as well as minimum shutdown margins (SDM) are met, and that the potential effects of a rod misalignment on associated accidents are limited.

The TSs for the ARPI system provide LCOs and SRs to ensure system operability, as required by 10 CFR 50.36. Further, TSs 3.1.3.1, 3.1.3.2, 3.1.3.5, and 3.1.3.6, respectively, require the shutdown and control rods to be operable and within the alignment limits, the ARPI and the Demand Position Indication systems to be operable, the shutdown rods to be fully withdrawn, and the control bands to be within the power-dependent Rod Bank Insertion Limits defined in the Core Operating Limits Report (COLR) during Modes 1 and 2 operation and, therefore, comply with GDC 13.

With the ARPI for a control rod inoperable, LCO 3.1.3.2 Action a(1) requires the position of the rod to be determined 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 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after any rod motion that exceeds 24 steps in one direction.

During Cycle 21 for Unit 4 and Cycle 22 for Unit 3, an ARPI became inoperable for an extended period and compliance with the TSs would have required excessive use of the movable incore detector system to monitor rod position. The NRC granted amendments that allowed an alternate method of determining rod position until the ARPI could be repaired, but no later than the subsequent refueling outage. The alternate method and its time limit were contained in footnotes that were added to the applicable TSs. Since the ARPIs were subsequently repaired and the applicable time periods have elapsed, the licensee proposes to delete these footnotes.

This is effectively an administrative change, since the alternate method was a temporary addition to the existing TSs, and deleting it does not affect the ability of the TSs to satisfy

regulatory requirements and ensure system operability. Therefore, the NRC staff finds the proposed change acceptable.

The NRC staff notes that in the intervening period between the request and approval of this amendment, the staff approved Amendments 237 and 232 to the subject licenses, which provided, on a permanent basis, wording that fulfilled the intent of the text that this amendment removes. Therefore, the notes are not only unnecessary, but also redundant.

The specific changes to the Unit 3 and Unit 4 TSs are as follows:

Unit 4 Technical Specification Changes The proposed Unit 4 Technical Specification changes, regarding the removal of the notes for control rod F-8 in Shutdown Bank B, are summarized below.

For TS Limiting Condition for Operation (LCO) 3.1.3.1, Movable Control Assemblies, delete the indications for the note "**" and the following note is removed:

"** During Unit 4 Cycle 21, the position of Rod F-8 Shutdown Bank B will be determined every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state, until the repair of the indication system for this rod is completed."

For TS Surveillance Requirement of 4.1.3.1.1, the indications for the notes "*" and "**" and the following notes are removed:

"* During Unit 4 Cycle 21, the position of Rod F-8 Shutdown Bank B will be determined every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state, until the repair of the indication system for this rod is completed."

"** During Unit 4 Cycle 21, the position of Rod F-8, Shutdown Bank B, may be monitored by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state and it will not provide an input into the Rod Position Deviation Monitor. The use of the alternate method for rod F-8 does not require the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> comparison of demanded versus actual position per 4.1.3.1.1."

For TS LCO 3.1.3.2, Position Indicating Systems - Operating, the indications for the note "*" and the following note are removed:

"* During Unit 4 Cycle 21, the position of Rod F-8 Shutdown Bank B will be determined every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state, until the repair of the indication system for this rod is completed."

For TS Surveillance Requirements 4.1.3.2.1, and 4.1.3.2.2, the indication for the notes "*" and the following notes for are removed:

"* During Unit 4 Cycle 21, the position of Rod F-8 Shutdown Bank B will be determined every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state, until the repair of the indication system for this rod is completed."

"** During Unit 4 Cycle 21, the position of Rod F-8, Shutdown Bank B, may be monitored by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state and it will not provide an input into the Rod Position Deviation Monitor. The use of the alternate method for rod F-8 does not require the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> comparison of demanded versus actual position per 4.1.3.1.1."

For TS Surveillance Requirement 4.1.3.5, Shutdown Rod Insertion Limit, the indication for the note "***" and the following note are removed:

"*** During Unit 4 Cycle 21, the position of Rod F-8 Shutdown Bank B will be determined every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state, until the repair of the indication system for this rod is completed."

Unit 3 Technical Specification Changes The proposed Unit 3 Technical Specification changes, regarding the removal of the notes for control rod M-6 in Control Bank C, are summarized below.

For TS LCO 3.1.3.1, Movable Control Assemblies, the indication for the note "**" and the following note is removed:

"** During Unit 3 Cycle 22, the position of Rod M-6 Control Bank C will be determined every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state, until the repair of the indication system for this rod is completed."

For TS Surveillance Requirement of 4.1.3.1.1, the indications for the notes "*" and "**" and the following notes are removed:

"* During Unit 3 Cycle 22, the position of Rod M-6 Control Bank C will be determined every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state, until the repair of the indication system for this rod is completed."

"** During Unit 3 Cycle 22, the position of Rod M-6, Control Bank C, may be monitored by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state and it will not provide an input into the Rod Position Deviation Monitor. The use of the alternate method for rod M-6 does not require the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> comparison of demanded versus actual position per 4.1.3.1.1."

For TS LCO 3.1.3.2, Position Indicating Systems - Operating, the indication for the note "*" and the following note are removed:

"* During Unit 3 Cycle 22, the position of Rod M-6 Control Bank C will be determined every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state, until the repair of the indication system for this rod is completed."

For TS Surveillance Requirements 4.1.3.2.1, and 4.1.3.2.2, the indication for the notes "*" and the following notes for are removed:

"* During Unit 3 Cycle 22, the position of Rod M-6 Control Bank C will be determined every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state, until the repair of the indication system for this rod is completed."

"** During Unit 3 Cycle 22, the position of Rod M-6, Control Bank C, may be monitored by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state and it will not provide an input into the Rod Position Deviation Monitor. The use of the alternate method for rod M-6 does not require the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> comparison of demanded versus actual position per 4.1.3.2.1."

For TS Surveillance Requirement 4.1.3.6, the indication for the note "***" and the following note are removed:

"*** During Unit 3 Cycle 22, the position of Rod M-6, Control Bank C, may be monitored by verifying gripper coil parameters of the Control Rod Drive Mechanism to determine it has not changed state. "

The NRC staff finds that these proposed changes effectively delete the unnecessary footnotes and are acceptable.

4.0 STATE CONSULTATION

Based upon a letter dated May 2, 2003, from Michael N. Stephens of the Florida Department of Health, Bureau of Radiation Control, to Brenda L. Mozafari, Senior Project Manager, U.S. Nuclear Regulatory Commission, the State of Florida does not desire notification of issuance of license amendments.

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 change surveillance requirements. The Commission has made a final no significant hazards finding with respect to this amendment. 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. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration published in the Federal Register on July 29, 2008, (73 FR 43956). A request for a hearing was filed on August 18, 2008, by Thomas Saporito, President of Saporito Energy Consultants.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that (1) the amendment does not: (a) involve a significant increase in the probability or consequences of an accident previously evaluated; or, (b) create the possibility of a new or different kind of accident from any previously evaluated; or, (c) involve a significant reduction in a margin of safety and therefore, the amendment does not involve a significant hazards consideration; (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (3) such activities will be conducted in compliance with the Commission's regulations, and (4) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: Brendan Moroney Tracy Orf Date: September 30, 2008