ML17345A359

Summary of 880830 Meeting W/Util in Rockville,Md Re Enhancement of Emergency Electrical Power Sys.Attendance List,Meeting Agenda & Handouts Encl

ML17345A359
Person / Time
Site:	Turkey Point
Issue date:	09/07/1988
From:	Edison G Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
TAC-69023, TAC-69024, NUDOCS 8809130109
Download: ML17345A359 (29)

Text

September 7,

198 Docket Nos.

50-250 and 50-251 LICENSEE:

FACILITY:

REFERENCE:

TAC Numbers 69023 and 69024 DISTRIBUTION C~~

NRC 5 Local PDRs PD22 Reading Florida Power and Light Company H. Berkow G. Edison Turkey Point Units 3 and 4

OGC E. Jordan

SUMMARY

OF MEETING HELD WITH FLORIDA POllER AND LIGHT COMPANY (FPSL)

ON AUGUST 30, 1988 REGARDING ENHANCEMENT OF THE EMERGENCY ELECTRIC POWER SYSTEM S.

Varga NRC Participants ACRS (10)

B. Troskoski G. Lainas S.

Varga B. Wilson, R-II A meeting was held in Rockvi lie, Maryland on August 30, 1988 with representa-tives of'lorida Power and Light Company (FP8L) to discuss their plans to improve the emergency electrical power system at the Turkey Point plant.

The plans included the addition of two, full-size emergency diesel generators and their associated electr ical, mechanical, structural, and operations supporting equipment.

The licensee intends to complete all work except electrical tie-in under 10 CFR 50.59.

This includes site preparation, building construction, and placement of equipment.

Electrical design changes (actual modification of the operating plant) will receive a Safety Evaluation (SE) from the NRC staff.

FP8L indicated they will consider a special FSAR update when the modifications are nearly complete.

This would be in addition to the usual annual update.

They will advise us of where this milestone fits into the overall plan submitted on May 27, 1988.

The NRC staff indicated we would need more information about which design codes and criteria are being used before an SE could be issued.

We will issue a

request for information in the next few months.

The NRC staff also indicated we would review the design changes in several technical disciplines, not just electr ica l.

An attendance list, meeting agenda and FP8L handouts depicting the plans and schedule are enclosed.

8a09isoi09 s80~07 1

PDR ADOCK 05000250 p

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Enclosures:

As stated cc w/enclosures:

See next page DMiller GEdison:bg 9/+88 9/g/88 Original signed by Gordon E. Edison, Sr. Project Manager Project Directorate II-2 Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation B

9/P/88

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Mr.

W. F.

Conway Florida Power and Light Company Turkey Point Plant CC:

Harold F. Reis, Esquire Newman and Holtzinger, P.C.

1615 L Street, N.W.

Washington, DC 20036 Mr. Jack Shreve Office of the Public Counsel Room 4, Holland Bui lding Ta'llahassee, Florida 32304 John T. Butler, Esquire

Steel, Hector and Davis 4000 Southeast Financial Center Miami, Florida 33131-2398 Mr. J.

Odom, Vice President Turkey Point Nuclear Plant Florida Power and Light Company P.O.

Box 029100 Miami, Florida 33102 County Manager of Metropolitan Dade County Miami, Flor ida 33130 Resident Inspector U.S. Nuclear Regulatory Commission Turkey Point Nuclear Generating Station Post Office Box 57-1185 Miami, Florida 33257-1185 Jacob Daniel Nash Office of Radiation Control Department of Health and Rehabilitative Services 1317 Winewood Blvd.

Ta1 1ahassee, Flor ida 32399-0700 Intergovernmental Coordination and Review Office of Planning

& Budget Executive Office of the Governor The Capitol Building Tallahassee, Florida 32301 Administrator Department of Environmental Regulation Power Plant Siting Section State of Florida 2600 Blair Stone Road Tallahassee, Florida 32301 Regional Administrator, Region II U.S. Nuclear Regulatory Commission Suite 2900 101 Marietta Street Atlanta, Georgia 30323 Attot ney General Department of Legal Affairs The Capitol Tallahassee, Florida 32304 Plant Manager Turkey Point Nuclear Plant Florida Power and Light Company P.O.

Box 029100 Miami, Florida 33102

ENCLOSURE I ATTENDANCE AT MEETING WITH FPSL ON 8/30/88 TO DISCUSS ENHANCEMENT OF TURKEY POINT ELECTRICAL POWER SYSTEMS NAME G.

E. Edison L. I. Kennedy Daniel Kohler Chris Baker Mark Kobi Thomas C. Grozan Jesus Arias, Jr.

Dominic Tondi Herbert Berkow Argil Toalston ORGANIZARION NRC/NRR FPSL - JPE Electrical FPKL - JPE Project Engineer FPSL - Project General Manager FPEL - JPE Licensing FPKL - Licensing FPSL - PTN NRC/NRR:DEST:SELB NRC/NRR NRC/NRR/DEST/SELB

ENCLOSURE 2

FPL/NRC MEETING EMERGENCY POWER SYSTEM UPGRADE AUGUST 30, 1988 AGENDA o

Introduction T. Grozan o

Emergency Power System Design Report M. Kobi 10 CFR 50.59 Heavy Loads o

Testing M. Kobi EDG Qualification Preoperational Testing o

Safety Evaluation M. Kobi o

Technical Specifications M. Kobi/J. Arias, Jr.

o Station Blackout M. Kobi

P'

ENCLOSURE 3

WORK PLAN OUTLINE August 1988 Submittal 81 EPS Enhancement Report.

This submittal would contain system design/operating information, a discussion of our proposed implementation plan, and a preliminary power distribution system FMEA fh-T ig-YN

- EDG Qualification (300 start test as appropriate)

Preoperational Testing Factory Production Test for EDG's Field Startup Testing Pre-op and Safeguards Testing (Scheduled Issue Date)

(6/20/88)

(9/30/88)

(11/2S/88)

~5 flt-0 i

1 hi include:

Review of FSAR Chapter 10 accidents

- Final EPS FMEA results PRA results (1/31/89)

Submittal f2

- Revised Technical Specifications and No Significant Hazards Evaluation (0/28/89)

Submittal f3

- Station Blackout - This submittal would contain (10/89)

FPL's position and supporting justification for resolution of station blackout.

P Q ~

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I 158 EMERGENCY DIESEL GENERATOR ADDITION MILESTONE SCHEDULE TURKEY POINT PLANT DATA OATE 30 JULY 88 KILESTONES TARGET ACTUAL/

{FORECASTS 1987 J ~ ~ ~ ~ >>>> ~ ~ ~ ~ ~

f. SITE %PAAATIOH 2I2

2. 8UILOIl4>> EfKCTION - 87"259

3. FIRE OET. COOI. "87-261 AIO HVAC

4. FIRE PROTECTION 260 6.

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PC/K ISSUE 87-2I2 87-259 SUP.O 87-259 SUP.I 87-259 SUP.2 87-26I 87-260 87-263 AEV.O 87-263 REV.I 87-263 REV.2 87-257 87-258 87-264 87-265 87-266 87-267 24 FEB 05 APR 23 SEP 14 DEC 23 SEP 13 KAA 27 JAN I2 APA 13 JUN 06 JAN 06 JAN 08 JUN 06 JUN 08 JUN 08 JUN 88 22 KAR 88 88 I8 JUL 88 88 06 OCT 88 88 27 FEB 89 88 I9 OCT 88 89 05 APR 89 89 I3 KAA 89 89 89 89 IO APA 89 89 27 FEB 89 89 IB KAY 89 89 IB KAY 89 89 89 7.

U4 ELEC SYS IHSTKL 257 8.

U3 ELEC SYS INSTALL 258 HlR.&~

9.

U4 'A'OUIP HOOS 264

10. Ui O'OUIP HOOS87-265 13.

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EOUIP HOOS87-266 I4. U3 '8 EOUIP HOOS 210 FLOAIOA POKER C LIGHT CHANT TURKEY POINT UHITS 3 C 4 ltW OIESEL 6EIElllfOA NllES10% SCtEQAE

J August 25, 1988 Docket Nos.

50-250 and 50-251 LICENSEE:

FACILITY:

REFERENCE:

TAC Numbers 63038 and 63039 DISTRIBUTION

.NRC S Local PDRs PD22 Reading Florida Power and Light Company H. Berkow G. Edison Turkey Point Units 3 and 4

OGC-Roc kvi 1 le E. Jordan

SUMMARY

OF MEETING HELD WITH FLORIDA POWER AND LIGHT COMPANY (FP&L) ON AUGUST 18, 1988 REGARDING TECHNICAL SPECIFICATIONS CONVERSION S.

Varga NRC Participants ACRS (10)

B. Troskoski G. Lainas A meeting was held in Rockvi lie, Maryland on August 18, 1988 with representa-tives of Florida Power and Light Company (FPSL) to discuss details of their Technical Specifications Revision Project.

This project is a voluntary effort by FPSL to upgrade their approved Technical Specifications (TS) towards Standard TS to the extent practical.

An initial proposal was submitted by FPSL to the NRC staff on September 29, 1986, followed by the electrical portion on November 28, 1986, with the expectation that detailed discussions with the staff would result in substantial changes to the proposal, and therefore result in a completely revised submittal for NRC staff review.

Previous meetings on this subject were held November 18,

1986, June 17 and 18, 1987, January 9, February 23, and March 28, 1988.

This recent meeting f'ocussed on:

(1) FPSL's efforts to provide comment on the staff's "Proof and Review" draft of revised TS, (2) the process for resolution of differences that may arise, and (3) the process for completion of the TS revision and issuance of a license amendment.

FPSL indicated that they have formed a special team to increase their effort on the TS Revision Project.

The licensee stated they would propose a

new plan in early September 1988 for completion of the project.

Within a week or two of this meeting, the first portions of their comments on the "Proof and Review" draft will be provided to the NRC staff, and the complete formal submittal will be made by September 23, 1988.

Any additional comments related to the technical basis for the revised TS will be incorporated into a "Final Draft" submittal f'ollowing the proof and review phase.

FPSL stated they will not attempt to incorporate into this project any new standard TS that might be developed by the nuclear power industry during the next year or so.

F 8808300265 880825 PDR ADOCK 05000250 P

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A meeting

agenda, attendance list, and FPSL handout materials from the meeting are enclosed.

Enclosures:

As stated Gordon E. Edison, Sr. Project Manager Project Directorate II-2 Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation cc w/enclosures:

See next page LA'M 8/g 88 PM: PDI I-2 GEdi on:bg 8/

/88 0:PR-HBer w

8/3/88

N 11 tl L

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f ll t'

Mr.

W. F.

Conway Florida Power and Light Company Turkey Point Plant CC:

Harold F. Reis, Esquire Newman and Holtzinger, P.C.

1615 L Street, N.W.

Washington, DC 20036 Mr. Jack Shreve Office of the Pub 1 ic Coun se 1 Room 4, Holland Building Ta 1 lahassee, Florida 32304 John T. Butler, Esquire

Steel, Hector and Davis 4000 Southeast Financial Center

Miami, F 1 orida 33131-2398 Mr. J.

Odom, Vice President Turkey Point Nuclear Plant Florida Power and Light Company P.O.

Box 029100

.Miami, Florida 33102 County Manager of Metropolitan Dade County Miami, Florida 33130 Resident Inspector U.S. Nuclear Regulatory Commission Tur key Point Nuclear Generating Station Post Office Box 57-1185 Miami, Florida 33257-1185 Jacob Daniel Nash Office of Radiation Control Department of Health and Rehabilitative Services 1317 Winewood Blvd.

Ta1 1 ahassee, Florida 32399-0700 Inter governmental Coordination and Review Office of Planning 5 Budget Executive Office of the Governor The Capitol Building Tallahassee, Florida 32301 Administrator Department of Environmental Regulation Power Plant Siting Section State of Florida 2600 Blair Stone Road Ta 1 lahassee, Florida 32301 Regional Administrator, Region II U.S. Nuclear Regulatory Commission Suite 2900 101 Marietta Street

Atlanta, Geor gia 30323 Attorney General Department of Legal Affairs The Capitol Tallahassee, Florida 32304 P lant Manager Turkey Point Nuclear Plant Florida Power and Light Company P.O.

Box 029100 Miami, Florida 33102

ENCLOSURE 1

FPL/NRC MEETING AUGUST 18, 1988 AGENDA 1.

FPL PROCESS FOR PROOF 5 REVIEW COMMENTS 2.

INFORMATION NEEDED FOR PROOF 5 REVIEW COMMENTS o

LEVEL OF DETAIL FOR COMMENT JUSTIFICATION (EXAMPLES)

FORMAT (MARKUP WITH SEPARATE JUSTIFICATXON) 3.

RESOLUTION OF COMMENTS o

NRC COMMENT RESOLUTION o

MEET1NGS TO RESOLVE FPL COMMENTS o

NRC TECHNICAL SUPPORT AT REVIEW MEETINGS o

PROCESS FOR RESOLUTION OF ITEMS THAT CANNOT BE RESOLVED BY WORKING GROUP (FPL/NRC TSCB) 4.

INFORMATION NEEDED TO PLAN FOR SUBMITTAL o

LEVEL OF DETAIL IN CURRENT SUBMITTAL o

DESCRIPTION OF CHANGES o

NO SIGNIFICANT HAZARDS EVALUATION

ENCLOSURE 2 ATTENDEES AT MEETING August 18, 1988 hANE 1.

G.

2.

H.

3.

V.

4.

5.

B.

6.

T.

7.

J.

8.

C.

9.

E.

E. Edison N. Berkow A. Kaminskas C, Balaguero P. Burdick C. Grozan Arias, Jr.

Hoon Butcher ORGANIZATION NRC/NRR NRC/NRR FP&L FP&L FP&L FP&L FP&L NRC/NRR/EOEA/OTSB NRC/NRR/EOEA/OTSB

• C. Christensen (Region II) par ticipanted via te1ephone.

I

ENCLOSURE 3

HANDOUT 1 OF 4 INTEROFFICE CORRESPONDENCE To:

Distribution W. F.

Conway

<<L ECT: mRKIX XOINZ REVISI~

TEXSNXCAL SHiCIItUCLTXCN HKQHCI'OCATION:

JNE/JB Augu COPIES TO:

K. N C. O. Woody

'Ihe purpose of this letter is to define the program being implemented for campletion of the Revised Technical Specification (RIS) project.

As discussed in the August 4, 1988 meetirxy at Turkey Point, two teams have been formed to ~rt this effort.

The caaIposition and abjectives of each

team, as well as the efforts required by other organizations to support these teams, is described below.

To complete the FPL review and ensure campletion of the RIS project a team has been established on a full time basis with the following aembership:

Project Manager:

MEmber:

MEariber:

MemI~r:

Meatber:

J. Arias, Jr.

J.

C. Balaguero (Plant Ta9nical)

B. P. Burdick (JPE)

V. A. Kaminslcas (Plant Operations)

P. L. Pace (JNE)

'Ihe objectives of the RlS Team willbe to:

2 ~

3 ~

4 ~

5.

7 ~

8.

9.

10.

Resolve FPI internal cmments on NRC's Proof and Review document t Brief Executive Oversight Cammittee on current status prior to September NRC meeting.

Identify the objectives for the early Septeatber meeting with the NBC.

Establish a schedule, by the early part of Sepbzttber, for RIS campletian.

Review RIS to ensure their consistency with PIN design (technical/accuracy/adequate justification).

Issue camposite set of FPL Proof and Review ccmmeIIts to the NRC by SeptEanber 23, 1988.

This may include partial issuance of camments as they are ccmpleted.

Resolve FPI1/'NRC caaments on Proof and Review with the NRC.

~mre suhnittal of license amendment to NRC. ~ will include representation at. PNSC and CURB.

Make recamaendations for impleaenting the RIS (including training).

Monthly meetings (more often if needed) with the Executive Oversight Cammittee to resolve key issues.

an FPL Group company Form 1008 (Stocked) Rev. 8/86

To provide management guidance and direction to this project an Executive Oversight Committee has been established with the following meanbership:

Chairman:

NemEmr:

Neunber:

hkunber:

Heanber:

Nenher:

J. S.

Odam D. A. Sager (JNE Staff)

J. E. Cmss (Plant Management)

J.

B. Hosmer (JPE)

J. K. Hays (JNL)

F. H. Sauthworth (Plant Technical)

'Ihe objectives of the Executive Oversight Cammittee will be to:

1 0 2.

3 ~

4 ~

5.

6.

Review and approve the RIS Team objectives.

Review and disposition the RXS Tam's recamnandations on key issues.

Neet with NRC Management to resolve issues that cannot be resolved through working level negatiations.

Provide resources for the RIS effort.

Advise senior management of the project status.

Provide feaReck to the RIS Team on senior level discussions with the NRC as they relate to the RIS project.

'Ihis camnLttee will meet as necessary to accamplish these objectives.

In addition to the primary representatives on the RIS

Team, additional personnel will be responsible to pravide support in certain areas of expertise.

Ihese individuals will be contacted by team menhers regarding the review support recpired and the methods the team will use to resolve canments in their areas of expertise.

'Ihese individuals and their assigned areas are as follows:

Nuclear Fuels:

Quality Assurance:

Fire Protection:

Instrumentation

& Control:

Training e D. C. ~eralski L. W. Bladow R. W. Kemmer D. J. Tamaszewski M. Wayland T. A. Finn J.

C. Strong

'Ihe averall theme of the RIS project is to provide Turkey Point with revised Technical Specifications that are technically accurate and issued in a timely fashion.

We have cammitted to provide FPL's ccawents on the NRC's Proof and Review version of the Technical Specifications by September 23, 1988.

'Ihe suocemful completion of this project will require the dedicated effort of these teams and the involved departneats.

W..

y Senior Vice President Nuclear

WFC/PLP/gp itive Oversight Cammttee

?4znbers Support contacts C. A. Pe11 PIN Superirrtendents JNE Staff Managers

• RTS.mdr08/l7/88 START HANDOUT 2 OF 4 Team reviews RTS and comments A

Accepts Comments/Justification Return to Department Head/Supt.

for signature STOP Rejects Comments Accepts Rejection Appeal Notify Department Head Accepts Comment/

Reject Justification Return to Department Head request further justification Approval by Department Head/Supt.

Department Head discuss with Team Rejects Team reviews Reject Accept Document Comment/

Justification Superintendent Approval Chain of Command NRC

HMDOUT 3 OF 4 5+~@~ ~AT'g, FPL CiINAIXMFF/SUSTIF.

PL ADMI TR VE CONTR S

6. 1 RESPONSIBILITY 6.1.1 The Plant Manager - Nuclear shall be responsible for overall unit opera-tion and shall de1egate in writing the succession to this responsibility during his absence.

6. 1.2 The Plant Supervisor - Nuclear (or during his absence from the control

room, a designated individual) shall be responsible for the control room com-mand function.

A management directive to this effect, signed by the Site Vice President - Nuclear Energy shall be reissued to all station personnel on an annual basis.

6. 2 ORGANIZATION ONSITE AND OFFSITE ORGANIZATION X$% ASC 6.2.1 An onsite and an afrite organization shall be or facility 8

operation and corporate management.

The onsite and offsite orga zation shall include the positions for activities affectin the fet of the nuclear power plant.

eh 0 rafetarf a.

Lines of authority, responsib'ility and coaeunication shall be established and defined from the highest management evels through intermediate levels to an including all operating organization positions.

Those relationships shall be documented and updated, as appropriate, in the form of organizational charts.

These organiza-tional charts will be documented in the Topical equality Assurance Report and updated in accordance with 10 CFR 50.54(a)(3).

b.

The Senior Vice President-Nuclear shall be responsible for overall plant nuclear safety, and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.

c.

The Plant Hanager-Nuclear shall be responsible for overall unit safe operation and shall have control over those onsite activities necessary for safe operation and maintenance of the plant.

d.

Although the individuals who train the operating staff and those who carry out the quality assurance functions say report to the appro-priate manager onsite, they shall have sufficient organizational freedom to be independent from operating pressures.

e.

Although health physics individuals aay report to any appropriate manager onsite, for matters relating to radiological health and safety of employees and the public, the health physics manager shall have direct access to that onsite individwl having responsibility for overall unit management.

Health physics personnel shall have the authority to cease any work activity when worker safety is

)eopardized or in the event of unnecessary personnel radiation exposures.

Shleglg 44Y84A5lff TURKEY POINT - UNITS 3 Es I 6-1

h TECH SPEC: 6.2 3USTlFlChTION:

1)

This is sample justification 81.

2)

This is sample justification 82.

HANDOUT 4 OF 4 Tg vicki KxnmpLz NO SIGNIFICANT HAZARDS EVALUATION PROPOSED TECHNICAL SPECIFICATION TITLE:

RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION -

LOW WATER LEVEL NO:

3/4.9.8.2 A.

DESCRIPTION OF CHANGES 1)

Present Condition of License:

As described in the current Turkey Point Unit'3 and 4 Technical Specification in Specification 3. 10'.7.2, Table 4.1-2 Item 18 and 83-10.7.

2)

Proposed Condition of License:

a.

The amendment consolidates the current requirements into this specification and explicitly states the LCO, APPLICABLE MODES, ACTION Limits and SURVEILLANCE REQUIREMENTS.

b.

The revision is more complete than the current Technical Specification as fo ows:

c ~

The surveillance requirement in the revision specifies verification that RHR loop ci rculation flow is at least 3000 gpm.

The current Technical Specification specifies verification of flow but does not specify a value.

The circulation flow which is an alarmed parameter has been exchanged for core outlet temperature which does not alarm in the control room.

The revision elaxes the following current requirement:

The frequency of monitoring the.RHR cooling system operation has been decreased from every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

B.

BASIS FOR NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION:

The standards used to arrive at a proposed determination that the changes described above involve no significant hazards consideration are included in 10 CFR 50.92.

The regulations state that if operation ol. the facility in accordance with the proposed amendment would not:

( 1) involve a

significant increase in the probability or consequences of an accident previously evaluated, or (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, then a

no significant hazards determination can be made.

App.

B 3/4 9-18

Proposed Tech.

Spec.

No. 3/4.9.8.2 The Commission has provided guidance concerning the application of the standards for determining whether a significant hazards consideration exists by providing certain examples (48 FR 14870) of amendments that are considered not likely to involve a significant hazards consideration; Example (i) relates to a purely administrative change to Technical Specifications:

for example, a change to achieve consistency throughout the Technical Specifications, correction of an error, or a change in'omenclature.

Example (ii) relates to a change that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications for example, a more stringent surveillance requirement.

I)

The proposed change as described in Item 2.a is similar to example (i) of 48 FR 14870 in that it is an administrative change which consolidates current requirements into a technical specification format consistent with the Standard Technical Specifications and does not involve technical or plant modifications.

2)

The proposed change as described in Item 2.b is similar to example (ii) of 48 FR 14870 in that it provides additional information by including the required minimum flow from the RHR cooling loop which is an alarmed parameter.

3)

The proposed change to relax the time interval for checking RHR loop cooling operability does not involve a significant hazards consideration because this change would not:

a)

Involve a significant increase in the probability of or consequence of an accident previously evaluated.

By exchanging the temperature measurement for the alarmed flow measurement to determine operability of the requi red RHR loop the probability of losing RHR cooling without being noticed by the operator is less.

The low flow alarm will alert the operator to investigate and restore cooling.

Increasing the surveillance time interval is justified by the continous monitor provided by the low flow alarm.-

b.

Create the possibility of a new or different kind of accident from any previously analyzed because the proposed change introduces no new mode of plant operation nor involves a

physical modification to the plant.

C.

Involve a significant reduction in a margin of safety because one method of monitoring RHR cooling capability is being exchanged for another and is consistent with industry practice in that it is the same as Standard Technical Specifications.

App.

B 3/4 9-19

Proposed Tech.

Spec.

No. 3/4.9.8.2 Based on the above considerations the changes included in the development of proposed Technical Specification 3/4.9.8.2 are considered not to involve a significant hazards consideration as defined in 10 CFR 50.92.

Further, there is reasonable assurance that the health and safety of the public will not be endangered by the propo'sed changes.

App.

B 3/4 9-20

4