ML20010B741

From kanterella
Jump to navigation Jump to search
Summary of 810803 Meeting W/Util in Bethesda,Md Re NRC Concerns Relating to Diesel Generator 1C Failures.Failures Possibly Related to Reg Guide 1.108 Testing.Relevant Tech Specs & Attendance Lists Encl
ML20010B741
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 08/10/1981
From: Reeves E
Office of Nuclear Reactor Regulation
To:
Office of Nuclear Reactor Regulation
Shared Package
ML20010B738 List:
References
NUDOCS 8108170490
Download: ML20010B741 (11)


Text

-

pa ssa

'c, UNI.TED STATES

}S{'k M~ [F %

W.

NUCLEAR REGULATORY COMMISSION

..E wash mGTON, D. C. 20555

c. V4.M

%.% /

AUG10 1531

..e Docket i;os. 50-348 and 50-364 LICE!!SEE:

Alabama Power Company ( APCo)

FACILITY:

Joseph M. Farley iluclear Plant Units 1 and 2 SU:0;ARY OF MEETING HELD ON AUGUST 3,1981 WITH REPRESENTATIVES OF APCo TO DISCUSS NRC STAFF CONCERNS RELATING TO TWO RECENT FAILURES OF DIESEL GENERATOR 1C.

On July 31, 1981, the NRC staff recuested a meeting with management repre-sentatives of APCo at Bethesda, Maryland.

A list of attendees is attached.

The purpose of the meeting veas to discuss NRC staff concerns relating to diesel generator (DG) 1C failures.

The failures resulted in issuance of emergency license amendments on May 8,1981 and on July 31, 1981.

The l

first amendment authorized a 10-day extension in the allowable outage time (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) and the second amendment authorized a 6-day extension.

Both a.nendments related to DG IC which sustained similar type failures (water in cylinder) during attempts to perform surveillance testing.

The sur-l veillance testing was specifically recuired by Technical Specifications and Regulatory Guide (RG) 1.105 which was implenented during licensing of l

Unit !,0.

2.

l The AFCo Vice Fresident of Nuclear Generation, Mr. R. F. Mcdonald, reviewed the situation effectir; diesel generator IC.

The ciesei is one of two Pai rbanks Morse type 350E-1/S, series OP, 2E50 KW, 900 RFM used at Farley site.

Fo rty-e i gnt similar machines are reported to be in service at nuclear facilities.

The Farley site uses three additionai '050 KW diesel cenerators l

in acdition to the two 2550 KW dieseTs for station emercency power.

DG 1C has about 400 cperating hours.

D31C and DS 2C (similar for Unit 2) have had about 150 starts for surveillance testing per RG 1.108 since March,1951.

On May 8,1981 water was found in cylinder #10 of DG 1C.

A cylinder o-ring l

had failed resulting in cooling water entering the cylinder.

The DG 1C had been tested in late April,1981 to requirements of the Technical Specification and RG 1.108.

Part of the testing was a 24-hour load run including 10% over-load for two hours.

APCo reported that due to operator error during tests on DG IC it exceeded the 10% overload value of 2838 KW on two noted occassions to loads of 3500 KW (136%) and 3300 KW (lM), respectively for short periods.

Previously on July 30, 1981 water had been found in cylinder =10 and a failed o-ring was replaced.

Investigation on July 31, 1981 revealed that the piston 8108170490 810810 PDR ADOCK 05000348 P

PDR-

NJG 1 0 1951 connecting rod wrist pin bushing was damaged causing cylinder overheating and other damages.

Repairs included replacement of twelve cylinder liners (new design with two seals vice one), the vertical drive assembly, and pisten rings, etc.

APCo stated that they now considered DG 1C to be in a completely overhauled condition.

Cylinders #1, #3, #5, #9, and #12 had shown leaking into the cylinders during. hydro-tests.

l buse of the failures appear to be the over-load tests which caused the upper wrist-pin bushing f ailures.

Consequently, the piston appeared to have over-heated the cylinder sleeves resulting in o-ring failures.

APCo and the Colt Industries (DG vendor) representative (Mr. J. Tangye) consider that checking

' the measurements of the wrist-pin: bushing extended length may indicate poten-tail for failures of this type.

Therefore, DG 2C, the other DG of this design at, Farley Plant will be che~cked in this manner.

A discus ion ensued relating to the testing to be done prior to accepting DG 1C for service at Farley Site.

APCo and the DG representative will provide l

them to NRC in their follow-up report on the DG failures.

In addition, the DG vendor representative, fir. J. Tangye, stated that he had not previously com-mented on RG 1.108, but the testing per RG 1.10B would not be his recomendation.

He stated that the 72-hour outage time requirement appeared overly restrictive and may result in short-cuts in getting repairs done in a thorough manner.

He advised that the overload testing probably camaged DG 1C at Farley.

As to out-l age time, he agreed that most minor repairs could easily be done within the i

existing 72-hour allcwable outage time.

l In conclusicn, AFCo agreed to provide the following information to the NRC staff:

(i)

Details of the DG 1C failure and repairs accomolishec, l

(2)

Detaile of testing accomplished on DG IC to assure its operability, and (3)

The recent report issued by a s6ecial APCo CG Task Group v.nich includes recomendations for improvements to the DG reliability at Farley Plant.

Items (1) acd (3) were included in the NRC Staff Safety Evaluation Report for License Amendments 21 and 3 for Farley Units 1 and 2 on July 31, 1981.

APCo l

had agreed to provide these reports, w

L /

76 Edaard A: Reeves, Proiect Manager Unit No.1 Operating Reactors, ranch sl, DL r

Attachment:

List of Attendees cc:

w/rttachment i

he next page j

i

)

f MEETING ATTENDANCE M

APCo Farley 1/2 DG 1C Failures August 3, 1981 NAME ORGANIZATION ORB #1/DL/NRR Ed Reeves Joe'Youngblood LBil/DL/NRR John Thoma LB#1/DL/NRR John Tangye Colt Ind./Fairbanks Morse APCo Ron George Al Ungaro

- PSS/PS/DSI 0.D. Kingsley, Jr.

APCo Doug Pickett NRC/ORAS/DL

5. Israel NRC P. Baranowsky NRC M. Srinivasan PSB/DSI S. Varga ORE!1/DL/NRR A. Thadani RRAS/DSI/NRR T. Novak DL/NRR C. Nelson ORES 3/D'/NRR R. P. Mcdonald APCo L

s

,r

.-..m

~_....

i 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES t

OPERATING LIMITING CONDITION FOR OPERATION i

l 3.'8.1.1 As a minimum, the following A.C. electrical power sources shall be-OPERABLE:

a.

Two physically independerat circuits between the offsite transmission network to the swit,chyar.d and two physically independent circuits from the switchyard to the onsite Class 1E distribution system, and l

b.

Two separate and independent diesel generator sets (Set A:

DG 1-2A l

and DG-1C, Set B:

DG-2B and DG-2C) each with:

1.

Separate day tanks containing a minimum volume of 900 gallons of fuel for the 4075 kw diesel generators and 700 gallons of

,. fuel for the 2850 kw diesel generator.

2.

A separate fuel transfer pump for,each diesel.

{

c.

A fuel storage system consisting of four, independent storage tanks each containing a minimum of 25;000 gallons of fuel.*

APPLICASILITY:

MODES 1, 2, 3 and 4.

~

ACTION:

a.

With an offsite circuit inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirements 4.8.1.1.1.a and 4.8.1.1.2.a.4 within ene hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; restore at least two offsite circuits to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDEY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN withirt the folicwing 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, b.

With one diesel generator set inoperable. demonstrate the operability of the remaining A.C. sources by performing Surveillance Requirements 4.8.1.1.1.a and 4.8.1.1.2.a.4 within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.

Restore both diesel generator sets to OPERABLE i

status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or comply with the following:

1)

Be in at least 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 /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

"One inoperable fuel storage tank is equivalent to one inoperable diesel generator set.

FARLEY-UNIT'2 3/4 8-1

..-,-..=:-

~

i:

ELECTRICAL POWER SYSTEMS ACTION (Continued) 2)

One diesel generator set may be made inoperable for up to 14 days to perform scheduled maintenance and testing on diesel generators t

1C (or 2C) provided all the following are satisfied:

4 Unit 1,is i'n MODE 5 or 6 and appropriate technical specifica-a) l tions covering the diesel generator sets are satisfied.

b)

The remaining Unit 2 diesel generators 1-2A, 2B,.1C (or 2C) are OPERABLE.

i c)

The service water system is recirculated to the pond and

]

surveillance requirement 4.7.6.2.1 is verified prior to removind 1C (or 2C) from service and once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.

d)

Diesel Generator IC (or 2C) is returned to 0.:ERABLE status as soon as maintenance is completed.

Otherwise, be in at least 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 /> and in 1

i COLD SHUTDOWN within the following 30 ' hours.

i

~

c.

With.one offsite circuit and one diesel generator set o' the above

['

{

required A.C.. electrical power sources-inoperable,. demonstrate the

(

OPERABILITY of the remaining A.C. sources by performing Surveillance Requirements 4.8.1.1.1. a and 4.8.1.1.2. a.4 within one hour and at l

least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; restore a,t least one of the i

inoperable sources to OPERABLE status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or be in et j

least 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 /> and in COLD SHUTDOWN j

within the.following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Restore at least two offsite '

i circuits and bo.th diesel generator sets to OPERABLE status within j

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from the time of initial less or be in at least HOT STANDBY i

within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> andrin COLD SHUTDOWN within the following 30 i

hours.

i d.

With two of the above required offsite A.C. circuits inoperable, demonstrate the OPERABILITY of both diesel generator sets by 2

performing Surveillance Requirement 4.8.1.1.2.a.4-within one hour i

and at least or.ce per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, unless the diesel j

generators are already operating; restore at least one of the inoperable offsite sources to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least 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 />.

With only one offsite source restored, restore both offsite circuits to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from time of initial loss or be in at least

]

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 /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

F l

1 4

FARLEY-UNIT-2 3/4 8-2

i b

l l

ELECTRICAL PCWER SYSTEMS ACT!ONi (Continued) i I

e.

With both~of the above required diesel generat,r sets inoperable, demonstrate the OPERABILITY of two offsite A.C. circuits by performing Surveillance, Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; restore at least one of the inoperable diesel generator sets to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDEY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD l

SHUTDCWN within the fo11 ewing 30-hours.

Restore both diesel generator sets to OPERAELE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from time of initial loss or be in least* HOT STANDSY.within the next 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 the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVh1LLANCEREOUIREMENTS 4.S.1.11 Eacil of the above. required independent circuits between the offsite transmission network and the ensite Class 1E distr.ibution system shall be:

a.'

Determined OPERAELE at least once per 7 days by verifying correct breaker alignments, indicated power avai-lability, and Demonstrated O' ERABLE at least once per iS,ponths during shutchn by P

b.

transferring unit power supply from the n'ormal circuit to the alternate circuit.

4.5.1.1.2' Each diesel generator shall be demonstrated OPERABLE:

In accordance with the frecuency specifiEd in Table 4.S-1 on a a.

STAGGERED TEST EASIS by:

~

1.

Verifying the fuel leve1 in the ' day tank, 2.

Verifying the fuel level in the fuel storage tanks, 3.

Verifying the fuel transfer pump can be started and transfers-fuei from the storage system to the day tank, l

4.

Verifying the diesel starts from ambient condition and accelerates to at least 900 rpm, for the 2550 kw generator and 514 rpm for the 4075 kw generators, in less than or equal to 10 seconds.

The generator voltage and frequency shall be > 3952 volts and > 57 H: within 10 seconds after the start signal.

5.

Verifying the generator is synchronized, loaded to greater than or equal to its continuous rating, and operates for greater than or equal to 60 minutes, FARLEY-UNIT 2 3/4 8-3

~,

ELECTRICAL POWER SYSTE;is SURVEILLANCE REQUIREMENTS (Continued) l 6.

Verifying the diesel generator is alicned to provide standby power to the associated emergency busses.

b.

At' leist once per 92 days by verifying that a sample of diesel. fuel from the fuel storace tank obtained in accordance with ASTM-D270-65 is within the acceptable limits specified in Table 1 of ASTM-D975-74 when checked for viscosity, water and sediment.

c.

At least once per 18 months by:

1.

Subjectingthelieseltoaninspecticninaccordancewith precedures prepared in conjunction with its manuf acturer's reccmmendatiens for this class of standby service, 2.

Verifyinc the capability to reject a icad of greater than or i

ecual to the larcest sinole icad associated with that diesel

~

_ generator, while maintaining voltage betwcen 3120 and 4910 volts and speed less than or equal to 75% of the difference between nominal speed and the everspeed trip setpoint and verifying recovery to 4160 : 420 volts and 6.0 1.2 H: within 2 seconds.

3.

Verifying the generater capability..to reject a. load equal to

(

its continuous rating withcut trippjcc.

The generator vcitage x

shall net exceed 120% curing and fclicwing the icad rejection.

4 Simulatinc a icss of cffsite power by i~tself, and:

a)

Verifying de-enerci aticn of the emercency busses and.ioad shecding frca the energency busses.

b)

Verifying the diese) starts en the auto start sicnal, energi:es the emeriency busses with permanently connected leads within 10 seconcs,* enerci:es the auto-cennected l

shutccwn Icads thrcugh the load sequencer and cperates for greater than or equal to 5 minutes while its cenerator is loaced with the shutdown leads.

After energization of all loads, the steady ' state voltage and frequency of the emer-gency busses shall be maintained at 4160 + 420 volts and 60 ; 1.2 H2 during this test.

5.

Verifying that on an Safety Injection test signal (withcut loss of offsite pcwer) the diesel generator starts on the auto-start j

signal and operates en standby for greater than or equal to 5 minutes.

The generatcr voltage and frequency shall be > 3952 volts and > 57 Hz within 10 seconds after the auto-start signal; the steady state generator voltage and frecuency shall be main-tained between 4160 : 420 volts and 60': 1.2 H: curina this test.

l

\\

^Energizatien of the Unit 2 emergency bus for diesel 2C is achieved within 24 seconds.

FARLEY-UNIT 2 3/4 S-4 Ament ent No. 1

ELECTRICAL POWIR SYSTEMS SURVEILLANCE REQUIREMENTS (Continue'd) 5.

Simulating a loss of offsite power in conjunction with a Safety Injection test signal, and a')

Verifying de-energi:ation of the emergency busses and. load l

l shedding from the emergency busses.

b)

Verifying the diesel starts frcm ambient condition on the auto-start signal, energizes the emergency besses with permane: tly connectec leads within 10 seconds," energizes the auto-connected emergency (accident) icads through the Icad secue'5cef and cperates for greater than or equal to 5 minutes,while its generater is loaded with the emergency l

leads.

After energization, the steady state voltage and i

frequency of the emergency busses shall be maintained at 4160 t 420 volts and 60 1.2 Hz during this test.

c)

Verifying that all autcmatic diesel generator trips, except engine overspeed and generator differential and low lebe cil pressure, are-automatically bypassed upon icss of voltage on the emergency bus And/or a safety injection test signal.

7.

Verifying the diesel generator cperates for at.least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

During the first 2 hcurs of this ten, the diesel generator shall be leaded to greater than er ecual tc 4474 kw for the 4075 kw dieseis and 3250 for the 2350 ciesels and durine the remaininc 22 neurs of.his test, the diesel generater shall be icaced to j

greater than er equal to 4075 kw fer the 4075 kw diesels and l

2550 kw for the 2550 kw diessis.

Ipmeciately af ter completing this 24 hcur test, perfcrm Specification 4.E.1.1.2.c.4 The generatcr voltage and frecuency shall be 1 3952 volts anc 1 57 Hz within 10 seconds after ;he start signal; the generator voltage and frequency shall te maintainec between 3120 and 4910 volts and 57 and 51.2 H: during this test.*

E.

Verifying that the autc-connected icads tc each diesel generator de not exceed the 2000 reur rating of 4353 kw for the 4075 kw generator and 3100 kw f;;r the 2550 kw generator.

'This survelilance is not recuired for MODE 3 cr a.

This is a one time change to plant cperations prior to initial criticality.

"Energ1:ation of the Unit 2 emergency bus for diesel 2C is achieved within 24 seconds.

FARLEY-UNIT 2 3/4 S-5 Amendment No. 1

ELECTRICAL POWER' SYSTEMS k

SURVEILLANCE REOUIREMENTS (Continued) l 10.

Verifying that with the diesel generator operating in a test me,de (cennected to its bus), a simulated safety injection signal overrides the test mode by returning the diesel generator to standby cperation.

11.

Verifying that the automatic load sequence timer is OPERABLE with each iced sequence time within : iC% of its required value or 0.5 seconds whichever is greater.

12.

Verifying that the felicwing diesel generator lockcut features prevent diesel generator starting enly when'rbquired:

a)

Oil Temperature High (OTH) b)

Coolant Temperature High (CTH) i I

~

Ccolant F essure Lew (CPL) c)

d)

Crankcase Pressure High (CCPH) d.

At least ence,per 10 years or after any modificatiens which could f'/

l af fect ciesei generater interdependence by_. starting the diesel generaters simultaneously, and verifying'that the diesel generators accelerate to at least 500 rpm, for the 2550 kw generater and 514 rpm fer the "C75 kw generater, in less than er egeal to 10 secenes.

4.5.1.1.3 Recorts - All ciesei generater failures, velid er non-valid, shall 1

be repcrtec to the Ccmmissien pursuant to Specification 5.9.1.

Reports of diesel generater f ailures shall include _ tne inf.ormatien reccmmended in Regulatcry Positicn C.3.b of Regulatcry' Guide 1.108, Revision 1, Aucust 1977.

l If the number of failures in the last 100 valid tests (en a per diesel type l

tasis) is greater than or equal to 7, the recort shall be supplemented to incluce the additionai informatien recemmended in Regulatory Pesition C.3.6 of l

l Regulatory Guide 1.10S, Revision 1, August 1977.

k'\\N.

FARLEY-UNIT 2 3/4 S-6

TABLE 4.8-1 DIESEL GENERATOR TEST SCHEDULE Number of Failures In Last 100 Valid Tests

  • Test Frecuency-t At least once per 31 days _

<1 2

At least once per 14 days 3

At least once per 7 days **

>4 At least once per 3 days **

.~

^rriteria for determining number of failures and number of valid tests shall be in accordance with Regulatory Position ~C.2.e of Regulatory Guide 1.108, Revision 1, August 1977, where the last 100 tests are determined on a per diesel type (2 types) basis.

For the purposes of this test schedule, only valid tests conducted after the OL issuance date shall be included in the computation of the "last 100 valid tests."

Entry into this test' schedule

'shall be made at the 31 day test frequency.

    • STAGGERED TEST BASIS not. applicable.

However, only one diesel generator may be tested at a time.

..? LEY - UNIT 2 3/4 8-7

ELECTRIChLPOWERSYSTEMS SHUTDOWN LIMITING CONDITION FOR OPERATION As.. a, minimum, the f ollowing A.C. electrical power sources shall be

3. 8.1. 2 OPERABLE:

One circuit between the offsite transmission network to the switchyard a.

and from the switchyard to the onsite Class lE distribution system, and b.

One 4075 kw diesel generator and one 2850 kw diesel generator each with:

1.

A day tank containing a minimum volume of 900 gallons for the 4075 kw generator and 700 gallons for the 2850 kw diesel generator, 2.

A fuel storage tank containing a minimum volume of 25,000 gallons of fuel, and 3.

A fael transfer pump.

APPLICABILITY:

MODES 5 and 6.

g ACTION:

With less than the above minimum required A.C. electrical power sources OPERABLE, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

SURVEILLANCE REQUIREMENTS 4.8.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1, 4.8.1.1.2" (except for requirement 4.8.1.1.2.a.5) and 4.8.1.1.3.

i

' Surveillance Requirement 4.8.1.1.2.cc7 is not required for MODE 5 or 6.

This is a one time change to plant operations prior to initial criticality.

4 FARLEY-UNIT 2 3/4 8-8 Amendment No. 1