ML20059G779

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Safety Evaluation Supporting Amends 170 & 108 to Licenses DPR-57 & NPF-5,respectively
ML20059G779
Person / Time
Site: Hatch  Southern Nuclear icon.png
Issue date: 08/30/1990
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20059G777 List:
References
NUDOCS 9009130143
Download: ML20059G779 (12)


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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACT 0'

.EGULATION SUPPORTING AMENDMENT NOS.170 AND 108 i0 FAC LITY OPERATlHG LICENSES DPR-57 AND NPF-5 GEORGIA POWER COMPANY E

OGLETHORPE POWER CORPORATION MUKlCIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON GEORGIA

_EDWIN 1. HATCH NUCLEAR PLANT, OHITS 1 AND 2 DOCKET NOS. 50-321 AND 50-366

1.0 INTRODUCTION

By letter dated March 2,1990 Georgia Power Company, the licensee for the Edwin 1. Hatch Nuclear Plant, proposed changes to the Technical Specifications

-(TSs)forUnits1and2. The ten proposed changes would modify TSs for Units 1 and 2 as follows:

1.

Allow a 24-hour period of time for Unit I to meet the requirements forsingle-loopoperation(SLO)beforeenteringa12-hourshutdown limitingconditionforoperation(LCO).

2.

All w placing an inoperable channel of a requirea Unit 1 Core and Containment Cooling Systen (CCCS) subsystem in the tripped cc.idition or declaring the associated CCCS inoperable within one hour.

3.

Change the Unit 1 definition of Surveillance Requirement to indicate

' that the performance Sf a surveillance requireinent within the specified surveillance interva, constitutes compliance with the operability requirement for an LCO.

4.

Change a number of Unit 1 TSs and associated Bases to delete the re-quirenent to perform additional surveillances when it is determined that the associated redundant components and/or subsystems are operable.

5.

(a) Change Unit 1 TS Table 3.2-8 to specify the requirement for one operable channel per trip system instead of two channels, as now

.specified.

(b) Modify the " Remarks" section to indicate that a trip signal will result in actuation of the Main Control Room Environmental Control System (MCRECS) in the pressurization mode and not in the isolation mode.

9009130143 900830 DR ADOCK 05000321 PDC

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2-(c) Modify TS Table 4.2-8 to delete Logic System Functional Test (LSfT) 6 and change LSFT 5 to MCRECS Control Room Pressurization Mode l

Actuation.

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Delete a number of individual surveillance requirements for pumps and valves, and change testing frequencies and post-maintenance testing requirements in accordance with the testing requirements of the American f

Society of Mechanical Engineers (ASME)Section XI pursu6nt to 10 CFR i

50.55a(g).

-7.

Administrative editorial changes to Unit 1 TSs and associated Bases.

8.

Modify Unit 1 TSs 3.5.J.2.b through 3.5.J.2.e to delete references to H

diesel generators having to be operable and add information requiring thatotherPlantServiceWater(PSW)componentsbeoperable.

9.

Modify Unit 1 TSs 4.5.D.1.b and 4.5.E.1.c to clarify the location for i

measurement of steam pressure supply for the testing of the high pressure coolant injection (HPCI) and the reactor core isolation cooling (RCIC) l systt.M. and to specify the acceptable range of test pressures,

10. Administrativo editortal changes to Unit 2 TSs.

2.0 EVALUATION 2.1 Proposed Change 1 l

-This proposed change would modify Unit 1 TS 3.6.J.3 to allow a 24-hour period oftimetomeettherequirementsforsingle-loopoperation(SLO)beforeentering L

the12-hourshutdownlimitingconditionforoperation(LCO).

The change would make the Unit I requirements for extended SLO consistent with i

the Unit 2 requirements as approved by the NRC on June 10, 1987, in Amendment 77 to the Unit 2 TSs (specifically, Specification 3.4.1.1).

The 24-hour period is mainly to allow time to adjust the flow-biased average power range monitor I

rod block and the simulated thermal power range monitor to account for minor L

changes in the core flow to drive flow relationship in SLO versus two-loop operation.

Prior to approval of continuous SLO, the Unit I and Unit 2 TSs allowed operation with a single pump for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without taking any i

compensatory measures (an analyzed condition). Without the 24-hour time period, operation with one pump imediately puts Unit 1 in e 12-hour shutdown LCO.

Since the proposed change would make the Unit 1 TSs consistent with both the l

l Unit 2 TSs and the BWR/4 Standard Technical Specifications, ar.d since the l

additional time allowed before entry into the 12-hour shutdowr LCO would not l

l place the unit in an un6nalyzed condition, we find this proposed change Lcccptable.

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2.2 Proposed Change 2 l

This proposed change would revise Note *b" to TS Tables 3.2-2, 3.2-3, 3.2-4, i

3.2-5, and 3.2-6 to allow an inoperable channel of a required Unit 1 Core and Containment Cooling System (CCCS) subsystem to be plcted in the tripped condition without declaring the associatea CCCS subsystem inoperable, provided at least one trip system is maintained with the minimum number of channels operable.

l This proposed change would make the Unit I requireinents for operating required CCCS subsystems with inoperable channels in the trip systems consistent with LCO t

r(quirements for Emergency Core Cooling System Actuation Instrunentation and Reactor Core Isolation Cooling System Actuation Instrunentation in Unit 2 TSs 3/4.3.3 and 3/4.3.4, respectively.

Further,theLCOinUnit1TS3.5(Coreend Containment Cooling Systems) assures the operability of CCCS subsystems under all conditions for which this cooling capetility is required. Also, by main-taining the minimum number of operable channels on at 1 cast one trip system with the other system placed in the tripped condition, the single failure criterion as defined in 10 CFR Part SU, Appendix A, will still be satisfied. Accordingly, i

the NRC staff finds this proposed ch6nge acceptable.

j 2.3 Proposeo Change 3 This proposed change would revise the Unit 1 TS Definition JJ, "Surve111ence Requirements," to indicate that perforir.ance of a surveillance requirenent within the specified surveillance interval constitutes compliance with the operability t

requirement for an LCO. The change also woulo revise TS 4.1.A to delete the requirement to functionally test other Reactor Protection System channels that monitor the same variable before the trip system containing the failed channel is tripped. The change would allow credit to be taken for the normal teriodic surveillance as a demonstration of operability and availability of the redundent components and subsystems and is consistent with heth the Unit 2 TSs and the BWR/4 STS.

Implementation of the change would eliminate unnecessary challenges and wear to the redundant con.ponents and subsystems. However, by their submittal of March 17, 1989, the Licensee has requested modification of definition JJ in accordance with GL 87-09. The combination of the previously requested change and the change proposed by this action address the staff position as stated in GL 87-09. Accordingly, the fiRC staff finds this change to be acceptable.

2.4 Proposed Change 4 This proposed change to the Unit 1 TSs would celete the requirements from a number of individual specifications to perform additional surveillances when it is dttermined the associated redundant components and/or subsystems have been found to be inoperable.

Specifir aecifications and changes are as 10110ws:

Specification 4.4.B - Delete the requirement to demonstrate operability of redur. dant Stancby Liquid Control System components when an associated component is 1ound to be inoperable.

Specification 4.5.A.2 - Delete the requirement to demonstrate operability of the other Core Spray (CS) loop and the Residual Heat Removal (RHR) system Low Pressure Coolant Injection (LPCI) mode when it is determined one CS loop is inoperable.

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Specification 4.5.8.2.a - Delete the requirement to descnstrate operability of the reneining LPCI pumps, associated flow paths, and the CS System when one LPCI punip is inoperable.

Specification 4.5.B.2.b - Delete the requirement to denonstrate operability of all active components of the remaining LPCI subsystem and the CS System j

when one LPCI subsystem is inoperabic.

j Specification 4.5.C.2 - Delete the requirenent to denonstrate operability '

i of the remaining active components of both RHR service water subsystems-when one RHR service water pump is inoperable.

l Specification 4.5.C.3 - Delete the requirement to demonstrate operability of the remaining operable RHR service water subsystems when two RHR service weter pumps are inoperable.

Specifict. tion 4.5.D.2 - Delete the requirement to demonstrate operability of the ADS actuation logic, the RCIC System. -the RHR System LPCI mode, and the CS System when the HPCI System is inoperable.

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Specification 4.5.E.2 - Delete the requirement to demonstrate operability I

of the itPCI Systen when the RCIC System is inoperable.

Specification 4.5.F.2 - Delete the requirement to dar.onstrate operability of the HPCI System and the actuation logic of the other Automatic Depres-surization System (ADS) valves when it is determinea one of the seven ADS' I

volves is incapable of automatic operation.

Specification 4.5.G - The licensee proposed to delete the requirement to demonstrate operability cf all the components in the RHR System LPCI mode and containnent cooling mode connected to the operable diesel generatcr when it is determined one of the stancby diesel generators is inoperable.

The str.ff does not agree with the liccnsee deletion request. However, we accept deletion of the phrase "immediately and daily thereafter," and the I

replacement of the word, "denonstrated" with, "verfied."

Specifications 4.5.J.2.b, 4.5.J.2.c, 4.5.J.2.d, 4.5.J.2.e - Delete the l

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reouirements to demonstrate oper6bility of various Plant Service Water (PSW) components end systems whm it is determined associated redundant PSW corrponents and/or systems ' ' inoper6ble.

l Cases for Specification 3.5.A.2 - Revise the wording to indicate additional-surveillance is not required to be performeo when CS components are in-operable. The change also provides additional information indicating that r

optrtbility and availability of recundant components ano subsystems of the l

CS System and the RHR System are demonstrated in Specifications 4.5.A.

4.5.B. 4.5.H. and 4.6.K.

Bases for Specification 3.5.B.2 - Revise the wording to inoicate additional surveillance is not required to be performed when LPCI cortponents are inoperable. The change r*.ao provides edditional information indicating that operability and availability of redundant components and subsystems L

of the LPCI mode and the CS System are demonstrated in Specifications l'

4.5.A 4.5.D, 4.5.H. and 4.6.K.

, Bases for Specification 3.5.D.2 - Revise the wording to indicate additional surveillance is not required to be perforiaed when HPCI components are inoperable.

The change also provides aoditional information indicating that operability and availability of redundant components and subsystems of the CS System, LPCI System, RCIC Systein, and ADS are demonstrated in Specifications 4.5.A. 4.5.B. 4.5.E, 4.5.F. 4.5.H. and 4.6.K.

Bases for Specification 3.5.E.2 - Revise the wording to indicate additional o

surveillance is not requircd to be performed when RCIC components are inoperable. The charge also provides additional information indicoting that operability and availability of redundant components and subsysterns of the HPCI System are demonstrateo in Specifications 4.5.0, 4.5 H and 4.6.K.

Bases for Specification 3.5.F.2 - Revise f.he wording to iudicate additional surveillance is not required to be performed when ADS components are inoperable. The change also provides additional information indicating that operatility and availability of redundant coinponents and subsystems of HPCI and ADS are demonstrated in Specifications 4.5.D. 4.5.F. 4.5.H.

and 4.6.X.

Bases for Specific 6 tion 3.5.J/4.5.J - The change provides acattional inforr.ation indicating that the operability and availability of redundant components and subsystems cf the pSW System are demont>trated in Speci-fications 4.5.J and 4.6.K.

These changes are consistent with Proposed Change 3 and would eliminate unneces-l sary testing of, and challenges to, recundant compenents and subsystems. The 1

reenges woulc n. ale the Unit 1 TSs consistent with the Unit 2 TSs and the BWR/4 ST5c in this reg 6rd.

l Except for RCIC System testing, the proposed surveillance regnirements are those norma Py performed in accordance with ASME Section~Al. pursuant to 10 CFR 50.55e(g). Normal testing required by ASME Section XI is significantly more comprehensive than the present testing requirements identified in the

.J existing Unit 1 TSs. Therefore, the STS approach can be judged to be an equiva-lent or more reliable ter. ting program.

The RCIC System is not currently in the ASME Section XI inservice testing pro-gram for Unit 1.

However, existing Technical Specification 4.5.E.1.c requires pump flow tests every 3 and 18 raor.ths and provides adequate assurance the RCIC system is operable.

The hF.C staff has reviewed these proposed changes and has found them to result in i

.TSs that are consistent with both the Unit 2 TSs and with the BWR/4 51Ss. They are, therefore, acceptable.

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6-2.5 Proposed Change 5 This proposed change to the Unit 1 TSs would revise Table 3.2-8 to change the required operable channels per trip system from 2 to 1 for the Control Room Intake Radiation Monitors tod would revise the " Remarks" section to indicate thatactuationoftheMainControlRoomEnvironmentalControlSystem(MCRECS) woulo be in the control room pressurization mode.

In TS Table 4.2-8, the title of Logic System Functional Test (LSFT) 5 would be changed to "MCRECS Control Room Pressurization Mode Actuation," and LSFT 6 would be deleted.

The installed design has only two channels, one per trip system. The instrument channels are arranged in a one upscale, two downscale trip logic with the trip settings based on lisaiting the radioactivity from eritering the control room f rom the outside.

In the pressurization mode, the MCRECS stops the normal control room exhaust f an and takes in outside air through charco61 filters. The change from 2 to 1 operable channels per trip system corrects the TSs to reflect the actual installed design ano is an editorial type correction. The change to the "Rerasrks" section to indicate that actuction of the MCRECS is in the pressuri-zation mode should have been made at the tiene Amendment 156 was issued, which deleted a previously installed alternate operation 61 modc (recirculation to avoid the possibility of chlorine gas entering the control rcom). This alternate operational mode was removed by Amendment 156 in conjunction with the licensee's elimin6 tion of the potential for release of chlorine gas on site.

This change, therefore, is an acministrative change to make the TSs conform to the present design. The changes to Table 4.2-8 also should have been made at the time Amendment 156 was issued to recognize the delt' tion of the recirculation mode of operation of the MCRECS. They are, thus, administrative in nature.

The NRC staff has reviewed proposed Change 5 and has concluded that the changes are aoniinistrative/ editorial-type changes ano that they are acceptable.

2.6 Prcposed Change 6 This proposed change to the Unit 1 TSs would delete individual surveillance requirements for certain pumps and valves, and change testing frequencies and post-n.aintenance testing requirements in accordance with testing required by ASMESectionXIpursuantto10CFR50.55a(g). Speciiic specifications ano changes are as follows:

Specification 4.5.A.1 - Delete existing Surevillance Requirements 4.5.A.1.c Operability)p Oper6bility) and 4.5.A.1.d (Itonthly Motor-Operated Yalve (Monthly pum

, and add proposed Surveillance Requirement 4.5.A.1.c to verify valve lineups once per 31 days.

Specification 4.5.B.1.a - Change the frequency of the test from "once per 5 years" to "once per 10 years."

Specification 4.5.B.1 - Delete existing Surveillance Requirements 4.5.B.1.d Operability)p Operability) and 4.5.B.1.e (Monthly Motor-0perated Valve, and ad (Monthly Pum valve lineups once per 31 days.

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Specification 4.5.C.1 - Delete existing Surveillance Requirement 4.5.C.1.a (once per 3 months pump and valve operability), and add proposed Surveillance Requirement 4.5.C.I.a to verify valve lineup every 31 days.

Specification 4.5.C.1 - Delete the requirement to perform a pump capacity test after pump maintenance.

Specificat%n 4.5.D.1 - Delete existing Surveillance Requirements 4.5.D.1.d (Monthly Pump Operability) and 4.5.D.1.e (Monthly-Motor Operated Valve Operability Surveillance Requirement), and add proposed Surveillance Re-quirement 4.5.D.1.c to verify proper valve lineup every 31 days.

Specification 4.5.E.1 - Delete existing Surveillance Requirements 4.5.E.1.d (Monthly Pump Operability) and 4.5.E.1.e (Monthly Motor-Operated Surveil-

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lance Requirement), and add proposed Surveillance Requirement 4.5.E.1.d to verify proper valve lird.up every 31 days.

The deletion of indivioual surveillance requirements for pumps and valves and changestotestfrequencyandpost-maintenancetestingrequirementsareallowed t

due to the inservice testing provisions of TSs 3.6.K and 4.6.K.

These specifi-t c6tions require inservice inspection / testing of ASME Code Class 1, 2 and 3 pumps and valves in accordance with Section XI of the ASME Boiler and Pressure Vesselcode,pursuantto10CFR50.55a(g). The testing required by ASME Section Al is significantly more comprehensive than the testing requirements now speci-fied in the existing TSs.

The revised requirements for the RHR, CS, RHR Service Water HPCI and RCIC l

l systems are similar to the requirements in the Unit 2 TSs 6nd the BWR/4 STSs and are acceptable.

2.7 Proposed Change 7

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This proposed change to the Unit 1 TSs would make revisions that are purely editorial in nature. Specific administrative changes made for clarity are as follows:

Specification 4.1, Table 4.1 Delete the requirement for " Reactor Pres-L l

sure Permissive." The basic function of these instrun.ents listed in Table t

l' 4.1-1.was deleted from Specification 2.1.A.5 by Amendment 103. This function required an automatic scram on MSIV closure when the reactor was in the startup/ hot standby mode, and the pressure was above 1045 psig. Since the high-pressure scram is operable for all nodes of operation, this reactor permissive scram was not required.

However, in Amendment 103, the require-ment to perform the surveillance was not deleted from Table 4.1-1.

This change corrects an inadvertcnt omission, is administrative in nature, and has no impact on plant operations or safety.

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'a Specification 4.5.B.1.c - Clarify that the discharge against which the test must be performed is "...a system head corresponding to a reactor vessel pressure of at least 20 psig." Clarifying what discharge pressure is being considered will eliminate any confusion that siay arise over the point of pressure swasurenent.

Specification 3.5.C.1.b - Add the word "or" at the end of the section.

Specification 3.5.D.1.a - Change "1." to "(1)" and "2." to "(2)" to make the section numbering consistent with other sections.

Specification 3.5.D.2 - Clarify what is meant by " adequate reactor steam pressure." The proposed change reads as follows:

... pressure is adequate (i.e., reactor pressure is such that the required steam pressure is main-tained at the turbine for the duration of the test) to perform the tests."

This change will eliminate any possible confusion as to when the 12-hour limitation must start.

Specification 4.5.F.1 - Indent subsections 4.5.F.1.a and 4.5.F.1.b to make the section formatting consistent with other sections.

Specification 4.5.H.2-Aftertheword" inoperable",addacomma(,)to correct a typographical error.

Specification 4.5.H.1 - Change the time from when the high point vents of the Core Spray _ and LPCI Systems must be checked from "Every month prior to the testing of the LPCI and core spray systenis," to "Every month, the discharge piping of the LPCI and core spray systems..." This is an.

editorial-type change to accommodate the changes n.ade to delete monthly surveillance requirenents of valves and pumps in the Core Spray and LPCI Systems.

Bases for Specification 3.5.H - Change wording in the Bases to reflect the editorial changes necessary to accommodate changes made to delete monthly surveillance requirements of valves and pumps in the Core Spray and LPCI Systems.

Specification 6.4.2 - Revise this specification to show who is responsible for each aspect of fire protection. This change is administrative in nature and clarifies the responsibilities for fire protection within the Plant Hatch management organization.

Specification 5.4 of the Unit 1 Environmental Technical Specifications -

Delete the words " effective August 1,1983, through December 5,1987" at the end of the first paragraph. This change eliminates the need to periodically.evise the Environmental Technical Specifications when the effective dates of the NPDES permit change. Since Plant Hatch is re-quired to maintain a current NPDES permit, deleting the effective dates is administrative in nature and has no impact on plant operation or safety.

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l The NRC staff has reviewed these proposed changes and agrees that they are editorial j

i in nature. Accordingly, we find them acceptable.

1 2.8 Proposed Change 8 This proposed change would delete references to the diesel generators having to i

be operable from Unit 1 TSs 3.5.J.2.b through 3.5.J.2.c, and would add infor-mation to require operabilit) of the other PSW components.

The diesel generator operebility is assured by TS 3/4.9 and PSW component opera-

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bility is assured by TS 3.5.J.2.

Equipment operation is not affected, no new i

mcde of f ailure is created, and equipment performance or safety analysis assumptions are not changed.

The proposed changes would m6ke the Unit 1 TSs consistent with both the Unit 2 j

TSs and the EWR/4 STSs, and they are, therefore, acceptable.

2.9 Proposed Change 9 This proposed change would clarify where the pressure of the steam supply is to be measured for testing the HPCI and RCIC turbines, and would specify a range of pressures required for conducting the tests.

.I This change eliminates possible confusion as to the pressure to be measured.

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would nake the Unit 1 TSs consistent with bcth the Unit 2 TSs and the BWR/4 STSs 1

hnd it is, therefore, acceptable.

2.10 Proposed Change 10 q

This proposed change to the Unit 2 TSs would make revisions that are purely l

editorial in nature.

Specific administrative changes made for clarity are as follows:

Specification 3.8.2.5 - In Specifications 3.8.2.5.a. 3.8.2.5.b, and L

3.8.2.5.c, change the word " Circuit" to "Dreaker." The change is a I

correction of terminology and has no impact on the breaker function.

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Specification 3.8.2.5 - In Specification 3.8.2.5.c, change "26" to "20" and "32" to "34."

This change is due to a renumbering of breakers within distribution panels to provide a consistent breaker numbering scheme throughout the plant.

There were no physical hardware changes or changes in breaker function; only breaker nunbers were changed.

Table 3.8.2.6 for type 4 breakers, correct the cable numbers actually L

powered by the circuits which require prtiaary contair. ment penetration I

conductor overcurrent protection. No physical plant changes were made.

Specification 6.4.2 - kevise the specification to show who is responsible for each aspect of fire protectior.. This change clarifies the responsi-bilities f or fire protection within the Plant Hatch management organization.

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E Specification 5.4 of-the Unit 2 Environmental Technical Specifications -

Delete the words " effective August 1,1983 through Dece.nber 5,1987" at the end of the 11rst paragraph. This change eliminates the need to j

periodically revise the Environnental Technical Specifications when the effective dates of the NPDES pcrmit change.

Plant Hatch is required to l

maintain a current NPDES permit at all times.

' Specifications 3.5.1 and 3.7.3 - In ACTION 8, clarify what is adequate reactor steam pressure. The proposed change reads as follows:

... pressure is acequate (i.e., reactor pressure is such that the required steam pressure is maintained at the turbine for the duration of the test) to perform the 1

tests." This change eliminates any possible confusion as to when-the 12-hour limitation must start. Also, in Specification 3.5.1.a. the acronym "HPCl" has been substituted for "high pressure coolant injection."

t Specification 4.6.6.5;1.a - Add the word " isolation" after "...each 18 inch drywell and suppression chamber." In Amendment 58, a new subsection (3/4.6.6.5.1) was added to the TS; however, the word " isolation" was inadvertently omitted.

The staff has reviewed these proposed changes and agrees that they are merely editorial or clarifying in nature. Accorcingly, we find them acceptable.

3.0 ENVIROMiENTAL CONSIDERATION l

These amendnents involve changes in requirements with respect to the instal-iction or use of facility components located within the restricted area as

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defined in 10 CFR Part 20 and changes in surveillance requirements. The staff has determined that the amendments involve no significant increase in the amounts, and no significaot change in the types, of any effluents-that may be, released offsite, and that there is no significant increase in individual or cumulative cccupational radiation exposure. The Consnission has previously issued a proposed finding that the amendments involve no significant hazards consi6eration, and there has been ro public corment on such finding. Accord-ingly..the amendments meet the eligibility criteria for categorical exclusion l

set forth in the 10 CTR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environ-mental impact statement or environmental assessment need be prepared in con-nection with the issuance of the anendnents.

4.0 CONCLUSION

The Cons;ission's proposed determination that the amencn,ents involve no sig-nificant hazards consideration was published in the. Federal Register on May 16, l

1990(55FR20356). The Commission consulted with the State of Georgia. No.

public comments were received, and the State of Georgia did not have any comments.

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L We have concluoed based on the considerations discussed above, that: (1) thereisreasonableassurancethatthehealthandsafetyofthepublicwill not be endangered by operation in the proposed manner, and (2) such activitier will be conducted in colapliance with the Commission's regulations, and the issuance of the amendnents will not be inirical to the cot. mon defense and security or to the health ar.d safety of the public.

Principal Contributors: Lawrence P. Crocker, PDII-3, DFR-I/II, NRR frt.nk Rinaldi, PDII-3, DRP-I/II, NRP.

l Dated:

August 30, 1990

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