ML20065F146

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Application for Amend to License NPF-57,proposing Changes to Ts,Which Would Establish AOT of 72 Hours for Any One Low Pressure ECCS Injection/Spray Subsystem Inoperable in Addition to Inoperable HPCI Sys
ML20065F146
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 03/31/1994
From: Miltenberger S
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20065F150 List:
References
LCR-94-01, LCR-94-1, NLR-N94022, NUDOCS 9404110246
Download: ML20065F146 (11)
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v Pubhc Service Electric and Gas Company St2ven E. Millenberger Public Service Electric and Gas Company P,0 Box 236, Hancocks Bridge NJ 08038 609-339-1100 Wce Pres; dent and Chief Nuclear Othcor NLR-N94022 LCR 94-01 United States Nuclear Regulatory Commission l

Document Control Desk Washington, DC 20555 I

Gentlemen:

LICENSE AMENDMENT APPLICATION AOT FOR HPCI AND ONE (1) LOW PRESSURE ECCS INJECTION / SPRAY SUBSYSTEM

~ FACILITY OPERATING LICENSE NPF HOPE CREEK GENERATING STATION DOCKET NO. 50-354 This letter submits an application for amendment to Appendix A of Facility Operating License NPF-57 for the Hope Creek Generating Station and is being filed in accordance with 10CFR50.90.

The change that is proposed in this submittal would establish an allowed out-of-service time (AOT) of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for any one low pressure ECCS (Emergency Core Cooling System) injection / spray subsystem inoperable in addition to an inoperable High Pressure Coolant Injection (HPCI) system. contains a detailed description of, and justification for, the proposed change.

Based upon the justification provided,.PSE&G believes that the proposed change does not involve a significant hazard consideration pursuant to 10CFR50.92.

The technical.information contained in Attachment 1 is based upon NUREG-1433, General Electric Company (GE) Standard Technical Specifications for Boiling Water Reactor 4 (BWR/4 STS) Rev. 0 (September 28, 1992).

As this change reflects an NRC approved generic change contained in the BWR/4 STS, PSE&G believes that a detailed NRC branch review or specialist review should.not be required.

. contains marked up Technical Specification pages which reflect the proposed change.

Pursuant.to the requirements of 10CFR50. 91(b) (1), a copy of this request for amendment has been sent to the State of New Jersey.

Upon NRC approval of this proposed change, PSE&G requests that the amendment be made effective on the date of issuance, but implemented within 60 days to provide sufficient time for associated administrative activities.

i}\\{f 9404110246 940331 0000:0

DR ADOCK 0500 4

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MAR 311994 Document Control Desk 2

NLR-N94022 l

i Should you have any questions regarding this request, we will be l

pleased to discuss them with you.

l Sincerely, Affidavit Attachments (2)

C Mr. T.

T.

Martin, Administrator - Region I l

U.

S.

Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr.

J.

Stone, Licensing Project Manager l

U.

S.

Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 l

Mr.

C. Marschall (SO9)

USNRC Senior Resident Inspector Mr.

K.

Tosch, Manager IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 f

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1 REF: NLR-N94022 LCR 94-01 1

I STATE OF NEW JERSEY

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SS.

COUNTY OF SALEM

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l S.

E. Miltenberger, being duly sworn according to law deposes and says:

I am Vice President and Chief Nuclear Officer of Public Service l

Electric and Gas Company, and as such, I find the matters set forth in the above' referenced letter, concerning the Hope Creek Generating Station, are true to the best of my knowledge, information and belief.

N/M i

f Subscribed and Sworn to before me this $f

_ day of 7a/td 1994

, i n l'c o A.

> bwe NotaryPublic[fNewJersey KIMBERLY JO BROWN My Commission expires on

[,9,{pY PUBllC OF NEW JERSEY

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ATTAOMENT 1 PaomSED ORNGES TO TE EDNICE SPECIFICATINS LICDEE NEMMENT APPLICATICN l

N7T RR HPCI AND NE (1) IN HE.EURE EOCS INJECTIN/SIEAY SUEMDI IDPE GEEK GENERATDC MWPIN FNYT'ITY OPERATING LIONSE NPF-57 NIR-N94022 DOGET NO. 50-354 IIR 94-01 I.

IESCRIPPIN OF ME MONSED ORNGES This license amerriment application proposes to change Technical Specification (TS) 3/4.5.1, " Emergency Core Cooling Systems - Operating",

and its associated Bases such that an Allowed Out-of-service Time (ACT) of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is established for any one low pressure ECCS injectiorg/ spray subsystem inoperable in addition to an inoperable HFCI system. Bases Section 3/4.5.1 is revised to reference the BWR/4 STS which justifies the above proposed change to the ECCS - Operating TS.

The proposed TS change described above is consistent with the ECCS - Operating Specifications approved in NURII;-1433, BWR/4 STS.

II.

REA9CN MR T1E PRDNSED ORNGES In the existing ECCS - Operating 7bchnical Specification 3/4.5.1, when the plant is in a cxxviition in which HPCI is inoperable in addition to any other ECCS or the Reactor Core Isolation Cooling (RCIC) system being inoperable, Technical Specification 3.0.3 imediately applies. Technical Specification 3.0.3 requires that Shutdown pro dures be initiated within one (1) hour, the plant be in at least STARIUP within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, at least HCTF SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and at least 00ID SHUTDOWN within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The proposed Technical Specification change would establish an AUT of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for HECI inoperable in addition to any one (1) low pressure injection / spray subsystem, consistent with NURED-1433, IMR/4 STS.

III. 3tEFIFICATICH KR THE IFDFOSED OMNGES A notable difference between the HOGS Technical Specification 3.5.1 and the NUREG-1433 Technical Specification 3.5.1 is the definition of the word subsystem for Iow Pressure Coolant Injection (IPCI). Specifically, HCGS has four (4) IPCI subsystems, each consisting of one (1) 100%

capacity punp. The NUREG-1433 plant has two (2) IECI subsystems, each consisting of two (2) 100% capacity punps. Therefore, two of the HO3S IPCI subsystems are the same as one (1) of the NURDG-1433 plant IPCI subsystem, because each ervv="a two (2) pumps.

In the existing TS 3.5.1, if HNI is found inoperable in Operating Corx11tions 1, 2, ~r 3 with the reactor steam dome pressure greater than 200 psig, given all c,ther ECCS and the RCIC system are operable, the HPCI system must be resto m i to operable status within 14 days or shutdown shall be initiatal. In addition, the IID also requires that with one Page 1 of 7

Attechm:nt 1 LCR 94-01.

AOT for HPCI and One (1) Low Pressure ECCS NLR-N94022 Injection / Spray Subsystem IPCI subsystem inoperable, pmvided that at least one core spray (CS) subsystem is operable, IPCI must be restored to operable status within 30 days. Furthermore, with two LPCI subsystems inoperable, provided that at least one CS subsystem is operable, at least one LPCI subsystem must be restored to operable status within 7 days. With three IICI subsystems inoperable, provided that both CS subsystem are operable, at least two LPCI subsystems must be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

With one CS subsystem inoperable, pmvided that at least two LPCI subsystems are operable, the TS requires that CS nust be restored to operable status within 7 days.

In NUREG-1433, an AOT of 14 days is permitted for HPCI pmvided that RCIC is operable, an ADT of 7 days is permitted for any one low pressure injectiorVspray subsystem inoperable, an ACT of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is permitted for IHCI and one low pressure injection / spray subsystem inoperable coincidentally, and inmediate initiation of shutdown procedures is required when two (2) or more low pressure injectiorVspray subsystem are inoperable.

PSE&G is proposing to incorporate the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> AUT for coincidental inoperability of HPCI and one low pressure injection / spray subsystem, and will retain the existing Aars for one, two,or three LPCI suhaystems inoperable. The justification for this change is based on the following:

The HCGS electrical distribution system that supplies the ECCS equipment with power contains four (4) Emergency Diesel Generators (EDGs) while the electrical distribution system of the NUREG-1433 plant contains only three (3) EDGs. This additional, redundant system adds reliability to the overall electrical distribution system.

In NUREG-1433, the loss of one EDG results in the inoperability of two (2) Iow Pressure Injection (IPCI) pumps or one (1) IICI pump and one (1) 100% capacity CS subsystem, whervas the loss of one EDG at HOGS would only result in the inoperability of one LPCI pump and one-half of a CS subsystem (50%

capacity). Another design feature of the HOGS LPCI system that makes it more reliable than the plant discussed in NUREG-1433 is that the LPCI system injects directly into the reactor vessel via water boxes nounted inside the core shroud. The LPCI system of the NURM-1433 plant injects into the reactor vessel via the recirculation loops, 2 IPCI pumps inject into each recirculation loop. Therefore, following a rupture of a recirculation line, a Design Base Accident Icss of Coolant Accident, the NUREG-1433 plant would lose 2 LPCI punps, while HOGS would maintain all 4 IPCI punps available for injection. The end result is that, following an===d loss of a single EDG electrical system, the HOGS plant is left with much more injection capability than the NUREG-1433 plant. For these reasons:

  • the HOGS ADT for one LPCI subsystem inoperable, given at least one CS subsystem is operable, is 30 days as opposed to 7 days as specified in NURE -1433 and, Page 2 of 7

Attachm:nt 1 LCR 94-01 AOT for HPCI and One (1) Low Pressure ECCS NLR-N94022 Injection / Spray Subsystem

  • the HOGS Aar for two LPCI subsystems inoperable, given at least one m subsystem is operable, is 7 days. mis Aar is the same as the Aar in NURIII-1433 for one (1) LPCI subsystem inoperable.

However, this Aar is less restrictive than the action required in NUREG-1433 for one (1) LPCI subsystem inoperable with one (1) CS subsystan inoperable, which is immdiate entry into Technical Specification 3.0.3., and

% e NUREG-1433 AOIb would be overly conservative for HOGS, since HOGS has four (4) EDGs and four (4) physically separate channels of electrical power, while the NUREG-1433 plant only has 3 EDGs. HCGS has greater capability to supply pcwer to its ECCS in an emergency than the NUREG-1433 plart. Similarly, the incorporation of an ADP of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for HPCI and one low pressure injectiorVspray subsystem as proposed in NUREG-1433 would also be conservative for HOGS.

In the HOGS safety analysis, the small break Icss of Coolant Accident (IOCA) is the design basis event for the HPCI system. S e ucst limiting sirgle failure coincident with a large or small break IDCA is the failuru of the DC source (Channel A) common to the HPCI system, one G subsystem, and one LPCI subsystem. We change made by this subnittal would establish a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Aar for either one LPCI subsystem or one CS subsystem to be incyrable coincident with HPCI beirq inoperable. As dimmesvi above, if an initiating event occurs while in the proposed AOr for the ECCS, the resulting scenario wculd be within the design basis of the HCES. Even with a failure of one CS subsystem while HPCI arxl LPCI are in a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> IID or a failure of one IPCI subsystem while HFCI and CS are in a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 100, HCGS would still be within its design basis it an initiatirg eveat occurred. Adequate ccre coolirq is ensured by the operability of the ADS and the remaining low pressure injection / spray subsystems.

%e loss of feedwater flow transient analyzed in Chapter 15 of the HOGS UFSAR assumes both the HPCI and RCIC system to be operable. We existing TS for HPCI allcw the system to be inoperable for up to 14 days.

Sufficient injection capability is ass" red because the RCIC system will be required to be operable if the HPCI is inoperable. For this transient, the proposed 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> AUT for the HPCI and one low pressure injectiorVspray subsystem inoperable present no challenge greater than the existing 14 day HPCI Aar.

For the steam line breaks outside of containment, the HPCI system is ammv1 unavailable. For feed line breaks outside of containment, either the HPCI or RCIC systems are capable of providing adequate cooling to the vessel to prevent cladding damage. m e RCIC system will be required to be operable during the proposed 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> A0r.

Page 3 of 7

LCR 94 Attachment 1 NLR-N94022 AOT for HPCI ^ and One. (1). Low Pressure ECCS Injection / Spray subsystem 7herefore, a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Aar for HPCI and one low pressure injection / spray subsystem is justified.

c The Core rhmaga Frequency (CDP) at HOGS is calculated based on Probabilistic Risk Anaacenant (PRA) nedala using present Technical Specifications that do not allow silmiltaneous outages of either HPCI and one LPCI subsyste or HPCI and one CS subsystem. The proposed action statment, whidt would allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of plant operation with the HPCI syste inoperable coincident with one low pressure E003 injectiorVspray subsystm (IPCI or CS) inoperable, was determined to have a potential inpact on 28 of the core riamary sequences. These 28 core damage sequences were requantified with a new model-(based on the proposed action statement that would allow the simultaneous outage). The affects on the CDF of the 28 sequences were daamed to be negligible.- All sequences remained below a CDF of 1E-10. This outcome is expected, since having HPCI and one low pressure injectiorVspray subsystem inoperable for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> still leaves five low pressure injectioryspray subsystems and the RCIC system available.

Finally, inpleentation of this proposed change would reduce untmacaary plant shutdowns without ccumensurate effects on safety and minimize associated challenges to safety systems.

IV.

SIGNIFICANP HA7ARDS CENSIEERATICN EVAIIRTICN PSE&G has, pursuant to 10 CFR 50.92, reviewed the proposed amendment to determine whether the request involves a significant hazards consideration. We have determined that operation of the Hope Creek Generating Station in accordance with the proposed changes:

1.

Will not involve a significant irauxase in the probability or

~

consequences of an widant previously evaluated.

The proposed charga establishes a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Allowed Out-of-Service Time (AUT) for ooincidental High Pressure Coolant Injection system (HPCI) and one low pressure injectiorVspray subsystem inoperability, in acmrdance with NURDG-1433. In addition, PSE&G will justify retaining the existing HOGS AJfs for one, two, and three Iow Pressure Coolant Injection'(LPCI) subsystems inoperable.

The HOGS electrical distribution system that supplies the EOCS (Emergency Core Cooling System) equipnent with power contains four (4) Emergency Diesel Generator (EDGs).while the electrical distribution system of the NUREG-1433 plant contains only three (3)

EDGs.. This additional, redurdant system adds reliability to the overall electrical distribution system. In NUREG-1433, the loss of one EDG (Emergency Diesel Generator) results in the inoperability of

-two (2) Iow Pressure Injection (IPCI) punps or one (1) IPCI and one (1) 100% capacity CS subsystem, whereas the loss of one EDG at HOGS would only result in the inoperability of one LPCI punp and one-half of a Cs subsystem (50% capacity). Another design feature.

of the HOGS LPCI system that makes it more reliable than the plant dia-aea in NUREG-1433 is that the LPCI system injects directly Page 4 of 7

Attachmrnt 1 LCR 94-01 l

AOT for HPCI and One (1) Low Pressure ECCS' NLR-N94022 Injection / Spray Subsystem l

into the reactor vessel via water boxes mounted inside the core shroud. 'Ibe IICI system of the NUREG-1433 plant injects into the reactor vessel via the recirculation loops, 2 IlCI pumps inject into each reciru11ation loop. 'Iherefore, follwing a rupture of a recirculation line, a Design Base Accident Ioss of Coolant Accident, the NURFE-1433 plant would lose 2 LPCI subsystems, while HCGS would maintain all 4 LPCI subsystems available for injection. 'Ihe end result is that, following a m - d loss of a single EDG electrical system, the HCGS plant is left with much more injection capability than the NUREG-1433 plant. For these reasons:

  • the HOGS AOr for two LPCI subsystems inoperable, given at least one CS subsystem is operablie, is 7 days. 'Ihis AOT is l

the same as the AOr in NUREG-1433 for one (1) IlCI subsystem inoperable. However, this Aar is less restrictive than the action required in NURIE-1433 for one (1) IICI subsystem inoperable with one (1) CS subsystem inoperable, which is inmxliate entry into Technical Specification 3.0.3., and

NUREG-1433 would be overly conservative for HCGS, since HOGS has i

four (4) EDGs and four (4) physically separate channels of electrical power, while the NUREG-1433 plant only has 3 EPCs. HOGS

)

has greater capability to supply power to its ECCS in an emergency than the NUREG-1433 plant. Similarly, the incorporation of an AOP of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for HPCI and one low pressure injectiory' spray subsystem as proposed in NUREG-1433 would also be conservative for HOGS.

In the HCGS safety analysis, the small break IDCA is the design basis event for the HPCI system. 'Ihe most limiting sirgle failure coincident with a large or small break IDCA is the failure of the DC source (Channel A) cormon to the HPCI system, one CS subsystem, and one LPCI subsystem. 'Ihe change made by this submittal would establish a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> ADT for either one LPCI subsystem or one G subsystem to be inoperable coincident with HPCI being inoperable.

As disemi above, if an initiating event occurs while in the proposed Aar for the ECX5, the resultirg scenario would be within the design basis of the HOGS. Even with a failure of one G subsystem while HECI and LPCI are in a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> IfD or a failure' of one LPCI subsystem while HECI and G are in a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> IDO, HCGS would still be within its design basis if an initiatirg event occurred. Adequate core cooling is ensured by the operability of the ADS and the remainirg lw pressure injectiory' spray subsystems.

Page 5 of 7

Attachm:nt 1 LCR 94-01 AOT for HPCI and One (1) Low Pressure ECCS NLR-N94022 Injection / Spray subsystem

'Ihe loss of feedwater flow transient analyzed in Chapter 15 of the HCGS UFSAR assumes both the HPCI and RCIC systems to be operable.

The existify TS for HPCI allows the system to be inoperable for up l

to 14 days. Sufficient injection capability is assured because the RCIC system will be required to be operable if the HPCI is inoperable. For this transient, the proposed 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> AOr for the HPCI arx1 one low pressure injection / spray subcystem inoperable presents no challenge greater than the existirq 14 day HPCI Aar.

For the steam line breaks outside of containment, the HPCI system is assumed unavailable. For feed line breaks outside of containment, either the HPCI or RCIC systems are capable of providing adequate cooling to the vessel to prevent cladding d = ga.

The RCIC system will be required to be operable during the proposed 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Aar.

The Core Damage Frequency (CDF) at HOGS is calculated based on Probabilistic Risk Assessment (PRA) models using present Technical Specifications that do not allow simultaneous outages of either HPCI and one LECI subsystem or HPCI and one CS subsystem.

The proposed action statement, which would allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of plant operation with the HPCI system inoperable coincident with one low pressure ECCS injectiorg/ spray subsystem (LPCI or CS) inoperable, was determined to have a potential inpact on 28 of the core damage sequences. These 28 core damage sequences were requantified with a new nxx3el (based on the proposed action statement that would allow the simultaneous outage), and none of the frequencies of the 28 sequences were significantly affected.

In addition, the probability of an accident is not affected because no physical modifications are being made to the plant.

Finally, inplementatiors of this proposed charge would reduce unncessary plant shutdowns without commensurate effects on safety and minimize associated challenges to safety systems.

2.

Will not create the possibility of a new or different kind of accident fran any accident previously evaluated.

Establishing an Aar of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for the HPCI system inoperable in addition to any ane (1) low pressure injection / spray subs'ystem does not alter the function of the equipuent nor involve any type of plant modification. Additionally, no new modes of plant operation are involved with these changes.. The pwssed change therefore will not create the possibility of a new or different kirri of accident fran any accident previously evaluated.

3.

Will not involve a significant Irvir+1ert in a margin of safety.

The basis for this statement is outlined in item 1 above.

Page 6 of 7

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LCR 94-01 l

AOT for HPCI and One (1) Low Pressure ECCS NLR-N94022 i

Injection / Spray Subsystem V.

gt!CIUSION As discussed above, PSE&G has concluded that the proposed changes to the Technical Specifications do not involve a significant hazards i

consideration since the changes: (1). do not involve a significant increase in the probability or consequences of an accident previously evaluated,- (ii) do not create the possibility of a new or different kind of accident frun any accident previously evaluated, and (iii) do not involve a significant reduction in a margin of safety.

I VI.

REMiRt2GS 1.

NUREG-1433, Standard Technical Specifications for General Electric Plants, IMR/4, dated September 1992.

l l

2.

Memorandum from R. L. Baer (NRC) to V. Stello, Jr. (NRC),

"Pa 4 - a-rded Interim Revisions to LOOS for ECXE Camponents,"

December 1, 1975.

3.

PSE&G Internal Memorandum SCI-94-0048 frun Jeff Isary, Nuclear l

Engineering Sciences, to L. Castagna, Nuclear Licensing, dated January 20, 1994.

Page 7 of 7

LCR 94-01 l

AOT for HPCI and One (1) Low Pressure ECCS NLR-N94022 l

. Injection / Spray Subsystem-l ATIAQ MENT 2 TE0NICAL SPIIHFICATION PAGES WI'lli PEN AND INK MANGES LIONSE AMENDENT APPLICATICE 94-01, NIR-N94022 SIT /AOf EXfENSICNS RR SEIECIED INSTRLMENIWfION FAcrim OPERATING IICENSE NPF-57

' IOPE CREEE GENERATING SIATICN DOCKEff NO. 50-354

'Ihe followirg Technical' Specifications have been revised to reflect the proposed changes:

Tecnnical Specification Page 3.5.1.c 3/4 5-3 3/4.5.1 Bases B 3/4 5-2 i

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