ML20137Y794

Proposed Tech Specs 3.0 & 4.0 Re Applicability of LCO & Surveillance Requirements,Per GL 87-09

ML20137Y794
Person / Time
Site:	Brunswick
Issue date:	04/14/1997
From:	CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML20137Y791	List: BSEP-97-0144, Suppl to Application for Amends to Licenses DPR-71 & DPR-62, Revising Tech Specs 3.0 & 4.0 & Respective Bases for Sections to Incorporate Guidance Contained in NRC GL 87-09 ML20137Y794
References
GL-87-09, GL-87-9, NUDOCS 9704230236
Download: ML20137Y794 (12)

Text

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l ENCLOSURE 3 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 SUPPLEMENT TO REQUEST FOR LICENSE AMENDMENTS 4 APPLICABILITY AND SURVEILLANCE REQUIREMENTS l

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l 9704230236 970414 PDR ADOCK 05000324:

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APPLICABILITY '

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SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL

, CONDITIONS or other specified conditions in the Applicability for individual l Limiting Conditions for Operation, unless otherwise stated in the Surveillance '

! Requirement. Failure to meet a Surveillance, whether such failure is l j experienced during the performance of the Surveillance or between performances '

4 of the Surveillance, shall be failure to meet the Limiting Condition for i '

Operation. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the Limiting Condition for Operation except as l provided in Technical Specification 4.0.3. Surveillances do not have to be

. performed on inoperable equipment or variables outside specified limits.

4.0.2 Each Surveillance Requirement shall be performed within the specified i

time interval with a maximum allowable extension not to exceed 25% of the surveillance interval.  ;

4.0.3 If it is discovered that a Surveillance was not performed within its 1 4

specified Frequency, then compliance with the recuirement to declare the Limiting Condition for Operation not met may be celayed, from the time of  ;

discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency. '

whichever is less. This delay period is permitted to allow performance of the l Surveillance.

a If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the

applicable Condition (s) must be entered.

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When the Surveillance is performed within the delay period and the i Surveillance is not met, the Limiting Condition.for Operation must immediately

be declared not met, and the applicable Condition (s) must be entered. I

, 4.0.4 Entry into an OPERATIONAL CONDITION or other specified applicable state i shall not be made unless the Surveillance Requirement (s) associated with the Limiting Condition for Operation have been performed within the applicable i surveillance interval or as otherwise specified.

, 4.0.5 Surveillance Requirements for inservice ins]ection and testing of ASME l Code Class 1, 2 and 3 components shall be applica31e as follows: '

a

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a. Inservice inspection of ASME Code Class 1, 2 and 3 components and

, inservice testing of ASME Code Class 1. 2. and 3 pumps and valves .

shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required- 4 l by 10 CFR 50. Section 50.55a(g). except where specific written 4 relief has been granted by the Commission pursuant to 10 CFR 50.

Section 50.55a(g) (6) (i).

i BRUNSWICK - UNIT 1 3/4 0-2 Amendment No.

APPLICABILITY

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BASES 4.0.1 Systems and components are assumed to be OPERABLE when the associated Surveillance Requirements have been met. Nothing in this Specification.

however, is to be construed as implying that systems or components are OPERABLE when;

a. The systems or components are known to be inoperable, although still meeting the Surveillance Requirements; or

b. The requirements of the Surveillance (s) are known to be not met between required Surveillance performances.

Surveillances do not have to be performed when the unit is in an OPERATIONAL CONDITION or other specified condition for which the requirements of the associated Limiting Condition for Operation are not applicable, unless otherwise specified. The Surveillance Requirements associated with a Special Test Exceptions Limiting Condition for Operation are only applicable when the Special Test Exceptions Limiting Condition for Operation is used as an allowable exception to the requirements of a Specification.

Surveillances, including Surveillances invoked by Required Actions, do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply. Surveillances have to be met and performed in accordance with Technicai Specification 4.0.2. prior to returning equipment to

' OPERABLE status.

1 Upon completion of maintenance, appropriate post maintenance testing is l required to declare equipment OPERABLE. This includes ensuring applicable '

Surveillances are not failed and their most recent performance is in l accordance with Technical Specification 4.0.2. Post maintenance testing may not be possible in the cL rent OPERATIONAL CONDITION or other specified conditions in the Ap]licability due to the necessary unit parameters not having been establis1ed. In these situations. the equipment may be considered OPERABLE provided testing has been satisfactorily _ completed to the extent l possible and the equipment is not otherwise believed to be incapable of l performing its function. This will allow operation to proceed to an '

GPrRATIONAL CONDITION or other specified condition where other necessary post maintenance tests can be completed.

Some examples of this process are:

a. Control Rod Drive maintenance during refueling that requires scram testing at > 800 psi. However. if other appropriate testing is satisfactorily completed and the scram time testing of Technical Specification 4.1.3.2 is satisfied, the control rod can be considered OPERABLE. ~This allows startup to proceed to reach 800 psi to perform other necessary testing.

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BRUNSWICK - UNIT 1 B 3/4 0-2 Amendment No.

. APPLICABILITY

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BASES 4.0.1 (Continued)

b. High pressure coolant injection (HPCI) maintenance during shutdown that recuires system functional tests at a specified pressure.

Providec other appropriate testing is satisfactorily completed, startup can proceed with HPCI considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing.

4.0.2 The provisions of this specification provide allowable tolerances for performing surveillance activities beyond those specified in the nominal surveillance interval These tolerances are necessary to provide operational flexibility because of schedulirq and performance considerations. The phrase "at least" associated with a surveillance frequency does not negate this f allowable tolerance value and permits the performance of more frequent surveillance activities. It is n ? intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillance that are not performed during refueling outages.

The tolerance value is sufficiently restrictive to ensure that the reliability associated with the surveillance activity is not significantly degraded beyond that obtained from the nominal specified interval.

4.0.3 Technical Specifications 4.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variabie outside the specified limits when a Surveillance has not been completed within the s)ecified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of t1e specified Frequency, whichever is less, applies from the point in time J that it is discovered that the Surveillance has not been oerformed in accordance with Tchnical 3pecification 4.0.2 and not at the time that the specified Frequency was not. met.

This delay period provides adecuate time to complete Surveillances that have been missed. This delay perioc permits the completion of a Surveillance before complying with Required Actions or other remedial measures that mignt preclude completion of the Surveillance.

2 The basis for this delay aeriod includes consideration of unit conditions, adequate planning, availa)ility of personnel, the time required to perform the Surveillance, the safety significace of the delay in completing tne required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

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When a Surveillance with a Frequency ba' sed not on time intervals, but upon specified unit conditions or operational situations, is ch /ered not to have been performed when specified. Technical Specification 4.0.3 allows the full delay period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform the Surveillarce.

Technical Specification 4.0.3 also provides a time limit for completm of Surveillances that become applicable as a consequence of OPERATIONAL CONDITION changes imposed by Required Actions.

..JT 1 B 3/4 0-3 Amendment No.

BRUNSWICK

l APPLICABILITY BASES 4.0.3 (Continued)

Failure to comply with specified Frequencies for Surveillance Recuirements is expected to be an infrequent occurrence. Use of the delay perioc established l

by Technical Specification 4.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals.

If a Sur'eillance is not completed within the allowed delay period, then the equipmen'; is considered inoperable or the variable is considered outside the specificd limli.s and the Completion Times of the Required Actions for the applicaole Limiting Condition for Operation begins immediately upon expiration l of the delay period. If a Surveillance is failed within the delay period.

l then the equipment is inoperable, or the variable is outside the specified l limits and the Completion Times of the Required Actions for the applicable l Limitin Condition for Operation begins immediately upon the failure of the l Surveil ance.

Completion of the Surveillance within the delay period allowed by this i Specification, or within the Completion Time of the ACTIONS. restores  ;

compliance with Technical Specification 4.0.1.

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l This specification incorporates the guidance provided in Generic Letter 87-09.

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! 4.0.4 This specification ensures that surveillance activities associated with i

a Limiting Condition for Operation have bee aerformed within the specified time interval prior to entry into an applica)le CONDITION. The intent of this l

' provision is to ensure that surveillance activities have been satisfactorily demonstrated on a current basis as required to meet the OPERABILITY requirements of the Limiting Condition for Operation.

! Under the terms of this specification, for example, during initial plant  !

l start-up or following extended plant outage, the applicable surveillance l

activities must be performed within the stated surveillance interval prior to placing or returning the system or equipment into OPERABLE status. Exceptions to some surveillance activities have been provided for in individual speci fications.

4.0.5 This specification ensures that inservice inspection of ASME Code Class

1. 2, and 3 components and inservice testing of ASME Coda Class 1, 2, and 3 pumps and valves will be performed in accordance with a periodically updated version of Section XI of the ASME Boiler and Pressure Vessel Code and Addenda as required by 10 CFR 50. Section 50.55a. Relief from any of the above requirements has been provided in writing by the Commission and is not a part of these technical specifications.

l This specification includes a clarification of the frequencies for performing the ins;rvice inspection and testing activities required by Section XI of the ASME Bei L r and Pressure Vessel Code and applicable Addenda. This clarificationisgrovideatoensureconsistencyinsurveillanceintervals throughout these iechnical Specifications and to remove any ambiguims

relative to the frequencies f ar performing the required inservice inspection and testing activities.

BRUNSWICK - UNIT 1 B 3/4 0-4 Amendment No.

PPLICABILITY BASES 4.0 5 Under the terms of this specification, the more restrictive requirements of the Technical Specifications take precedence over the ASME Boiler and Pressure Vessel Code and applicable Addenda. For example, the requirements of Specification 4.0.4 to perform surveillance activities prior to entry into an OPERATIONAL MODE or other specified applicability condition takes precedence over the ASME Boiler and Pressure Vessel Code provision which allows pumps to be tested up to one week after return to normal operation. And, for example, the Technical Soecification definition of OPERABLE does not grant a grace period before . device that is not capable of performing its specified function is declared inoperable and takes precedence over the ASME Boiler and Pressure Vessel Code provision which allows a valve to be incapable of performing its specified function for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before being declared inoperable.

This specification includes a statement that the Inservice Inspection Program for pipe covered by the scope of GL 88-01 will be in conformance with the staff positions on schedule, methods and personnel, and sample expansion included in GL 88-01.. This requirement may be removed from the technical specifications in the future in line with the Technical Specification Improvement Programs.

BRUNSWICK - UNIT 1 B 3/4 0-5 Amendment No. I

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!' ' l I J r . ,

i ENCLOSURE 4 i

l' . BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 i l' OPERATING LICENSE NE. DPR-71 AND DPR-62 i SUPPLEMENT TO REQUEST FOR LICENSE AMENDMENTS

. APPLICABILITY AND SURVEILLANCE REQUIREMENTS j

4 l

4 j.

i 1

1

)

1 l

1 i

l TYPED TECHNICAL SPECIFICATION PAGES - UNIT 2 i

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APPLICABILITY

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SURVEILLANCE REQUIREMENTS l 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL CONDITIONS or other specified conditions in the Applicability for individual Limiting Conditions for Operation, unless otherwise stated in the Surveillance Requirement. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances I of the Surveillance, shall be failure to meet the Limiting Condition for 0)eration. Failure to perform a Surveillance within the specified Frequency  ;

slall be failure to meet the Limiting Condition for Operation except as l provided in Technical Specification 4.0.3. Surveillances do not have to be performed cn inoperable equipment or variables outside specified limits. I 1

4.0.2 Each Surveillance Requirement shall be performed within the specified time int uval with a maximum allowable extension not to exceed 25% of the surveillance interval.

4.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the recuirement to declare the Limiting Condition for Operation not met may be celayed, from the time of discovery, up to 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.s or up to the limit of the specified Frequency, whichever is less. This delay period is permitted to allow performance of the Surveillance.

If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable Condition (s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately I be declared not met, and the applicable Condition (s) must be entered. I 4.0.4 Entry into an OPERATIONAL CONDITION or other specified applicable state {

shall not be made unless the Surveillance Requirement (s) associated with the Limitina Cont.ition for Operation tave been performed within the applicable surveilkn& interval or as otherwise specified.

4.0.5 Surveillance Requirements 'or inservice ins)ection and testing of ASME Code Class 1, 2. and 3 components shall be applica)le as follows:

a. Inservice inspection of ASME Code Class 1. 2. and 3 l components and inservice testing of ASME Code Class 1. l

2. and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and i Pressure Vessel Code and applicable Addenda as '

required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the  ;

Commission pursuant to 10 CFR 50. Section 50.55a(g) '

(6) (i).

BRUNSWICK - UNIT 2 3/4 0-2 Amendment No.

APPLICABILITY BASES l

4.0.1 Systems and components are assumed to be OPERABLE when the associated Surveillance Requirements have been met. Nothing in this Specification. I however, is to be construed as implying that systems or components are OPERABLE when:

a. The systems or components are known to be inoperable, although still l' meeting the Surveillance Requirements: or

b. The requirements of the Surveillance (s) are known to be not met between required Surveillance performances. '

Surveillances do not have to be performed when the unit is in an OPERATIONAL CONDITION or other specified condition for which the requirements of the associated Limiting Condition for Operation are not applicable, unless otherwise specified. The Surveillance Requirements associated with a Special i

Test Exceptions Limiting Condition for Operation are only applicable when the  ;

Special Test Exceptions Limiting Condition for Operation is used as an i allowable exception to the requirements of a Specification.

1 Surveillances, including Surveillances invoked by Required Actions, do not '

have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply. Surveillances have to be met r,1d performed in accordance with Technical Specification 4.0.2, prior to returning equipment to OPERABLE status.

Upon completion of maintenance, appropriate post maintenance testing is I required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with Technical Specificatica 4.0.2. Post. maintenance testing may not be possible in the current OPERATIONAL CONDITION or other specified conditions in the Applicability due to the necessary unit parameters not having been established. In these . situations, the equipment may be considered OPERABLE provided testing has beer. satisfactorily completed to the extent possible and the equipment-is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to an  !

OPERATIONAL CONDITION or other specified condition where other necessary post maintenance tests can be completed.

Some examples of this process are:

a. Control Rod Drive maintenance during refueling that requires scram testing at > 800 psi. However, if other appropriate testing is satisfactorily completed and the scram time testing of Technical Specification 4.1.3.2 is satisfied, the control rod can be considered OPERABLE. This allows startup to proceed to reach 800 psi to perform other necessary testing.

BRUNSWICK - UNIT 2 B 3/4 0-2 Amendment No.

.- , i 1

APPLICABILITY

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BASES 4l0.1.(Continued) i

b. High pressure coolant injection (HPCI) maintenance during shutdown that recuires system functional tests at a specified pressure.

Providec other appropriate testing is satisfactorily completed, startup can proceed with HPCI considered OPERABLE. This allows operation to reach the specified pressure to complete the i necessary post maintenance testing.

4.0.2 The provisions of this specification arovide allowable tolerances for performing surveillance activities beyond t1ose specified in the nominal i surveillance interval. These tolerances are necessary to provide operational i flexibility because of scheduling and performance considerations. The phrase  !

"at least" associated with a surveillance frequency does not negate this I allowable tolerance value and permits the performance of more frequent surveillance activities. It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that i specified for surveillance that are not performed during refueling outages.  :

The tolerance value is sufficiently restrictive to ensure that the reliability associated with the surveillance activity is not significantly degraded beyond that obtained from the nominal specified interval.

4.0.3 Technical Specifications 4.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the '

specified limits when a Surveillance has not been completed within the s]ecified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of t1e specified Frequency, whichever is less, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with Technical Specification 4.0.2 and not at the time that the specified Frequency was not met.

This delay period provides adequate time to complete Surveillances that have i been missed. This delay period permits the completion of a Surveillance l before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance.

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions or operational situations, is discovered not to have been performed when specified. Technical Specification 4.0.3 allows the full delay period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform the Surveillance.

Technical Specification 4.0.3 also provides a time limit for completion of Surveillances that become applicable as a consequence of OPERATIONAL CONDITION changes imposed by Required Actions.

BRUNSWICK - UNIT 2 B 3/4 0-3 Amendment No.

APPLICABILITY l

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BASES 410.3 '(Continued)

Failure to comply with specified Frequencies for Surveillance Recuirements is l expected to be an infrequent occurrence. Use of the delay perioc established by Technical Specification 4.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals.

If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable Limiting Condition for Operation begins immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable Limiting Condition for Operation begins immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with Technical Specification 4.0.1.

This specification incorporates the guidance provided in Generic Letter 87-09.

4.0.4 This specification ensures that surveillance activities associated with a Limiting Condition for Operation have bee ]erformed within the specified time interval prior to entry into an applica)le CONDITION. The intent of this provision is to ensure that surveillance activities have been satisfactorily demonstrated on a current basis as required to meet the OPERABILITY requirements of the Limiting Condition for Operation.

Under the terms of this specification, for example, during initial plant start-up or following exteaded plant outage, the applicable surveillance activities must be performed within the stated surveillance interval prior to placing or returning the system or equipment into OPERABLE status. Exceptions to some surveillance activities have been provided for in individual specifications.

4.0.5 This specification ensures that inservice inspection of ASME Code Class

1. 2. and 3 components and inservice testing of ASME Code Class 1. 2, and 3 pumps and valves will be performed in accordance with a periodically updated version of Section XI of the ASME Boiler and Pressure Vessel Code and Addenda as required by 10 CFR 50, Section 50.55a. Relief from any of the above requirements has been provided in writing by the Commission and is not a part of these technical specifications.

This specification includes a clarification of the frequencies for performing the inservice inspection and testing activities required by Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda. This clarification is provided to ensure consistency in surveillance intervals throughout these Technical Specifications and to remove any ambiguities relative to the frequencies for performing the required inservice inspection and testing activities. l l

BRUNSWICK - UNIT 2 B 3/4 0-4 Amendment No. l I

APPLICABILITY

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BASES  !

4 .'0. 5 iContinued)

Under the terms of this specification. the more restrictive requirements of the Technical Specifications take precedence over the ASME Boiler and Pressure Vessel Code and applicable Addenda. For example the requirements of j Specification 4.0.4 to perform surveillance activities prinr to entry into an OPERATIONAL MODE or other specified applicability condition takes precedence over the ASME Boiler and Pressure Vessel Code provision which allows pumps to be tested up to one week after return to normal operation. And, for example.

the Technical Specification definition of OPERABLE does not grant a grace {

period before a device that is not capable of performing its specified  !

function is declared inoperable and takes precedence over the ASME Boiler and Pressure Vessel Code provision which allows a valve to be incapable of

. performing its specified function for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before being declared inoperable.

This specification includes a statement that the Inservice Inspection Program for pipe covered by the scope of GL 88-01 will be in conformance with the staff positions on schedule, methods and personnel, and sample expansion included in GL 88-01. This requirement may be removed form the technical specif ications in the future in line with the Technical Specification Impro/ement Programs.

+

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BRUNSWICK - UNIT 2 B 3/4 0-5 Amendment No. I