ML20151C278

Proposed Tech Specs Changing Section 6 Re Administrative Controls

ML20151C278
Person / Time
Site:	Hope Creek
Issue date:	07/12/1988
From:	Public Service Enterprise Group
To:
Shared Package
ML20151C263	List: ML20151C260 ML20151C278
References
NUDOCS 8807210296
Download: ML20151C278 (15)

Text

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INDEX ADMINISTRATIVE CONTROLS SECTION PAGE 6.1 R E S P0 N S I B I t. I TY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6-1

6. 2 ORGANIZATION...................................................

y 6-1 6*2*1 " +-->

C.ONSITEAND6ffSlifDWA02Aflti$***''''''''''''''''*** 6-1 6.2.2 UNIT STAFF................................................ 6-1 V

F i gu re 6. 2.1-1 M+ u,-ernan+7atten-L(.MI . . . . . . . . . . . 6-3 e,

F i gu re 6. 2. 2- 1 Ithri t-6.n i zattorr.1 I?E,L,gD,)............... 6-4 Figure 6.2.2-2 Minimum Shift Crew Composition Single Unit Facility..................... 6-5 6.2.3 SHIFT TECHNICAL ADVIS0R................................... 6-6 6.3 UNIT STAFF QUALIFICATIONS.....,................................ ,

6-6 6.4 TRAINING....................................................... 6-6

6. 5 REVIEW AND AUDIT............................................... 6-6 6.5.1 STATION OPERATIONS REVIEW COMMITTEE'(S0RC)................ 6-6 FUNCTION ................................................. 6-6 COMPOSITION .............................................. 6-7 ALTERNATES................................................ 6-7 MEETING FREQUENCY ........................................ 6-7 QU0RUH.................................................... 6-7 RESPONSIBILITIES ......................................... 6-7 i I

REVIEW PR0 CESS........................................ ... 6-8 l

AUTHORITY..........................................,....... 6-9 l

RECOR05................................................... 6-9 HOPE CREEK xxiv Amendment No.

8807210296 880712 PDH P ADOCK 05000354 '

PDC

6.0 ADMINISTRATIVE CONTROLS s

6.1 RESPONSIBILITY 6.1.1 The General Manager - Hope Creek Operations shall be responsible for overal) unit operation and shall delegate in writing the succession to this responsibility during his absence.

6.1.2 The Senior Nbelear Shift Supervisor or during his absence from the control roca., a designated individual shall be responsible for the control room p v command function. A management directive to this effect, signed by thelvice---I

-fPres+ dent--"=rk:Hshall be reissued to all station personnel on an annual basis.

H senior corporate nuclear officer )

6.2 ORGANIZATION INSERT 1 f ,.172...

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---be- a s de ,a -en-fi atn r-6-t.-M--- 1 UNIT STAFF subject to the following: l g 6.2.2 The unit organization shall be 1s-eewn-emMm M.-2-1-en+-4

a. Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2.2-1;

b. At least one licensed Reactor Operator shall be in the control room when fuel is in the reactor. In addition, while the unit is in OPERATIONAL CONDITION 1, 2 or 3, at least one licensed Senior Reactor Operator shall be in the control room;

c. A Radiation Protection Technician

• shall be on site when fuel is in the reactor;

o. ALL CORE ALTERATIONS shall be observed and directly supervised by either a licensed Senior Reactor Operator or licensed Senior Reactor Operator Limited to Fuel Handling who has no other concur-rent retponsibilities during this operation; and ,

l l

"The Radiation Protection Technician may be unavailable for a period of time  !

not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to accommodate unexpected absence, provided immediate action is taken to fill the required position.

HOPE CREEK 6-1 Amendment No.

( .

INSERT 1 6.2.1 ONSITE AND OFFSITE ORGANIZATIONS ,

Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include positions for activities affecting the safety of the nuclear power plant,

a. Lines of authority, responsibility, and communication shall be established and defined from the highest management levels through intermediate levels to and including all operating organization positions. These relationships shall be documented and updated, as appropriate in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirementsshall be documented in the Hope Creek Generating Station Updated Final Safety Analysis Report and updated in accordance with 10CFR50.71(e).

o. The General Manager - Hope Creek Operations shall be responsible for overall unit safe operation and shall have control over those onsite activities necessary for safe operation and maintenar.ce of the plant.

c. The senior corporate nuclear officer shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.

d. The individuals who train the operating staff and those l who carry out health physics and quality assurance functions may report to the appropriate onsite manager; however, they shall have sufficient organizational freedom to ensure their independence from operating pressures. j l

i Page 1 of 1

ADMINISTRATIVE CONTROLS UNIT STAFF (continued)

e. Administrative procedures shall be developed and implemented to limit the working hours of unit staff who perform safety-related functions e.g. , licensed Senior Reactor Operators, licensed Reactor Operators, radiation protection technicians, equipment operators, and key main-tenance personnel.

Adequate shift coverage shall be maintained without routine heavy use of over-time. The objective shall be to have operating personnel work a nomal 8-hour day, 40-hour week while the unit is operating. However, in the event that un-foreseen problems require substantial amounts of overtime to be used, or during extended periods of shutdown for refueling, major maintenance on major unit modifications, on a temporary basis the following guidelines shall be followed:

1. An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight, excluding shift turnover time.

2. An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7 day period, all excluding shift turnover time.

3. A break of at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> should be allowed between work periods, in-cluding shift turnover time.

4. Except during extended shutdown periods, the use of overtime should be con-sidered on an individual basis and not for the entire staff on a shift.

Any deviation from the above guidelines shall be authorized by the appropriate department manager, or higher levels of management, in accordance with estab-lished procedures and with documentation of the basis for granting the deviation.

Controls shall be included in the procedures such that individual overtime shall be reviewed monthly by the General Manager-Hope Creek Operations or his designee to assure that excessive hours have not been assigned. Routine deviation from the above guidelines is not authorized.

HOPE CREEK 6-2 Amendmen t No.

INSERT 2

f. The Cperations Manager. Operating Engineer. Senior Nuclear Shif t S>pervisors. Nuclear Shif t Supervisors, and Senior Operating Supervisor shall hold a senior reactor operator license.

The Nuclear Control Operators shall hold a reactor operator license, i

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HOPE CREEK 6-3 Amendment No.

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1ll ll lll jl HOPE CREEK 6-4 Amendment No.

ADMINISTRATIVE CONTROLS procedures that involve a significant safety issue as described in Section 6.5.3.2.d.

b.

Paview of all proposed tests and experiments that affect nuclear safety.

c. Review of all proposed changes to Appendix "A" Technica1 Specifications.

d. Review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety.

e. Review of the safety evaluations that have been completed under the provisions of 10 CFR 50.59.

f. Investigation of all violations of the Technical Specifications includ-ing the preparation and forwarding of reports covering evaluations y and recogendations to prevent recurrence to the mm+rertsent- ------ i

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n r muc3eurand to the General Manager - Nuclar Safety Review.

g. Review of all REPORTABLE EVENTS.

h. Review of facility operations to detect potential nuclear safety hazards,

i. Performance of special reviews, investigations or analyses and reports thereon as requested by the General Manager - Hope Creek Operations or General Manager - Nuclear Safety Review.

j. Review of the Facility Security Plan and implementing procedures and shall submit recommended changes to the General Manager - Nuclear Safety Review.

k. Review of the Facility Emergency Plan and implementing procedures and shall submit recommended changes to the General Manager - Nuclear Safety Review.

1. Review of the Fire Protection Program and implementing procedures and shall submit recommended changes to the General Manager - Nuclear Safety Review,

m. Review of all unplanned on-site releases of radioactivity to the environs including the preparation of reports covering evaluation, recommendations, and disposition of the corrective action to prevent _p j eentor corporate ArecurrenAe and the fomarding of these reports to the ~::: "= ::: ne- -I nuclear officer

.musteas4and to the General Manager - Nuclear Safety Review.

n. Review of changes to the PROCESS CONTROL MANUAL and the OFF-SITE DOSE CALCULATION MANUAL, and the Radwaste Treatment Systems.

1 REVIEW PROCESS i

6.5.1.7 A technical review and control system utilizing qualified reviewers i shall function to perform the periodic or routine review of procedures and i changes thereto. Details of this technical review process are provided in l Section 6.5.3.

t I

H' OPE CREEK 6-8 Amendment No.

I 4

4

ADMINISTRATIVE CONTROLS AUTHORITY 6.5.1.8 The SORC shall:

l a. Recommend in writing to the Getieral Manager - Hope Creek Operations l approval or disapproval of items considered under Specifica-tion 6.5.1.6.a. through e. prior to their implementation.

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senior corporate V l

I nuclear officer '

b. Provide yritter. notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the hi e-Wesittent--,

4-nue4eena'nd to the General Manager - Nuclear Safety Review of dis-agreement between the S0RC and the General Manager - Hope Creek Operations; however, the General Manager - Hope Creek Operations shall have responsibility for resolution of such disagreements pursuant to Specification 6.1.1.

RECORDS l senior corporate nuclear officer 6.5.1.9 The 50RC stall maintain minutes of,each SORC meeting, and copies shall be provided to the -Presittent---Ntrelearf, General Manager - Nuclear Safety Review and Manager - Offsite Safety Revi u.

6.5.2 NUCLEAR SAFETY REVIEW FUNCTION 6.5.2.1 The Nuclear Safety Review Department (NSR) shall function to provide the independent safety review program and audit of designated activities.

COMPOSITION 6.5.2.2 NSR shall consist of the General Manager - Nuclear Safety Review, the Manager - Offsite Safety Review, who is supported by at ieast four dedicated, full-time engineers, and the Onsite Safety Review Group, which is managed by the Onsite Safety Review Engineer and is supported by at least three dedicated, full-time engineers located onsite.

The Manager - Offsite Safety Review and staff shall meet or exceed the qualifica-tions described in Section 4.7 of ANS 3.1 - 1981 and shall be guided by the provisions for independent review described in Section 4.3 of ANSI N18.7 -

1976 (ANS 3.2).

The Offsits Safety Review staff shall geoerally possess experience and com-petence in the areas listed in Section 6.5.2.4.1. A system of qualified re-viewers from other technical organizations shall be utilized to augment ex-pertise in the disciplines of Section 6.5.2.4.1, where appropriate. Such qualified reviewers shall meet the same qualification requirements as the Offsite Safety Review staff, ani shall not have been involved with performance '

of the original work.

Tha Onsite Safety Review Engineer and staff shall meet or exceed the qualifica-tions described in Section 4.4 of ANS 3.1 - 1981.

HOPE CREEK 6-9 Amendmen t No.

l ADMINISTRATIVE CONTROLS

f. All REPORTABLE EVENTS.

g. All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, of components tha.t coul,d affect nuclear safety; and

h. Reports and meeting minutes of the 50RC.

A110lTS 6.5.2.4.3 Audits of facility activities shall be performed under the cognizance of the OSR. These audits shall encompass:

a. The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months;

b. The performance, training and qualifications of the entire facility staff at least once per 12 months;

c. The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems, or method of operation that affect nuclear safety, at least once per 6 months;

d. The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix B, 10 CFR Part 50, at least once per 24 months;

e. The Facility Emergency Plan and implementing procedures at least once per 12 months;

f. The Facility Security Plan and implementing procedures at least once seniorcorooratenuclearofficerI

g. Any other area of facility operation considered 4 appropriate by the a, General Manager - Nuclear Safety Review or theIWa-hesMent---_-NueteaM;

h. The facility Fire Protection Program and the implementing procedures I at least once per 24 months; )

i. The fire protection and loss prevention program implementation at least once per 12 months utilizing either a qualified off-site licensee fire protection engineer (s) or an outside independent fire protection consultant. An outside independent fire protection con-sultant shall be utilized at least once per 36 months; and

j. The radiological environmental monitoring program and the results thereof at least once per 12 months.

k. The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months; HOPE CREEK 6-11 Amendmen t No.

ADMINISTRATIVE CONTROLS

1. The PROCESS CONTROL PROGRAM and implementing procedures for process-ing and packaging of radioactive wastes at least once per 24 months; and,

m. The performance of activities required by the Quality Assurance Program for effluent and environmental monitoring at least once per 12 months.

The above audits shall be conducted by the Nuclear Quality Assurance Department or an independent consultant. Audit plans and final audit reports shall be reviewed by the OSR prior to issuance.

RECORDS 6.5.2.4.4 Records of OSR activities shall be maintained. Reports of reviews and audits shall be prepared and distributed as indicated below:

a. The results of reviews performed pursuant to Section 6.5.2.4.2 shall be reported to the Vice President - Nuclear at least monthly.

b. Audit reports prepared pursuaat to Specification 6.5.2.4.3 shall be p' senior corporate forwarded by the auditino oPoanization to th%Ytcirfrertdent -Nurteart-nuclear officer and to the management positions responsible P6r the areas audited (1) within 30 days after completion of tha audit for those audits con-ducted by the Nuclear Quality Assuratice Department, and (2) within 60 days after completion of the audit for those audits conducted by an independent consultant.

6. 5. 2. 5 ONSITE SAFETY REVIEW GROUP (SRG) 6.5.2.5.1 The SRG shall function to provide: the review of plant design and operating experience for potential opportunities to improve plant safety; evalua-tion of plant operations and maintenance activities; and advice to management on the overall quality cnd safety of plant operations.

The SRG chall make recommendations for revised procedures, equipment modifica-tions, or other means of improving plant safety to appropriate station / corporate management.

RESPONSIBILITIES 6.5.2.5.2 The SRG shall be responsible for:

a. Review of selected plant operating characteristics, NRC issuances, industry advisories, and other appropriate sources of plant design and operating experience information which may indicate areas for improving plant safety.

b. Review of selected facility features, equipment, and systems.

c. Review of selected procedures and plant activities including maintenance, modification, operational problems, and operational analysis.

HOPE CREEK 6-12 Amendmen t No.

l ADMINISTRATIVE CONTROLS l

d. Surveillance of selected plant operations and maintenance activities to i' provide independent verification

• that they are performed correctly and that human errors are reduced to as low as reasonably achievable.

AUTHORITY seniorcorporatenuclearoffger1 6.5.2.6 NSR shall report to and advise the IVicetres+ dent-- -Nuttevrlon those areas of responsibility specified in Sections 6.5.2.4 and 6.5.2.5.

6.5.3 TECHNICAL REVIEW AND CONTROL ACTIVITIES J

6.5.3.1 All programs and procedures required by Technical Specification 6.8 and changes thereto, and any other proposed procedures or changes thereto, which affect ,

plant nuclear safety as determined by the General Manager - Hope Creek Opera- 1 tions, other than editorial or typographical changes, shall be reviewed as follows:

1 PROCEDURE RELATED DOCUMENTS 6.5.3.2 Procedures, Programs and changes thereto shall be reviewed as follows:

a. Each newly created procedure, program or change thereto shall be i independently reviewed by an individual knowledgeable in the area i affected other than the individual who prepared the procedure, pro-gram or procedure change, but who may be from the same organization as the individual / group which prepared the procedure or procedure .

change. Procedures other than Station Administrative procedures will )

Q be approved by the appropriate station Department Manager or by the ,

rass1stanuGeneral Manager - Hope Creek Operations. Each station I Department Manager shall be responsible for a pre-designated class I of procedures. The General Manager - Hope Creek Operations shall approve Station Administrative Procedures, Security Plan implementing l procedures and Emergency Plan implementing procedures. j

b. On-the-spot changes to procedures which clearly do not change the intent of the approved procedures shall be approved by two members .

of the plant management staff, at least one of whom holds a Senior l Reactor Operator's License. Revisions to procedures which may l involve a change in intent of the approved procedures, shall be '

, reviewed in accordance with Section 6.5.3.2.a above.

c. Individuals responsible for reviews performed in accordance with item 6.5 3.2.a above shall be approved by the 50RC Chairman and designated as a Station Qualified Reviewer. A system of Station Qualified Reviewers shall be maintained by the 50RC Chairman. Each review shall include a written determination of whether or not additional "Not responsible for sign-off function.

HOPE CREEK 6-13 Amendmen t No.

r NT

(

ADMINISTRATIVE CONTROLS cross-disciplinary review is necessary. If deened necessary, such review shall be performed by the appropifato designated review personnel. Trie C++ 'on Qualified Reviewers shall meet or exceed the quali H ' ' , . uescriud in Section 4.4 of ANS 3.1,1981,

d. If the Departir,ent Manager determines that the documents involved contain significant safety issues, the documents shall be forwarded for SORC review and also to NSR for an independent review to deter-mine whether or not an unreviewed safety question is involved. Pur-suant to 10 CFR 50.59, NRC approval of items involving unreviewed safety questions or requiring Technical Specification changes shall be obtained prior to implementation.

NON-PROCEDURE RELATED DOCUMENTS 6.5 S.3 Tests or experiments, and changes to equipment or systems shall be fc,cwarded for SORC review and also to NSR for an independent review to determine whether or not an unreviewed safety question is involved.- The results of NSR reviews will be provided to SORC. Recommendations for approval are made by SORC to the General Manager - Hope Creek Operations. Pursuant to 10 CFR 50.59, NRC approval of items involving unreviewed safety questions or requiring Technical Specification changes shall be obt;*nad prior to implementation. .

RECORDS 6.5.3.4 Written records of reviews performed in accordance with item 6.5.3.2a above, including recommendations for approval or disapproval, shall be maintained.

Copies shall be provided to the General Manager - Hope Creek Operations, SORC, NSR, and/or NRC as necessary when their reviews are required.

6.6 REFORTABLE EVENT ACTION 6.6.1 The following actions shall be-taken for REPORTAF4E EVENTS:

a. The Commission shall be notified pursuant to the requirements of Section 50.72 to 10 CFR Part 50 and a repn % sebmittal pursuant to the requirements of Section 50.73 te 10 CFR Part 50, and

b. Each REPORl'ABLE EVENT shall be reviewed by the SORC, and the results g of this revi,ew shall be submitted to the NSR and the.,tvice-Presteem--t h senior corporate nuclear officer. l 6.7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a Safety Limit is violated:

1 senior corporate nuclear officer l

a. The MC Operations Center shall be notified bf ftelephone as soon as o possible and in all cases withi.: I hour. The Iv4ce-Feesioen e--nc44u- i and the General Manager - NSR shall be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

HOPE C.1EEK 6-14 Amendmen t No.

ADMINISTRATIVE CONTROLS

b. A Safety Limit Violation Report shall be prepared. The report shall be reviewed by the 50RC. This report shall describe (1) applicable circumstances preceding the violation, (2) effects of the violation upon unit components, systems, or structures, and (3) corrective action taken to prevent recurrence, senior corporate nuclear officer

c. The Safety Limit Violation Report shall be submitted to the Commission, p a the General Manager - Nuclear Safety Review and thEiv+ce-President----, J

-F-Nueleertwithin 30 days of the violation.

d. Critical operation of th9 uait shall not be resumed until authorized by the Commission.

6.8 PROCEDURES AND OR0 GRAMS 6.8.1 Written procedures shall be established, implemented, and maintained covering the activities referenced below:

a. The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. '

1

b. The applicable procedures required to implement the requirements of l NUREG-0737 and supplements thereto,

c. Refueling operations,

d. Surveillance and test activities of safety-related equipment.

e. Security Plan implementation.

f. Emergency Plan implementation,

g. Fire Protection Program implementation.

h. PROCESS CONTROL PROGRAM implementation.

i 0FFSITE DOSE CALCULATION MANUAL implementation.

J. Quality Assurance Program for effluent and environment monitoring.

6.8.2 Each procedure and administrative policy of 6.8.1 above, and changes thereto, shall be reviewed and approved in accordance with specification 6.5.1.6 or 6.5.3, as appropriate, prior to implementation and reviewed periodically as set forth in administrative procedures.

6.8.3 On-the-Spot changes to procedures of Specification S.8.1 may be made provit.ad:

a. The intent of the original procedure is not altered;

b. The change is approved by two members of the unit management staff, at least one.of whom holds a Senior Reactor Operator license on the unit affected; and HOPE (i EK 6-15 Amendcien t No.

ADMINISTRATIVE CONTROLS SEMIANNUALRADI0ACTIVEEfFLUENTRELEASEREPORT(Continued)

The radioactive effluent release report to be submitted within 60 days after January 1, of each year @all' also include an assessment of radiation doses to the likely most exposed MEMBER OF THE PUBLIC frc.i reactor releases and other nearby uranium fuel cycle sources (including doses from primary effluent pathways and direct radiation) for the previous 12 consecutive j months to show conformance with 40 CFR 190, Environmental Radiation  !

Protection Standards for Nuclear Power Operation. Acceptable methods for i calculating the dose contribution from liquid aqd gaseous effluents are given in Regulatory Guide 1.109, Rev.1.

The radioactive effluents release shall include the following information for each class of solid waste (as defined by 10 CFR 61) shipped offsite during the report period:

a. Container volume,

b. Total curie quantity (specify whether determined by measurement or estimate),

c. Principal radionuclide (specify whether determined by measurement i or estimate),

d. Type of waste (e.g., spent resin, compact dry waste, evaporator )

bottoms),

e. Type of container (e.g., LSA, Type A, Type B, Large Quantity), and

f. Solidification agent (e.g.. cement, urea formaldehyde).

The radioactive effluent release rept vts shall include unplanned releases from the site to the UNRESTRICTED AREM of radioactive materials in gaseous and liquid effluents on a quarterly basis.

The radioactive effluent release reports shall include any changes to the PROCESS CONTROL PROGRAM (PCP), OFFSITE DOSE CALCULATION MANUAL (ODCM) or radioactive waste systems made during.the reporting period.

MONTHLY OPERATING REPORTS 6.9.1.8 Routine reports of operating statistics and shutdown experience shall be submitted on a monthly basis to the U.S. Nuclear Regulatory Commission.

Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator of the Regional Office no later than the 15th of each month following the calendar month covered by the report.

'to the U.S. Nuclear Regulatory Commission, Document Control SPECIAL REPORTS Desk. Washington DC 20555, with a copy i 6.9.2 Special reports shall be submitted \ to the Regional Administrator of the Regional Office of the NRC within the time period specified for each report.

6.9.3 Violations of the requirements of the fire protection program described in the Final Safety Analysis Report which would have adversely affected the ability to achieve and maintain safe shutdown in the event of a fire shall be 69 epee 4eef to the Regional Administrator of the Regional Office of NRC via the Licensee Event Report System within 30 days, suomitted to the U.S. Nuclear Regulatory f HOPE CREEK 6-20 commission, Document Control Desk, j Washington, DC 20555, with a copy j Amendment No.

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