ML20245F251

Safety Evaluation Supporting Amends 75 & 63 to Licenses NPF-10 & NPF-15,respectively

ML20245F251
Person / Time
Site:	San Onofre
Issue date:	07/27/1989
From:	Office of Nuclear Reactor Regulation
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ML20245F250	List: ML20245F245 ML20245F251 ML20245F265
References
NUDOCS 8908140216
Download: ML20245F251 (10)

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'k UNITED STATES NUCLEAR REGULATORY COMMISSION j

WASHING TON, 0. C. 20555 s,,

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

_RELATED TO AMENDMENT NO.75 TO FACILITY OnERATING LICENSE NO. NPF-10 AND AMENDMENT NO.63 TO FACILITY OPERATING LICENSE NO. NPF-15 SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS AND ELECTRIC COMPANY THE CITY OF RIVERSIDE, CALIFORNIA M CITY OF ANAHEIM, CALIFORNIA SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 DOCKET NOS. 50-361 AND 50-362

1.0 INTRODUCTION

By letters dated April 26, October 11, October 24, November 7, and December 16, 1988; and January 16, January 20, and March 28, 1989, Southern California Edison Company (SCE), et al., (the licensees) requested changes to the Technical Specifications for Facility Operating Licenses No. NPF-10 and No. NPF-15 that authorize operation of San Onofre Nuclear Generating Station (SONGS), Units 2 and 3 in San Diego County, California. These requests - designated as PCNs 250, 252, 254, 255, 259, 260, 281, and 283 -

proposed to extend the interval for certain of the required 18 month surveillance tests in order to support the nominal 24 month fuel cycle.

Both Units 2 and 3 are operating in their first such cycle and will be forced to shut down to perform the 18 month surzeillances unless the required interval is extended. SCE has submitted proposed changes to cover all the 18 month surveillance tests which cannot be performed during plant operation. Many of these requests would have changed the required. interval from "at least once every 18 months" to "at least once per refueling interval." By letter dated March 20, 1989, SCE amended these requests to define " refueling interval" as 24 months. This definition has been included in the Frequency Notation table of the Technical Specifications (Table 1.2) by Amendments 73 and 61 to Licenses No. NPF-10 and No. NPF-15 respectively.

2.0 DISCUSSION AND EVALUATION PCN-250 By letter dated April 26, 1988, the licensees proposed to change Technical Specification 3/4.3.3.10 " Loose-Part Detection Instrumentation," to 8908140216 890728 PDR ADOCK 05000361 F

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, extenc the 18 month surveillance interval to at least once per refueling interval (24 months). Specification 3/4.3.3.10 requires the loose-part detection system to be operable in Modes 1 and 2, defines surveillance tests'to verify operability, and specifies compensatory actions to be taken when the minimum operability requirements are not met.

The loose-part detection instrumentation serves to provide early detection of loose metallic parts in the primary system to avoid and/or mitigate damage to primary s Monitoring System (ystem components. The Vibration and Loose PartsV& LPM) m components. The selected locations provide qualitative indications of vibration throughout the primary system.

Surveillaree Requirement 4.3.3.10.c states that each channel of the loose-part detection system shall be demonstrated operable by the perfor-mance of a channel calibration at least once per 18 months. SCE states that the channel calibration repeats the functional testing done monthly and also checks the sensors.

SCE has reviewed the history of the 18 month surveillance tests of the V&LPf' at SONGS Units 2 and 3 from the start of commercial operation to the date of the review (November 1, 1987). All deficiencies which occurred ouring that time, except one, were found during the otily and monthly surveillance and by alarm indications.The one exception - Channel 14, Core Internals, Channel B - failed a common mode rejection section of the 18 month test. SCE states that this would be conservative in that an alarm would occur sooner than necessary due to the noise effect. In addition, SCE states that V&LPH does not perform a safety-related function but is solely a monitoring system.

Based upon the ability of the daily and monthly surveillance to detect deficiencies, and the fact thi.t the V& LPM is not safety-related, the staff concluces that extension of the 18 month surveillar.ce interval to 24 mcnths is acceptable.

l PCN-252 By letter dated October 24, 1988, the licensees proposed to change Technical Specification 3/4.8.1.1, "AC Sources," to extend the 18 month surveillance interval to at least once per refueling interval (24 months).

l This Specification requires operability of two physically independent circuits between the offsite transmission network and the onsite Class IE distribution system, and two separate and independent diesel generators, in Modes 1 through 4. It also defines periodic surveillance tests to verify operability and specifies compensatory action to be taken when minimum operability requirements are not met.

Operability of the AC sources ensures that sufficient power will be available to supply the safety related equipment required for safe shut-down of the facility and for mitigation and control of accident conditions within the facility. Surveillance Requirement 4.8.1.1.1.b requires each independent circuit between the offs.ite transmission network and the

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1 onsite Class IE distribution system to be demonstrated operableLat least I

once per 18 months by transferring (manually and automatically), unit power L

from the normal offsite power source to the alternate offsite power i

source. Surveillance Requirement 4.8.1.1.2.d requires each diesel generator j

to-be demonstrated operable at least once per 18 months;by performing an

. inspection of the diesel generator; by starting the diesel generator automatically _ on a simulated loss of offsite power, with and without an

.ESF test signal; and by testing the. load capacity, sequencing, load shed,

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load rejection, logic, and fuel transfer features of diesel operation.

j SCE states'that a review of.the required 18 month surveillance' tests has l

determined that no significant problems occurred. One failure to activate the auto transfer of the bus tie breakers occurred due to misalignment of i

a' breaker. This was classified as a startup problem which should not recur. One failure to' achieve the two-hour rating of 110% of full would heve been detected on a monthly surveillance test. SCE also'. load' reviewed the maintenance history of start-on-demand-failures, which showed seven

' failures on the four diesel generators between January 1984 and' June 1987.

It was noted that, without exception, all'the failurer were detectable by monthly. surveillance testing. The failure history. indicates that the AC power systems have been extremely reliable. Additionally, weekly, monthly, and quarterly tests remain unchanged and have been shown to be effective in detecting. problems. All vendor recomended preventative maintenance will continue to be performed on the same schedule.

The staff has evaluated the licensees' submittal and has found that the proposed change affects only the frequency of the 18 month surveillance tests of the AC power systems, which may result in.a small reduction in confidence in system operability and in the associated margin of safety.

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However,'the failure history indicates that the systems at SONGS 2 and 3 have been extremely reliable. In addition, the weekly, quarterly, and monthly surveillance tests will continue to provide effective indications of system capability. Also, Technical Specification 4.0.2 allows the current 18 month interval to be extended by 255, to 22.5 months. For these reasons, any reduction in confidence in system operability is expected to be small for an increase from the currently allowable 22.5 months to 24 months. Therefore, a surveillance interval of 24 months is acceptable.

l However, the 255 extension of the surveillance interval allowed under Technical Specification 4.0.2 will no longer be permitted, and the proposed Technical SperJfication has been modified accordingly.

PCN-254 By letter dated December 16, 1988, the licensees proposed to change Technical Specification 3/4.8.4, " Electrical Equipment Protective Devices,"

to extend the 18 month surveillance intervals to at least once per refuel-

.i ing interval (24 months). Specification 3/4.8.4.1 requires circuits entering containment to be provided with overcurrent protective devices (listed in Table 3.8-1) which must be operable in Modes 1 through 4.

Specification 3/4.8.4.2 requires thermal overload protection to be bypassed by a device integral with the motor starter for each valve listed in Table 3.8-2.

Each bypass device is required to be operable whenever its motor-

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. operated vaive is required to be operable.

These Specifications also define surveillance tests ar.d inspections to verify operability, and compensatory actions to be taken when the minimum operability requirements are not met.

The overcurrent protective devices provide protection to the containment penetration to maintain containment integrity. Surveillance Requirement 4.8.4 1.a requires containment penetration conductor overcurrent devices to be demonstrated operable at least once per 18 months. Tha medium voltage (4 KV - 15 KV) circuit breakers are demonstrated operable by performing a channel calibration of the associated protective relays and an integrated system functional test of at least 10% of the circuit breakers of each voltage level selected on a rotating basis. For any circuit breaker found inoperable, an additional representative sample of at least 10% of the circuit breakers of the inoperable type shall also be functionally tested. The lower voltage circuit breakers are demonstrated I

operable by performing functional testing of a representative sample of each type, as described above for the medium voltage circuit breakers.

The thermal overload bypass ensures that the motor will not trip off due to a thermal overload. Surveillance Requirement 4.8.4.2.a requires veri-fying that the thermal overload protection is bypassed by integral bypass devices at least once per 18 months. Surveillance Requirements 4.8.4.2.b and c require the same verification following maintenance on a valve notor starter, and following any periodic testing during which the thermal overload device was temporarily placed in force, respectively.

SCE has examined the history of the 18 month tests of the electrical i

equipment protective devices at SONGS 2 and 3 from the beginning of

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commercial operation to the present. All surveillance on Unit 2 have been i

successful. All but two of the overcurrent protective device surveillance i

on Unit 3 have been successful. One failure was caused by loose screws.

f The other failure required replacement of a neutral relay. All thermal overload bypass surveillance on Unit 3 have been successful.

The staff has evaluated the licensees' submittal. We have determined that the surveillance history has been acceptable.

In addition, verification of the thermal overload bypasses will continue to be performed following maintenance or periodic testing which affect the thermal overloads. For j

these reasons, Aquipment reliability would not be significantly degraded i

by extension of the surveillance intervals. Therefore, the staff finds the i

proposed changes acceptable.

PCN-256 By letter dated November 7, 1988, the licensees proposed to change l

Technical Specifications 3/4.3.1, " Reactor Protective Instrumentation,"

l and 3/4.3.2, " Engineered Safety Features Actuation System Instrumentation,"

to extend the 18 month surveillance intervals for the bypass lof c to at i

least once per refueling interval (24 months). Specification 3/4.3.1 defines the Reactor Protective System (RPS) instrumentation channels and bypasses required to be operable, defines periodic surveillance tests to n

verify operability, and specifies compensatory action to be taken when minimum operability requirements are not met. Specification 3/4.3.2 defines the Engineered Safety Features Actuation System (ESFAS) instru-mentation channels and bypasses required to be operable, defines periodic surveillance tests to verify operability, and specifies compensatory action to be taken when minimum operability requirements are not met.

Operability of the RPS and ESFAS instrumentation and bypasses ensures that (1) associated ESFAS action and/or reactor trip will be initiated when the parameter monitored by each channel or combination thereof reaches its setpoint,(2)thespecifiedcoincidencelogicismaintained,(3) sufficient i

redundancy is maintained to permit a channel to be out of service for I

testing or maintenance, and (4) sufficient functional capability is available from diverse parameters. The RPS and ESFAS have bypass circuits i

that disable system trips for startup, shutdown, testing, or maintenance.

Bypasses are catalogued as either trip channel bypasses or operational i

bypasses. Trip channel bypass logic allows manual bypass of one and only j

one channel at any time. Operational bypasses are either automatic, manual, or a combination of the two, and may involve bypass of the selected parameter (s) on more then one of the two channels. Surveillance Require-

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ments 4.3.1.2 (for the RPS) and 4.3.2.2 (for the ESFAS) require tl.at the

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total bypass function be demonstrated operable at least once per 18 months during channel calibration testing of each channel affected by bypass i

operation.

SCE states that, except for the Steam Generator Low Flow (S/G LF) bypass

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l logic, monthly surveillance tests are the same as the 18 month surveillance tests. The monthly test of the S/G LF tests the bypass logic on a single channel ba~is. In addition, all bypasses are annunciated on the main s

control board and operating procedures require control room personnel to check for proper bypass operation during plant evolutions. Most failures of a bypass would be indicated on the annunciators and would be detected by the operators.

By letter dated June 30, 1989, SCE stated that calibration of all RPS and ESFAS channels was completed during the February 1989 and May/ June 1989 outages.of Unit 2 and that they are withdrawing their request to extend the surveillance interval for the RPS and ESFAS channel calibrations for Unit 2. The licensees are committed to calibrate all RPS and ESFAS channels on an 18 month interval for both Units 2 and 3, which will maintain instrument drift within acceptable limits. In addition, Technical Speci-fication 4.0.2 allows the current 18 month interval to be extended by 25%,

to 22.5 months. For these reasons, and because the monthly bypass logic j

surveillance tests are nearly identical to the 18 month surveillance i

tests, any reduction in confidence in 'oypass logic operability is expected l

to be small for an increase from the currently allowable 22.5 months to 24 months. Therefore, a surveillance interval of 24 months is acceptable.

However, the 25% extension of the surveillance interval allowed under Technical Specification 4.0.2 will no longer be permitted, and the proposed Technical Specification has been modified accordingly.

Also, the wording proposed by SCE in Surveillance Requirements 4.3.1.2 and 4.3.2.2 conflicts with Surveillance Requirements 4.3.1.1 and 4.3.2.1. While the surveillance l

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7Y interval for the bypass logic test will become the refueling intervel (24 months), the surveillance interval for the channel :: calibrations will remain at 18 months. Hoever, SCE's proposect wording of Surveillance Requirements 4.3.1.2 and 4.3.2.2 would continue to tie bypass logic testing to channel calibration testing. Therefore, the staff has changed the 4

wording to remove the connection between the two tests.

-PCN-259 By letter dated October 11, 1988, the licensees proposed to change Technical Specification 3/4.6.4.3, " Containment Dome Air Circulators,"'to extend the 18. month surveillance interval to at least once per refueling interval (24 months). Specification 3/4.6.4.3 defines the number of containment dome air circulator trains required to be operable, defines-i periodic surveillance tests to verify operability, and specifies. compen-satory action to be taken when minimum operability requirements are not met.

Operability of'the dome air circulators ensures adequate mixing of the containment atmosphere following a loss-of-coolant-accident (LOCA). In conjunction with other containment systems, the. dome air circulators will prevent localized accumulations of hydrogen from exceeding its flannable limit. Surveillance Requirement 4.6.4.3 require that each dome' air circulator. train be demonstrated operable at least once per 18 months by starting the system on a Containment Cooling Actuation Signal (CCAS), by verifying that it operates for at least 15 minutes, and by verifying a system flow rate of at least 37,000 cubic feet per minute.

SCE states that Surveillance Req (ESF) Actuation System (ESFAS) relays in a uirement 4.6.4.3 is met by testing all of theEngineeredSafety(e.g.tures, CCAS) as a total unit.

Fea actuation subsystem The Plant Protection System (PPS) encompasses the Reactor Protective System (RPS) and the Engineered Safety Features (ESF) Actuation System (ESFAS), including the electrical and mechanical devices and circuitry required to perform those functions. Surveillance Requirements 4.3.1.1 and 4.3.2.1 require periodic surveillance testing of the RPS and ESFAS instrumentation channels, respectively. Table 4.3-2 of Specification' 4.3.2.1 specifies monthly and semiannual functional testing of the ESFAS instrumentation. SCE states that these requirements are satisfied by performance orthe PPS Monthly Test and the ESF Semiannual Functional Test, which together test the ESF actuation logic from sensor inputs through actuation of the tested devices. Final Safety Analysis Report (FSAR)Section 7.3.1.1.1.9 describes a typical test program. The active logic components in the ESFAS actuation path are the PPS bistables, PPS matrix relays, PPS initiation relays, ESFAS subgrous relays ESF motor controllers, and the ESF actuated devices. The PPS Mont11y Test checks the 3

pPS bistables, matrix relays, and initiation relays. The ESF Semiannual Functional Test checks the ESFAS subgroup relays and motor controllers and actuates the devices. SCE states that the major difference between the combination of these two tests and the 18 month ESFAS test is that the f

latter tests all of the logic and actuated devices for a particular i

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,. function at.once. Components.which carnot be tested during power operation are tested during the first. cold _ shutdown longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />'if they

-have not;been tested in the last six renths. All of the CCAS components can be operated at power, however, access to the containment is necessary -

to install and monitor the test instrumentation required for the flow.

measurement. SCE has reviewed the history of the' flow measurement tests since the start of commercial operation and has found that all have been satisfactory.

The staff has evaluated the licensees' submittal..We have determined that the monthly and semiannual functional tests of the ESFAS channels provide sufficient assurance of Containment Dome Air Circulator response to the CCAS signal te allow extension of the 18 nonth surveillance interval to 24 months. In addition, the test history of the flow measurement tests indicate that. system reliability would not be significantly degraded by extension of the surveillance interval. Therefore, the staff finds the proposed change acceptable.

PCN-260 By letter dated January 20, 1989, the licensees proposed to change Technical' Specifications 3/4.7.1.2, "Acxiliary Feedwater System," 3/4.7.3,

'"Compenent Coolitig Water System," 3/4.7.4, " Salt Water Cooling System,"

and 3/4.7.10, " Emergency Chilled Water System," to extend the 18 month surveillance interval to at least once per refueling interval (24 months).

-Those Specifications define the equipment and/or flow paths that are required to be operable, define periodic surveillance tests to verify eprability, and specify compensatory action to be taken when minimum operability requirements are not s.et.

Operability of the Auxiliary Feedwater (AFW) Syster, ensures that the Reacter Coolant System can be cooled down to less than 350 degrees Fahren-heit from normal operating ccnditions in the event of a total loss of offsite gewer. Operability of the Component Cooling Water (CCW) System ensures that sufficient cooling capacity is available for continued Operability of the Salt Water Cooling (SWC)g normal and accident conditions.

operation of safety related equipment durin System ensures that sufficient cooling capacity is available for continued operation of equipment during normal and accident conditions. Operability of the Emergency Chilled Water System (ECWS) ensures that sufficient space cooling capacity is available for continued operation of safety related equipment during accident conditions. Surveillance Requirement 4.7.1.2.1.b requires that each AFW.

pump be demonstrated operable at least once per 18 months by verifying that each autonatic valve in the AFW flow path and each AFW pump be verified to actuate to its desired position upon an Energency Feedwater Actuation Signal (EFAS) test signal. Surveillance Requirement 4.7.3.b requires that at 1cest two CCW loops be denenstrated operable at least once per 18 months during shutdown by verifying that each automatic valve servicing safety related equipment actuates to its correct position, and i

Signal ($1AS) pump starts automatically upon a Safety Injection Actuation that each CCW test signal. Surveillance Requirement 4.7.4.b requires that i

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at least two SWC loops be demonstrated operable at least once per 18 i

months during shutdown by verifying that each automatic valve servicing safety related equipment actuates to its correct position, and that each SWC pump starts automatically upon a SIAS test signal. Surveillance i

Requirement 4.7.10.b requires that each ECWS be dernonstrated operable at least once per 18 monthi by verifying that each Emergency Chilled Wate?

pump and ea::h power operated or automatic valve servicing safety related j

equipment actuates to its correct position upon any of the following test j

signals: SIAS, loxic Gas Isolation Signal (TGIS), Control Room Isoletion 3

Signal (CRIS), and Fuel Handling Isolation Signal (FiilS) when irradiated fuel is in the storage pool.

t SCE states thht these requirements are met by testing ell of the ESFAS relays in an actuation subsystem (e.g., SIAS) as a total unit, with the j

execption of the Containment Purge Isolation System (CPIS) valves.

As described under PCN-259 above, the PPS Monthly Test and the ESF i

Semi-ernual Functional Test together test the ESF actuation logic from

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sensor inputs through actuation of the tested devicer; Compunents which

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cannot be tested during plant operation are tested during the first cold J

shutdown longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if they have not been tested in the last 6 months. SCE stetes that all of the components coVerd by the above Surveillance Requirements can be tested at power. In addition, Specifice-tion 4.0.5 requires inservice testing of all ASME Class 1, 2, and 3 yelves in ac.cordanc.e with Section XI of the ASME Boiler ar.J Pressure Vessel Sode.

The staff has evaluated the licensees' submittal. We have determined that the mcnthly and semiannual functional tests of the ESFAS channels provide sufficient assurance of AFW, CCW, SWC, and ECWS response to ESFAS signals to allow extension of the 18 month surveillance interval to 24 months.

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adciition, the inservice testing of the pumps and valves provides added t

i assurance that these systems are capable of performing their design f

functions. Therefore, the staff finds the proposed changes acceptable.

PCN-281 l

By letter dated January 16, 1989, tne licensees proposed to change Technical Specification 3/4.3.3.3, " Seismic Instrumentation," to extend the 18 month surveillance interval to at least once per refueling interval (24 months). Specification 3/4.3.3.3 defines the seistaic monitoring instrutnentation required to be operable, defines periodic surveillance tests to verify operability, snd specifies compensatory action to be taken j

when minimum operability requirements are not met.

l Operability of the seismic monitoring instrumentation ensures that suffi-l cient capability is available to promptly determine the magnitude of a i

seismic event and evaluate the response of those features important to 1

safety. This capability is required to permit corparison of the measured response to that used in the design basis for the facility to determine if plant shutdown is requi' ed pursuant tu Appendix A of 10 CFR Part 100.

r Surveillance Requirement 4.3.3.3.1 requires performance of channel cali-brations at least once per 18 monthi.

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SCE has reviewed the history of the 18 month surveillance tests from the start of commercial operation to the present. Only one test failed. SCE states that the monthly channel check and the semiannual functional test provide a high level of assurance that the system is capable of performing its design function.

The staff has evaluated the licensees' submittal. We have detemined that the monthly and-semiannual functional tests of the seismic _ inonitoring instrumentation provide evidence of system operability. Ih addition, Technical Specification 4.0.2 allows the current 18 month interval to be extended by 25%, to 22.5 months. For these reasons, and because the staff belihves that accelerometer characteristics willi et change significantly n

for an increase from the currently allowable 22.5 months to 24 months, a' surveillance interval of 24 months for the channel calibration is accept-able. However, the 25% extension of the surveillance interval allowed under Technical Specification 4.0.2 will no longer be permitted, and the proposed Technical Specification has bean modified accordingly.

pCN-283 By letter dated March 23, 1989; the licensees proposed to change Technical Specification 3/4.7.8.1, " Fire Suppression Water System " to extend the 18 nonth surveillance interval to at least once per refue1Ing in'terval (24 months) for those valves not testable during plant operation that are located in areas that are inaccessible during non-refueling operations.

Specification 3.4.7.8.1. defines the operability requirements of the Fire Suppression Water Systeng defines periodic surveillance tests to verify operability, and specifies compensatory action to be taken wher! minimum operability requirements are not m' t.

e Operability of the Fire Suppression Water System ensures that adequate fire suppression capability is available to confine and extinguish fires occurring in any plant area where safety related equipment is located.

Surveillance Requirement 4.7.8.1.1.e. requires that the fire suppression w3ter system be demonstrated operable by performing a system functional test at least once per 18 months; Surveillance Requirement 4.7.8.1.1.e.2 requires that each valve in the flow path that is not testable during plant operation be cycled through at least one complete cycle of travel.

SCE has reviewed the results of the surveillance tests and found that no unsatisfactory conditions have been identified as a resu~lt of the surveillance.

The staff has evaluated the licensees' submittal. Because a 24 month surveillance interval conforms to the guidance of the National Fire Protection Association Standards, we conclude that the increase in the surveillance interval will not significantly reduce the reliability of these fire protection systems. Therefore, the proposed change is accept-able.

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3.0 CONTACT WITH STATE OFFICIAL The NRC staff has advised the Chief of the Radiological Health Branch, State Department of Health Services State of California, of the proposed daternination of no significant hazards consideration. N6 coments were received.

4.0 ENVIRONMENTAL CONSIDERATION

I The amendments involve changes in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 r

and changes in surveillance requirements. The staff has determined that approval of PCNs 250,' 254, 259, 260 and 283 involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Comission has previously issued a proposed finding for these changes that the aesndments involve no significant hazards consideration and there has been no public comment on such finding. Accordingly, these amendments meet the eligibilit,y criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact state-nont or environmental assessment need be prepared in connection with the issuance of the amendments.

Pursuafit to 10 CFR 51.21, 51.32, and 51.35, an Environmental Assessment and Finding of No Significant Impact for PCNs 252, 256, and 281 has been prepared and published in the Federn1 Register on July 28, 1989 (54 FR 31394 ).

Accordingly, based upon the environmental assessment, the Ccmission has determined that the issuaia,e of these amendments will not have a significant effect on the quality of the human environment.

5.0 CONCLUSION

We have concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, i

(2) such activities will be conducted in compliance with the Comission's regulations and (3) the issuance of the amendments will not be inimical to the comon defense and security or to the health and safety of the public.

Principal Contributors:

D. Hickman, N. Trehan, I. Ahmed Dated; July 27,1989

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