Text

Application to Revise Technical Specifications to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program Using the Consolidated Line Item Improvement
	ML20262H225
Person / Time
Site:	Grand Gulf, River Bend
Issue date:	09/18/2020
From:	Gaston R; Entergy Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	CNRO-2020/00017
	Download: ML20262H225 (19)
	v • d • e

Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5138 Ron Gaston Director, Nuclear Licensing 10 CFR 50.90 CNRO-2020/00017 September 18, 2020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Application to Revise Technical Specifications to Adopt TSTF-563, "Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program" using the Consolidated Line Item Improvement Process Grand Gulf Nuclear Station, Unit 1 NRC Docket No. 50-416 Renewed Facility Operating License No. NPF-29 River Bend Station, Unit 1 NRC Docket No. 50-458 Renewed Facility Operating License No. NPF-47 In accordance with Title 10 of the Code of Federal Regulations (CFR) Part 50, Section 50.90, "Application for amendment of license, construction permit, or early site permit," Entergy Operations, Inc. (Entergy) is submitting a request for an amendment to Renewed Facility Operating License, Appendix A, "Technical Specifications" (TS) for Grand Gulf Nuclear Station, Unit 1 (GGNS) and River Bend Station, Unit 1 (RBS).

These proposed changes adopt the U.S. Nuclear Regulatory Commission (NRC)-approved Technical Specification Task Force (TSTF) Traveler TSTF-563, "Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program," Revision 0 into the GGNS TS and the RBS TS.

The proposed amendment revises the definition of Channel Calibration and Channel Functional Test which currently permit performance by any series of sequential, overlapping, or total channel steps to allow the required frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program.

The Enclosure to this letter provides a description and assessment of the proposed changes.

Attachments 1.a and 1.b to the Enclosure provide the existing TS pages for GGNS and RBS, respectively, marked-up to show the proposed changes. Attachments 2.a and 2.b provide revised (clean) TS pages.

CNRO-2020/00017 Page 2 of 2 Entergy requests approval of the proposed license amendment by July 30, 2021. The proposed changes would be implemented within 90 days of issuance of the amendment.

This letter contains no new regulatory commitments.

Should you have any questions or require additional information, please contact Ron Gaston, Director, Nuclear Licensing at 601-368-5138.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), a copy of this application, with attachments, is being provided to the designated State Officials.

I declare under penalty of perjury, the foregoing is true and correct. Executed on September 18, 2020.

Respectfully, Ron Gaston RG/jls

Enclosure:

Description and Assessment of the Proposed Changes Attachments to

Enclosure:

1.a. Markup of Technical Specification (TS) Pages, Grand Gulf Nuclear Station, Unit 1 1.b. Markup of Technical Specification (TS) Pages, River Bend Station, Unit 1 2.a. Clean Technical Specification (TS) Pages, Grand Gulf Nuclear Station, Unit 1 2.b. Clean Technical Specification (TS) Pages, River Bend Station, Unit 1 cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - Grand Gulf Nuclear Station, Unit 1 NRC Senior Resident Inspector - River Bend Station, Unit 1 State Health Officer, Mississippi Department of Health Louisiana of Department of Environmental Quality NRC Project Manager - Entergy fleet NRC Project Manager - Grand Gulf Nuclear Station, Unit 1 NRC Project Manager - River Bend Station, Unit 1

Enclosure CNRO-2020/00017 Description and Assessment of the Proposed Changes Application to Adopt TSTF-563, "Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program" Grand Gulf Nuclear Station, Unit 1 River Bend Station, Unit 1 (4 Pages) 1.0 Description 2.0 Assessment 2.1 Applicability of Published Safety Evaluation 2.2 Variations 3.0 Regulatory Analysis 3.1 No Significant Hazards Determination 4.0 Environmental Consideration 5.0 References

CNRO-2020/00017 Enclosure Page 1 of 4

1.0 DESCRIPTION

In accordance with Title 10 of the Code of Federal Regulations (CFR) Part 50, Section 50.90, "Application for amendment of license, construction permit, or early site permit," Entergy Operations, Inc. (Entergy) is submitting a request for an amendment to Renewed Facility Operating License, Appendix A, "Technical Specifications" (TS) for Grand Gulf Nuclear Station, Unit 1 (GGNS) and River Bend Station, Unit 1 (RBS).

These proposed changes adopt the U.S. Nuclear Regulatory Commission (NRC)-approved Technical Specification Task Force (TSTF) Traveler TSTF-563, "Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program," Revision 0 (Reference 1) into the GGNS TS and the RBS TS. The proposed amendment revises the definition of Channel Calibration and Channel Functional Test which currently permit performance by any series of sequential, overlapping, or total channel steps to allow the required frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program (SFCP).

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation TSTF-563 revises the TS definitions of Channel Calibration and Channel Functional Test to allow the required frequency for testing the components or devices in each step to be determined in accordance with the TS SFCP. An SFCP was incorporated into the GGNS TS in license amendment 219, dated June 11, 2019 (ADAMS Accession No. ML19094A799) and into the RBS TS in license amendment 196, dated April 29, 2019 (ML19066A008).

Entergy has reviewed the U.S. Nuclear Regulatory Commission (NRC) safety evaluation (SE) for TSTF-563 provided to the TSTF by letter dated December 4, 2018 (ML18333A146). This review included a review of the NRC's SE (ML18333A147), as well as the information provided in TSTF-563. Entergy has concluded that the justifications presented in TSTF-563 and the SE prepared by the NRC are applicable to GGNS and RBS and justify this amendment for the incorporation of the changes to the GGNS and RBS TS.

2.2 Variations Entergy is not proposing any variations from the TS changes described in TSTF-563 or the applicable parts of the associated NRC SE.

However, the current GGNS and RBS TS definitions for Channel Calibration and Channel Functional Test differ slightly from the definitions in NUREG-1434, "Standard Technical Specifications, General Electric Plants, BWR/6," (i.e., the basis for TSTF-563). Specifically, the GGNS and RBS TS definitions explicitly name the components in a channel that are required for channel OPERABILITY (i.e., the required sensor, alarm, display, and trip functions). The same definitions in NUREG-1434 only refer to the collective term "all devices." In addition, the GGNS and RBS TS definitions include the qualifying phrase:

CNRO-2020/00017 Enclosure Page 2 of 4 "so that the entire channel is tested," in reference to test performance ".by means of any series of sequential, overlapping, or total channel steps." These differences are administrative in nature, in that they clarify the intent of the definitions, and do not affect the applicability of TSTF-563 to either GGNS or RBS.

3.0 Regulatory Analysis 3.1 No Significant Hazards Consideration Analysis Entergy Operations Inc. (Entergy) requests adoption of TSTF-563, "Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program," Revision 0, which is a Nuclear Regulatory Commission (NRC)- approved change to the Improved Standard Technical Specifications (ISTS), into the Grand Gulf Nuclear Station, Unit 1 (GGNS) and River Bend Station, Unit 1 (RBS) Technical Specifications (TS). The proposed amendment revises the definition of Channel Calibration and Channel Functional Test which currently permit performance by any series of sequential, overlapping, or total channel steps to allow the required frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program (SFCP).

Entergy has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

1. Do the proposed amendments involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change revises the TS definitions of Channel Calibration and Channel Functional Test to allow the frequency for testing the components or devices in each step to be determined in accordance with the TS SFCP. All components in the channel continue to be tested. The frequency at which a channel test is performed is not an initiator of any accident previously evaluated; therefore, the probability of an accident is not affected by the proposed change. The channels surveilled in accordance with the affected definitions continue to be required to be operable and the acceptance criteria of the surveillances are unchanged. As a result, any mitigating functions assumed in the accident analysis will continue to be performed.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated..

CNRO-2020/00017 Enclosure Page 3 of 4

2. Do the proposed amendments create the possibility of a new or different kind of accident from any previously evaluated?

Response: No The proposed change revises the TS definitions of Channel Calibration and Channel Functional Test to allow the frequency for testing the components or devices in each step to be determined in accordance with the TS SFCP. The design function or operation of the components involved are not affected and there is no physical alteration of the plant (i.e., no new or different type of equipment will be installed). No credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases are introduced. The changes do not alter assumptions made in the safety analysis. The proposed changes are consistent with the safety analysis assumptions.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

3. Do the proposed amendments involve a significant reduction in a margin of safety?

Response: No The proposed change revises the TS definitions of Channel Calibration and Channel Functional Test to allow the frequency for testing the components or devices in each step to be determined in accordance with the TS SFCP. The SFCP assures sufficient safety margins are maintained, and that the design, operation, surveillance methods, and acceptance criteria specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the plants' licensing basis. The proposed change does not adversely affect existing plant safety margins, or the reliability of the equipment assumed to operate in the safety analysis.

As such, there are no changes being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as a result of the proposed change. Margins of safety are unaffected by method of determining surveillance test intervals under an NRC-approved licensee-controlled program.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above, Entergy concludes that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c),

and, accordingly, a finding of no significant hazard consideration is justified.

CNRO-2020/00017 Enclosure Page 4 of 4 3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

4.0 Environmental Consideration The proposed changes would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed changes meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed changes.

5.0 Reference

1. Technical Specification Task Force (TSTF) Traveler TSTF-563, "Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program,"

Revision 0 (ADAMS Accession No. ML18333A152)

Enclosure, Attachment 1.a CNRO-2020/00017 Markup of Technical Specification (TS) Pages Grand Gulf Nuclear Station, Unit 1 TS Pages 1.0-1 1.0-2

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions

NOTE-------------------------------------

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

AVERAGE PLANAR LINEAR The APLHGR shall be applicable to a specific HEAT GENERATION RATE planar height and is equal to the sum of the (APLHGR) LHGRs for all the fuel rods in the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, display, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps so that the entire channel is calibrated.

CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument

, and each step must be performed within channels measuring the same parameter.

the Frequency in the Surveillance Frequency Control Program for the devices included in the step, (continued)

GRAND GULF 1 .0-1 Amendment No. 120

, and each step must be performed within the Frequency in the Surveillance Definitions Frequency Control Program for the 1.1 devices included in the step, 1.1 Definitions (continued)

CHANNEL FUNCTIONAL TEST A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY, including required alarm, interlock, display, and trip functions, and channel failure trips. The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps so that the entire channel is tested.

CORE ALTERATION CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components within the reactor vessel with the vessel head removed and fuel in the vessel. The following exceptions are not considered to be CORE ALTERATIONS:

a. Movement of source range monitors, local power range monitors, intermediate range monitors, traversing incore probes, or special movable detectors (including undervessel replacement);

and

b. Control rod movement provided there are no fuel assemblies in the associated core cell.

Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.

CORE OPERATING LIMITS The COLR is the unit specific document that REPORT (COLR) provides cycle specific parameter limits for the current reload cycle. These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT I-131 DOSE EQUIVALENT I-131 shall be that concentration of 1-131 (microcuries/gram) that alone would produce the same thyroid dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The thyroid dose conversion factors used for this calculation shall (continued)

GRAND GULF 1.0-2 Amendment No. 120

Enclosure, Attachment 1.b CNRO-2020/00017 Markup of Technical Specification (TS) Pages River Bend Station, Unit 1 TS Pages 1.0-1 1.0-2

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions

NOTE----------------------------------------------------------------

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

AVERAGE PLANAR LINEAR The APLHGR shall be applicable to a specific planar height HEAT GENERATION RATE and is equal to the sum of the LHGRs for all the fuel rods in (APLHGR) the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, display, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel.

The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps so that the entire channel is calibrated.

CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

(continued)

, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step, RIVER BEND 1.0-1 Amendment No. 81

Definitions 1.1 1.1 Definitions (continued)

CHANNEL FUNCTIONAL TEST A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY, including required alarm, interlock, display, and trip functions, and channel failure trips. The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps so that the entire channel is tested.

CORE ALTERATION CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components within the reactor vessel with the vessel head removed and fuel in the vessel.

The following exceptions are not considered to be CORE

, and each step must be performed ALTERATIONS:

within the Frequency in the Surveillance Frequency Control Program for the a. Movement of source range monitors, local power range devices included in the step, monitors, intermediate range monitors, traversing incore probes, or special movable detectors (including undervessel replacement); and

b. Control rod movement provided there are no fuel assemblies in the associated core cell.

Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.

CORE OPERATING LIMITS The COLR is the unit specific document that provides cycle REPORT (COLR) specific parameter limits for the current reload cycle. These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT I-131 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/gram) that alone would produce the same thyroid dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in Federal Guidance Report (FGR) 11, Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion, 1989.

(continued)

RIVER BEND 1.0-2 Amendment No. 81, 132

Enclosure, Attachment 2.a CNRO-2020/00017 Clean Technical Specification (TS) Pages Grand Gulf Nuclear Station, Unit 1 TS Pages 1.0-1 1.0-2

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions

NOTE------------------------------------------------------------

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

AVERAGE PLANAR LINEAR The APLHGR shall be applicable to a specific HEAT GENERATION RATE planar height and is equal to the sum of the (APLHGR) LHGRs for all the fuel rods in the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, display, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an in place qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel.

The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step, so that the entire channel is calibrated.

CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

(continued)

GRAND GULF 1.0-1 Amendment No. 120, ____

Definitions 1.1 1.1 Definitions (continued)

CHANNEL FUNCTIONAL TEST A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY, including required alarm, interlock, display, and trip functions, and channel failure trips. The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step, so that the entire channel is tested.

CORE ALTERATION CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components within the reactor vessel with the vessel head removed and fuel in the vessel.

The following exceptions are not considered to be CORE ALTERATIONS:

a. Movement of source range monitors, local power range monitors, intermediate range monitors, traversing incore probes, or special movable detectors (including undervessel replacement); and

b. Control rod movement provided there are no fuel assemblies in the associated core cell.

Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.

CORE OPERATING LIMITS The COLR is the unit specific document that REPORT (COLR) provides cycle specific parameter limits for the current reload cycle. These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5.6.5.

Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT I-131 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/gram) that alone would produce the same thyroid dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The thyroid dose conversion factors used for this calculation shall (continued)

GRAND GULF 1.0-2 Amendment No. 120, ____

Enclosure, Attachment 2.b CNRO-2020/00017 Clean Technical Specification (TS) Pages River Bend Station, Unit 1 TS Pages 1.0-1 1.0-2

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions

NOTE----------------------------------------------------------------

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

AVERAGE PLANAR LINEAR The APLHGR shall be applicable to a specific planar height HEAT GENERATION RATE and is equal to the sum of the LHGRs for all the fuel rods in (APLHGR) the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, display, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel.

The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step, so that the entire channel is calibrated.

CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

(continued)

RIVER BEND 1.0-1 Amendment No. 81