ML100910313

Staff'S Responses to Public Comments

ML100910313
Person / Time
Issue date:	05/31/2011
From:	Don Helton NRC/RES/DRA
To:
O'Donnell, Edward, RES/DE/RGB 251-7455
Shared Package
ML100910007	List: ML100910313
References
DG-1227 RG 1.177, Rev. 1
Download: ML100910313 (13)

Text

Response to Public Comments on Draft Regulatory Guide (DG) -1227 An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications" Proposed Revision 2 of RG 1.174 A notice that Draft Regulatory Guide, DG-1227 (Proposed Revision 1 of RG 1.177) was available for public comment was published in the Federal Register on September 3, 2009 on page 74 FR 45655. The Public Comment period ended November 3, 2009.

Comments were received from the organizations listed below. The NRC has combined the comments and NRC staff disposition in the following table.

1. Section / Comment Comment NRC Response Reference Source

1. General NEI A key companion document, RG 1.200, An Approach for determining the The staff does not agree with the Technical Adequacy of Probabilistic Risk Assessment Results for Risk- commenter. Regulatory Guide Informed Activities, is listed in the references without a revision number; 1.177 references the revision of this should be corrected to specifically reference Revision 2. Referencing RG 1.200 appropriate for the RG 1.200 without a revision number is not conducive to maintaining application in question (i.e., the regulatory stability, as issuance of future revisions of RG 1.200 could current revision unless a grace appreciably alter the implications of portions of RG 1.177 without any prior period is in effect).

NRC or public review. The lack of a specific revision number in the reference could also lead to ambiguity in the guidance during the implementation period for any future revisions to RG 1.200, as during this time, it would not be clear which revision is intended in the reference.

2. General NEI, Suggest changing allowed outage time to completion time and The requested changes have PWROG surveillance test interval to surveillance frequency throughout the been made throughout the document to achieve consistency with NUREGs 1430-1434 as noted in the document.

footnote on Page 2.

3. Page 4, NEI While the guide at hand focuses on changes to AOTs and STIs, it is The requested change has been Purpose of understood that other type changes to the Technical Specifications can also made.

this utilize the guidance; this should be better emphasized in this section. It is Regulatory recommended that the second sentence of this paragraph, which deals with Guide, Last other types of TS changes, be moved to the end of the section as a stand-Paragraph alone paragraph.

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1. Section / Comment Comment NRC Response Reference Source

4. Page 4, NEI The last sentence in this paragraph, which discusses the possibility of The staff does not agree with the Purpose of additional or revised guidance for plants licensed under 10 CFR 52, should commenters concern. No change this be removed. This issue is being addressed in separate venues, and a has been made.

Regulatory Commission-level decision may be forthcoming. The industry suggests that Guide, Last such statements not be incorporated into regulatory guides until the Paragraph decisionmaking process is complete.

5. Page 4, NEI The industry appreciates that the RG has been revised to explicitly address No change requested.

Scope of both permanent and one-time changes.

Regulatory Guide, Last Paragraph

6. Page 4, Exelon In this section, the word "permanent" has been deleted from the phrase, The parenthetical around AOT Scope of "proposed permanent TS changes" in the first sentence and a revised last was removed. The staff believes Regulatory sentence now states: "... This regulatory guide provides guidance for both that the existing wording already Guide, Last permanent and one time only (AOT)changes to TS." In the past, this RG has clarifies that exigent TS changes Paragraph been specifically applicable ONLY to proposed permanent Technical are included, while NOEDs are Specifications (TS) changes. One-time TS changes (e.g., Allowed not.

Outage Time (AOT) extensions, Notices of Enforcement Discretion (NOEDs), exigent TS changes), were not formally subject to the guidance of this RG, and expanding the scope provides useful guidance for evaluation of such non-permanent changes. However, in expanding the scope of applicability, does the inclusion of the parenthetical "(AOT)" in the last sentence limit one-time only changes to just AOT changes? Exelon requests clarification whether this draft RG is specifically not applicable to NOEDs or exigent TS changes.

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1. Section / Comment Comment NRC Response Reference Source

7. Page 4, Exelon DG-1 227 does not refer to either RG 1.200 or NUREG-1 855. Both of those Regulatory Guide 1.200 is in fact "Relationshi documents establish expectations for PRA scope and technical acceptability referenced in the DG. To augment p to Other for risk-informed applications in a broad context. Exelon considers it the existing reference, a Guidance important for an RG for particular types of applications such as DG-1 227 to paragraph has been added in the Documents" provide additional guidance regarding how the other relevant guidance Relationship to Other Guidance documents are to be applied. Documents section. A reference to NUREG-1855 has also been added. Also, the pending revision to RG 1.174 addresses the nexus between application-specific RGs (e.g., 1.177) and the guidance provided by RG 1.200 and NUREG-1855.

8. Page 5, NEI There appears to be a philosophical difference in approach between DG- We do not agree that the two DGs Risk- 1227 and DG-1226 (RG 1.174) when it comes to treatment of the traditional are inconsistent in this respect. In Informed engineering aspects of risk-informed decisionmaking. RG 1.174 states that fact, the very sentence quoted Philosophy, PRA can provide insights into whether the extent of defense-in-depth is from DG-1227 also appears in Third appropriate to ensure protection of public health and safety. However, to DG-1226. No change has been Paragraph address the unknown and unforeseen failure mechanisms or phenomena, made.

traditional defense-in-depth considerations should be used or maintained.

DG-1227, on the other hand, states that risk analysis techniques can be, and are encouraged to be, used to help ensure and show that these

[traditional engineering] principles are met. This seems inconsistent; further, Section 2.2.1 of DG-1227 appears to actually use the PRA to provide insights, not to show that the principles are met, which is more consistent with the RG 1.174 approach.

9. Page 5, NEI While this section discusses the five principles, there is no specific reference A pointer to Figure 1 has been Risk- to Figure 1, which depicts these principles, and the term Integrated added. Integrated decisionmaking Informed decisionmaking is never used. It is recommended Figure 1 be specifically is already mentioned in the Philosophy referenced, and that Integrated Decisionmaking as portrayed in Figure 1 second paragraph of this section.

also be mentioned.

10. Page 5, NEI For items 2 and 3 change Regulatory Position 2.2 to Regulatory Position The requested change was made.

Risk- 2.2.1 and Regulatory Position 2.2.2, respectively.

Informed Philosophy, Items 2 and 3 3

1. Section / Comment Comment NRC Response Reference Source

11. Page 5, PWROG Discussion under Risk-Informed Philosophy, item 3: There is slightly The requested change was made.

Risk- inconsistent with other sections by leaving out the words of this regulatory Informed guide after Regulatory Position 2.2. Revise to be consistent.

Philosophy, Item 3

12. Page 6, NEI The implied stipulation for the licensee to directly describe how the proposed The sentence is unchanged from Element 1 TS change meets the objectives of the PRA Policy Statement would be the current active version. The more clear if a reference were made to the guidance under Element 1 of subsequent sentence states Section C, Regulatory Position. It is recommended the second to last "Regulatory Position 1 describes sentence be revised to read The licensee should describe the proposed element 1 in more detail." This change and how it meets the objectives of the Commissions PRA Policy sentence provides the necessary Statement, including enhanced decisionmaking, more efficient use of reference to details in the resources, and reduction of unnecessary burden as provided below in referenced sections. A similar Sections 1.1.1, 1.1.2, and 1.1.3. sentence is used in each of the subsequent elements 2-4, so making this element unique and referring to specific subsections of the regulatory position would introduce inconsistency.

13. Page 8, NEI The implied need for the applicant to directly evaluate compliance with the This does not represent a change Section 2, NRC Safety Goal Policy Statement rather than just with the acceptance from the currently published First guidelines of the regulatory guide seems an unnecessary burden for the version of the RG. No change has Paragraph licensee. The first sentence should be revised to read The licensee should been made to the DG.

examine the proposed TS change to verify that it meets existing applicable rules and regulations as expressed through the acceptance guidelines given in this regulatory guide.

14. Page 9, NEI The meaning of STS should be defined. The acronym STS (Standard Element 2, Technical Specifications) is Last already defined on page 1.

Paragraph

15. Page 10, NEI The fourth bullet should be modified unless it is deemed credible for No change has been made.

Section changes to AOTs to introduce a new CCF mode, as opposed to changing Technical specification changes 2.2.1, the magnitude of CCF rates. could introduce new CCF Fourth mechanisms, since AOT changes Bullet are not the only changes covered by the Regulatory Guide.

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1. Section / Comment Comment NRC Response Reference Source

16. Page 12, NEI To achieve better consistency with established (a)(4) guidance, the industry The requested change has been Section 2.3, suggests changing the first sentence of this section such that evaluated made.

Tier 3 before performing any maintenance activity is replaced with assessed and Heading managed.

17. Page 12, NEI Add and demonstration that a licensee meets the (a)(4) requirements is No change has been made. The Section 2.3, sufficient for Tier 3 assessments to the end of the first sentence of the first staff disagrees with the notion that Tier 3 paragraph. the (a)(4) program alone always Heading satisfies Tier 3.

18. Page 12, Exelon "Contemporaneous Configuration Control," refers to Regulatory Position 2.3, No change has been made. The

'Tier 3," 1 st Tier 3, and with the revisions to Regulatory Position 2.3, these discussions intent of the minor changes to the paragraph, imply that the licensee program for compliance with 10 CFR 50.65(a)(4) Tier 3 program discussion is to and Page should provide an adequate approach to meeting Tier 3. The section of DG- identify that the (a)(4) risk 20, "Key 1227 that originally specified inclusion of Configuration Risk Management assessment is adequate to satisfy Component Program (CRMP) in the Administrative Section of the TS has been removed. that portion of Tier 3. Other 1,"Item #3 However, the discussion describing when to invoke the CRMP is still linked existing items in the Regulatory Section to TS AOTs, whereas 10 CFR 50.65(a)(4) does not link the performance of Guide (such as consideration of 2.3.7, any aspect of risk assessment to TS. Section 2.4 requires implementation of external events risk, procedural a "risk-informed plant configuration control program" as a prerequisite for controls, use for risk-informed TS AOT changes. In this regard: AOTs, etc.) are beyond the (a)(4)

• Exelon requests clarification whether a licensee program which is in requirements and are retained.

compliance with 10 CFR 50.65(a)(4) meets the total intent of the "risk-informed plant configuration control program" prescribed in Section 2.4.

• Exelon requests clarification whether licensee programs for compliance with 10 CFR 50.65(a)(4) are adequate "as-is" for supporting TS changes pursuant to DG-1227. Are there additional requirements vis-a-vis Structures, Systems, or Components (SSCs) with TS AOTs?

• Exelon recommends that if additional requirements are intended, then DG-1227 should be clear with respect to the scope of those SSCs. In other words, do those additional requirements apply to all TS SSCs with AOTs, or just the SSCs with AOTs that have been changed pursuant to DG-1 227?

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1. Section / Comment Comment NRC Response Reference Source

19. Page 12, NEI The last two paragraphs under the Tier 3 heading do not appear to be Several changes were made to Section 2.3, relevant to Tier 3 exclusively. As such, the information should be relocated address this comment. The two Tier 3 to the appropriate sections on Tiers 1, 2, or 3; alternatively, a separate paragraphs in question were Heading heading could provide additional clarity. Additionally, the discussion should moved to the end of the Section be revised to specify applicability of Regulatory Position 2.3.1 to any tiers. It 2.3 introduction, the requested is suggested that Regulatory Position 2.3.1 applies only to Tier 1. change to the first sentence under Tier 3 was made, and a new final sentence was added to the first paragraph under Section 2.3.1.

20. Page 12, NEI In the second sentence, in general should be changed to specifically. The requested change was made.

Section 2.3, Note that the paragraph in Tier 3 question was moved up in Heading, response to the previous Second comment.

Paragraph

21. Page 12, NEI, In the heading for Section 2.3.1, the word acceptability should be changed The requested change has been Section PWROG, to adequacy to achieve consistency with other NRC documents, such as made.

2.3.1 Exelon RG 1.200. This terminology should be similarly aligned throughout the document.

22. 2.3.1 PWROG C. Regulatory Position: Note that no revision number to RG 1.200 is No change has been made. The identified in the draft document. Add a one-sentence statement or footnote applicable revision of RG 1.200 is regarding the process by which the appropriate revision can be identified. the same revision that is germane to the application in question (i.e.,

the latest revision unless a grace period is in effect).

23. Page 13, NEI As written, the first sentence could be interpreted as equating Level 2 The requested change has been Section analysis with LERF. Suggest changing the sentence to read Evaluations of made.

2.3.2, CDF and LERF should be performed to support any risk-informed changes Second to TS.

Paragraph

24. 2.3.1 NEI In Section 2.3.1, which discusses PRA technical acceptability and the The DG is intended to reference applicability of RG 1.200 to risk-informed technical specifications, the the revision of RG 1.200 reference to RG 1.200 needs to be specific to the current revision, which will appropriate for the application in be Revision 2, effective April 2010. question (i.e., the current revision unless a grace period is in effect).

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1. Section / Comment Comment NRC Response Reference Source

25. Page 13, NEI The discussion on technical adequacy should be enhanced to include The requested change has been Section guidance on expectations for capability categories for the supporting made.

2.3.1, Last requirements from RG 1.200. A concise discussion is given in DG-1226 and Paragraph could be replicated here.

26. Page 13, NEI, From cover letter: Section 2.3.2 states that the scope of the analysis should The paragraph has been updated Section PWROG include all hazard groups unless it can be shown that the contribution from to address the comment.

2.3.2, the specific hazard group is insignificant. The wording of the commissions Second phased approach to PRA scope states that contributors that are significant Paragraph to the decision should be addressed using an assessment to the PRA standards. The wording in the DG should be revised to be consistent with the commission position. Otherwise, with current definitions relative to insignificant, it could be concluded that the risk contributor must be quantified before it can be determined if quantification is unnecessary.

From specific comments: For improved clarity, the second sentence should be revised to read The scope of the analysis should include those hazard groups that have a significant impact on the decision.

27. 2.3.2 PWROG In the second paragraph, there is a requirement for external event analyses This comment has been unless the issue can be shown insignificant to the decision. addressed, in part, by changes to There are three changes: the paragraph in question. The

1) Since formal analytical models may not be available, analysis should be staff does not agree with other replaced by risk-informed assessment. parts of the comment, or they are

2) Change the term insignificant to not significant. Insignificant can be addressed elsewhere in this DG or interpreted as negligible, and not significant can be interpreted as small. RG 1.174.

The use of the phrase not significant is more appropriate.

3) It should be acknowledged that while NFPA-805 fire PRA models are conservative, alternate more realistic models are acceptable for other risk informed application, such as risk informed Technical Specification initiatives.

28. Page 13, NEI For clarity, in the first sentence, involved should be revised to read The requested change has been Section involved in the change. made.

2.3.3.1 7

1. Section / Comment Comment NRC Response Reference Source

29. Page 14, NEI For clarity, AOT should be revised to read extended AOT in the No change has been made. The Section parenthetical phrase. use of the term "extended AOT" 2.3.3.1, assumes the proposed change is First Bullet to extend an existing AOT, which in Second is overly restrictive.

Bullet List

30. Page 14, NEI Section A.1.3.2 should be changed to Section A-1.3.2. The requested change was made.

Section 2.3.3.1, Third to Last Full Paragraph on Page

31. Page 15, NEI Section A.2 should be changed to Section A-1.3.2. No change has been made. The Section existing reference is correct.

2.3.3.2, Last Paragraph

32. Page 16, NEI This section should refer to the guidance in the ASME/ANS PRA Standard The staff does not agree with this Section and otherwise discourage the use of pre-solved cutsets. comment. The DG already 2.3.3.4, invokes the standard through RG Second 1.200.

Paragraph

33. Page 16, NEI It is recommended that the last sentence of Item 1 be changed to read If The requested change was made.

Section the risk evaluation is marginal or exceeds the guidelines for a proposed AOT 2.3.4, Item increase and the systems involve those needed for shutdown (e.g. residual 1 heat removal systems, auxiliary feedwater systems, service water systems),

the licensee may want to perform comparative risk evaluations of continued power operation versus plant shutdown.

34. Page 17, NEI For licensees considering the zero maintenance option, it may be helpful to No change has been made. This Section add the following after the second sentence: Note that the stated portion of the Regulatory Guide is 2.3.4, Item acceptance criteria are based on a baseline CDF with nominal expected not being revised, and it is not 2 equipment unavailabilities. clear what value this note adds.

35. Page 17, NEI Change Regulatory Positions 2.3.7 and 4.1 to Regulatory Positions 2.3.7 The text has been changed to only Section and 4. cross-reference Section 2.3.7.

2.3.4, Item 5

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1. Section / Comment Comment NRC Response Reference Source

36. Page 18, NEI Section 2.3.5 of the Regulatory Position should refer to NUREG-1855 and A reference to NUREG-1855 has Section describe how uncertainty analysis should support risk-informed technical been added. Further guidance has 2.3.5 specification applications. A hypothetical example of application of NUREG- not been added, as it is available 1855 to a completion time extension was prepared for a joint NRC/EPRI in the NUREG itself.

workshop on NUREG-1855 and may be helpful to consult.

37. Page 18, NEI From cover letter: Section 2.3.5 discusses sensitivity and uncertainty The sentence in question has Section analysis related to assumptions. A final sentence has been added, noting been changed to read: Therefore, 2.3.5, that the applicant will have to provide substantial justification relative to tier the Tier 2 and Tier 3 aspects of Second to 2 and tier 3 controls. It is not clear why this sentence was added, and, as a such TS changes should be Last substantial addition to the previous wording, the need for this change should justified as robust and adequate to Paragraph be explained, or it should be removed. Further, regulatory guides are not control the resulting potential for regulations and should not use requirements language (e.g., will have to). significant risk increases.

From specific comments: The last sentence in this paragraph should be revised to remove the phrase applicant will have to. The industry suggests revising the sentence to read Applicant-provided justification may be appropriate.

PWROG C. Regulatory Position: Section 2.3.5: In the last paragraph, there is an added sentence at the end of Section 2.3.5 (Page 18) that reads However, the applicant will have to provide substantial justification. In this new sentence, substantial justification is versus the deleted wording that said, may be more difficult to justify. This appears to be changing this requirement. The added sentence is not helpful. The meaning of substantial is unclear. The initial portion of the paragraph states that the expectation for the Tier 2 and Tier 3 activity is expected to be robust. This is in the Sensitivity and Uncertainty Section. Tier 2 assessments evaluate the potential for high risk configurations. What is being requested in addition to Tier 2 requirements or (a)(4) of the Maintenance Rule to assess and manage risk? Delete final sentence and replace with a clear alternative, such as: If such circumstances are expected, the utility should provide justification to ensure that the risk consequences of multiple entries into longer duration CTs is properly considered.

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1. Section / Comment Comment NRC Response Reference Source

38. 2.3.6 PWROG C. Regulatory Position, Section 2.2.1: In the second bullet, the following is The requested change has been deleted: to compensate for weaknesses in design. In the first sentence in made.

Section 2.3.6, second paragraph, the same words were not deleted.

Consistency. Remove the words in the second paragraph of Section 2.3.6 and replace them with the words similar to those in Section 2.2.1.

39. Page 20, NEI, It appears that 10 CFR 50.65(a)(4) is inadvertently mistyped as 10 CFR The requested change has been Section Exelon 50.65(a)(3). made.

2.3.7.2, Key Component 1 Heading

40. 2.3.7.2 PWROG Item 3 on page 20 refers to TS action statement, which is not consistent The requested change has been with the terminology in NUREGs 1430-1434. made.

Revise TS action statement, to TS Action, to be consistent with the terminology in NUREGs 1430-1434.

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1. Section / Comment Comment NRC Response Reference Source

41. 2.3.7 NEI Section 2.3.7 discusses configuration control and the Configuration Risk The staff does not agree with the Management Program (CRMP). As noted in the DG, the CRMP is met though commenters concern. No change reliance on 10 CFR 50.65(a)(4). This regulatory position has been in effect since has been made with regard to this shortly after the promulgation of (a)(4). The NRC is currently performing a regulatory issue.

analysis to justify expansion of the scope of (a)(4) to include non-internal events initiators. However, this regulatory analysis is not complete. The DG is unclear in its discussion of PRA technical adequacy relative to the applicability of RG 1.200 on the tier 3 process; however, NRC staff has recently stated their intent that RG 1.200 should be applied to tier 3. This is a significant revision to an accepted regulatory position, and is neither justified nor appropriate. We request that the staff clarify the final RG to clearly state that RG 1.200 does not apply to tier 3. 10 CFR 50.65(a)(4) and its NRC-endorsed implementation guidance (RG 1.182) allow quantitative, qualitative or blended approaches to address risk assessment and management.

Further, the scope of initiators is limited to internal events. These attributes reflect overt decisions made by the NRC in endorsing the guidance and reflect limits on the state of practice and modeling for configuration control purposes. All plants use their Level 1 internal events PRA in some fashion in their (a)(4) program, and most plants are approaching general conformance with the internal events portion of RG 1.200.

However, the PRA is not expected to be compared to RG 1.200 specifically for the purposes of (a)(4) compliance. To invoke RG 1.200, Revision 2, or to make an unspecified reference to RG 1.200 in the context of tier 3 assessments will create substantial problems for the CRMP and (a)(4). The following problems would be created: Rulemaking and Directives Branch November 3, 2009 Page 3

1. The expectations for the CRMP would diverge greatly from the (a)(4) program due to different initiators, and different expectations for quantification.

2. The CRMP expectation would essentially obviate the ongoing (a)(4) regulatory analysis, and is potentially subject to the same regulatory analysis considerations under 10 CFR 109, since it is a new regulatory position.

3. Invoking RG 1.200, Revision 2 into CRMP suggests an expectation for quantification of fire and external events (including seismic) risk. This capability at a level to support (a)(4) is many years away. Significant problems with conservatism in fire PRAs would lead to skewed risk assessments and incorrect risk management actions. The fire PRA will not be usable for decision-making involving comparison to internal events until the existing models are made more realistic. NRC staff involved in the ongoing (a)(4) regulatory analysis have stated that fire can be addressed qualitatively. Further, no plants have external events (seismic) PRAs meeting RG 1.200, Revision 2, and the pilot application is not yet complete.

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1. Section / Comment Comment NRC Response Reference Source

42. 2.4 PWROG The next to the last paragraph on page 21 discusses PRA-informed In the sentence indicated, PRA-results, which should be risk-informed results. informed results has been Revise PRA-informed results to risk informed results. changed to PRA results. An occurrence of PRA-informed results in the appendix was also modified.

43. 2.4 PWROG Item 1 on page 22 refers to TS AOT entry, which is not consistent with the The requested change has been terminology in NUREGs 1430-1434. made.

Revise TS AOT entry, to TS Condition entry, to be consistent with the terminology in NUREGs 1430-1434.

44. Page 22, NEI, The industry appreciates that, for one-time changes, different acceptance No change has been made.

Quantitative Exelon guidelines that are consistent with NUMARC 93-01 have been added. Additional flexibility is provided for Acceptance However, for permanent changes, the acceptance guidelines are structured one-time changes since Guidelines differently. For example, for one-time changes, there are two ICCDP compensatory measures may be thresholds (i.e., 10-6 and 10-7). This is consistent with both NUMARC 93-01 implemented. For permanent and the Region 2/Region 3 demarcations from RG 1.174 in that the limit is changes, compensatory measures treated as permeable if additional actions are taken. However, for the are not typically specified in the permanent changes, only one threshold is specified (i.e., ICCDP of 10-6), TS, and the additional flexibility in even though ICCDPs below that threshold are allowed without any risk risk is not justified.

management actions under licensee (a)(4) programs. This is inconsistent with both NUMARC 93-01 and RG 1.174, and is overly restrictive, especially for CTs that are expected to be utilized infrequently. Furthermore, for permanent changes, the CDF/LERF guidelines are also applied. The CDF/LERF guidelines, along with risk monitoring, ensure that there is not a large change in risk to the public over time and should provide a sufficient backstop to allow for an additional ICCDP/ICLERP threshold to be applied, with appropriate considerations of risk management actions that might be applicable above an ICCDP of 10-6 or an ICLERP of 10-7

45. Page 27, NEI It should be specified that RG 1.200, Revision 2 is the revision referenced The revision number has been References, throughout this DG. removed, consistent to the Reference responses on other similar 13 comments on both DG-1226 and DG-1227.

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1. Section / Comment Comment NRC Response Reference Source

46. Page A-2, NEI For clarity, insert the word equipment after the word given. No change has been made. The Section A- requested change is not 1.1, Fourth necessary.

Bullet

47. Page A-2, NEI For clarity, insert the words the plant after the words shutting down. The requested change has been Section A- made.

1.1, Fifth Bullet

48. A-1.3.2.2 PWROG Typo: Section A-1.3.2.2, paragraph 2, page A-5, OC should be QC. The requested change has been Revise OC to QC. made.

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