ML20244C445

Safety Evaluation Supporting Amend 117 to License DPR-61

ML20244C445
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	06/01/1989
From:	Office of Nuclear Reactor Regulation
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ML20244C439	List: ML20244C436 ML20244C441 ML20244C445
References
NUDOCS 8906140312
Download: ML20244C445 (12)

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UNITED STATES NUCLEAR REGULATORY COMMISSION T

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.117 TO FACILITY OPERATING LICENSE NO. DPR-61 CONNECTICUT, YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT DOCKET NO. 50-213

1.0 INTRODUCTION

By letter dated March 31, 1989, Connecticut Yankee Atomic Power Company (CYAPC0/ licensee) req.uested changes to plant Technical Specification (TS)

Section 3.11.B as previously amended in License Amendment No.112 to provide a revision of the one-time relaxation of containment integrity specifications to allow the four containment air recirculation (CAR) fan motor heat exchangers to be cleaned or replaced while at power.

2.0 DISCUSSION On December 16, 1988, the licensee found that the four CAR units provided inadequate cooling capability, and therefore, declared them to be inoperable.

The CAR fan system is designed to depressurize and cool the reactor contain-ment following a loss of coolant accident (LOCA). -Subsequently, the licensee provided a justification for continued operation (JCO), which placed a number

! of restrictions on plant operation with the degraded CAR. fan system. One of L those restrictions was to limit plant operation te when the service water (Connecticut River) supply temperature is less than 50'F. The licensee .

identified that the flow in the CAR cooling coils was partially blocked and, therefore, the cooling capability of the CAR system was reduced. As part of '

the effort to restore the cooling capability of the CAR units before the 50'F limit is reached, the licensee developed procedures to clean the CAR coils without shutting down the plant. Hewever, the proposed cleaning operation would have violated the existing containment integrity TS, thus necessitating the issuance of Amendment ho. 112. Amendment No. 112 modified TS Section 3.11.B to allow a one-time relaxation of containment integrity requirements with compensatory measures to allow the CAR fan heat exchangers to be cleaned while the plant is at power.

l l Following receipt of the license amendment, CYAPC0 initiated the process of l cleaning each CAR fan heat exchanger. Upon opening the heat exchangers, l CYAPC0 confirmed that there was a buildup of material that restricted service l water flow through the exchangers. However, the fouling mechanism was

. somewhat different than anticipated in that rather than providing localized tube plugging, there was a uniform buildup over the whole heat exchanger, h61 P

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-In addition to the CAR fan heat exchangers, there is a smaller motor heat exchanger for each of the four CAR fans (two cooling coils per fan motor heat exchanger). Because of the fouling mechanism identified, CYAPCO has concluded it is necessary to clean these heat exchangers as well. CYAPC0 has performed a reevaluation of the service water system and concluded that with the CAR heat exchangers cleaned, Haddam Neck Plant operation is acceptable with a service water temperature up to 75 F. CYAPC0 has determined that to operate above 75'F to the design limit of 85'F, the CAR fan motor heat exchangers would have to be cleaned or replaced as well. Therefore, CYAPC0 proposes a TS change to extend the use of the one-time relaxation of the containment integrity, issued in License Amendment No. 112, to allow the CAR fan motor heat exchangers to be cleaned or replaced while at power.

3.0 EVALUATION CYAPC0 has stated that the evaluation for Amendment No. 112 (Attachment to this SE) envelopes this proposed amendment. However, because Amendment No. 112 specifically allowed the cleaning of only the CAR fan heat exchangers and not the CAR fan motor heat exchangers, it was necessary to propose this TS amendment.

CYAPCO proposes to do the cleaning / replacement within the limits of Amendment No. 112. That is, the total of 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br /> established in License Amendment No.

112 for cleaning the CAR fan heat exchangers will remain as the absolute limit.

The service water piping (containment boundary) for each CAR fan motor heat exchanger may be impacted for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> at a time to install or remove threaded pipe caps and test the newly established containment boundary during power operation. If the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> limit is exceeded, this additional time when containment integrity is relaxed shall be counted towards the 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br />.

The CAR fan motor heat exchangers which are inside containment, are in parallel with the CAR fan heat exchangers (see Figure 1). The CAR fan motor heat exchangers have manual isolation valves inside of containment. Because these valves are not normally leak tested to insure containment integrity after the service water lines are opened, blank flanges will be installed. The blank flanges will be leak tested only if the isolation valve is leaking. The leakage criteria is zero water leakage for the valve or flange. In addition, a water seal at a pressure greater than the peak accident pressure (Pa) will be provided to the isolation valves. This will be accomplished by closing the service water outlet isolation valve outside of containment. However, in the unlikely event that offsite power is lost and one emergency diesel generator fails to start, it cannot be assured that service water pressure will remain above Pa. The water seal at a lower pressure will be maintained which would limit leakage. Thus,

~during the period that the service water piping may be open, the containment barrier will be the manual isolation valves, the seismically qualified piping, the blank flange and the water seal in the service water piping.

The staff has reviewed this amendment and agrees that the evaluation for Amendment No.112 does envelop this amendment and, if not for the specific reference to the CAR fan heat exchangers, the CAR fan motor heat exchangers could have been cleaned / replaced during the CAR fan heat exchanger cleaning. Also, because the isolation valves are inside containment, the cleaning procedure with respect to containment integrity will be less rigorous because the service water

piping inside containment will always be isolated from the containment atmosphere unlike the case of the CAR fan heat exchanger cleaning. If the CAR fan motor heat exchange'r isolation valves are leak tight, an argument could be made that contain-ment integrity is not violated even without the blank flanges. Tha staff con-cludes that in the event of a LOCA, the closed isolation valve sealed with water with a pressure in the opposite direction of the accident releases, in series with a blank flange, all of which are connected to seismically qualified piping inside containment, would prevent any post-LOCA releases to the environment through the service water line. Therefore, the staff finds CYAPCO's proposed CAR fan motor heat exchanger cleaning / replacing operation at power to be acceptable.

Based on the above, the staff concludes that the licensee's proposed technical specification change and plans to clean the CAR fan motor heat exchangers at power with compensatory measures in place for maintaining containment integrity are adequate to ensure that unacceptable offsite releases will not occur in the event of a LOCA during the interim period while the cleaning operation is pursued.

The staff, therefore, finds the proposed change acceptable with incorporation of reference to the compensatory measures in the interim TS as agreed to by the licensee.

4.0 EMERGENCY CIRCUMSTANCES Pursuant to 10 CFR 50.91(a)(6), CYAPC0 by letter dated May 25, 1989, requested the NRC to approve this proposed amendment under emergency circumstances. In a letter dated February 10, 1989. CYAPC0 proposed changes to the TS for the

! Haddam Neck Plant that would allow the service water side of the four CAR fan heat exchangers to be cleaned while the plant was at power. In a letter dated March 7, 1989, the HRC staff issued the license amendment approving CYAPCO's request.

Following receipt of the license amendment CYAPCO initiated the process of cleaning the CAR fan heat exchangers. During the cleaning process (from 10-14 days in length), CYAPC0 concluded that it would be necessary to clean (or

, replace) the CAR fan motor heat exchangers as well. CYAPC0 reevaluated the l service water system and concluded that with the CAR fan heat exchangers cleaned, Haddam Neck Plant operation would be acceptable up to a service water temperature of 75*F. However, to operate above 75F, CYAPC0 determined that the CAR fan motor heat exchangers would have to be cleaned or replaced as well. CYAPC0 began to discuss with the NRC staff different options as to the most appropriate regulatory vehicle to authorize cleaning or replacement of these CAR fan motor heat exchangers while the plant continued operation, given existing TS as amended by the license amendment issued on March 7, 1989.

( Following consultation with the NRC staff, CYAPCO expeditiously processed a proposed change to the Haddam Neck Plant TS to support the CAR fan motor heat exchanger cleaning or replacement and submitted a license amendment request to the NRC staff by letter dated March 31, 1989. CYAPCO made every effort to have l this license amendment request processed under normal circumstances recognizing the uncertainty of the rate of increase in service water temperature (Connecticut River water) during this time of the year.

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The Federal Register notice on this license amendment request expires on June 12, 1989. Therefore, the license amendment could not be issued until at least_that date. In addition, CYAPCO projects that at least one week will be required to perform the CAR fan motor heat exchanger cleaning / replacement evolution. Accordingly, if the normal license amendment request process continues, the Haddao Neck Plant will be required to shutdown if the service water temperature exceeds 75'F on or before June 19, 1989. A review of recent historical trends in service water temperature reveals that temperatures of 70*F can be achieved during the second half of May with 75'F following shortly thereafter. Also, tidal effects can result in very rapid, short term increases in service water temperature. As of Monday, May 22, 1989, service water temperature at the Haddam Neck Plan was at 64'F. More significantly, the temperature had increased over 10'F in the course of one week, demonstrating that substantial increases in temperature over short time periods are quite possible this time of year. In addition, the long tem forecast for Southern New England is for warmer weather over the next week. Further contributing to the existence of emergency circumstances is the fact that at least a one week buffer is prudent between license amendment issuance and service water temperature reaching 75*F to allow the cleaning / replacement of the CAR fan motor coolers. Of course, this seven day estimate to conduct the cleaning /

replacement evolution is only an estimate, and this period could be longer if unexpected problems are encountered. Thus, the NRC staff does not believe that the licensee has abused the emergency provisions in this instance. Accordingly, the Commission has detemined that these are emergency circumstances warranting prompt approval by the Commission.

5.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION

DETERMINATION The Commission's regulations in 10 CFR 50.92 state that the Comission may make a final determination that a license amendment involves no significant hazards considerations, if operation of the facility, in accordance with the amendment would not:

(1) Involve a significant increase in the probability or consequences of any accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin or safety.

This amendent has been evaluated against the standards in 10 CFR 50.92. It does not involve a significant hazards consideration because the changes would not:

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1. Involve a significant increase in the probability or consequences of an accident previously evaluated. This TS change is bounded by the evaluation submitted in CYAPCO's letter dated February 10, 1989, and approved by the NRC staff in Amendment No. 112. The total time restriction of 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br /> for having the service water system open envelopes this proposed change as well. CYAPC0 is not requesting an additional 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br />, but proposes to perform the work allowed by this license amendment under the original 64-hour restriction approved in Amendment No.112.

Therefore, the 10 CFR 50.92 evaluation described in CYAPCO's February 10, 1989 license amendment request bounds this proposed change as well.

The purpose of the proposed change is to clean / replace the CAR fan motor heat exchangers. In so doing, service water flow through the heat exchanger will increase. This increase in heat removal capacity is necessary to restore the CAR unit performance to that assumed in the Updated Final Safety Analysis Report for the design service water temperature. The net effect of the change will be to improve CAR unit cooling system performance, specifically by ensuring proper fan motor cooling.

2. Create the possibility of a new or different kind of accident from any previously evaluated. The possibility for an accident or malfunction of a different type than any evaluated previously in the Final Safety Analysis Report is not created since the change and/or failure modes associated with the change do not modify the plant response to the point where it can be considered a new design basis accident.

The compensatory measures, combined with the short duration of containment integrity relaxation, result in an increase in tge probability of a failure of containment isolation of 7 x 10~ when averaged over a year. This low probability, coupled with the icw probability of accidents resulting in a release of significant .

radioactivity into the containment, is judged to be negligible and need not be considered for this maintenance evolution. The basis for this determination is that containment isolation failure in the current configuration has some finite probability, and the incremental increase resulting from the proposed changed would be significantly small. The proposed change does not create a new unanalyzed event based on compensatory measures which will be in effect.

3. Involve a significant reduction in a margin of safety. The proposed change does not impact the consequences of an accident on the fuel or reactor coolant system protective boundaries. The proposed change will allow the opening of the service water piping inside containment for relatively short periods of time. This piping serves as the containment boundary. The relaxation of containment integrity does not represent a significant reduction in the margin of safety. As noted above, the compensatory measures which will be implemented provide reasonable

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. . i assurance that the containment boundary will be maintained and that the allowable off-site dose limit will not be exceeded.

Based on the above discussion, the proposed change will not decrease the margin of safety because of:

a. The compensatory measures to maintain the containment boundary.

b. The relatively short duration when the service water piping inside containment is open.

c. The unavailability of the CAR fan units is bounded by that allowed by both the TS and existing administrative controls.

Accordingly, the Commission has determined that this amendment involves no significant hazards considerations.

6.0 STATE CONSULTATION

In accordance with the Commission's regulations, efforts were made to contact the Cr M cticut State representatives. The state representative was contacted and had no comments.

7.0 ENVIRONMENTAL CONSIDERATION

This amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. We have determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any efflu-ents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The staff has pre-viously published a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding.

Accordingly, the amendment meets the eligibility criteria for categorical exclu-sion set forth in 10 CFR 651.22(c)(9). Pursuant to 10 CFR 651.22(b), no envi-ronmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

8.0 CONCLUSION

We have concluded, based on the considerations discussed above, that (1) there is reasonsble assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducced in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Dated: June 1, 1989 y

Principal Contributor:

A. Wang

Attachment:

1. Amenoment No. 112 Safety Evaluation

2. Figure 1

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Enclosure 1  ;

. SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION PLANT SYSTEMS BRANCH j C0hTAINMENT INTEGRITY TECHNICAL SPECIFICATIONS 1 HADDAM NECK PLANT DOCKET NO. 50-213

1.0 INTRODUCTION

By letter dated February 10, 1989, Connecticut Yankee Atomic Power Company (the licensee) requested changes to plant Technical Specification (TS)

Section 3.11.0, Containment Integrity, .for the Heddam Neck Plant. The proposed TS change provides a one-time relaxation of containment integrity requirements to allow the service water side of the four containment air recirculation (CAR) far heat exchangers to be cleaned while the plant is at power.

On December 16, 1988, the licensee found that the four CAR units provided inadequate cooling capability, and therefore, declared them to be inoperable.

The CAR fan system is designed to depressurize and cool the reactor containment following a loss of coolant accident (LOCA). Subsequently, the licensee provided a justification for continued operation (JCO), which placed a number of restric-tions on plant operation with the degraded CAR fan system. One of those restric-tions was to limit the service water (Connecticut River) supply temperature to less than 50*F. The licensee identified that the flow in the CAR cooling coils was partially blocked, and therefore, tne cooling capability of the CAR

. system was reduced. As part of the efforts to restore the cooling capability of the CAR units before the 50*F limit is reached, the licensee developed the following procedures to clean the CAR coils without shutting down the plant.

However, the proposed cleaning operation would violate the existing contain-ment integrity TS, thus necessitating the proposed temporary change.

The cleaning operation will require removal of all the four CAR units one at a time for a period not to exceed seven days for each unit. Each CAR unit is com-prised of five cooling coils. When the CAR cooling coils are removed from their flanged elbows to be cleaned, blank flanges will be installed and leak tested in order to maintain containment integrity. In the process of removing the CAR coils and installing the blank flarges, the service water piping inside contain-ment will be opened to the containment atmosphere and current TS Section 3.11.B will be violated.. Therefore, the licensee proposed changes to TS Section 3.11.B to allow a one-tine relaxation of containment integrity requirements with compen-satory measures in place as discussed below.

2. EVALUATION The licensee stated that the current plant TS require that only three CAR units be operable wher.ever the reactor is critical, and current administrative controls allow a fourth CAR unit to be removed from service for up to 7 days. In addition, the licensee's evaluations in support of the JC0 confirmed that four

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service water pumps and three operable CAR units in their degraded condition with'a service water temperature less than 50*F are adequate to meet all normal and post-accident service water cooling requirements. Therefore, taking one CAR unit out of service for less than 7 days during the cleaning operation does not violate the CAR system TS. However, it will affect the con-tainment integrity TS.

Current TS Section 3.11.B requires containment integrity to be maintained wher.ever the reactor coolant system is above 300 psig and 200*F. The proposed changes add the following footnote to TS Section 3.11.B:

"The service water piping (containment boundary) for each CAR fan heat exchanger may be opened for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> at a time to install or. remove blank flanges. If rentainment integrity is not restored within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The cumulative time for the service water piping to be open shall not exceed 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br />. The four CAR. fan heat exchangers nay be cleaned only once during Cycle 15 under this specification."

The above change is necessary because the process of cleaning the CAR cooling coils will require the service water piping inside containment to be opened to containment atmosphere for a period up to 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br /> since it takes up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> each time to install and remove the blank flanges. Thus, for four CAR units to ,

be cleaned sequentially, the process will take 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br /> total. If a LOCA should  !

occur during this period, the radioactive gases in the containment could be released through the service water piping to the environment which could exceed the allowable offsite dose. To provide alternatives to TS Section 3.11.B for the period of installing and removing the blank flanges, the licensee proposed the following compensatory measures. Prior to the service water pi opened, the service water supply manual valve (outside containment) ping being will be closed and a blank installed between the existing mating flanges upstream of the service water return manual valve outside containment. Pressure above the calculated maximum post-accident containment pressure will be maintained on the closed inlet valve to prevent containment leakage, and the outlet blank flange will be leak tested. Thus, during the period that the service water piping may be open, the containment barrier will be the manual valve, the seismically qualified piping on the CAR unit supply side, and the blank flange and associated piping on the return side. The return piping outside containment between the containment penetration and the discharge valve was built to ANSI B31.1 - 1955 standards.

The staff has reviewed the licensee's proposed compensatory measures and has determined the following. The service water supply to each CAR unit consists of a six inch supply line penetrating containment at P-55, 56, 57, and 58. Each supply line has a check valve inside containment. Each CAR unit consists of five sections connected together by a header along with common vent and drain connections. The return lines are also six inch piping which penetrate contain-ment at P-51, 52, 53 and 54. Each return line has a manuc1 ball valve outside containment. The four return lines are joined together downstream of the ball valves by a header prior to entering the discharge tunnel. Since the return piping cuiside containment is not seismically cualified and the supply line

manual. valves are not subject to Appendix J. Type C leak testing, the compensa-tory measures do not satisfy the containment integrity guidlines of Standard Review' Plan (SRP) Section 6.2.4.

However, in case of a LOCA, a check valve in series with a closed inlet valve sealed with water at higher pressure in the opposite direction of the-accident releases from the supply line, and the blank flange in the return

.line would prevent any post-LOCA releases to the environment through the-service water line. This configuration is taken as an alternative to the containment integrity criteria of the SRP for at most 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br />. For such a short duration, the staff believes that the proposed compensatory measures provide adequate protection against unacceptable-radioactive releases. Therefore, the staff finds the licer.see's proposed CAR units cleaning operation at power and the associated interim TS change for ensuring containment integrity to be acceptable. Since the compensatory measures are important to the staff's acceptance, the staff recommends that the footnote in the proposed TS change be modified to state

... install or remove blank flanges. During this time, compensatory measures will be taken. ..." Thereby providing further ensurance that containment in-tegrity can be maintained as necessary during the cleaning operation. The licensee has agreed to include this additional wording.

3. CONCLUSION Based on the above, the staff concludes that the licensee's proposed technical specification _ change and plans to clean the CAR fan heat exchangers at power with compensatory measures in place for maintaining containment integrity are adequate to ensure that unacceptable offsite releases will not occur in the event of a LOCA during the interim period while the cleaning operation is pursued.

The staff, therefore finds the proposed change acceptable with incorporation of reference to the compensatory measures in the interim TS as agreed to by the licensee.

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3.11 CONTAINMENT ADD 11cability: Applies to the operating status of reactor containment.

.Obiective: To insure containment integrity.

i Specification: A. Leakaae The reactor shall not be critical if the containment leakage exceeds 0.25 weight percent of the contained air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when extrapolated to 40 psig in j accordance with Surveillance Standard 4.4. I I

B. Containment Intearity* l (1) Containment integrity shall be maintained whenever the geactor coolant system is above 300 psig and 200 F. The shutdown margin shall be greater than 2600pcm when the containment is open.

(2) Containment integrity shall not be violated when the reactor vessel head is removed unless the reactor coolant system is borated to the refueling boron concentration.

(3) Positive reactivity changes shall not be made by rod drive motion or boron dilution whenever the containment integrity is not intact.

C. Internal Pressure l The reactor shall not be critical if the containment ,

internal pressure exceeds 3 psig, or the internal '

vacuum exceeds 2.0 psig.

D. Air Recirculation System ,

l Three of the four air recirculation units shall be -

operable whenever the reactor is critical.

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'bn 4kis tim , compens4r3 g$Arwes vio k td.. . ,

• Theservicewaerpiping(containmentboundary)for,eachCARfanheat exchanger may e opened for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> at a timd to install or remove i blank flanges. If containment integrity is not res'tored within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, be in HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN kithin the following 30 ,

hours. The cumulative time for the service water piping to be open shall not 1

exceed 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br />. The four CAR fan heat exchangers may be cleaned only once I during Cycle 15 under this specification.

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Enclosure 3 SPLD SALP INPUT Plant Name: Haddam Neck Plant SER

Subject:

Technical Specification Changes on Containment Integrity During CAR Fan Heat Exchanger Cleaning

-TAC No.: 720?4 Summary of Review / Inspection Activities The staff her reviewed the licensee's proposed TS changes to support the opera-tion of cleaning the . service water side of the containment air recirculation fan heat exchangers et power.

Narrative Discussion of Licensee Performance - Functional Area The proposed changes'of TS on conteir. ment integrity addressed the regulatory concern associated witn a relaxation of a requirement on containment integrity during the cleaning operation end the proposed compensatory measures addressed the safety concern of potential releases following a LOCA. The licensee's res-ponse to the staff's request for clarification was prompt and complete.

Author: C. Li Date* Fe b r ua ry 27, 1989

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