ML20129K206

Safety Evaluation Supporting Amend 174 to License DPR-20

ML20129K206
Person / Time
Site:	Palisades
Issue date:	10/31/1996
From:	NRC (Affiliation Not Assigned)
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ML20129K202	List: ML20129K206
References
NUDOCS 9611080255
Download: ML20129K206 (21)

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.174 TO FACILITY OPERATING LICENSE NO. DPR-20 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET NO. 50-255 4

1.0 INTRODUCTION

By letter dated December 11, 1995, as supplemented by letters dated January 18, September 3, and October 2, October 18, and October 25, 1996, Consumers Power Company (the licensee) requested an amendment to the Technical 4

Specifications (TS) appended to Facility Operating License No. DPR-20 for the Palisades Plant. The proposed amendment would modify TS Section 6.0 by removing or relocating requirements that are adequately controlled by existing regulations other than 10 CFR 50.36 and the TS. The proposed changes would also revise other TS associated with the Section 6.0 revisions. Guidance on the proposed changes was developed by the NRC and provided in the Standard Technical Specifications (STS) for Combustion Engineering Plants, NUREG-1432, and Administrative Letter 95-06, " Relocation of Technical Specification Administrative Controls Related to Quality Assurance," issued on December 12, 1995.

In addition to the proposed changes described above, the licensee also proposed to revise containment leak rate testing requirements to allow the Type A integrated leak rate test (ILRT) to be scheduled in accordance with Option B of 10 CFR Part 50, Appendix J.

The October 2, October 18, and October 25, 1996, letters provided clarifying information and updated TS pages that were within the scope of the initial application and did not affect the staff's initial proposed no significant hazards consideration determination, which was published following the September 3, 1996, submittal.

2.0 BACKGROUND

Section 182a of the Atomic Energy Act (the "Act") requires applicants for nuclear power plant operating licenses to state TS to be included as part of the license.

The Commission's regulatory requirements related to the content of TS are set forth in 10 CFR 50.36. That regulation requires that the TS include items in five specific categories, including (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements; (4) design features; and (5) administrative controls. However, the regulation does not specify the particular requirements to be included in a plant's TS.

9611080255 961031 PDR ADOCK 05000255 P

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The Commission provided guidance for the contents of TS in its " Final Policy l

Statement on Technical Specifications Improvements for Nuclear Power Reactors"

(" Final Policy Statement"), 58 FR 39132 (July 22,1993), in which the Commission indicated that compliance with the Final Policy Statement satisfies Section 182a of the Act.

In particular, the Commission indicated that certain LCOs, and related surveillance requirements and action statements, could be 4

relocated from the TS to licensee-controlled documents.

In Portland General Electric Co. (Trojan Nuclear Plant), ALAB-531, 9 NRC 263, 273 (1979), the Atomic Safety and Licensing Appeal Board indicated that, " technical 1

specifications are to be reserved for those matters as to which the imposition i

of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving rise to an j

immediate threat to the public health and safety."

4 The Commission recently adopted amendments to 10 CFR 50.36, pursuant to which the rule was revised to codify and incorporate four criteria to be used in determining whether a particular matter is required to be included in an LCO, j

as follows:

Final Rule, " Technical Specifications," 60 FR 36593 (July 19, i

1995) (1) Installed instrumentation that is used to detect, and indicate in j

the control room, a significant abnormal degradation of the reactor coolant pressure boundary; (2) a process variable, design feature, or operating l

restriction that is an initial condition of a design-basis accident or transient analysis that either assumes the failure of pr presents a challenge l

to the integrity of a fission product barrier; (3) a-si.ructure, system, or component that is part of the primary success path and which functions or j

actuates to mitigate a design-basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product I

barrier; or (4) a structure, system, or component which operating experience l

or probabilistic safety assessment has shown to be significant to public health and safety.

LCOs and related requirements that fall within or satisfy i

any of the criteria in the Final Policy Statement must be retained in the TS, j

while those requirements that do not fall within or satisfy these criteria may be relocated to licensee-controlled documents. While the criteria

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specifically apply to LCOs, in adopting the revision to the rule the Commission noted that the staff had used the intent of these criteria to j

j identify the optimum set of administrative controls in the TS (60 FR 36957).

i 10 CFR 50.36 states that " Administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, i

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and reporting necessary to assure operation of the facility in a safe manner."

The specific content of the administrative controls section of the TS is i

therefore that information that the Commission deems essential for the safe operation of the facility that is not already adequately covered by other regulations. Accordingly, the staff has determined that requirements that are not specifically required under 10 CFR 50.36(c)(5) and that are not otherwise necessary for operation of the facility in a safe manner, can be removed from administrative controls.

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3.0 DESCRIPTION

AND EVALUATION OF PROPOSED CHANGES i

The licensee proposed to extensively restructure TS Section 6, " Administrative Controls," to closely emulate the Administrative Controls section of the STS.

Certain requirements that are redundant to regulatory requirements would be deleted, other requirements would be relocated to licensee-controlled procedures and programs, and the remaining requirements would be reorganized to closely emulate the STS Administrative Controls section. The licensee also i

proposed changes to several requirements contained in other sections of the TS that were affected by this restructuring and proposed adoption of Option B of 10 CFR Part 50, Appendix J, for performance of Type A containment leak rate testing.

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3.1 Reauirements Deleted From Technical Soecifications or Relocated To Other Licensee-Controlled Documents l

Definitions i

The licensee proposed to delete the definitions for MEMBER (S) 0F THE PUBLIC, SITE BOUNDARY, and UNRESTRICTED AREA. Where these defined terms appear in the i

balance of the TS in capitalized text to indicate a term defined in Section 1, i

they would be replaced with lower case text.

No requirements would be changed. The subject definitions are redundant to definitions contained in 10 CFR Part 20. There is no safety benefit to retaining these definitions in TS; therefore, the proposed change is acceptable.

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Inservice Insoection Proaram Evaluation

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The licensee proposed to delete TS 4.3e, which requires reevaluation of the Inservice Inspection Program in accordance with 10 CFR 50.55a(g)(5). This requirement is redundant to the referenced section of 10 CFR Part 50, and is included in the Inservice Inspection and Testing Program.

The staff concludes j

that the regulatory requirements under 10 CFR 50.55a and the requirements of the Inservice Inspection and Testing Program provide sufficient control over reevaluatica of the Inservice Inspection Program, such that removing these provisions from the TS is acceptable.

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Plant Staff

.I' The licensee has proposed that requirements contained in Table 6.2-1, " Minimum i

Shift Crew Composition," which are redundant to the requirements of l

10 CFR 50.54(k), (1), and (m) be deleted. The regulations describe the minimum shift composition for operating modes, as well as for cold shutdown j

and refueling. The staff concludes that the shift staffing requirements in 10 CFR 50.54, in conjunction with the organizational responsibilities and authorities retained in the administrative controls, provide adequate control over the plant staffing requirements. Therefore, removing these requirements from the TS is acceptable.

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. Desianation of Radiation Safety Manaaer i

j TS 6.3.2 would be revised to delete the requirements that the radiation safety i

manager be designated by the Plant General Manager, and that the radiation safety manager shall have direct access to the plant manager.

In addition, i

the associated footnote, regarding clarification of the meaning of

" Equivalent" as used in Regulatory Guide 1.8, would be incorporated into the j

main paragraph. The licensee stated that neither of the requirements regarding lines of responsibility between the Plant General Manager and the radiation safety officer are germane to a section on qualifications. The i

staff verified that these requirements are currently contained in the final i

safety analysis report (FSAR) section 12.1. The staff concludes that i

regulatory requirements of 10 CFR 50.59 and Part 50, Appendix B, provide i

adequate control of changes to these requirements. Therefore, removing these j

requirements from the TS is acceptable.

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Safety Limit Violation

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The licensee proposed to delete the requirements of existing TS 6.7, " Safety 4

Limit Violation." As discussed in section 3.1 of this safety evaluation (SE),

i the Safety Limit violation shutdown requirement of TS 6.7.la, would be moved j

to TS 2.1.1 and 2.2.1, which currently reference TS 6.7.

TS 6.7.1.b, j

regarding 1-hour notification, and TS 6.7.lc and 6.7.ld, regarding written reporting would be deleted. The licensee stated that the TS 6.7.1.b i

requirement is redundant to 10 CFR 50.72(b)(1)(1)(A); and the requirements of i

TS 6.7.1.c and 6.7.1.d are redundant to 10 CFR 50.36(c)(1)(1)(A) and to 10 CFR 50.73(a)(2)(i)(A), (i)(B), and (ii)(B).

This change would extend the required i

time for submitting a Safety Limit violation report from 14 days, as required by TS 6.7.lc and d, to 30 days, as required by 10 CFR 50.73.

Since plant l

operation may not resume until authorized by the Commission, the staff finds j

that the extended reporting time would not have a significant impact on safety and is therefore acceptable.

c Radioloaical Environmental Monitorina Proaram The licensee proposed to delete the requirements of TS 6.8.4.b related to the l

Radiological Environmental Monitoring Program.

The existing Radiological j

Environmental Monitoring Program requires that procedures be prepared for i

monitoring the radiation and radionuclides in the environs of plants, consistent with the guidance specified in 10 CFR Part 50, Appendiy. I.

These procedures were developed to ensure that radioactive effluents are restricted to levels as low as reasonably achievable and have no impact on plant nuclear safety. The licensee has proposed to relocate the details and description of the program to the Offsite Dose Calculation Manual (00CM), as was described in GL 89-01, " Implementation of Programmatic Controls for Radiological Effluent l

Technical Specifications in the Administrative Controls Section of Technical Specifications and Relocation of Procedural Details of RETS to the Offsite i

Dose Calculational Manual or the Process Control Program." The staff concludes that the requirements in 10 CFR 20.1302, 40 CFR Part 190, and 10 CFR Part 50, Appendix I, provide sufficient control of these provisions, and removing them from the TS is acceptable.

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4 Startuo Report j

The licensee proposed to delete TS 6.9.la, Startup Report. The existing TS l

requires that a summary of plant startup and power escalation testing be submitted within 90 days following completion of the start-up test program following amendment to the license involving a planned increase in power i

level, installation of fuel that has a different design or has been manufactured by a different fuel supplier, and modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the plant. This reporting requirement simply summarizes-plant records that are available for NRC review.

The 90 days of operation allowed before submittal of the report and the lack of any required approval indicate that the report is not necessary for safe operation of the facility. This requirement is not specifically required under 10 CFR 50.36(c)(5) and the staff has determined that it is not otherwise necessary for operation of the facility in a safe manner. Therefore, this requirement can be removed from the administrative controls.

Reportable Events and Special Reports The licensee proposed that the TS 6.9.2 requirement that the Commission be notified of all reportable events be deleted from the TS on the basis that this requirement is adequately addressed in the regulations. Requirements are provided in 10 CFR 50.73(a)(2) for the licensee to submit a Licensee Event Report (LER) for all reportable events specified in 10 CFR 50.73. The licensee also proposed to delete TS 6.9.4.b, which requires that special reports shall be submitted in accordance with 10 CFR 50.4, within the time period specified for each report. This TS merely repeats the requirement contained in 10 CFR 50.4.

The staff concludes that the regulations contained in 10 CFR Part 50 provide sufficient control over these reporting requirements. Therefore, removing these requirements from the TS is acceptable.

Nonroutine Reports The licensee proposed to delete TS 6.9.3, "Nonroutine Reports." Part (a) of the requirement requires submittal of a report in the event that the Radiological Environmental Monitoring Programs are not substantially conducted as described in the ODCM.

Part (b) of the requirement dictates submittal of a report in the event of an occurrence that causes or could have caused a significant environmental impact.

The licensee stated that part (a) is not redundant to any other requirement, but plant administrative procedures require initiation of a Condition Report for such an event. Condition Reports are available for audit by the NRC resident inspector. This reporting requirement is not included in the STS, which reflects current staff position on those requirements which the staff considers to be necessary for safe operation of the facuility. This requirement is not specifically required under 10 CFR 50.36(c)(5) and the staff has determined that it is not otherwise necessary for operation of the

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the administrative controls.

The licensee stated that part (b) is redundant to Subsection 4.1 of Appendix B. " Environmental Protection Plan (Non-Radiological)," of the i

Palisades Facility Operating License. Appendix B Subsection 4.1 requires that l

any event that could or did result in significant environmental impact shall be promptly reported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, followed by a written report 5

within 30 days.

Because the information is duplicated in other required

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reports, the staff has concluded that the TS 6.9.3(b) requirement to submit environmental impact reports is unnecessary and deletion of this requirement i

is acceptable.

l Record Retention l

The requirements of Section 6.10, " Record Retention," would be deleted from i

the TS and relocated to the Quality Program Description, CPC-2A. There are no l

comparable Record Retention requirements in STS. The licensee proposed that the requirements be relocated because they are adequately addressed by CPC-2A, j

which implements 10 CFR Part 50, Appendix B, " Quality Assurance Criteria fcr i

Nuclear Power Plants and Fuel Reprocessing Plants." The provisions in CPC-2A i

implement the Commission's regulations pertaining to the maintenance of 4

records related to activities affecting quality contained in Criterion XVII,

" Quality Assurance Records," of 10 CFR Part 50, Appendix B.

Record retention 4

requirements are specified in various regulations (e.g.10 CFR Part 20, 3

Subpart L, and 50.71).

The staff has determined that record retention requirements are adequately addressed by the existing regulations and the 1

related CPC-2A commitments relocated from the TS. The licensee submitted a j

revision to CPC-2A on May 31, 1996, which incorporated the record retention l

requirements into Sections 1, 2, and 3 of Appendix E to CPC-2A. The staff has i

verified that the record retention requirements have been incorporated without i

change into CPC-2A.

Future changes to CPC-2A which would reduce the j

effectiveness of these commitments will be subject to prior review and approval by the NRC in accordance with 10 CFR 50.54(a).

i The staff concludes that the regulatory requirements under 10 CFR Part 50, 1

Appendix B, provide sufficient control of the plant records, and sufficient j

regulatory controls exist for future changes to the program pursuant to i

10 CFR 50.54(a).

In addition, other regulations (e.g. 10 CFR Part 20, Subpart L,'and 10 CFR 50.71) require the retention of certain records related to operation of the plant. The staff concludes that these other regulatory requirements provide sufficient control of these recordkeeping provisions and removing them from the TS is acceptable. These requirements are not I

specifically required under 10 CFR 50.36(c)(5), and the staff has determined j

that they are adequately covered by other regulations. Therefore, these requirements can be removed from administrative controls.

l Radiation Protection Proaram The licensee proposed to remove the requirements in TS 6.11 related to the j

Radiation Protection Program.

The existing TS for.the Radiation Protection l

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- - -- Program requires procedures to be prepared for personnel radiation protection consistent with the requirements of 10 CFR Part 20.

The requirement for procedures to implement Part 20 is also contained in 10 CFR 20.1101(b).

Periodic review of these procedures is addressed under 10 CFR 20.1101(c).

The staff concludes that the requirements of the regulations provide sufficient requirements for the Radiation Protection Program, such that administrative controls in the TS are unnecessary. On this basis, the staff concludes that the requirements for the Radiation Protection Program do not have to be controlled by TS, and changes to the Radiation Protection Program are adequately controlled by 10 CFR Part 20, 50.54, 50.59, and Part 50, Appendix B.

Therefore, the proposed change is acceptable.

Process Control Proaram The requirement of existing TS 6.19 for Plant Review Committee (PRC) review and approval prior to Process Control Program changes becoming effective would be deleted. This requirement is redundant to the requirement of proposed TS 6.8.1.6a for PRC review and approval of changes to programs specified in TS 6.5.

As discussed in section 3.4 of this SE, the remaining requirements of TS 6.19 would be relocated to TS 6.5.15.

As a result of this relocation, the requirement for PRC review and approval of program changes contained in TS 6.19 would become redundant to the requirement of TS 6.8.1.6a.

The staff concludes that the TS 6.8.1.6a requirement provides sufficient control of PRC review and approval of changes to the Process Control Program.

Therefore, removing this requirement from the TS is acceptable.

Sealed Source Contamination The existing requirement of TS 6.21 for a sealed source contamination program specifies limitations on fixed contamination for sources requiring leak testing, and states that sealed sources containing radioactive material shall be free of specified levels of removable contamination. The associated actions require that if the removable contamination exceeds limitations, the sealed source shall be either decontaminated or disposed of. The provisions will be relocated to the ODCM and the procedures regarding control of sealed source contamination will be adequately controlled in accordance with 10 CFR 50.59 and Part 20. These requirements are not specifically required j

under 10 CFR 50.36(c)(5) and are not necessary for operation of the facility i

in a safe manner.

In addition, the staff has determined that the requirements are adequately covered by other regulations. Therefore, the requirements can be removed from administrative controls.

Summary The existing TS requirements that would be deleted or relocated do not meet the intent of the four criteria described in 10 CFR 50.36(c)(2), and therefore are not required to be in the TS under 10 CFR 50.36 or Section 182a of the Atomic Energy Act. The requirements are not specifically required under 10 CFR 50.36(c)(5) and are adequately covered by other regulations.

In addition, the staff finds that sufficient regulatory controls exist under 10 CFR 50.59 i

4 i i and 50.54(a) to control future changes to relocated requirements. These i

requirements are not specifically required under 10 CFR 50.36(c)(5) and the g

staff has determined that they are not otherwise.necessary for operation of 1

the facility in a safe manner. Therefore, the staff has concluded that these requirements may be deleted or relocated from the TS to the specified l

documents.

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3.2 Containment Leak Rate Testina Reauirements By supplemental application dated January 18, 1996, the licensee requested changes to permit implementation of 10 CFR Part 50, Appendix J, Option B.

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licensee has established a " Containment Leak Rate Testing Program," and l

proposed adding this program to the TS. The program references Regulatory Guide (RG) 1.163, " Performance-Based Containment Leak Test Program," dated i

September 1995, which specifies a method acceptable to the NRC for complying with Option B.

3.2.1 Backaround Compliance with 10 CFR Part 50, Appendix J, provides assurance that the primary containment, including those systems and components which penetrate the primary containment, do not exceed the allowable leakage rate specified in the TS and Bases. The allowable leakage rate is determined so that the leakage assumed in the safety analyses is not exceeded.

On February 4,1992, the NRC published a notice in the Federal Reaister (57 FR 4166) discussing a planned initiative to begin eliminating requirements marginal to safety which impose a significant regulatory burden. Appendix J of 10 CFR Part 50 was considered for this initiative and the staff undertook a study of possible changes to this regulation. The study examined the previous performance history of domestic containments and examined the effect on risk i

of a revision to the requirements of Appendix J.

The results of this study are reported in NUREG-1493, " Performance-Based Leak-Test Program."

Based on the results of this study, the staff developed a performance-based approach to containment leakage rate testing. On September 12, 1995, the NRC approved issuance of this revision to 10 CFR Part 50, Appendix J, which was subsequently published in the Federal Reaister on September 26, 1995, and became effective on October 26, 1995.

The revision added Option B, Performance-Based Requirements, to Appendix J to allow licensees to voluntarily replace the prescriptive testing requirements of Appendix J with testing requirements based on both overall and individual component leakage rate performance.

RG 1.163 was developed as a method acceptable to the NRC staff for implementing Option B.

This regulatory guide states that the Nuclear Energy Institute (NEI) guidance document NEI 94-01, " Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," provides methods acceptable to the NRC staff for complying with Option B with four exceptions which are described therein.

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i Option B requires that the RG or other implementation document used by a licensee to develop a performance-based leakage rate testing program must be included, by general reference, in the plant TS. The licensee has referenced RG 1.163 in the Palisades TS.

RG 1.163 specifies an. extension in Type-A test frequency to at least one test in 10 years based upon two consecutive successful tests. Type B tests may be extended up to a maximum interval of 10 years based upon completion of two consecutive successful tests and Type C tests may be extended up to 5 years based on two consecutive successful tests.

By "05000255/LER-1995-008, :on 950728,discovered That None of Four Containment High Pressure Channels Would Initiate Reactor Trip Due to Programmatic Deficiencies.Administrative Procedure (AP) 9.44,AP 9.45 & [[administrative procedure" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Will Be Revised|letter dated October 20, 1995]], NEI proposed TS to implement Option B.

After some discussion, the staff and NEI agreed on final TS which were attached to a letter from C. Grimes (NRC) to D. Modeen (NEI) dated November 2, 1995. These TS are to serve as a model for licensees to develop plant-specific TS in preparing amendment requests to implement Option B.

For a licensee to determine the performance of each component, factors that are indicative of or affect performance, such as an administrative leakage limit, must be established. The administrative limit is selected to be indicative of the potential onset of component degradation. Although these limits are subject to NRC inspection to assure that they are selected in a reasonable manner, they are not TS requirements.

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administrative limit requires the licensee to return to the minimum value of the test interval.

Option B requires that the licensee maintain records to show that the criteria for Type A, B, and C tests have been met.

In addition, the licensee must maintain comparisons of the performance of the overall containment system and the individual components to show that the test intervals are adequate. These records are subject to NRC inspection.

3.2.2 Evaluation The licensee's January 18, 1996, letter to the NRC proposes to establish a Containment Leakage Rate Testing Program and proposes to add this program to l

the TS. The program references RG 1.163, which specifies a method acceptable to the NRC for complying with Option B.

This requires a change to existing TS 4.5.1, " Containment Tests," and the addition of TS 6.5.14, " Containment Leak Rate Testing Program." Option B permits a licensee to choose Type A, or Type B and C, or Type A, B, and C testing to be done on a performance basis.

The licensee has elected to perform Type A testing on a performance basis. The TS changes proposed by the licensee are in compliance with the requirements of Option B and consistent with the guidance of RG 1.163 and the generic TS of the November 2,1995, letter and are, therefore, acceptable to the staff.

3.3 Additional Proposed TS Reauirement Chanaes The licensee proposed several changes to TS requirements not directly related to the proposed administrative controls revision.

These changes were proposed i

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affected by the proposed administrative controls changes.

TS Table 4.2.3 The licensee proposed several revisions to the TS Table 4.2.3 testing requirements for the control room and fuel pool area ventilation systems. The existing requirement to verify that the control room ventilation system maintains the control room at a positive pressure of 0.1-inch water gauge (W.G.) would be revised to increase the required differential pressure j

capability to 1/8-inch (0.125-inch) W.G. and would require this differential j

pressure to be maintained with respect to the outside atmosphere rather than i

the viewing gallery. The existing requirement to verify control room i

temperature is less than or equal to 120 degrees F each 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> would be J

revised to require that the control room temperature be maintained less than or equal to 90 degrees F.

Requirement 2.c would be added to Table 4.2.3, requiring verification each refueling cycle that the Fuel Pool Ventilation l

System is operable by initiation of flow through the HEPA filter from the j

control room.

i The more restrictive requirements proposed by these changes are currently being administratively maintained by the licensee to provide assurance of ventilation system operability. The licensee stated that the revision of j

Table 4.2.3 made to support the revision of the Administrative Controls j

section provided a convenient opportunity to request revision of the existing i

requirements. These changes constitute more restrictive requirements which i

provide additional assurance that equipment conforms to the plant design basis and will operate reliably when called upon; therefore, the staff finds the proposed changes to be acceptable.

TS 4.6.2b The licensee proposed to revise the TS 4.6.2b surveillance requirement and basis regarding verification that the containment spray nozzles are open to extend the surveillance frequency from 5 to 10 years. This requested change is consistent with the recommendation to extend this surveillance frequency contained in NVREG-1366, " Improvements to Technical Specifications Surveillance Requirements," and GL 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation." NUREG-1366 documented the staff's finding that the only problems of this nature have been construction-related and no such problems have been detected at any plants following completion of construction and startup testing.

The licensee stated that there is no unusual feature of the Palisades spray nozzles that should require more frequent testing, and past testing at the 5-year interval has not identified any problems.

The proposed change is consistent with staff guidance and is therefore acceptable.

TS 6.1.1 The licensee proposed to add a requirement to Section 6.1.1 for the plant superintendent to approve tests, experiments, and modifications.

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i proposed wording is consistent with the STS. This change constitutes a more restrictive requirement that provides additional assurance that changes to 2

plant procedures or equipment that could affect safety will receive an appropriate level of review prior to implementation, therefore the proposed change is acceptable.

l TS 6.2.1 The licensee proposed to replace the specific titles of supervisory positions throughout the TS with generic titles and to revise TS 6.2.la to require that the relationship between generic titles and plant-specific titles be included l

in the FSAR. The replacement of plant-specific titles with generic titles is an admiriistrative change that does not result in a change in any TS i

requirements. The requirement to include the relationship between the TS generic titles and plant-specific titles in the FSAR will ensure changes to i

the titles will be adequately controlled in accordance with 10 CFR 50.59, and

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is therefore acceptable.

4 TS 6.7 4

The proposed change would add TS 6.7.3, which would allow high radiation areas with dose rates greater than 1000 mrem per hour inside large areas such as the containment, where no enclosure exists for purposes of locking, to be controlled by barricading and posting and identification with a flashing light..The current TS require that high radiation areas be locked.

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licensee stated that construction of lockable enclosures solely for the i

purpose of bounding high radiation areas inside large areas such as the containment incurs both significant cost and personnel radiation exposure, f

10 CFR Part 20.1601 requires strict controls for access to areas where an individual could receive greater than 0.001 Sv (100 mrem) in I hour (high radiation areas), providing reasonable assurance that individuals at licensed i

facilities are not exposed to radiation levels in excess of the regulatory limits. A list of optional controls for high radiation areas is provided in i

10 CFR Part 20.1601(a) and (b).

For large complex facilities, such as a nuclear power plant, the most practical of these options is to maintain the entrances to high radiation areas locked except during periods of authorized personnel access.

In cases where the controls provided in 10 CFR 20.1601(a) i and (b) unnecessarily restrict plant operations 10 CFR 20.1601(c) provides i

that the licensee may apply to the Commission for approval of alternative controls for the access of their high radiation areas.

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Regulatory Position C.2.4 of Regulatory Guide 8.38, Revision 0, dated June 1993, describes acceptable alternative methods for controlling access to high radiation areas. Under this alternative control scheme, areas where i

individuals could receive doses in excess of 0.01 Sv (1000 mrem) in one hour, and which are within large areas where no enclosure exists to enable locking and where no enclosure can be reasonably constructed around the individual area, should be barricaded and conspicuously posted, with a flashing light i

activated as a warning device whenever the dose rate in such areas exceeds or

- is expected to exceed 0.01 Sv (1000 mrem) in I hour.

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__.._ The proposed TS 6.7.3 requirement is consistent with the NRC's position on acceptable alternative methods for access control to high radiation areas in large areas as described in Regulatory Position C.2.4 of Regulatory Guide 8.38, Revision 0,.and is consistent with the STS.

Therefore, the proposed change is acceptable.

Summary The proposed changes provide additional assurance that control room and fuel area ventilation equipment will operate reliably when called upon, revise the containment spray nozzle surveillance frequency to be consistent with current staff position regarding spray nozzle testing, provide additional assurance that changes to plant procedures or equipment will receive an appropriate level of review prior to implementation, ensure changes to the relationship between generic and plant-specific titles will be adequately controlled, and ensure that occupational doses continue to be maintained as low as reasonably achievable. These proposed changes are acceptable to the staff.

3.4 Editorial Restructurina The licensee proposed editorial changes throughout the TS to support the proposed revision of the Administrative Controls section. The proposed changes primarily relocate TS requirements to, or within, the revised Administrative Controls section, or make minor editorial revisions.

The proposed changes are described and evaluated individually in the following paragraphs.

TS 1.1 and 1.2 TS 1.1, " Operating Definitions," and 1.2, " Miscellaneous Definitions," would be combined into Section 1.0, " Definitions." The definitions for the Offsite Dose Calculation Manual and the Process Control Program would be combined with their respective program descriptions, which are moved to TS 6.5.1 and 6.5.15, respectively, as discussed under the TS 6.5 discussion, below. The definition for Core Operating Limits Report (COLR) would be arranged alphabetically with the remaining definitions.

The reference in the COLR definition to the TS 6.9.1 COLR requirements would be revised to match the proposed relocation of these requirements to TS 6.6.5.

These changes do not alter any TS requirements. This is purely an administrative change in the location of the requirements within TS, and is therefore acceptable.

TS 2.1.1 and 2.2.1 The licensee proposed to move the requirement to shut down the reactor following a Safety Limit violation currently contained in TS 6.7.la to TS 2.1.1 and 2.2.1.

This change would place the operating requirement directly into the Action Statement, instead of incorporating it by reference.

This is considered a more logical location from a human factors perspective.

While this requirement is redundant to the noted Section of 10 CFR 50.36, it

-is retained in the TS to assure that operators are aware of the required action to immediately shut down the reactor if a Safety Limit is violated.

This is purely an administrative change in the location of the requirement within TS, and is therefore acceptable.

TS 3.17.4 The licensee proposed to revise TS 3.17.4, " Accident Monitoring Instrumentation," to move reporting requirements to the Administrative Controls section. TS 3.17.4.7 would be revised to reference the reporting requirement of TS 6.6.7, " Accident Monitoring Instrument Report." The proposed reporting requirement of TS 6.6.7 is unchanged from the existing TS 3.17.4.7 requirement. This is purely an administrative change in the location of the requirements within TS, and is therefore acceptable.

TS 4.0.5 The requirements of TS 4.0.5 would be moved to Administrative Controls TS 6.5.7, " Inservice Inspection and Testing Program." The wording of the proposed specification would be editorially modified to be consistent with the STS; but there would be no change in requirements.

References to TS 4.0.5 in the balance of the TS would be revised to reference TS 6.5.7.

This is purely an administrative change in the location of the requirements within TS, and is therefore acceptable.

TS Table 4.2.3 The ventilation filter testing requirements of Table 4.2.3 would be replaced with a requirement to " Perform required Control Room Ventilation and Fuel Storage Area filter testing in accordance with the Ventilation Filter Testing i

Program." The details of the TS Table 4.2.3 ventilation filter testing requirements would be moved to TS 6.5.10, " Ventilation Filter Testing Program." Existing surveillance requirement c.2 (proposed requirement 2.a) would be editorially revised from "a recirculation mode of operation" to "the emergency mode of operation" to more closely agree with current plant terminology. No requirements would be changed. These are purely administrative changes in the content or location of the requirements within TS, and are therefore acceptable.

TS 4.3f TS 4.3f primary coolant pump testing requirements would be moved to proposed TS 6.5.6, " Primary Coolant Pump Flywheel Surveillance Program." There would be no change in primary coolant pump flywheel testing requirements. This is purely an administrative change in the location of the requirements within TS, and is therefore acceptable.

i TS 4.14 TS 4.14 would be retitled " Steam Generator Surveillance." The details of the testing requirements would be relocated to Administrative Controls as discussed below.

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i Existing TS 4.14.1, which currently requires the steam generators to be 1

i demonstrated operable by performance of the testing specified by TS 4.14.2 j

through 4.14.5 and TS 4.0.5 would be revised to require steam generator tube i

integrity to be verified in accordance with proposed TS 6.5.7, " Inservice Inspection and Testing Program," and proposed TS 6.5.8, " Steam Generator Tube l

Surveillance Program." The requirements of TS 4.14.2 through 4.14.5 would be moved to proposed TS 6.5.8, " Steam Generator Tube Surveillance Program." The i

requirements of TS 4.14.6 would be moved to proposed TS 6.6.9, " Steam j

Generator Tube Surveillance Report."

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Table 4.14-1 would be eliminated, because the preservice and first inservice l

inspections have been completed and the requirements are no longer applicable.

The Table 4.14-1 footnote, regarding performance of steam generator

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inspections on a rotating schedule, would be incorporated into the first paragraph of TS 6.5.8.

The wording of the existing testing requirements would be revised to eliminate redundancies and to remove requirements pertinent only to preservice and initial testing.

The proposed testing program and reporting requirements are equivalent to the requirements of existing TS 4.14, with the exception of deletion of the i

preservice and initial inservice testing requirements, which have been i

completed and are therefore no longer required to be retained in TS. This is purely an administrative change in the content or location of the requirements j

within TS, and is therefore acceptable.

l TS 4.16.1 4

i The licensee proposed to revise the record retention requirement of TS 4.16.lf to eliminate reference to TS 6.10.2.1, which would be deleted by this j

amendment as discussed in section 3.1 of this SE. The TS still requires that i

records regarding snubbers be retained. As discussed in section 3.1 of this i

SE, existing regulatory requirements provide sufficient control of plant l

record retention. This is purely an administrative change, and is therefore acceptable.

i TS 6.2.2 l

The requirements of TS Table 6.2-1, " Minimum Shift Crew Composition," which would not be deleted, as discussed in section 3.1 of this SE, would be included as separate requirements under TS 6.2.2.

This is purely an administrative change in the location of the requirements within TS, and is therefore acceptable.

TS 6.2.3 The licensee proposed to remove the reference to formerly deleted TS 6.2.3.

The licensee stated that its retention served no function. This is purely an administrative change, and is therefore acceptable.

! 4 TS 6.3.4 J

TS 6.3.4 would be revised to delete reference to reviews performed in accordance with existing TS 6.5.3, and replace it with reference to reviews required by 10 CFR 50.59. The TS would be revised to allow the assignment of these reviews to any qualified plant staff. The TS currently requires reviews to be conducted by Plant Safety and Licensing staff. The qualification requirement for the individuals who perform the reviews would remain 1

unchanged. The reference to existing TS 6.5.3 was reworded because this change request proposes deleting that section from TS as discussed in section l

3.5 of this SE. The qualification requirements of the persons performing the subject reviews have not been changed, only the reference to their assignment in the plant organization. Therefore, the proposed changes are acceptable.

TS 6.3.5 TS 6.3.5 would be deleted. The requirements are redundant to other TS requirements either already present in existing TS or proposed by this amendment request.

The first requirement, for an operations manager to hold an SR0 license, and the third requirement, for the individual holding an SR0 license to be responsible for directing activities of licensed operators, would be moved to proposed TS 6.2.2f.

The second requirement, regarding l

Operations Manager qualifications of ANSI N18.1-1971, is redundant to existing TS 6.3.1 and would be deleted. No requirements would be changed. This is purely an administrative change in the location of the requirements within TS, and is therefore acceptable.

TS 6.4 TS 6.4, which was deleted by a prior amendment, would be reestablished under a new title, " Procedures." Except as discussed for the security and emergency plans in section 3.1 of this SE, the existing procedure requirements of TS 6.8.1 would be moved to this section. TS 6.8.la would be reworded slightly to emulate STS wording.

With the exception of the deletion of the security and emergency plan requirements, no requirements would be changed. This is purely an administrative change in the location of the requirements within TS, and is therefore acceptable.

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TS 6.5. Proarams and Manuals The review and audit requirements of TS 6.5 would be renumbered to TS 6.8 as discussed in section 3.5 of this SE, and TS 6.5 would be retitled " Programs and Manuals." Existing program and manual requirements contained in the Administrative Controls section, and new requirements proposed by this amendment, would be gathered in this section.

Existina Proaram Reauirements Moved to TS 6.5 The licensee proposed to consolidate the following existing TS program requirements in proposed TS 6.5:

- TS 6.8.4a, " Radioactive Effluent Controls Program," would be moved to TS 6.5.4.

Editorial revisions would be made to make the wording consistent with the STS.

TS 6.15, " Systems Integrity," would be moved to TS 6.5.2, " Primary Coolant Sources outside Containment." The requirements of TS 4.5.3,

" Recirculation Heat Removal Systems," which contain additional testing requirements for systems outside the containment that could potentially contain highly radioactive fluids, would be incorporated into TS 6.5.2.

The licensee stated that this change would consolidate all requirements for such testing in one location.

The requirements of TS 6.16, " Iodine Monitoring," and TS 6.17, " Post Accident Sampling," would be combined in proposed TS 6.5.3, " Post Accident Sampling Program."

TS 6.18, "Offsite Dose Calculation Manual," would be combined with its definition (moved from existing TS 1.2 as discussed in this SE) and would be moved to TS 6.5.1.

TS 6.19. " Process Control Program," would be combined with its definition (moved from existing TS 1.2 as discussed in this SE) and would be moved to TS 6.5.15.

The existing requirement for PRC review and approval prior to Process Control Program changes becoming effective would be relocated to the Quality Program Description, CPC-2A, as discussed in section 3.1 of this SE.

The requirements of TS 6.22, " Secondary Water Chemistry," would be moved to TS 6.5.9, " Secondary Water Chemistry Program." The wording would be revised editorially to more closely match the STS.

None of the requirements of the existing TS consolidated under TS 6.5 would be changed, with the exception of editorial revisions for consistency with the STS and the change to the Process Control Program discussed in section 3.1 of this SE. These are purely administrative changes in the location of the requirements within TS, and are therefore acceptable.

New Proaram Reauirements The following program requirements would be added to TS 6.5, as previously discussed in this SE:

TS 6.5.6, " Primary Coolant Pump Flywheel Surveillance Program" TS 6.5.7, " Inservice Inspection and Testing Program" TS 6.5.8, " Steam Generator Tube Surveillance Program" TS 6.5.10, " Ventilation Filter Testing Program" TS 6.5.14, " Containment Leak Rate Testing Program" TS 6.5.12, " Technical Specification Bases Control Program" would be added.

-The Bases Control Program is provided to specifically delineate the appropriate methods and reviews necessary for a change to the TS Bases.

i TS 6.5.5, would be reserved for future addition of the " Containment Structural Integrity Surveillance Program," as discussed in section 3.5 of this SE.

TS 6.5.11 would be reserved for future addition of a " Fuel Oil Testing Program." TS 6.5.13 would be reserved for future addition of a " Safety Function Determination Program." No requirements would be added. This is purely an editorial change intended to reserve space for future additions to the Administrative Controls section to be consistent with the STS, and is therefore acceptable.

TS 6.6. Reportina Reauirements TS 6.9, " Reporting Requirements," would be moved to TS 6.6.

Existing reporting requirements contained in the Administrative Controls section, and new requirements proposed by this amendment, would be gathered in this section.

Existina Reportina Reauirements Moved to TS 6.6 The licensee proposed to consolidate the following existing TS reporting requirements in proposed TS 6.6:

The requirements of TS 6.9.lb, " Annual Report," would be moved to TS 6.6.1, " Occupational Radiation Exposure Report."

The requirements of TS 6.9.lc, " Monthly Operating Report," would be moved to TS 6.6.4.

The requirements of TS 6.9.1d, " Radioactive Effluent Release Report,"

would be moved to TS G.6.3.

The requirements of TS 6.9.le, " Radiological Environmental Operating Report," would be moved to TS 6.6.2.

The requirements of TS 6.9.lf, " Core Operating Limits Report," would be moved to TS 6.6.5.

The requirements of TS 6.9.4a, would be moved to TS 6.6.8, " Containment Structural Integrity Report."

The licensee proposed to add an option to the requirements of TS 6.6.1 to base radiation exposure reports on electronic dosimeters. Use of electronic dosimeters is equivalent to the other methods currently contained in the TS, as indicated by its inclusion in the STS, which reflects current staff position. The staff considers this to be an acceptable administrative change in the methods available for collecting and reporting radiation exposure data.

The licensee proposed to replace the reference in TS 6.6.1 to 10 CFR 20.407 with reference to 10 CFR 20.2206. The revised reporting requirement is equivalent to the existing reporting requirement of TS 6.9.lb.

This is an administrative change to make the requirement consistent with the revised 10 CFR Part 20, and is acceptable.

5 None of the requirements of the existing TS consolidated under TS 6.6 would be changed, with the exception of editorial revisions for consistency with the STS and the revised 10 CFR Part 20. These are considered to be purely l

administrative changes in the content or location of the requirements within

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TS, and are therefore acceptable.

1 2

New Renortina Reauirements 4

The following reporting requirements would be added to TS 6.6, as previously j

discussed in this SE:

i TS 6.6.7, " Accident Monitoring Instrument Report" l

TS 6.6.g " Steam Generator Tube Surveillance Report" TS 6.6.6 would be reserved for future addition of a " Pressure and Temperature Limits Repert." This is purely an editorial change intended to reserve space for a future addition to the Administrative Controls to be consistent with the l

STS.

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TS 6.7 Existing TS 6.7, " Safety Limit Violation,' would be deleted as discussed in section 3.1 of this SE, and TS 6.12. "High Radiation Area," would be moved to TS 6.7.

TS 6.7.3 would be added as discussed in section 3.3 of this SE.

TS 6.12.1 and 6.12.2 would be moved to TS 6.7.1 and 6.7.2, respectively. The wording of the proposed TS would be revised to be consistent with the STS.

The TS 6.12.1 reference to the outdated 10 CFR 20.203(c) requirement would be revised to refer to the equivalent requirement of the revised 10 CFR ' art 20, 10 CFR 20. M01.

The updated requirements are equivalent to the existing 10 CFR Part 20 reference. No requirements of existing TS 6.12.1 and 6.12.2 would be changed. This is purely an administrative change in the location of the requirements within TS.

General Editorial Revisions The licensee proposed the following general editorial changes to reformat the revised TS to eliminate voids and blank pages created as a result of the proposed changes.

TS 4.5.6, " Containment Isolation Valves," would be renumbered to TS 4.5.3.

The existing requirements of TS 4.5.3, would be relocated to TS 6.5.2 as discussed previously in this SE. The licensee proposed to revise wording throughout the Administrative Controls section to be consistent with the STS.

The text of TS 4.2 through TS 4.6 and the entire Administrative Controls section would be repaginated to eliminate blank pages.

Repagination would require that the list of modifying amendments, which appears at the bottom of each page, be rewritten to list only those amendments that modified the subject matter appearing on each proposed page.

Existing pages 4-25 and 4-26 contain a notation at the bottom of the page that they were altered by " Change No. 16" and by " Amendment hq. 12".

The licensee stated that these are two identifiers for the same TS revision; " Change No.

16" to the TS was issued by " Amendment No. 12" to the Facility Operating Litelse on February 25, 1975. The references to " Change No. 16" would be i

i i

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omitted. The licensee also proposed to revise the TS 8ases as necessary to be j

consistent with the proposed changes to the TS requirements.

Summarv l

The proposed changes relocate requirements within the TS, add requirements, 1

and make minor editorial revisions to be consistent with the revised 10 CFR Part 20 and the STS. The preservice and initial inservice testing l

requirements have been completed and are therefore no longer required to be retained in TS.

The use of electronic dosimeters is an acceptable alternative to measure personnel radiation exposure.

Except as noted regarding the i;

preservice and initial inservice steam generator inspections and the addition

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of the use of electronic dosimeters,.no requirements would be changed.

These are purely administrative and editorial changes, and are therefore acceptable.

s i

j 3.5 Prooosed Chanaes Still Under Staff Review 1

i Review of the following changes proposed by the licensee has not yet been completed by the staff and will be the subject of subsequent licensing action.

l The licensee proposed to relocate the requirements of TS 6.5 related to review j

and audit functions, TS 6.8.2 related to procedure review and approval, and l

TS 6.8.3 related to temporary procedure changes, to the Quality Program j

Description, CPC-2A. The licensee submitted a revision to CPC-2A on May 31, 1996, which was intended to incorporate the existing TS requirements. The staff identified several discrepancies between the existing TS requirements and the relocated requirements contained in the May 31, 1996, CPC-2A revision.

The licensee will need to revise CPC-2A to correctly incorporate the TS requirements and submit the changes to the NRC for review prior to staff approval to delete these requirements from the TS.

In addition to the proposed relocation of the TS 4.3f primary coolant pump flywheel inspection requirement to the Administrative Controls section as discussed in section 3.4 of this SE, the licensee proposed to delete the TS 4.3f requirement to inspect the regenerative heat exchanger. This change, in concert with the relocation of the flywheel requirements, would permit deletion of TS Table 4.3.2, which is referenced by TS 4.3f and which contains the details of the inspections required by TS 4.3f.

The licensee stated that this requirement is redundant to the ASME Boiler and Pressure Vessel Code, which requires the inspection to be performed once every 10 years. The existing requirement mandates that the inspection be performed at a maximum 5-year frequency. The staff requires additional information regarding the design codes and inspection results for the heat exchanger to complete review of this proposed change.

The licensee proposed to delete the requirements of TS 4.5.4, " Surveillance for Prestressing System," 4.5.5, "End Anchorage Concrete Surveillance," and 4.5.8, " Dome Delamination Surveillance," and replace the requirements with proposed TS 4.5.4, which would require verification of containment structural integrity in accordance with proposed TS 6.5.5, " Containment Structural Integrity Surveillance Program," which would require containment tendons to be inspected in accordance with Regulatory Guide (RG) 1.35, Rev 3, July 1990.

During review of the proposed change the staff identified that the RG does not address the dome delamination surveillances currently required by TS 4.5.8.

Additional information will be necessary for the staff to complete its review of this proposed change.

The licensee proposed to revise limits on liquid and gaseous effluent release concentrations of proposed TS 6.5.4b and e, respectively, to adopt the requirements of 10 CFR Part 20, Appendix B, Table 2, in place of the former Appendix B, Table II limits.

The licensee also proposed to revise related references to 10 CFR 20.106 contained in proposed TS 6.5.lc and 6.5.4c to refer to the revised requirement, 10 CFR 20.1301. During review, the staff identified that licensees proposing this revision typically adopt a requirement to require effluent concentrations to be maintained below 10 times the 10 CFR Part 20, Appendix B, Table 2, limits, which is equivalent to the existing requirement. The licensee stated that this was its intent and it will submit a supplement to revise this request. The existing references to 10 CFR Part 20, Appendix B, Table II, and related references to 10 CFR 20.106, will be retained pending completion of staff review.

The licensee provided revised TS pages by letters dated October 18 and October 25, 1996, which incorporated the existing requirements into the revised TS pages.

In order to accommodate the proposed restructuring of the administrative controls section as discussed in section 3.4 of this SE, the review and audit requirements of existing TS 6.5 have been renumbered as TS 6.8, and the requirements of existing TS 6.8.2 and 6.8.3 have been renumbered as TS 6.4.2 and 6.4.3, respectively. Several typographical errors in the resubmitted pages were corrected to properly reincorporate those items still under :,taff review. This was done to maintain the requirements in the TS while proceeding with the requested editorial restructuring of the TS.

Summary These changes are under continued staff review. The NRC will issue a license i

amendment for proposed changes that are found to be acceptable upon completion of staff review. The page changes provided by letters dated October 18 and October 25, 1996, incorporate the existing TS requirements into the proposed revised TS pages. This is purely an administrative change to minimize the impact of the staff's continuing review of the requested changes on the proposed editorial repagination of the TS.

3.6 Conclusion The staff has found that the existing TS requirements that would be deleted or relocated are appropriately governed by other regulatory requirements, do not meet the intent of the criteria described in 10 CFR 50.36(c)(2), are not specifically required under 10 CFR 50.36(c)(5), and are not otherwise necessary for operation of the facility in a safe manner.

Sufficient regulatory controls exist to control future changes to relocated requirements.

With the exception of the proposed changes to TS requirements that remain under review by the staff, the containment leak rate testing and other TS i

requirement changes proposed by the licensee ensure continued conformance with the plant design bases and are consistent with the STS.

The proposed editorial restructuring would administratively revise the TS requirements without affecting their technical content.

Based on these considerations, the staff finds the proposed changes to be acceptable.

4.0 STATE CONSULTATION

i In accordance with the Commission's regulations, the Michigan State official was notified of the proposed issuance of the amendment. The Michigan State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

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The amendment changes requirements with respect to the installation or use of 1

facility components located within the restricted area as defined in 10 CFR Part 20, and changes surveillance requirements. The staff has determined that the amendment involves 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 Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (61 FR 49493). The amendment also changes recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (10).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The staff has 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, (2) such activities will be conducted 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.

Principal Contributors: T. Tjader R. Schaaf Date: October 31, 1996