15
October 1, 1986 Dockets Nos. 50-325/324 Mr. E. E. Utley Senior Executive Vice President Power Supply and Engineering & Construction Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 Dear Mr. Utley: The Commission has issued the enclosed Amendments Nos. 100 and129 to Facility Operating Licenses Nos. DPR-71 and DPR-62 for the Brunswick Steam Electric Plant, Units 1 and 2. The amendments consist of changes to the Technical Specifications in response to your submittal of May 6, 1985, as supplemented February 19, 1986. The amendments change the Technical Specifications (TS) by modifying the surveillance requirements in TS Table 4.3.1-1 for the Turbine Stop Valve-Closure and Turbine Control Valve Fast Closure, Control Oil Pressure-Low functions of the Reactor Protection System. The amendments eliminate the need to test these functions when thermal power is below 30% of rated power. A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's Bi-Weekly Federal Register Notice. Sincerely, Ernest D. Sylvester, Project Manager BWR Project Directorate #2 Division of BWR Licensing Enclosures: 1. Amendment No. 100 to License No. DPR-71 2. Amendment No. 129 to License No. DPR-62 3. Safety Evaluation 8610080487 861001 PDR ADOCK 05000324 P PDR cc w/enclosures: See next page DISTRIBUTION Docket File NRC PDR Local PDR LJHarmon NThompson SNorri s ESylvester OGC - Bethesda DVassallo EJordan BGrimes TBarnhart (8) WJones JPartlow ACRS (10) OPA LFMB Plant File EButcher RBernero OFFICIAL RECORD COPY,> DBLAPD#2 2 DBL:PD#2qU7 SNo~rrifL ESylvester c / t /86 e /zi/86 OGC B thesd 0/8'66 DBL: Pj~ 4Wy086 DBL:RB -• , DBL-RS B( MHodges r/1/86 -

E. Hollar Mr. Christopher Chappell, Chairman Post Office ... · (the licensee) dated May 6, 1985, as supplemented February 19, 1986 complies with the standards and requirements of

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Page 1: E. Hollar Mr. Christopher Chappell, Chairman Post Office ... · (the licensee) dated May 6, 1985, as supplemented February 19, 1986 complies with the standards and requirements of

October 1, 1986

Dockets Nos. 50-325/324

Mr. E. E. Utley Senior Executive Vice President Power Supply and Engineering & Construction Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602

Dear Mr. Utley:

The Commission has issued the enclosed Amendments Nos. 100 and129 to Facility Operating Licenses Nos. DPR-71 and DPR-62 for the Brunswick Steam Electric Plant, Units 1 and 2. The amendments consist of changes to the Technical Specifications in response to your submittal of May 6, 1985, as supplemented February 19, 1986.

The amendments change the Technical Specifications (TS) by modifying the surveillance requirements in TS Table 4.3.1-1 for the Turbine Stop Valve-Closure and Turbine Control Valve Fast Closure, Control Oil Pressure-Low functions of the Reactor Protection System. The amendments eliminate the need to test these functions when thermal power is below 30% of rated power.

A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's Bi-Weekly Federal Register Notice.

Sincerely,

Ernest D. Sylvester, Project Manager BWR Project Directorate #2 Division of BWR Licensing

Enclosures: 1. Amendment No. 100 to

License No. DPR-71 2. Amendment No. 129 to

License No. DPR-62 3. Safety Evaluation

8610080487 861001 PDR ADOCK 05000324 P PDR

cc w/enclosures: See next page DISTRIBUTION Docket File NRC PDR Local PDR LJHarmon NThompson

SNorri s ESylvester OGC - Bethesda DVassallo EJordan

BGrimes TBarnhart (8) WJones JPartlow ACRS (10)

OPA LFMB Plant File EButcher RBernero

OFFICIAL RECORD COPY,> DBLAPD#2 2 DBL:PD#2qU7 SNo~rrifL ESylvester c / t /86 e /zi/86

OGC B thesd

0/8'66

DBL: Pj~

4Wy086

DBL:RB -• , DBL-RS B( MHodges r/1/86 -

Page 2: E. Hollar Mr. Christopher Chappell, Chairman Post Office ... · (the licensee) dated May 6, 1985, as supplemented February 19, 1986 complies with the standards and requirements of

N----

Mr. E. E. Utley Carolina Power & Light Company

Brunswick Steam Electric Plant Units I and 2

cc:

Mr. P. W. Howe Vice President Brunswick Nuclear Project Box 10429 Southport, North Carolina

Mr. C. R. Dietz Plant General Manager Brunswick Nuclear Project Box 10429 Southport, North Carolina28461 28461

Thomas A. Baxter, Esquire Shaw, Pittman, Potts & Trowbridge 2300 N Street, N. W. Washington, D. C. 20037

Mr. D. E. Hollar Associate General Counsel Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602

Mr. Christopher Chappell, Chairman Board of Commissioners Post Office Box 249 Bolivia, North Carolina 28422

Mrs. Chrys Baggett State Clearinghouse Budget and Management 116 West Jones Street Raleigh, North Carolina

Mr. H. A. Cole Special Deputy Attorney General State of North Carolina Post Office Box 629 Raleigh, North Carolina 27602

Mr. Robert P. Gruber Executive Director Public Staff - NCUC Post Office Box 29b20 Raleigh, North Carolina 27626-0b20

27603

Resident Inspector U. S. Nuclear Regulatory Commission Star Route 1 Post Office Box 208 Southport, North Carolina 28461

Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta Street, Suite 2900 Atlanta, Georgia 30303

Mr. Dayne H. Brown, Chief Radiation Protection Branch Division of Facility Services N. C. Department of Human Resources 701 Barbour Drive Raleigh, North Carolina 27603-2008

Page 3: E. Hollar Mr. Christopher Chappell, Chairman Post Office ... · (the licensee) dated May 6, 1985, as supplemented February 19, 1986 complies with the standards and requirements of

-0 UNITED STATES 0i NUCLEAR REGULATORY COMMISSION

WASHINGTON, D. C. 20555

CAROLINA POWER & LIGHT COMPANY

DOCKET NO. 50-3Z5

BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1

AMENDMENT TO FACILITY OPERATING LICENSE

Amendment No. 100 License No. DPR-71

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Carolina Power & Light Company (the licensee) dated May 6, 1985, as supplemented February 19, 1986 complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I;

B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission;

C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations;

D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and

E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR-71 is hereby amended to read as follows:

8610090488 861001 PDR ADOCK 05000324 P PDR

Page 4: E. Hollar Mr. Christopher Chappell, Chairman Post Office ... · (the licensee) dated May 6, 1985, as supplemented February 19, 1986 complies with the standards and requirements of

-2-

(2) Technical Specifications

The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 100 , are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

Daniel R. Muller, Director BWR Project Directorate #2 Division of BWR Licensing

-Attachment:

Changes to the Technical Specifications

Date ot Issuance: October 1, 1986

Page 5: E. Hollar Mr. Christopher Chappell, Chairman Post Office ... · (the licensee) dated May 6, 1985, as supplemented February 19, 1986 complies with the standards and requirements of

ATTACHMENT TO LICENSE AMENDMENT NO. 100

FACILITY OPERATING LICENSE NO. DPR-71

DOCKET NO. 50-3Z5

Replace the following pages of the Appendix A Technical Specifications with

the enclosed pages. The revised areas are indicated by marginal lines.

Pages

3/4 3-8 3/4 3-8a

Page 6: E. Hollar Mr. Christopher Chappell, Chairman Post Office ... · (the licensee) dated May 6, 1985, as supplemented February 19, 1986 complies with the standards and requirements of

(BSEP-1-49)

TABLE 4.3.1-i (Continued)

REACTOR PROTECTION SYSTEM INSTRUMENTATION

t'

H

('

H

CHANNEL CHECK

5. Main Steam Line Isolation Valve Closure (B21-F022A,BC,D and B21-FO28A,B,CD)

6. Main Steam Line Radiation - High (Dl2-RM-K603A,B,C,D)

7. Drywell Pressure - High (C71-PT-NOO2ABCD) (C71-PTM-NOO2A-1,B-lC-I,D-l)

8. Scram Discharge Volume Water Level - High (Cll-LSH-NO13A,BC,D) (Cll-LSH-4516A,B,C,D)

9. Turbine Stop Valve - Closure (EHC-SVOS-lX,2X,3X,4X)

10. Turbine Control Valve Fast Closure, Control Oil Pressure Low (EHC-PSL-1756,1757,1758,1759)

11. Reactor Mode Switch in Shutdown Position (C71A-SI)

12. Manual Scram (C71A-S3A,B)

NA

S

NA(k) D

NA

NA

NA

NA

NA

CHANNEL, FUNCTIONAL

TEST

M

M(i)

NA M

Q

M

M

R

Q

SURVEI LLANCE REOUI REMENTS

CHANNEL CALIBRATION(a)

R(h)

R(J)

R(M) M

R

R(h)

R

NA

NA

OPERATIONAL CONDITIONS IN WHICH

SURVEILLANCE REQUIRED

1

k1,2

1,2 1, 2

1, 2, 5

l(o)

l(o)

1, 2, 3, 4, 5

1, 2, 3, 4, 5

FUNCTIONAL UNIT AND INSTRUMENT NUMBER

0,

rrt

o?

z

0

I-

SURVEILLANCE REQUIREMENTS

I! f

Page 7: E. Hollar Mr. Christopher Chappell, Chairman Post Office ... · (the licensee) dated May 6, 1985, as supplemented February 19, 1986 complies with the standards and requirements of

(BSEP-1-49)

t TABLE 4.3.1-1 (Continued) REACTOR PROTECTION SYSTEM INSTRUMENT4TION SURVEILLANCE REQUIREMENTS

(a) Neutron detectors may be excluded from CHANNEL CALIBRATION.

: (b) Within 24 hours prior to startup, if not performed within the previous 7 days. H

(c) The IRM channels shall be compared to the APRM channels and the SRM instruments for overlap during each startup, if not performed within the previous 7 days.

(d) When changing from OPERATIONAL CONDITION 1 to OPERATIONAL CONDITION 2, perform the required surveillance within 12 hours after entering OPERATIONAL CONDITION 2.

(e) This calibration shall consist of the adjustment of the APRM readout to conform to the power values calculated by a heat balance during OPERATIONAL CONDITION 1 when THERMAL POWER is greater than or equal to 25% of RATED THERMAL POWER.

W (f) This calibration shall consist of the adjustment of the APRM flow-biased setpoint to conform to a calibrated flow signal.

co (g) The LPRMs shall be calibrated at least once per effective full power month (EFPM) using the TIP system.

(h) This calibration shall consist of a physical inspection and actuation of these position switches.

(i) Instrument alignment using a standard current source.

(j) Calibration using a standard radiation source.

(k) The transmitter channel check is satisfied by the trip unit channel check. A separate transmitter check is not required.

(i) Transmitters are exempted from the monthly channel calibration.

(m) Placement of Reactor Mode Switch into the Startup/Hot Standby position is permitted for the purpoie of M performing the required surveillance prior to withdrawal of control rods for the purpose of bringing the t reactor to criticality.

? (n) Placement of Reactor Mode Switch into the Shutdown or Refuel position is permitted for the purpose of b performing the required surveillance provided all control rods are fully inserted and the vessel head

bolts are tensioned.

(o) Surveillance is not required when THERMAL POWER is less than 30% of RATED THERMAL POWER.

Page 8: E. Hollar Mr. Christopher Chappell, Chairman Post Office ... · (the licensee) dated May 6, 1985, as supplemented February 19, 1986 complies with the standards and requirements of

UNITED STATES NUU-EAR REGULATORY COMMISSION

WASHINGTON, D. C. 20555

CAROLINA POWER & LIGHT COMPANY

DOCKET NO. 50-324

BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2

AMENDMENI TO FACILITY OPERATING LICENSE

Amendment No. 129 License No. DPR-62

-1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Carolina Power & Light Company (the licensee) dated May 6, 1985, as supplemented February 19, 1986 complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I;

B. The 1acility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission;

C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations;

D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety ot the public; and

E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR-6Z is hereby amended to read as follows:

Page 9: E. Hollar Mr. Christopher Chappell, Chairman Post Office ... · (the licensee) dated May 6, 1985, as supplemented February 19, 1986 complies with the standards and requirements of

-2-

(2) Technical Specifications

The Technical Specifications contained in Appendices A and B, as revised through Amendment No.129 , are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is eftective as of the date of its issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

trý 2 Daniel R. Muller, Director BWR Project Directorate #2 Division of BWR Licensing

- Attachmeht: Ghanges to the Technical

Specifications

Date of Issuance: October 1, 1986

Page 10: E. Hollar Mr. Christopher Chappell, Chairman Post Office ... · (the licensee) dated May 6, 1985, as supplemented February 19, 1986 complies with the standards and requirements of

ATTACHMENT TO LICENSE AMENDMENT NO.129

FACILITY OPERATING LICENSE NO. DPR-62

DOCKET NO. 50-324

Replace the following pages of the Appendix A Technical Specifications with

the enclosed pages. The revised areas are indicated by marginal lines.

Pages

3/4 3-8 3/4 3-8a

Page 11: E. Hollar Mr. Christopher Chappell, Chairman Post Office ... · (the licensee) dated May 6, 1985, as supplemented February 19, 1986 complies with the standards and requirements of

(BSEP-2-45)

TABLE 4.3.--1' (Continued)

REACTOR PROTECTION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS

FUNCTIONAL UNIT AND INSTRUMENT NUMBER

CHANNEL CHECKH

H

"3NA

S

NA(k) D

NA

NA

5. Main Steam Line Isolation Valve Closure (B21-FO22A,B,C,D and

B21-FO28A,B,CD)

6. Main Steam Line Radiation - High (D12-RM-K603A,B,C,D)

7. Drywell Pressure - High (C72-PT-NO02A,B,C,D) (C72-PTM-NOO2A-I,B-I,C-l,D-l)

8. Scram Discharge Volume Water Level - High (C12-LSH-NOl3A,B,C,D) (CI2-LSH-4516A,B,C,D)

9. Turbine Stop Valve - Closure (EHC-SVOS-lX,2X,3X,4X)

10. Turbine Control Valve Fast Closure, Control Oil Pressure Low (EHC-PSL-1756,1757,1758,1759)

11. Reactor Mode Switch in Shutdown Position (C72A-SI)

12. Manual Scram (C72A-S3A,B)

CHANNEL FUNCTIONAL

TEST

M

M(i)

NA M

Q

M

M

R

Q

CHANNEL CALIBRATION(a)

R(h)

R(J)

R(1)

M

R

R(h)

R

NA

NA

OPERATIONAL CONDITIONS IN WHICH

SURVEILLANCE REQUIRED

1

1, 2

1, 2 1, 2

1, 2, 5

(l(o)

1, 2, 3, 4, 5

1, 2, 3, 4, 5

NA

NA

NA

01

Ii(o)

I

Page 12: E. Hollar Mr. Christopher Chappell, Chairman Post Office ... · (the licensee) dated May 6, 1985, as supplemented February 19, 1986 complies with the standards and requirements of

(BSEP-2-45)

TABLE 4.3.1-1 (Continued)

REACTOR PROTECTION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS

(a) Neutron detectors may be excluded from CHANNEL CALIBRATION.

(b) Within 24 hours prior to startup, if not performed within the previous 7 days.

H (c) The IRM channels shall be compared to the APRM channels and the SRM instruments for overlap during each

startup, if not performed within the previous 7 days.

(d) When changing from OPERATIONAL CONDITION 1 to OPERATIONAL CONDITION 2, perform the required surveillance within 12 hours after entering OPERATIONAL CONDITION 2.

(e) This calibration shall consist of the adjustment of the APRM readout to conform to the power values calculated by a heat balance during OPERATIONAL CONDITION 1 when THERMAL POWER greater than or equal to 25% of RATED THERMAL POWER.

(f) This calibration shall consist of the adjustment of the APRM flow-biased setpoint to conform to a

calibrated flow signal.

(g) The LPRMs shall be calibrated at least once per effective full power month (EFPM) using the TIP system.

(h) This calibration shall consist of a physical inspection and actuation of these position switches.

(i) Instrument alignment using a standard current source.

(j) Calibration using a standard radiation source.

(k) The transmitter channel check is satisfied by the trip unit channel check. A separate transmitter check is not required.

S(1) Transmitters are exempted from the monthly channel calibration.

((m) Placement of Reactor Mode Switch into the Startup/Hot Standby position is permitted for the purpose ef performing the required surveillance prior to withdrawal of control rods for the purpose of bringing the

r reactor to criticality.

? (n) Placement of Reactor Mode Switch into the Shutdown or Refuel position is permitted for the purpose of "performing the required surveillance provided all control rods are fully inserted and the vessel head bolts are tensioned.

(o) Surveillance is not required when THERMAL POWER is less than 30% of RATED THERMAL POWER.

Page 13: E. Hollar Mr. Christopher Chappell, Chairman Post Office ... · (the licensee) dated May 6, 1985, as supplemented February 19, 1986 complies with the standards and requirements of

UNITED STATES NUCLEAR REGULATORY COMMISSION

WASHINGTON, D. C. 20555

40e

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

SUPPORTING AMENDMENT NO. 100 TO FACILITY OPERATING LICENSE NO. DPR-71

AND AMENDMENT NO. 129 TO FACILITY OPERATING LICENSE NO. DPR-62

CAROLINA POWER & LIGHT COMPANY

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2

DOCKET NOS. 50-325 AND 50-324

1.0 INTRODUCTION

By letter dated May 6, 1985, as supplemented February 19, 1986, the Carolina Power and Light Company (the licensee) submitted proposed changes to the Technical Specifications (TS) appended to Facility Operating License Nos. DPR-71 and DPR-62 for the Brunswick Steam Electric Plant, Units 1 and 2. The licensee proposed to modify the surveillance requirement in TS Table 4.3.1-1 for the Turbine Stop Valve-Closure and Turbine Control Valve Fast Closure, Control Oil Pressure-Low functions of the Reactor Protection System.

2.0 EVALUATION

Currently, TS Table 4.3.1-1 (Items 9 and 10) requires the Turbine Stop Valve-Closure and Turbine Control Valve Fast Closure, Control Oil Pressure-Low functions to be tested monthly whenever the reactor is in Operational Condition 1. Further, to meet the requirements of TS Section 4.0.4, these functions must also be tested prior to entering Operational Condition 1. The proposed change to the TS would add a footnote to Items 9 and 10 of Table 4.3.1-1 to indicate that surveillance is not required when thermal power is below 30% of rated power. With the proposed change, the turbine stop and control valve surveillance would be performed every month while operating above 30% power and, per TS Section 4.0.4, prior to exceeding 30% power.

As justification for the proposed change, the licensee noted that the proposed change would be consistent with existing TS Table 3.3.1-1 which permits the fast closure scram functions of the turbine stop and control valves to be bypassed while below 30% power. These functions may be bypassed because the capacity of the turbine bypass valves is sufficient, at these lower power levels, to maintain proper system pressure. The turbine stop valve closure scram, which initiates a scram earlier than either the neutron monitoring system or reactor coolant system high pressure, is required at higher power levels to provide a satisfactory margin below core thermal-hydraulic limits.

8600904 0500324 PDR ADOCK 0 pDR P

Page 14: E. Hollar Mr. Christopher Chappell, Chairman Post Office ... · (the licensee) dated May 6, 1985, as supplemented February 19, 1986 complies with the standards and requirements of

-2-

The licensee has further indicated that the current TS requirements of TS Table 4.3.1-1 in conjunction with TS Section 4.0.4, result in unnecessary complications to the surveillance procedure. These TS sections require surveillance testing before entering Operational Condition 1, i.e., while in Operational Condition 2, 3 or 4. However, performance of these tests causes large power swings and significant thermal cycling of plant systems. Since the Intermediate Range Monitors (IRM) are not bypassed in Operational Condition 2, a high IRM scram is likely to occur due to a pressure transient if the tests are performed in Operational Condition 2. In Operational Condition 3 or 4, the system configuration to perform the surveillance is complex and/or requires the.use of jumpers. Therefore, it is advantageous to perform the required surveillance in Operational Condition 1 when the IRMs are bypassed but prior to reaching 30% power.

We have reviewed the licensee's submittal and have determined that the surveillance need not be performed on the Turbine Stop Valve-Closure and-Turbine Control Valve Fast Closure, Control Oil Pressure-Low functions while operating below 30% power. Since these functions are bypassed below 30% power, the proposed change to the TS is consistent with TS Section 4.0.3 which indicates that surveillance need not be performed on inoperable equipment. In addition, the surveillance requirements reflected by the proposed change have been accepted in the past by the NRC staff for other boiling water reactor facilities. Based on our review, we, therefore, conclude that the proposed change to TS Table 4.3.1-1 is acceptable.

3.0 ENVIRONMENTAL CONSIDERATIONS

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite; and that there should be no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously published a proposed finding that the amendments involve no significant hazards consideration and there has been no public comment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR §51.22(c)(9). Pursuant to 10 CFR §51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

4.0 CONCLUSION

We have concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations, and the issuance of the amendments will not be

Page 15: E. Hollar Mr. Christopher Chappell, Chairman Post Office ... · (the licensee) dated May 6, 1985, as supplemented February 19, 1986 complies with the standards and requirements of

-3

inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: K.W. Van Dyne

Dated: October 1, 1986