ML071940050

Conforming License Amendment to Incorporate the Mitigation Strategies Required by Section B.5.b. of Commission Order EA-02-026 (Tac MD4536)

ML071940050
Person / Time
Site:	Grand Gulf
Issue date:	07/18/2007
From:	Bhalchandra Vaidya NRC/NRR/ADRO/DORL/LPLIV
To:	Brian W Entergy Operations
vaidya B, NRR/DLPM, 415-3308
Shared Package
ML071940043	List: ML071940050 ML071970075
References
EA-02-026, TAC MD4536
Download: ML071940050 (17)

Text

0 rrloI:.L coc iiv: ZEZL IT UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 18, 2007 Mr. William R. Brian Vice President of Operations Grand Gulf Nuclear Station Entergy Operations, Inc.

P.O. Box 756 Port Gibson, MS 39150

SUBJECT:

GRAND GULF NUCLEAR STATION, UNIT 1 - CONFORMING LICENSE AMENDMENT TO INCORPORATE THE MITIGATION STRATEGIES REQUIRED BY SECTION B.5.b. OF COMMISSION ORDER EA-02-026 (TAC NO. MD4536)

Dear Mr. Brian:

This letter documents the results of the U.S. Nuclear Regulatory Commission (NRC) staff's regulatory assessment of the adequacy of the actions taken by the Entergy Operations, Inc., for the Grand Gulf Nuclear Station, Unit 1, in response to Section B.5.b. of the February 25, 2002, Interim Compensatory Measures (ICM) Order (EA-02-026) and related NRC guidance.

The ICM Order was issued following the events of September 11, 2001, as part of a comprehensive effort by the NRC, in coordination with other government agencies, to improve the capabilities of commercial nuclear reactor facilities to respond to terrorist threats.

Section B.5.b. of the Order required licensees to develop specific guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities using existing or readily available resources (equipment and personnel) that could be effectively implemented under the circumstances associated with loss of large areas of the plant due to explosions or fire, including those that an aircraft impact might create. Although it was recognized prior to September 11, 2001, that nuclear reactors already had significant capabilities to withstand a broad range of attacks, implementing these mitigation strategies would significantly enhance the plants' capabilities to withstand a broad range of threats. It should be noted that portions of the ICM Order, as well as other documents referenced in this letter, contain security-related or safeguards information, and are not publicly available.

Licensee actions to implement Section B.5.b mitigation strategies have been ongoing since the issuance of the 2002 ICM Order. In 2005, the NRC issued guidance to more fully describe the NRC staff's expectations for implementing Section B.5.b of the lCM Order. The NRC guidance relied upon lessons learned from detailed NRC engineering studies and industry best practices.

Additionally, the NRC conducted two on-site team assessments at each reactor facility that identified additional mitigating strategies for preservation of core cooling, containment integrity, and spent fuel pool cooling. In total, these efforts have added defense in depth through the use of additional equipment and strategies. Moreover, these enhancements that have strengthened the interface between plant safety and security operations now include fire-fighting response strategies; plant operations to mitigate fuel damage; and actions to minimize releases.

NOTICE: The attachments to the Safety Evaluation.

contain Security-Related Information. Upon separation from these attachments, this letter and Enclosures 1 and 2 are DECONTROLLED.

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W. The enclosed Safety Evaluation (SE) details the interactions between the NRC staff and the Entergy Operations, Inc., as well as the rest of the nuclear industry, related to the final resolution of Section B.5.b. of the ICM Order.

The NRC is incorporating requirements for the B.5.b mitigating strategies into the Facility Operating License. This letter, therefore, also transmits the license condition that captures the ICM Order Section B.5.b mitigation strategy requirements and incorporates them into the licensing basis.

This proposed license condition was transmitted by the NRC to the Entergy Operations, Inc., in a letter dated October 13, 2006. By letter dated January 11, 2007, the Entergy Operations, Inc., informed the NRC staff that it would accept the proposed license condition, with a minor change that the NRC staff finds acceptable. The effectiveness of the licensee's actions to implement the mitigative strategies contained in this license condition will be subject to future NRC review and inspection.

Consistent with the Order, an administrative license change to Facility Operating License No. NPF-29 for the Grand Gulf Nuclear Station, Unit 1, is being made to incorporate the agreed upon license condition. This change complies with the standards and requirements of the Atomic Energy Act of 1954, as amended, and the Commission's rules and regulations set forth in Title 10 of the Code of Federal Regulations (10 CFR) Chapter I. Please replace the affected page of the Facility Operating License with the enclosed pages (Enclosure 1).

The attachments to the SE are designated exempt from public disclosure under 10 CFR 2.390(d)(1) since they contain security-related information and are Official Use Only.

If you have any questions, please contact me at (301) 415-3308.

Sincerely, Bhalchandra Vaidya, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-416

Enclosures:

1. Revised Pages of Facility Operating License No. NPF-29

2. Safety Evaluation cc w/o atts to Encl. 2: See next page a orrioL-2... ~CE OrL" CO~2flW' flE2TED I~i~OflFV~TlOtI wr`r

Grand Gulf Nuclear Station cc w/o atts to Encl. 2:

Executive Vice President

& Chief Operating Officer-Entergy Operations, Inc.

P.O. Box 31995 Jackson, MS 39286-1995 Chief Energy and Transportation Branch Environmental Compliance and Enforcement Division Mississippi Department of Environmental Quality P.O. Box 10385 Jackson, MS 39289-0385 President Claiborne County Board of Supervisors P.O. Box 339 Port Gibson, MS 39150 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 399 Port Gibson, MS 39150 General Plant Manager Operations Entergy Operations, Inc.

P.O. Box 756 Port Gibson, MS 39150 Attorney General Department of Justice State of Louisiana P.O. Box 94005 Baton Rouge, LA 70804-9005 Office of the Governor State of Mississippi Jackson, MS 39201 Attorney General Asst. Attorney General State of Mississippi P.O. Box 22947 Jackson, MS 39225-2947 Vice President, Operations Support Entergy Operations, Inc.

P.O. Box 31995 Jackson, MS 39286-1995 Director Nuclear Safety Assurance Entergy Operations, Inc.

P.O. Box 756 Port Gibson, MS 39150 Director Nuclear Safety & Licensing Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213-8298 Manager, Licensing Entergy Operations, Inc.

P.O. Box 756 Port Gibson, MS 39150 Richard Penrod, Senior Environmental Scientist/State Liaison Officer Office of Environmental Services Northwestern State University Russsell Hall, Room 201 Natchitoches, LA 71497 State Health Officer State Board of Health P.O. Box 139 Jackson, MS 39205 November 2006

ENCLOSURE 1 REVISED PAGE OF FACILITY OPERATING LICENSE NO. NPF-29 DOCKET NO. 50-416 GRAND GULF NUCLEAR STATION. UNIT 1 Replace the following page of the Facility Operating License with the attached revised pages.

The revised pages are identified by the date of the letter issuing these pages and contain marginal lines indicating the areas of change.

REMOVE Page 16 INSERT Page 16 Page 16a

(41)

Fire Protection Proqram Entergy Operations, Inc. shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in Revision 5 to the Updated Final Safety.Analysis Report, and as approved in the Safety Evaluations dated August 23,

1991, and September 29, 2006, subject to the following provisidns:

The licensee may make changes to the approved Fire Protection Program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(42)

MitiqationStratecy License Condition The Licensee shall develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a)

Fire fighting response strategy with the following elements:

1.

Pre-defined coordinated fire response strategy and guidance

2.

Assessment of mutual aid fire fighting assets

3.

Designated staging areas for equipment and materials

4.

Command and control

51. Training of response personnel (b)

Operations to mitigate fuel damage considering the following:

1.

Protection and use of personnel assets

2.

Communications

3.

Minimizing fire spread

4.

Procedures for implementing integrated fire response strategy

5.

Identification of readily-available pre-staged equipment

6.

Training on integrated fire response strategy

7.

Spent fuel pool mitigation measures (c)

Actions to minimize release to include consideration of:

1.

Water spray scrubbing

2.

Dose to onsite responders D.

The facility required exemptions from certain requirements of Appendices A and J to 10 CFR Part 50 and from certain requirements of 10 CFR Part

100, These include:

(a) exemption from General Design Criterion 17 of Appendix A until startup following the first refueling outage, for (1) the emergency override of the test mode for the Division 3 diesel engine, (2) the second level undervoltage'protection for the Division 3 diesel engine, 16 Amendment No.

170 Revised by Letter dated July 18, 2007

and (3) the generator ground over current trip function for the Division 1 and 2 diesel generators (Section 8.3.1 of SSER #7) and (b) exemption from the requirements of Paragraph III.D.2(b)(ii) of Appendix J for the containment airlock testing following normal door opening when containment integrity is not required (Section 6.2.6 of SSER #7).

These exemptions are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest.

In

addition, by exemption dated December 20, 1986, the Commission exempted licensees from 10 CFR 100.11(a)(1),

insofar as it incorporates the definition of exclusion area in 10 CFR 100.3(a), until April 30, 1987 regarding demonstration of authority to control all activities within the exclusion area (safety evaluation accompanying Amendment No.

27 to License (NPF-29).

This exemption is authorized by law, and will not present an undue risk to the public health and'safety, and is consistent with the common defense and security.

In addition, special circumstances have been found justifying the exemption.

Therefore, these exemptions are hereby granted pursuant to 10 CFR 50.12.

With the granting of these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act and the rules and regulations of the Commission.

E.

The licensee shall fully implement and maintain in effect all provision.

of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled:

"Physical Security, Safeguards Contingency and Training and Qualification Plan," and were submitted to the NRC on May 18, 2006.

16a Revised by letter dated Janulry 21, 2007 Revised by letter dated ZJuly 18, 2007

t REG(,

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001

'e SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO ORDER NO. EA-02-026 ENTERGY OPERATIONS, INC., ET AL.

GRAND GULF NUCLEAR STATION, UNIT 1 DOCKET NO. 50-416

1.0 INTRODUCTION

1.1 Purpose The purpose of this Safety Evaluation (SE) is to document the U.S. Nuclear Regulatory Commission (NRC) staff's regulatory assessment of the adequacy of the actions taken by the Entergy Operations, Inc. (the licensee), in response to the February 25, 2002, Interim Compensatory Measures (ICM).Order and the subsequent NRC letter to licensees dated February 25, 2005, transmitting NRC guidance (Phase 1 guidance document). This SE describes the basis for finding licensee strategies adequate to satisfy the requirements of the ICM Order. This SE also discusses the license condition that satisfactorily captures the mitigation strategy requirements. If the licensee makes future changes to its strategies within its commitment management program, this SE will be useful to the NRC staff in determining if the changed strategies are adequate to meet the license condition. It should be noted that portions of the ICM Order, as well as other documents referenced in this SE, contain security-related or safeguards information, and are not publicly available.

1.2 Background

The February 25, 2002, ICM Order that imposed interim compensatory measures on power reactor licensees required in Section B.5.b, Mitigative Measures, the development of "specific guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities using existing or readily available resources (equipment and personnel) that can be effectively implemented under the circumstances associated with loss of large areas of plant due to explosions or fire." These actions were to be implemented by the end of August 2002. Inspections of the implementation of the Section B.5.b requirements were conducted in 2002 and 2003 (Temporary Instruction (TI) 2515/148). The inspections identified large variabilities in scope and depth of the enhancements made by licensees. As a result, the NOTICE: The attachments to the Safety Evaluation contain Security-Related Information. Upon separation from these attachments, this Safety Evaluation is-DECONTROLLED.

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uI l-l a Il NRC determined that additional guidance and clarification was needed for nuclear power plant licensees.

Subsequent to the conduct of the TI 2515/148 inspections, engineering studies conducted by the NRC Office of Regulatory Research (RES) provided insights into the implementation of mitigation strategies to address the loss of large areas of a plant due to explosions or fire, including those that an aircraft impact might create. The NRC actions resulting from these studies included: (1) inspections of licensee actions that address plant-specific consequences, (2) issuance of advisories that involve processes and protocols for licensee notification of an imminent aircraft threat, and (3) identification of mitigative measures to enhance plant response to explosions or fire.

On November 24, 2004, the NRC issued a letter to licensees providing information on the Commission's phased approach for enhancing reactor mitigative measures and strategies for responding to Section B.5.b of the ICM Order. On February 25, 2005, the NRC issued guidance (Phase 1 guidance document) to describe more fully the NRC staff's expectations for implementing Section B.5.b of the ICM Order. Determination of the specific strategies required to satisfy the Order, elaborated on by the Phase 1 guidance document, was termed Phase 1.

Further information on the Commission's phased approach and its reliance on the Phase 1 guidance document and related workshop was described in an NRC letter to licensees dated January 14, 2005.

The NRC Phase 1 guidance document relied upon lessons learned from recent NRC engineering studies involving plant assessments, as well as industry best practices. This guidance also included the spent fuel pool mitigative measures described in a NRC letter to licensees dated July 29, 2004, "Issuance of Spent Fuel Pool Mitigative Measures." These best practices were identified during the inspections conducted in 2002 and 2003. The Phase 1 guidance document also incorporated industry comments made at two B.5.b-related workshops held on January 14, 2005, and February 2, 2005.

2.0 REGULATORY EVALUATION

Section B.5.b of the ICM Order required licensees to develop specific guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities using existing or readily-available resources (equipment and personnel) that can be effectively implemented under the circumstances associated with loss of large areas of the plant due to explosions or fire. Determination of the specific strategies required to satisfy the Order, elaborated on in the Phase 1 guidance document, was termed Phase 1.

In order to assure adequate protection of public health and safety and common defense and security, the NRC determined that differences in plant design and configuration warranted independent assessments to verify that the likelihood of damage to the reactor core, containment, and spent fuel pools and the release of radioactivity is low at each nuclear power plant. The Commission directed the NRC staff to conduct site-specific security and safety assessments to further identify enhanced mitigation capabilities. Site-specific assessments of spent fuel pools were deemed Phase 2 and site-specific assessments of reactor core and containments were deemed Phase 3.

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nrrirn-~ unr nri~x ornunrn: flrL.2rrD IlironriATlor: The goal of the Phase 2 and 3 mitigation strategy assessments was for the NRC and the licensees to achieve a new level of cognition of safety and security through a comprehensive understanding of the capabilities and limitations of the plants under normal, abnormal, and severe circumstances (from whatever cause). Based on this improved understanding, licensees could take reasonable steps to strengthen their capabilities and reduce their limitations. The NRC expected that safety and security would be well served by further enhancing the licensee's severe accident management strategies for mitigating a wide spectrum of events through the use of readily-available resources and by identifying potential practicable areas for the use of beyond-readily-available resources.

During 2005, the NRC staff performed inspections (TI 2515/164) to determine licensees' compliance with Section B.5.b of the ICM Order (Phase 1). Subsequent meetings were held with licensees to resolve identified open issues. Confirmatory B.5.b Phase 1 inspections (TI 2515/168) were conducted during the period of June to December 2006. The NRC staff conducted site visits as part of the Phase 2 assessments during 2005. In 2006, the NRC staff observed licensee Phase 3 studies and conducted independent Phase 3 assessments.

On January 24, 2006, the Nuclear Energy Institute (NEI) submitted a letter (M. Fertel to L. Reyes) describing an industry proposal for resolving ("closing") Phase 2 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML060260220). The industry proposed high level functional mitigating strategies for a spectrum of potential scenarios involving spent fuel pools. In a letter to all Holders of Licenses for Operating Power Reactors dated June 21, 2006 (ADAMS Accession No. ML061670146), the NRC accepted the Phase 2 proposal pending review of site-specific details of its application and implementation.

In arriving at this conclusion, the NRC staff placed significant weight on portions of the proposal that rely on industry commitments to provide beyond-readily-available resources not previously available. These additions will significantly enhance licensees' mitigating strategies capabilities.

On June 27, 2006, the NEI submitted two letters (M. Fertel to W. Kane). In one of the letters, the NEI proposed a license condition to capture the Section B.5.b requirements and addressed items deferred from Phase 1 to Phase 2 (ADAMS Accession No. ML061790400). The license condition includes 14 items in the same broad categories as the February 25, 2005, Phase 1 guidance document; fire fighting response strategy, plant operations to mitigate fuel damage, and actions to minimize releases. The proposal suggested that the implementing details found to be an acceptable means of meeting the license condition would be treated as commitments, and managed in accordance with NEI 99-04, "Guidelines for Managing NRC Commitment Changes." In the second letter, the NEI proposed generic strategies for closure of Phase 3 (ADAMS Accession No. ML061860753). The required strategies for all three phases would be covered by the license condition and all implementing details would be managed by NEI 99-04.

The February 25, 2005, Phase 1 guidance document included 34 expectations. Two of these items were deferred to Phase 2 and seven items (i.e., six expectations and one element of a seventh expectation) were deferred to Phase 3. The NRC staff reached agreement with licensees on the-non-deferred items under Phase 1.

Table 1 provides a cross reference of how the 34 elements of the February 25, 2005, Phase 1 guidance document and Phases 2 and 3 mitigating strategies correspond to the sections of the license condition.

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CJ Jiu lWI m I4 On June 29, 2006, the NRC staff issued a letter to the NEI conditionally accepting its proposed license condition and strategies (ADAMS Accession No. ML061790306). The letter reiterated that mitigation strategies in NEI's proposals that were identified during the Phase 2 and 3 assessments, which utilize reasonable, evident, readily-available resources (as identified in the February 25, 2005, Phase 1 guidance document) are required pursuant to Section B.5.b of the ICM Order. The implementing details of the required strategies will be implemented by commitment and managed in accordance with the NEI commitment management guideline, NEI 99-04. The NRC staff believes the NEI proposal reasonably justifies excluding from formal regulatory controls those additional strategies identified during the site-specific Phases 2 and 3 assessments that the NRC previously deemed required under Section B.5.b of the ICM Order, but not identified in NEI's proposals. Inherent in this conclusion is recognition of the addition of beyond-readily-available resources included in the proposals. The implementing details of mitigation strategies included in the proposal, including those that utilize beyond-readily-available resources, will be treated as commitments, which will become part of the licensing basis of the plant. Additional strategies identified during site-specific assessments which licensees deem acceptable and valuable to promote diversification and survivability, will be incorporated into licensees' Severe Accident Management Guidelines, Extreme Damage Mitigation Guidelines, or appended to other site implementation guidance. To verify compliance, the NRC staff evaluated the site-specific implementation and documentation of the proposed Phases 2 and 3 mitigating strategies for each U.S. nuclear power plant.

3.0 TECHNICAL EVALUATION

The NRC staff's technical evaluation for strategies identified in Phase 1 of Section B.5.b is found in Appendix A. The NRC staff's technical evaluation for strategies identified in Phases 2 and 3 of Section B.5.b is found in Appendix B.

The Mitigating Strategies Table (MST) is included as Appendix C. The purpose of the MST is to capture, at the functional level, a summary of licensee strategies for compliance with the 34 measures presented in the February 25, 2005, Phase 1 guidance document and to indicate how the 34 items correlate to the 14 items in the license condition.

4.0 REGULATORY COMMITMENTS The implementing details of the mitigating strategies required by the license condition are identified in licensee submittals dated January 11, 2007 (ADAMS Accession No. ML070160048), June 7, 2007 (ADAMS Accession No. ML071660019), and July 3, 2007 (ADAMS Accession No. ML071980352). These details will be implemented by commitment and managed in accordance with the NEI commitment management guideline, NEI 99-04. The NRC staff concludes this provides reasonable controls for mitigating strategy implementation and for subsequent evaluation of licensee-identified changes.

Because the 14 items required by the license condition correlate to the 34 items presented in the February 25, 2005, Phase 1 guidance document and the mitigating strategies within NEI's Phase 2 and 3 proposals, and because the implementing details will be managed under NEI 99-04, the NRC staff is satisfied that there will be sufficient controls to ensure that the strategies are adequately maintained.

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5.0 CONCLUSION

Based on the NRC staff's review described in Appendices A, B, and C of this SE, the licensee's responses to the February 25, 2005, Phase 1 guidance document and the spent fuel pool and reactor core and containment mitigating strategy assessments meet the requirements of Section B.5.b, Mitigative Measures, of the February 25, 2002, ICM Order that imposed interim compensatory measures on power reactor licensees. The NRC staff concludes that full implementation of the licensee's enhancements in the submittals identified in Section 4.0, above, constitutes satisfactory compliance with Section B.5.b and the licensee condition, and represents reasonable measures to enhance the licensee's effectiveness in maintaining reactor core and spent fuel pool cooling and containment integrity under circumstances involving the loss of large areas of the plant due to fires or explosions.

The Commission 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 amendments will not be inimical to the common defense and security or to the health and safety of the public.

Attachments (Official Use Only - Security-Related Information - ADAMS Accession No. ML071990329):

1. Phase 1 Assessment (Appendix A)

2. Phases 2 and 3 Assessment (Appendix B)

3. Mitigating Strategies Table (Appendix C)

Principal Contributors: David J. Nelson Michael K. Webb Nathan T. Sanfilippo Date: July 18, 2007 3i lIZlAL U)E 3i!LX l

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_IchAPNIT 9=1 PhAPKITIZ License Condition section Guidance Document Elements A. Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and B.1.b Staging of personnel guidance B.1.e Outside organization Support B.1.j Treatment of casualties B.1.k Site assembly areas (mass casualties)

B.1.m Industry best practice - feeding fire protection ring header

2. Assessment of mutual aid fire fighting assets B.1.c Airlifted resources B.1.f Mobilization of fire fighting resources - existing or new MOUs B.1.g Mobilization of fire fighting resources - coordination with other than local mutual aid fire fighting resources (i.e, Industrial facilities, large municipal fire departments, airports, and military bases)

3. Designated staging areas for equipment and B.1.a Staging of equipment materials B.1.h Controlling emergency response vehicles (includes rad monitoring)

4. Command and Control B.l.d Command and control B.1.i Communications enhancements

5. Training of response personnel B.1.1 Training considerations z~rrOI~ UOE0hZ OE~flW fl' ~TD Ilr

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7. Spent fuel pool mitigation measures B.2.m.1 Dispersal of Fuel B.2.m.2 Hot fuel over rack feet B.2.m.3 Downcomer area B.2.m.4 Enhanced air circulation (Included in Phase 2 strategies)

B.2.m.5 Emergency pool makeup, leak reduction/repair (Included in Phase 2 strategies)

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1. Water spray scrubbing B.3.a Water spray scrubbing B.3.b Prestaging of equipment

2. Dose to onsite responders B.3.c Dose projection models (Included in Phase 3 strategies)

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Pkg ML071940043 (Letter & Encl 2: ML071940050, Encl 1 :ML071970075, Attachments to SE (OUO): ML071990329)

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Pkg ML071940043 Letter & Encl 2: ML071940050, Encl 1:ML071970075, Attachments to SE (OUO): ML07)

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