ML090410636

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Summary of Meeting with FPL Energy Point Beach, Llc., on Proposed Auxiliary Feedwater Amendment and Extended Power Uprate
ML090410636
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 02/24/2009
From: Justin Poole
Plant Licensing Branch III
To:
Division of Operating Reactor Licensing
Poole Justin/DORL/LPL3-1/ 301-415-2048
References
TAC MD9526, TAC MD9527
Download: ML090410636 (35)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 24, 2009 LICENSEE:

FPL Energy Point Beach, LLC FACILITY:

Point Beach Nuclear Plant, Units 1 and 2 SUB..IECT:

SUMMARY

OF THE JANUARY 22,2009, MEETING WITH FPL ENERGY POINT BEACH, LLC, ON THE PROPOSED AUXILIARY FEEDWATER AMENDMENT AND EXTENDED POWER UPRATE (TAC NOS. MD9526 AND MD9527)

On January 22,2009, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of FPL Energy Point Beach, LLC (the licensee) at NRC Headquarters, Executive Boulevard Building, 6003 Executive Boulevard, Rockville, Maryland. A list of attendees is provided as Enclosure 1.

The purpose of the meeting was to discuss proposed changes to the auxiliary feedwater (AFW) system and to get an update on the licensee's progress with a planned Extended Power Uprate (EPU) amendment. The meeting was requested by the licensee to seek NRC comments on their latest design approach since the previous AFW amendment application by the licensee was withdrawn (See the Agencywide Documents Access and Management System (ADAMS)

Accession No. ML082380149).

The licensee's presentation is attached as Enclosure 2.

DISCUSSION The licensee started off the presentation by talking about their previous amendment submittal to change out the motor-driven AFW (MDAFW) pumps and some of the design features that the NRC staff had concerns with, which led to the licensee's withdrawal. The licensee's previous amendment intended to extend the allowed outage time for from 7 days to 16 days in order to install higher capacity motors on the AFW pumps, during a refueling outage with one unit still operating.

The licensee then went on to describe their current plans to replace the MDAFW pumps for Point Beach. The proposed new design will install two new safety grade MDAFW pump trains with one train assigned per unit. Each train will contain a new MDAFW pump that is capable of providing 100 percent capacity. Additional piping and electrical modifications to the plant will be proposed to finish off the design of these new trains, some of which are described in the licensee's presentation.

The existing MDAFW pumps will be renamed as Standby Steam Generator (SSG) pumps.

These will have their auto start features removed, will not provide a safety-related function, and will be removed from the technical specifications (TS). The primary use for these pumps will be during startup and shutdown, but could be used for beyond design basis postulated events.

- 2 Due to the licensee's new proposed design of leaving the current pumps installed, most of the work for the new MDAFW trains can be done online and does not require an extension to the allowed outage time. In the licensee's proposed plan, the final tie-ins would be made during outages when AFW is not required by that unit.

In terms of fire protection, one of the NRC's concerns with the previous submittal, the licensee plans on locating these new pumps in separate rooms and in a different location than the current MDAFW pumps and turbine-driven AFW pumps.

At the end of the AFW presentation, the licensee requested feedback from the NRC staff.

Overall the NRC staff felt that this design approach was an improvement from the previous attempt. The proposed AFW system modifications have the potential to improve (1) the availability and reliability of the AFW system, (2) the overall risk profile of the site by improving the overall risk profile of the AFW system, and (3) improving the risk associated with fire concerns by installing the new pumps in a separate fire area. The NRC staff did point out for the electrical design of the pumps, to include in the submittal, discussion on the pump interlocks associated with diesel loading. Since the SSG pumps can still be run from the diesel generators, the staff was concerned with preventing accidental starting of SSG pumps while the new MDAFW pumps were operating. Some discussion was had over the TS that would be proposed for this new system. The licensee stated that they based their proposed change to follow the standard TS.

The second portion of the meeting was focused on the licensee's progress with a planned EPU amendment. The licensee discussed some NRC staff recommendations that were made at a previous public meeting on the EPU s'ubmittal and the status of where the licensee was with these recommendations. The NRC staff acknowledged the status of these items.

A member of the public was in attendance. Public Meeting Feedback forms were not received.

Please direct any inquiries to Justin Poole at 301-415-2048, or Justin.Poole@nrc.gov.

Justin C. Poole, Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-266 and 50-301

Enclosures:

1. List of Attendees
2. Licensee's Handout cc w/encls: Distribution via ListServ.

ATTENDANCE LIST MEETING BETWEEN THE NRC AND FPL ON THE PROPOSED AUXILIARY FEEDWATER AND EXTENDED POWER UPRATE AMENDMENT JANUARY 22, 2009 NAME ORGANIZATION Justin Poole NRR/DORL/LPL3-1 Gene Poletto Performance Power Services Harold Barrett NRR/DRNAFPB Daniel Horner Platts Vincent Rubano FPLE Jim Peschel FPLE Ching Guey FPLE Mike Moran FPLE Harv Hanneman FPLE Dave Dominicis Westinghouse Mike Millen FPLE Raj Kundalkar FPLE OJ Tomaszecoski FPLE Jim Costedio FPLE Jeff Novak FPLE N. E. Hanley Shaw William Jessup NRRIDE/EMCB Matthew McConnell NRR/DE/EEEB Lois James NRR/DORL/LPL3-1 Allen Howe NRR/DORL Andrea Russell NRR/DPR Tom Alexion NRR/DPR Shawn Marshall RES/DSNRSAB Stanley Gardocki NRR/DSS/SBPB Andrew Bowman Westinghouse Jorge Fontes Westinghouse Scott Snider Westinghouse Liz Abbott FPLE Bridin Tully NRR/DORL/LPL3-1 Robert Krsek (on conference line)

RlIl/DRP/Branch 5 John Jandovitz (on conference line)

Rlll/DRP/Branch 5

  • F=PI-Energy.......-..-

Point Beach Nuclear Plant Auxiliary Feedwater System Margin Improvements Meeting with Nuclear Regulatory Commission January 22, 2009

Agenda

  • Introductions
  • Purpose
  • Background

- Overview

- Benefits

  • Technical Specifications
  • Implementation Overview
  • Questions
  • F=PLEnergy

~

2

Purpose

- Current AFW Conceptual Design

- Planned Margin Improvement Modifications

- Integration with Extended Power Uprate

- Schedule for Technical Specification

- Current Plans for Installation

  • Update NRC Staff on Extended Power Uprate License Amendment Request
  • Seek NRC input/comments on approach
  • I=PLEnergy

~

3

=

Background===

  • In August 2008, FPLE discussed replacement of existing Motor Driven Auxiliary Feedwater (MDAFW) pumps including installation of a temporary Standby Steam Generator (SSG) pump to support replacement of the existing MDAFW pump under a one time Technical Specification Action Condition (TSAC) completion time License Amendment request (LAR)
  • After discussions with Staff, FPLE withdrew its TSAC extension request and commenced a new integrated review of Auxiliary Feedwater (AFW)

Considered Extended Power Uprate (EPU) design optimization Considered alternative implementation approaches Considered reducing plant risk by installing a permanent SSG pump

  • As a result of this review, AFW conceptual design has been updated
  • This presentation shares the current plans for AFW margin improvement modifications
  • The AFW margin improvement modifications are planned to be installed under the existing TSAC and the revised EPU Technical Specifications 4
  • I=PLEnergy

~

New AFW Design

  • Integrated EPU/AFW Review

- AFW Reliability Improvement

- EPU Chapter 14 accident analysis for AFW flow requirements

  • LONF - Loss of Normal Feed
  • LOAC - Loss Of all AC power to the station auxiliaries
  • SBLOCA - Small Break Loss Of Coolant Accident

- Existing Plant Corrective action program items

  • Create, Preserve and Protect AFW design margin
  • I=PLEnergy

~.

5

New AFW Design

  • FPLE current plan Install two new safety grade MDAFW pump trains (one pump per unit)

Install within the existing TSAC's Tie-ins made during outages when AFW is not required to that unit Pre-work implemented online independent of existing AFW system availability Short final transition after NRC approval (EPU LAR)

Reconfigure existing MDAFW pump trains Equipment to remain in place Rename to Standby Steam Generator (SSG) Pumps Remove auto start signals No safety related functions Remove from technical specifications

  • F=PL. Energy

~

6

New AFW Design (Continued)

Design Attributes of new MDAFW pump trains Unitize MDAFW pump trains 100

% capacity pumps Powered by 4 kV safety related switchgear Controls in control room and local Pumps will be automatically started for SG low low level, LOOP and SI signals and can be manually operated New suction line from Condensate Storage Tank (CST) supply for new MDAFW pumps Auto transfer of normal suction source from CST to Service Water (SW) for MDAFW and TDAFW pump Anticipated Transient Without SCRAM Mitigating System Actuation Circuitry (AMSAC) Start Signal

  • F=PLEnergy

~

7

New AFW Design (Continued)

  • SSG Trains (Non safety related function)

Use in normal plant startups and shutdowns Available for beyond design basis postulated events Overall plant safety improvement

  • SSG trains retain all manual control capability from the control room and AFW rooms AFW Auto initiation is removed from SSG trains AFW Auto initiation trips SSG pumps (if necessary)
  • SSG Train powered from existing 480 VAC load centers May be loaded by operations using load management procedures
  • Single pump used in better estimate flow requirements for decay heat removal with atmospheric steam dump valves

(-220 gpm)

  • F=PLEnergy

~

8

Benefits of New System Increased Flow Margin MDAFW Pump Flow Margin:

New MDAFW train needs - 275 gpm @ -2860 ft New MDAFW pump is capable of 275 gpm @ 3060 ft Capable of -375 gpm with full open discharge control valve Margin is dependent on final full open Cv of the control valve Turbine Driven Auxiliary Feedwater (TDAFW) Pump Flow Margin TDAFW train needs - 275 gpm @ 2640 ft TDAFW pump is capable of 275 gpm @ 3010 ft Capable of -425 gpm with full open discharge valve 480 V System Margins Gained With Replacement Reduces operator manual action requirements Reduce risk of motor trip on start Retains original MDAFW pumps as SSG pumps AFW reliability improved Reliability is dominated by Operator failing to switch AFW pump suction to SW Auto switch-over eliminates this operator action and interruption of AFW flow F=PLEnergy

~

9

AFW System Design AFW System - Major Flow Paths Per Unit With Shared Standby Steam Generator (SSG) pump System 10 UNIT l

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  • F=PLEnergy

~

10

General Arrangement LAKE SIDE I'

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~

Electrical Design

  • AC system analyzed for impact of new MDAFW pumps
  • AC degraded grid performance for the existing limiting safety related equipment improved by moving MDAFW pump from 480V to 4160 V.
  • Short circuit duty reduced for 480 V safety buses during DBA.
  • Calculations performed with new 4160 V MDAFW pumps Maximum loading case for each A train EDG is maintained below the 2000 hr rating for the entire event duration Maximum loading case for B train EDGs is maintained below the 200 hr rating (2951 kW) during initial plant response and below the 2000 hr rating (2848 kW) during long term plant response.
  • Consistent with 1994 SER considerations (short term operation in 200 hour0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> rating)
  • Current analysis is 2927 kW load up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
  • F=PLEnergy

~

12

New AFW Improves Plant Safety

  • Dominant operator action (switchover to service water) is eliminated
  • Two new MDAFW pumps located in separate fire areas from existing TDAFW pumps and cabling protected
  • For Control Room and Cable Spreading Room fire scenarios, the new MDAFW pumps will be isolatable and have local control capability
  • New AFW pump recirculation valve to be provided with backup air supply
  • Better estimate analysis shows single SSG pump adequate for decay heat removal with atmospheric dump valves
  • F=PLEnergy

~

13

New AFW Timeline

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,...-lb-EPU Implementation planned in

-Test unit 1 pump Receive EPU LAR approval Spring 2010 (Unit 1) and Spring and new AFW Tech Spec 2011 (Unit 2) Outages prior to end of spring outage

- Convert to new AFW system with unit 2 online and unit 1 while in cold shutdown

  • FPLEnergy

~

Pre Fall 2009 Outage

-Pre-installation Fall 2009 Outage

-Breaker Logic &Testing (unit 2 breaker)

- Retrain unit 2 TDAFW pump Interim (Between Fall 2009 and Spring 2010 Outages)

-Install unit 1and unit 2 pumps and piping

-Test unit 2 pump Spring 2010 Outage

-Complete unit 1 install

- Retrain unit 1 TDAFW pump 14

NUREG-OBOO Standard Review Plan Comparison of Proposed System Changes

- Evaluated for consistency with functional attributes

  • Proposed system consists of one 100% (275 gpm) existing steam driven pump and one 100% (275 gpm) electrically (AC) driven pump
  • Comparison is focused on the new MDAFW pump trains
  • F=PLEnergy

~

15

NUREG-OBOO Comparison

1)

The failure of non-essential equipment or components does not affect essential functions of the system

2)

The system is capable of withstanding a single active failure

3)

The system has diverse motive power sources and can meet performance requirements with either of the assigned power sources Consistent

  • Failure of CST did require Operator Action this operation is proposed to be automated
  • Existing Heating Ventilation and Air Conditioning (HVAC) system is credited
  • Consistent
  • AFW system is proposed to be unitized and single active failure proof
  • Consistent
  • TDAFW pump with steam power and DC controls
  • F=PLEnergy

~

16

NUREG-OBOO Comparison

4)

The system design precludes fluid flow instabilities

-Consistent

-Address in system mechanical design

5)

System leakage can be detected, collected, and controlled and isolated

-Consistent

-Valves and indications will be provided to provide isolation in the event of excessive leakage or component malfunctions

6)

There are provisions for operational testing

-Consistent

-Full flow testing to the CST and SG available for MDAFW 17

  • I=PLEnergy

~.

NUREG-OBOO Comparison

7)

Instrumentation and control features are provided to verify that the system is operating in an acceptable mode

-Consistent

-Pump Suction Pressure RG 1.97 type 0, 2

-Pump Discharge Pressure RG 1.97 type 0, 3

-Pump Flow RG 1.97 type 0, 2

-AFW Flow to each SG RG 1.97 type A, 2

-CST Level RG 1.97 type A, 1

-Consistent

-Currently, Operator action is required to balance MDAFW flow between units

-This is eliminated with proposed system

8)

The system can automatically initiate auxiliary feedwater flow upon a system actuation signal

9)

The system satisfies the recommendations of Regulatory Guide (RG) 1.62 for capability to manually initiate protective action by the AFWS

-Consistent

-AFW trains and SSG trains can be manually initiated

  • F=PLEnergy

~

18

NUREG-OBOO Comparison

10)

Designed to terminate auxiliary feedwater flow to a depressurized steam generator and to provide feedwater to the intact steam generator automatically.

Alternatively operator action may be relied upon to isolate the depressurized steam generator

-Consistent

-Operator action still required to isolate AFW to faulted SG; however, the addition of Flow Control Valves (FCVs) on MD train reduces flow to faulted SG and increases flow to non-faulted SG

-EPU analysis demonstrates acceptable containment response 11 )

The system possesses sufficient auxiliary feedwater flow capacity to achieve a cold shutdown and decay heat removal

-Consistent

-Either Safety Grade AFW train capacity of 275 gpm is sufficient. In addition SSG provide redundancy to MDAFW train after unit is stabilized.

12)

Technical specifications assure the continued reliability of the AFWS during plant operation

-Consistent

-Eliminate sharing of MDAFW pumps.

-New TS will follow STS as applicable

13)

The system design meets the generic short-and long-term recommendations identified in NUREG-0611

-Consistent

-Documented in 1981 NRC and Wisconsin Electric (WE) correspondence

-Resolution to GS-1 and GL-4 improved

  • F=PLEnergy

~

19

NUREG-OBOO Come.arison

14)

An AFWS reliability analysis is performed as required by Three Mile Island (TMI) Action Plan Item II.E.1.1 of NUREG-0737 and 10 CFR 50.34(f)(1 )(ii) for applicants subject to 10 CFR 50.34(f).

-Consistent

-AFW System Reliability Study Done

-Expected to be < 1E-4

15)

Design meets TMI Action Plan item II.E.1.2 of NUREG-0737 for the automatic and manual initiation of the AFWS and 10 CFR 50.62(c)(1) for automatic initiation of the AFWS in an anticipated transient without scram (ATWS).

-Consistent AFW trains are automatically initiated on

-Low-low water level in either steam generator

-Loss of both 4.16 kv buses supplying the main feedwater pump motors

-Safety Injection sequence

-ATWS Mitigation System Activation Signal (AMSAC). AMSAC signal is generated on a loss of normal feedwater at power levels above 40%, or

-AFW and SSG trains can also be manually initiated from control room or from local location outside the control room

  • F=PLEnergy

~

20

NUREG-OBOO Com arlson

16)

The system design permits operation at hot shutdown for at least four hours followed by cool down to the residual heat removal (RHR) cut-in temperature from the control room with only safety grade equipment, assuming the worst-case single active failure in accordance with Branch Technical Position (BTP) 5-4

  • Consistent
  • SW will auto transfer if necessary

.Proposed System will meet Current Licensing Basis (CLB)

17)

AFWS diversity and performance are reviewed for decay heat removal capability and station blackout capacity

  • Consistent
  • Diversity is provided by AC powered MDAFW train and TDAFW with DC powered controls.
18)

Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC).

Not Applicable

19)

COL Action Items and Certification Requirements and Restrictions Not Applicable

  • F=PLEnergy

~

21

NUREG-OBOO Comearison GEN

-"a typical system is assumed which has redundant auxiliary feedwater trains, with a 50-percent capacity motor-driven pump in each train feed ing directly to the steam generators, and a 1OO-percent capacity steam turbine-driven pump"

-"The 50-percent capacity pump should have sufficient capacity for decay heat removal following any accident or transient although cool down to RHR cut in temperature may take longer than design."

-Not typical

-One 100

% TDAFW pump

-One 100

% MDAFW pump

-Non-safety related SSG trains provide back-up for longer-term portion of cooldown (beyond design basis condition)

GEN

-SRP 10.4.9 Section III, 1, G: Design features have been incorporated to provide for automatic switch-over to the safety-related water supply without an interruption in water flow

-Consistent

-AFW trains auto-transfer (SSG trains are manually transferred)

-New system risk improvement feature

  • F=PLEnergy

~

22

Tech Spec Changes Proposed Changes Based on STS

  • New Technical Specification would consist of Two AFW trains per unit (one TDAFW pump and one MDAFW pump)
  • Current MDAFW pumps are shared and have a 7 day TSAC
  • TSAC for the new MDAFW pumps would be 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />
  • F=PLEnergy

~

23

New AFW System Summary

  • New AFW design benefit highlights Unitized 100% capacity pumps Separate CST suction Auto SW swap-over Pumps in separate fire areas Existing MDAFW pumps become SSG pumps Numerous Risk reductions
  • Implemented without TSAC extension Final conversion after EPU LAR approval
  • Technical Specification TSAC based on STS (72 Hrs)

Request Staff input/comments on approach

  • F=PLEnergy

~

24

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Point Beach Extended Power Uprate Introduction

  • Meeting Previously Held on September 8, 2008 to Discuss Proposed Point Beach EPU
  • Proposed Uprate:

17% Increase in Reactor Thermal Power (RTP) from 1540 to 1800 MWt Similar to 17% Uprate of Ginna to 1775 MWt in 2005 and 6%

Uprate of Kewaunee to 1772 MWt in 2004 (2-loop Westinghouse PWRs)

- Planned Implementation in Spring 2010 (U 1) and Spring 2011 (U 2) 26

  • F=PLEnergy

~

Point Beach Extended Power Uprate NRC Staff Recommendations

  • Review AFW System Upgrades with Staff Design requirements for EPU evaluated Design discussed in this meeting Tech Spec changes will be included in EPU LAR Design implementation required to support LAR
  • FPLEnergy

~

27

Point Beach Extended Power Uprate NRC Staff Recommendations (continued)

Setpoints in the EPU LAR Non-conservative Tech Specs RPS/ESFAS Setpoints will be revised in Tech Spec mark-ups for EPU LAR to provide calculational basis for each setpoint

- Setpoint calculation methodology is described with examples in EPU LAR Appendix

  • Provide Input Files for Small Break LOCA SBLOCA data files submitted on 10/17/08 and 12/5/08
  • F=PLEnergy

~

28

Point Beach Extended Power Uprate NRC Staff Recommendations (continued)

  • Submit Required Large Break LOCA Analysis under 10 CFR 50.46 Best Estimate Large Break LOCA ASTRUM (Automated Statistical Treatment of Uncertainties Method) LAR 258 Submitted 11/25/08 Draft RAls reviewed and clarified with Staff LBLOCA Analysis performed for EPU conditions and LAR 258 approval required for EPU LAR implementation Evaluate the Environmental Qualification (EQ) of Plant Equipment in EPU LAR (not AST)

EO will be addressed in EPU LAR

  • Provide Grid Stability Study by Grid Operator Grid Stability Study has been completed by ATC for MISO Summarized in EPU LAR Will be transmitted under separate cover
  • I=PLEnergy

~

29

Point Beach Extended Power Uprate NRC Staff Recommendations (continued)

  • Identify Modifications Planned to Reduce Core Damage Frequency (CDF)

EPU risk assessment discussed in EPU LAR AFW upgrades significantly reduce CDF

- Additional risk reduction modifications planned to reduce overall CDF and LERF (Large Early Release Frequency)

  • Additional back up air supply to Pressurizer Auxiliary Spray Valves
  • Air cooled back up air compressor
  • Review R8-001 and Tables 8-3 and 8-4 of 10 CFR 51 to ensure All Environmental Impacts are Analyzed EPU LAR contains Supplemental Environmental Report in Appendix 0 Above documents were reviewed and addressed
  • F=PLEnergy 30

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- 2 Due to the licensee's new proposed design of leaving the current pumps installed, most of the work for the new MDAFW trains can be done online and does not require an extension to the allowed outage time. In the licensee's proposed plan, the final tie-ins would be made during outages when AFW is not required by that unit.

In terms of fire protection, one of the NRC's concerns with the previous submittal, the licensee plans on locating these new pumps in separate rooms and in a different location than the current MDAFW pumps and turbine-driven AFW pumps.

At the end of the AFW presentation, the licensee requested feedback from the NRC staff.

Overall the NRC staff felt that this design approach was an improvement from the previous attempt. The proposed AFW system modifications have the potential to improve (1) the availability and reliability of the AFW system, (2) the overall risk profile of the site by improving the overall risk profile of the AFW system, and (3) improving the risk associated with fire concerns by installing the new pumps in a separate fire area. The NRC staff did point out for the electrical design of the pumps, to include in the submittal, discussion on the pump interlocks associated with diesel loading. Since the SSG pumps can still be run from the diesel generators, the staff was concerned with preventing accidental starting of SSG pumps while the new MDAFW pumps were operating. Some discussion was had over the TS that would be proposed for this new system. The licensee stated that they based their proposed change to follow the standard TS.

The second portion of the meeting was focused on the licensee's progress with a planned EPU amendment. The licensee discussed some NRC staff recommendations that were made at a previous public meeting on the EPU submittal and the status of where the licensee was with these recommendations. The NRC staff acknowledged the status of these items.

A member of the public was in attendance. Public Meeting Feedback forms were not received.

Please direct any inquiries to Justin Poole at 301-415-2048, or Justin.Poole@nrc.qov.

IRA!

Justin C. Poole, Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of l\\Iuclear Reactor Regulation Docket Nos. 50-266 and 50-301

Enclosures:

1. List of Attendees
2. Licensee's Handout cc w/encls: Distribution via ListServ DISTRIBUTION:

PUBLIC RidsAcrsAcnw_MailCTR Resource M. McConnell, NRR LPL3-1 R/F RidsNrrDorlLpl3-1 Resource A. Howe, NRR C. Tucci, NRR RidsNrrPMPointBeach Resource A. Russell, NRR S. Campbell, EDO Rill RidsNrrLATHarris Resource

1. Alexion, NRR H. Barrett, NRR RidsOgcRp Resource S. Marshall, RES W. Jessup, NRR RidsRgn3MailCenter Resource S. Gardocki, NRR ADAMS Accession Number' ML090410636 OFFICE LPL3-1/PM LPL3-1/LA LPL3-1/BC NAME JPoole THarris (BTully for)

LJames DATE 2/8/09 2/18/09 2/24/09 OFFICIAL RECORD COPY

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