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MONTHYEARLIC-09-0088, Request for Use of an Alternate Depth Sizing Qualification2009-10-30030 October 2009 Request for Use of an Alternate Depth Sizing Qualification Project stage: Request ML0932402572009-11-20020 November 2009 Email to Licensee, Change to Normal Review Schedule for Request to Use of an Alternate Depth Sizing Qualification Relief Request Project stage: Other ML0932402402009-11-20020 November 2009 Acceptance Review Email, Request for Use of Alternate to Depth Sizing Qualification for Volumetric Examinations of Reactor Pressure Vessel Welds Project stage: Acceptance Review LIC-09-0071, Request for Exemption from Physical Security Requirements2009-12-31031 December 2009 Request for Exemption from Physical Security Requirements Project stage: Request ML1001508452010-01-15015 January 2010 RAI, Regarding Use of Alternate Depth Sizing Qualification for Volumetric Examinations of Reactor Pressure Vessel Welds Project stage: RAI LIC-10-0004, Response to Request for Additional Information Re Use of Alternate Depth Sizing Qualification2010-02-16016 February 2010 Response to Request for Additional Information Re Use of Alternate Depth Sizing Qualification Project stage: Response to RAI ML1004707252010-02-16016 February 2010 Acceptance Review Email, Request for Exemption from 10 CFR Part 73 Physical Security Requirements Project stage: Acceptance Review ML1003602182010-03-0202 March 2010 Environmental Assessment and Finding of No Significant Impact, Related to 10 CFR Part 73 Exemption Request Project stage: Other ML1003601772010-03-0202 March 2010 Cover Letter, Environmental Assessment and Finding of No Significant Impact, Related to 10 CFR Part 73 Exemption Request Project stage: Other ML1006304472010-03-23023 March 2010 Exemption from 10 CFR Part 73 Physical Security Requirements Project stage: Approval ML1006304512010-03-23023 March 2010 FRN: General Notice. Fort Calhoun Station, Unit 1 - Exemption from 10 CFR Part 73 Physical Security Requirements Project stage: Approval NRC-2010-0087, FRN: General Notice. Fort Calhoun Station, Unit 1 - Exemption from 10 CFR Part 73 Physical Security Requirements2010-03-23023 March 2010 FRN: General Notice. Fort Calhoun Station, Unit 1 - Exemption from 10 CFR Part 73 Physical Security Requirements Project stage: Approval ML1022101332010-08-20020 August 2010 Request for Use of Alternative to Depth-Sizing Qualification for Volumetric Examinations of Reactor Pressure Vessel Welds for 4th 10-year Inservice Inspection Interval Project stage: Other LIC-11-0107, Closure to NRC TAC Issues2011-10-26026 October 2011 Closure to NRC TAC Issues Project stage: Other 2010-02-16
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Category:Letter type:LIC
MONTHYEARLIC-24-0007, License Amendment Request (LAR) to Revise License Termination Plan (LTP)2024-06-18018 June 2024 License Amendment Request (LAR) to Revise License Termination Plan (LTP) LIC-24-0008, Proposed Revision to the Omaha Public Power District (OPPD) Fort Calhoun Station (FCS) Decommissioning Quality Assurance Plan (Dqap), Unit No. 1 and ISFSI2024-05-16016 May 2024 Proposed Revision to the Omaha Public Power District (OPPD) Fort Calhoun Station (FCS) Decommissioning Quality Assurance Plan (Dqap), Unit No. 1 and ISFSI LIC-24-0003, Independent Spent Fuel Storage Installation - Radiological Effluent Release Report and Radiological Environmental Operating Report2024-04-25025 April 2024 Independent Spent Fuel Storage Installation - Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-24-0006, (Fcs), Unit 1, Independent Spent Fuel Storage Installation, Phase 1 Final Status Survey Report to Support Approved License Termination Plan2024-04-17017 April 2024 (Fcs), Unit 1, Independent Spent Fuel Storage Installation, Phase 1 Final Status Survey Report to Support Approved License Termination Plan LIC-24-0005, Annual Decommissioning Funding / Irradiated Fuel Management Status Report2024-03-0101 March 2024 Annual Decommissioning Funding / Irradiated Fuel Management Status Report LIC-24-0002, Independent Spent Fuel Storage Installation - Submittal of Annual Radioactive Effluent Release Report2024-02-27027 February 2024 Independent Spent Fuel Storage Installation - Submittal of Annual Radioactive Effluent Release Report LIC-23-0007, Response to Fort Calhoun, Unit 1 & Independent Spent Fuel Storage Installation Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements – Request for Additional Information2023-12-0606 December 2023 Response to Fort Calhoun, Unit 1 & Independent Spent Fuel Storage Installation Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements – Request for Additional Information LIC-23-0005, Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - 2nd Request for Additional Information (EPID L-2021-LIT-0000) June 2, 20232023-08-24024 August 2023 Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - 2nd Request for Additional Information (EPID L-2021-LIT-0000) June 2, 2023 LIC-23-0004, (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report2023-04-20020 April 2023 (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-23-0003, Annual Decommissioning Funding / Irradiated Fuel Management Status Report2023-03-15015 March 2023 Annual Decommissioning Funding / Irradiated Fuel Management Status Report LIC-23-0001, Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - Request for Additional Information2023-02-27027 February 2023 Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - Request for Additional Information LIC-23-0002, Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report2023-02-20020 February 2023 Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report LIC-22-0010, Response to Fort Calhoun Station, Unit No. 1 - Review of License Termination Plan Requirements - Request for Additional Information2022-06-15015 June 2022 Response to Fort Calhoun Station, Unit No. 1 - Review of License Termination Plan Requirements - Request for Additional Information LIC-22-0005, (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report2022-04-20020 April 2022 (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-22-0009, Annual Decommissioning Funding / Irradiated Fuel Management Status Report2022-03-30030 March 2022 Annual Decommissioning Funding / Irradiated Fuel Management Status Report LIC-22-0006, Reactor Head Disposition Project Overview2022-03-17017 March 2022 Reactor Head Disposition Project Overview LIC-22-0004, Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report2022-02-17017 February 2022 Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report LIC-21-0008, Organizational and Management Change2021-10-28028 October 2021 Organizational and Management Change LIC-21-0007, ISFSI Only Emergency Plan Update2021-09-0808 September 2021 ISFSI Only Emergency Plan Update LIC-21-0004, Radiological Effluent Release Report and Radiological Environmental Operating Report2021-04-29029 April 2021 Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-21-0003, Independent Spent Fuel Storage Installation - 2021 Annual Decommissioning Funding / Irradiated Fuel Management Status Report2021-03-30030 March 2021 Independent Spent Fuel Storage Installation - 2021 Annual Decommissioning Funding / Irradiated Fuel Management Status Report LIC-21-0002, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2021-02-22022 February 2021 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report LIC-20-0015, Correction to Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report 2019 (ML20121A092)2020-07-29029 July 2020 Correction to Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report 2019 (ML20121A092) LIC-20-0014, Submittal of Revision 8 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP)2020-07-15015 July 2020 Submittal of Revision 8 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP) LIC-20-0012, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration and Certification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool2020-05-18018 May 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration and Certification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool LIC-20-0011, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2020-05-0707 May 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-20-0009, (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report2020-04-30030 April 2020 (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-20-0008, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2020-04-13013 April 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-20-0006, (Fcs), Unit 1, Request for Exemption from 10 CFR 20, Appendix G, Section Iii.E2020-03-26026 March 2020 (Fcs), Unit 1, Request for Exemption from 10 CFR 20, Appendix G, Section Iii.E LIC-20-0004, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2020-03-10010 March 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-20-0003, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2020-02-27027 February 2020 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report LIC-20-0002, Independent Spent Fuel Storage Installation - Submittal of Revision 7 to Physical Security Plan2020-02-27027 February 2020 Independent Spent Fuel Storage Installation - Submittal of Revision 7 to Physical Security Plan LIC-20-0001, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2020-02-0606 February 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-19-0025, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2019-12-19019 December 2019 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-19-0007, Post-Shutdown Decommissioning Activities Report2019-12-16016 December 2019 Post-Shutdown Decommissioning Activities Report LIC-19-0021, Independent Spent Fuel Storage Installation - Response to Request for Additional Information License Amendment for ISFSI-only EP and EAL Scheme2019-11-20020 November 2019 Independent Spent Fuel Storage Installation - Response to Request for Additional Information License Amendment for ISFSI-only EP and EAL Scheme LIC-19-0022, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2019-11-18018 November 2019 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-19-0018, Submittal of Revision 6 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP)2019-11-14014 November 2019 Submittal of Revision 6 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP) LIC-19-0020, Independent Spent Fuel Storage Installation - Updated Information Submittal and Revision 1 of the Blast Analysis2019-10-17017 October 2019 Independent Spent Fuel Storage Installation - Updated Information Submittal and Revision 1 of the Blast Analysis LIC-19-0017, Clarification to Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 20042019-08-0808 August 2019 Clarification to Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 2004 An LIC-19-0010, License Amendment Request (LAR) 19-03; Revised Fort Calhoun Station License in Support of the Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associa2019-05-20020 May 2019 License Amendment Request (LAR) 19-03; Revised Fort Calhoun Station License in Support of the Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated LIC-19-0008, Submittal of 2018 Annual Report2019-04-0404 April 2019 Submittal of 2018 Annual Report LIC-19-0004, Independent Spent Fuel Storage Installation - Submittal of Revision 4 to Physical Security Plan (PSP)2019-03-28028 March 2019 Independent Spent Fuel Storage Installation - Submittal of Revision 4 to Physical Security Plan (PSP) LIC-19-0005, 2019 Annual Decommissioning Funding I Irradiated Fuel Management Status Report2019-03-28028 March 2019 2019 Annual Decommissioning Funding I Irradiated Fuel Management Status Report LIC-19-0001, License Amendment Request (LAR) 19-01: Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan and Emergency Action Level Scheme2019-02-28028 February 2019 License Amendment Request (LAR) 19-01: Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan and Emergency Action Level Scheme LIC-19-0003, Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 2004 and Relaxation R2019-02-28028 February 2019 Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 2004 and Relaxation Requ LIC-19-0002, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2019-01-0303 January 2019 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report LIC-18-0031, Independent Spent Fuel Storage Installation - Transmittal of Emergency Plan Update2018-12-17017 December 2018 Independent Spent Fuel Storage Installation - Transmittal of Emergency Plan Update LIC-18-0030, Request for Partial Site Release Phase 22018-11-12012 November 2018 Request for Partial Site Release Phase 2 LIC-18-0028, Letter of Intent to Submit Request for Additional Partial Site Release2018-10-18018 October 2018 Letter of Intent to Submit Request for Additional Partial Site Release 2024-06-18
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UPPU 0mI", Pub/It: POWIf' O/slrlct 444 South J6h Street Mall Omaha, NE 68102-2247 October 30, 2009 LlC-09-0088 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555
Reference:
Docket No. 50-285
SUBJECT:
Request for Use of an Alternate Depth Sizing Qualification Pursuant to 10 CFR 50.55a(g)(5)(iii), the Omaha Public Power District (OPPD) requests approval for use of an alternate depth sizing qualification on the Fort Calhoun Station (FCS), Unit No.1 reactor pressure vessel (RPV) nozzle-to-safe end dissimilar metal (DM) welds from the inside surface.
OPPD will perform volumetric examinations on RPV nozzle-to-safe end DM welds from the inside surface utilizing the ultrasonic (UT) examination technique for a Materials Reliability Program (MRP-139) inspection during the refueling outage beginning November 1, 2009. These examinations are scheduled to be performed again for a 10-year reactor vessel inservice inspection at the end of the current interval in 2013. OPPD requests approval to implement the NRC approved alternative requirements of Code Case N-695 as described in Attachment 1. The NRC has approved similar alternatives.
Code Case N-695 requires that examination procedures and personnel demonstrate a flaw depth sizing error of less than 0.125-inch root mean square (RMS). OPPD proposes the use of an alternative RMS depth sizing error that is greater than the 0.125-inch RMS error value stated in Code Case N-695. Approval for use of this alternative criterion will be needed if flaws are detected.
American Society of Mechanical Engineers (ASME), Code Section XI (Appendix VIII),
Code Case N-695, requires that the maximum error for flaw depth measurements, when compared to the true flaw depth, must not exceed 0.125-inch RMS error. The nuclear power industry has attempted to qualify personnel and procedures for examinations performed from the inside surface of DM welds (Supplement 10, Code Case N-69~)
since November 2002. The most recent attempt at achieving the 0.125-inch RMS was in early 2008. This attempt, as well as all previous attempts, did not achieve the required RMS values for personnel or procedures.
Employment with Equal Opportunity
U. S. Nuclear Regulatory Commission LlC-09-0088 Page 2 The difficulties are associated with the surface roughness of the field welds. At this time, achieving a O.125-inch maximum RMS error is impractical. The vendor that OPPD has chosen achieved a O.189-inch RMS in their Supplement 10 (Code Case N-695) performance demonstration.
If you have any questions regarding this submittal, please contact Mr. Bill Hansher at (402) 533-6894.
emens n Manager
~uclear Engineering RPC/BLlmle
Attachment:
Relief Request in Accordance with 10 CFR 50.55a(g)(5)(iii) c: E. E. Collins, NRC Regional Administrator, Region IV L. E. Wilkins, NRC Project Manager J. C. Kirkland, NRC Senior Resident Inspector
LlC-09-0088 Attachment Page 1 RELIEF REQUEST IN ACCORDANCE WITH 10 CFR SO.SSa(g)(S)(iii)
ALTERNATIVE TO THE DEPTH SIZING QUALIFICATION REQUIREMENT OF ASME SECTION XI, SUPPLEMENT 10 FOR PIPING EXAMINATIONS PERFORMED FROM THE INSIDE SURFACE FOR FORT CALHOUN STATION, UNIT NO.1
LlC-09-0088 Attachment Page 2
1.0 ASME Code Components Affected
Code class: 1 System: RC Examination Categories: B-F, Inservice Inspection Program TABLE 1 WELD NUMBERS BY lSI DESIGNATION Nozzle-to-Safe End Weld Item Location Weld Type 1 N1A Outlet Nozzle (0°) MRC-1/01 Shop 2 N2A Inlet Nozzle (60°) MRC-1/18 Shop 3 N2B Inlet Nozzle (120°) MRC-1/30 Shop 4 N1B Outlet Nozzle (180°) MRC-2/01 Shop 5 N2C Inlet Nozzle (240°) MRC-2/18 Shop 6 N2D Inlet Nozzle (300°) MRC-2/30 Shop
2.0 Applicable Code Edition and Addenda
Fort Calhoun Station (FCS) is currently in the fourth 10-year Inservice Inspection (lSI) interval ending in 2013. The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) of record for the current 10-year lSI interval isSection XI, 1998 Edition, including Addenda through 2000 (Reference 1).
3.0 Applicable Code Requirement
The examination of Class 1 piping welds are required to be performed using procedures, personnel and equipment qualified to the criteria of the applicable ASME Code,Section XI, Appendix VIII, Supplements. The applicable supplement to this relief is 10, "QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS."
Paragraph 3.2, "Sizing Acceptance Criteria," Subparagraph (b) of Supplement 10, states that the "examination procedures, equipment, and personnel are qualified for depth-sizing when the RMS [rootmean square] error of the flaw depth measurements, as compared to the true flaw depths, is less than or equal to 0.125-inch (3.2mm)."
L1C-09-0088 Attachment Page 3 Code Case N-695, "Qualification Requirements for Dissimilar Metal Piping Welds,Section XI, Division 1," provides alternative requirements to Appendix VIII, Supplement 10. Paragraph 3.3(c) of Code Case N-695 states, "Examination procedures, equipment, and personnel are qualified for depth-sizing when the RMS error of the flaw depth measurements, as compared to the true flaw depths, do not exceed 0.125-in. (3 mm)." Code Case N-695 is unconditionally approved for use through Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1," Revision 15.
1.0 Impracticality of Compliance OPPD will perform volumetric examinations of the FCS reactor pressure vessel (RPV) nozzle-to-safe end dissimilar metal (DM) welds from the inside surface for a Materials Reliability Program (MRP-139) inspection during the Fall 2009 refueling outage beginning November 1, 2009. These examinations are scheduled to be performed again for a 10-year reactor vessel inservice inspection at the end of the current interval. OPPD will implement the NRC approved alternative requirements of Code Case N-695 for the qualification of procedures and personnel for examinations performed during these inspections.
This reHef is submitted due to the impracticality of meeting the required 0.125- inch RMS value required by Code Case N-695. Code Case N-695 requires that qualified procedures and personnel shall demonstrate a flaw depth sizing error less than or equal to 0.125-inch. RMS.
The nuclear power industry has attempted to qualify personnel and procedures for depth sizing examinations performed from the inside surface of dissimilar metal welds (Supplement 10, Code Case N-695) since November 2002. To date, no personnel or procedure has achieved less than or equal to the ASME Code required 0.125-inch RMS error (Reference 2).
The inability of examination procedures to achieve the required RMS value is primarily due to a combination offactorssuch as surface condition, scan access, base materials and the dendritic structure in the welds themselves. The combination of these factors has proven too difficult for procedures and personnel to achieve an RMS value that meet current Code requirements or Code Case N-695.
2.0 Burden Caused by Compliance The most recent attempt at achieving 0.125-inch RMS was in early 2008. This attempt, as well as previous attempts, did not achieve the required RMS values for personnel or procedures.
The qualification attempts have been substantial. The attempts have involved multiple vendors, ultrasonic instruments, personnel and flaw depth sizing methodologies, all of which have been incapable of achieving the 0.125-inch RMS value.
The process of qualification for this type of flaw sizing is well established. The cost and effort involved to perform a successful demonstration is quantifiable when a capable technique is available. However, when a capable technique is not available, the costs and effort required for a successful demonstration cannot be easily quantified.
LI C-09-0088 Attachment Page 4 3.0 Proposed Alternative And Basis for Use Fort Calhoun proposes using an alternative depth-sizing RMS error value greater than the 0.125-inch RMS error value stated in Code Case N-695 for the examination of welds listed in Table 1 of this relief request. Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested to use an alternative that will provide an acceptable level of quality and safety.
As an alternative to the required RMS error stated in Code Case N-695 for procedure and personnel depth sizing, Fort Calhoun will add the difference between the required RMS value of 0.125-inch and the actual RMS value achieved by our inspection vendor to the flaw depth as determined during flaw sizing. The inspection vendor chosen has achieved an RMS of 0.189" for Supplement 10 welds.
Applying the difference between the required RMS error and the achieved RMS error to the actual flaw size, will ensure a conservative flaw bounding approach and provide an acceptable level of quality and safety.
4.0 Duration of Proposed Alternative The alternative requirements of this request will be applied for the duration of the Fourth 10-year lSI interval.
5.0 Precedents Similar relief requests have been granted to the following plants:
- 1. Seabrook Station, "Seabrook Station Unit No.1 Relief Request For Use Of An Alternate Flaw Sizing Methodology for the Second Inservice Inspection Interval (TAC No. MD9785)," dated May 19, 2009 (ML090850504)
- 2. Exelon Generating Company, LLC, "Braidwood Station, Units 1 and 2 - Relief Request (12R-49) Regarding Inservice Inspection Program Alternative Method (TAC Nos. MD5996 and MD5997)," dated November 8,2007 (ML072760048)
- 3. Southern Nuclear Operating Company Inc., "Joseph M. Farley Nuclear Plant Unit 1, and Vogtle Electric Generating Plant, Units 1 and 2 - Evaluation of Relief Request ISI-GEN-ALT-06-02," (TAC Nos. MD 2482, MD2483 and MD2484), dated September 29, 2006 (ML062770359) 6.0 References
- 1. ASME Code,Section XI, 1998 Edition, including Addenda through 2000
- 2. Letter from EPRI (C. Latiolais) to OPPD (B. Lisowyj) , "Summary of WESDYNElnternational, LLC Supplements 2 & 10 Depth Sizing Results Obtained from the Inside Surface," dated October 27, 2009