ML102170335
| ML102170335 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 11/03/2010 |
| From: | Balwant Singal Plant Licensing Branch IV |
| To: | Matthew Sunseri Wolf Creek |
| Singal, Balwant, 415-3016, NRR/DORL/LPL4 | |
| References | |
| TAC ME3279 | |
| Download: ML102170335 (15) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 3, 2010 Mr. Matthew W. Sunseri President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation Post Office Box 411 Burlington, KS 66839
SUBJECT:
WOLF CREEK GENERATING STATION -ISSUANCE OF AMENDMENT RE:
REVISION TO TECHNICAL SPECIFICATION 3.6.3, "CONTAINMENT ISOLATION VALVES" (TAC NO. ME3279)
Dear Mr. Sunseri:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 190 to Renewed Facility Operating License No. NPF-42 for the Wolf Creek Generating Station. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated January 28, 2010.
The amendment revises TS 3.6.3, "Containment Isolation Valves," adding a note to Limiting Condition for Operation 3.6.3 to allow the reactor coolant pump seal injection valves to be considered OPERABLE with the valves open and power removed.
A copy of our related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.
Sincerely,
~~ \ U) &\ l~- ~1~ caJ-Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-482
Enclosures:
- 1. Amendment No. 190 to NPF-42
- 2. Safety Evaluation cc w/encls: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION DOCKET NO. 50-482 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 190 License No. NPF-42
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment to the Wolf Creek Generating Station (the facility)
Renewed Facility Operating License No. NPF-42 filed by the Wolf Creek Nuclear Operating Corporation (the Corporation), dated January 28, 2010, 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, as amended, 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 license 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.
Enclosure 1
-2
- 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 Renewed Facility Operating License No. NPF-42 is hereby amended to read as follows:
(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 190, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated in the license. The Corporation shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3. The license amendment is effective as of its date of issuance and shall be implemented within 90 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: November 3, 2010
ATTACHMENT TO LICENSE AMENDMENT NO. 190 RENEWED FACILITY OPERATING LICENSE NO. NPF-42 DOCKET NO. 50-482 Replace the following pages of the Renewed Facility Operating License No. NPF-42 and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
The corresponding overleaf pages are provided to maintain document completeness.
Renewed Facility Operating License REMOVE INSERT 4 4 Technical Specifications REMOVE INSERT 3.6-7 3.6-7
4 (5) The Operating Corporation, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) The Operating Corporation, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission, now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1) Maximum Power Level The Operating Corporation is authorized to operate the facility at reactor core power levels not in excess of 3565 megawatts thermal (100% power) in accordance with the conditions specified herein.
(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 190, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated in the license. The Corporation shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(3) Antitrust Conditions Kansas Gas & Electric Company and Kansas City Power & Light Company shall comply with the antitrust conditions delineated in Appendix C to this license.
(4) Environmental Qualification (Section 3.11! SSER #4, Section 3.11, SSER #5)*
Deleted per Amendment No. 141.
- The parenthetical notation following the title of many license conditions denotes the section of the supporting Safety Evaluation Report and/or its supplements wherein the license condition is discussed.
Renewed License No. NPF-42 Amendment No. 190
Containment Isolation Valves 3.6.3 3.6 CONTAINMENT SYSTEMS 3.6.3 Containment Isolation Valves LCO 3.6.3 Each containment isolation valve shall be OPERABLE.
NOTE-----------------------------------------------
All reactor coolant pump seal injection valves may be open with power removed.
APPLICABILITY: MODES 1, 2, 3, and 4.
ACTIONS
NOTES-----------------------------------------------------------
- 1. Penetration flow path(s) except for containment shutdown purge valve flow paths may be unisolated intermittently under administrative controls.
- 2. Separate Condition entry is allowed for each penetration flow path.
- 3. Enter applicable Conditions and Required Actions for systems made inoperable by containment isolation valves.
- 4. Enter applicable Conditions and Required Actions of LCO 3.6.1, "Containment," when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more penetration A.1 Isolate the affected 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for flow paths with one penetration flow path by Category 1 CIVs containment isolation valve use of at least one closed (CIV) inoperable except for and de-activated purge valve leakage not automatic valve, closed within limit. manual valve, blind 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for flange, or check valve with Category 2 CIVs flow through the valve secured. AND 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for Category 3 CIVs AND (continued)
Wolf Creek - Unit 1 3.6-7 Amendment No. 123, 131, 167, 190
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 190 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-42 WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION DOCKET NO. 50-482
1.0 INTRODUCTION
By application dated January 28, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML100350402), Wolf Creek Nuclear Operating Corporation (the licensee) requested a license amendment for Wolf Creek Generating Station (WCGS). The proposed amendment revises the limiting condition for operation (LCO) of WCGS's Technical Specification (TS) 3.6.3, "Containment Isolation Valves," by adding a note to LCO 3.6.3 to allow the reactor coolant pump (RCP) seal injection valves to be considered OPERABLE with the valves open and power removed.
2.0 REGULATORY EVALUATION
Section 182a of the Atomic Energy Act (Act) requires applicants for nuclear power plant operating licenses to include TSs as part of the license. These TSs are derived from the plant safety analyses. Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36, "Technical specifications," contains the requirements for the content of TS. Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls. Licensees may revise the TSs provided that a plant specific review supports a finding of continued adequate safety. The licensee has proposed to change LCO 3.6.3, "Containment Isolation Valves," to add a Note in this amendment request.
The regulations in 10 CFR Part 50, Appendix A, General Design Criterion (GDC) 55, "Reactor coolant pressure boundary penetrating containment," require, in part, that Each line that is part of the reactor coolant pressure boundary and that penetrates primary reactor containment shall be provided with containment isolation valves as follows, unless it can be demonstrated that the containment Enclosure 2
-2 isolation provisions for a specific class of lines, such as instrument lines, are acceptable on some other defined basis:
- 1. One locked closed isolation valve inside and one locked closed isolation valve outside containment; or
- 2. One automatic isolation valve inside and one locked closed isolation valve outside containment; or
- 3. One locked closed isolation valve inside and one automatic isolation valve outside containment. A simple check valve may be not be used as the automatic isolation valve outside containment; or
- 4. One automatic isolation valve inside and one automatic isolation valve outside containment. A simple check valve may not be used as the automatic isolation valve outside containment.
Isolation valves outside containment shall be located as close to containment as practical and upon loss of actuating power, automatic isolation valves shall be designed to take the position that provides greater safety.
NUREG-0800, Branch Technical Position (BTP) 8-4, "Application of the Single Failure Criterion to Manually Controlled Electrically Operated Valves," establishes the acceptability of disconnecting power to electrical components of a fluid system as one means of designing against a single failure that might cause an undesirable component action.
Paragraph B.2 of BTP 8-4 states, in part:
When it is determined that failure of an electrical system component can cause undesired mechanical motion of a valve or other fluid system component, and this motion results in loss of the system safety function, it is acceptable, in lieu of design changes that also may be acceptable, to disconnect power to the electric systems of the valve or other fluid system component.
Paragraph B.4 of the BTP 8-4 states:
When the single failure criterion is satisfied by removal of electrical power from valves described in items 2 and 3, above [items 2 and 3 of the BTP 8-4], these valves should have redundant position indication in the main control room, and the position indication system should, itself, meet the single failure criterion.
In its letter dated January 28, 2010, the licensee stated:
Generic Safety Issue (GSI) 23, "Reactor Coolant Pump Seal Failures," was identified in 1980 as a result of [U.S. Nuclear Regulatory Commission (NRC)]
staff concerns about RCP seal failures (seal degradation leading to a significant unisolable loss of reactor coolant) .... A potential cause of RCP seal failure is the
-3 loss of all seal cooling as a result of a station blackout, a loss of component cooling water, or a loss of service water. GSI-23 was closed in 1999 based on a number of considerations as discussed in Regulatory Issue Summary 2000-02, "Closure of Generic Safety Issue 23, Reactor Coolant Pump Seal Failure."
(Reference 6.5) [ADAMS Accession No. ML003680402].
The regulations in 10 CFR 50 Appendix R, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979, state in Paragraph I., "Introduction and Scope," that:
When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boiloff.
3.0 TECHNICAL EVALUATION
3.1 Background In its letter dated January 28, 2010, the licensee stated that:
In December 2008, the NRC completed a Triennial Fire Protection Inspection at WCGS as documented in the NRC inspection report [dated January 2, 2009]
(Reference 6.1) [ADAMS Accession No. ML090020490]. The inspection report documents an unresolved item concerning the availability of diagnostics instrumentation needed to respond to a loss of reactor coolant pump seal cooling during certain fire scenarios. [RCP seal injection and thermal barrier cooling are the two methods used to cool the RCP seals.] Procedure OFN KC-016, "Fire Response," requires operators to recognize when one or both seal cooling methods are lost and take specific mitigating actions. The NRC determined that neither procedure OFN KC-016 nor any other fire protection program document identified the instrumentation needed to identify a loss of seal cooling.
The reactor coolant pumps (RCPs) are designed with shaft seals that keep reactor coolant fluid from leaking out along the pump shaft onto the containment floor. The seals must be kept cool to prevent degradation and possible increased leakage. The two systems which are used to keep the seals cool;
- 1) the Component Cooling Water [CCW] System, cooling the RCP thermal barrier heat exchanger, and 2) the Chemical and Volume Control System (CVCS), injecting cool water directly onto the seals [through the seal injection lines]. By design, either one of the two systems are sufficient by itself to keep the RCP seals from degradation due to overheating.
The seal injection system provides cooling to the [RCP] seals to keep them at a 0
temperature of less than 150 F. A back-up cooling method is provided by the thermal barrier cooling heat exchanger that uses component cooling water as a cooling medium to cool any upward flow of reactor coolant before it nears the
-4 seals. The cooled reactor coolant provides cooling to the seals and stable leakoff flows in the case of a loss of seal injection.
As stated by the licensee in its letter dated January 28, 2010, it has been determined that a fire in multiple areas of the plant could result in electrical cable damage that could cause both spurious closure of one or more of the RCP seal injection valves, and the thermal barrier heat exchanger cooling also to be lost. It has also been determined that if the valves were left in the open position with the electrical power removed from the motor operators, a fire could not spuriously cause the valves to close. The licensee discussed maintaining the RCP seal injection valves open with power removed with the NRC inspectors during the Fire Protection Triennial Inspection and with the NRC staff in a public meeting on January 15, 2009. A summary of the meeting discussions, dated January 23, 2009, is located at ADAMS Accession No. ML090210206.
During the public meeting on January 15, 2009, between the NRC staff and the licensee, the NRC staff expressed interest as to what extent BTP 8-4 is applicable and how the proposed change conforms with or varies from the BTP. Also, the NRC staff inquired about whether the power would be removed by opening the supply load breaker or by removing the control room power fuses. In addition, the NRC requested clarification at to who performs this procedure and how long it takes to reinstall the power after the need is recognized. The licensee addressed these concerns in its submittal dated January 28, 2010.
3.2 Proposed Change TS 3.6.3, "Containment Isolation Valves," requires that each containment isolation valve be operable in Modes 1, 2, 3, and 4. The RCP seal injection valves are considered containment isolation valves and are listed in Table B 3.6.3-1 of the TS Bases. Based on the TS definition of "OPERABLE-OPERABILITY," removing electrical power to the RCP seal injection valves would make the valve inoperable.
The licensee proposes to add the follOWing note to LCO 3.6.3 of TS 3.6.3, "Containment Isolation Valves." to allow RCP seal injection valves to be considered operable with the valve open and power removed:
All reactor coolant pump seal injection valves may be open with power removed.
3.3 NRC Staff Evaluation The RCP seals prevent reactor coolant from leaking up the rotating shaft and spilling on the containment floor, resulting in a small break loss-of-coolant accident (LOCA). The seals require cooling to meet design conditions and to avoid failure. A fire in multiple areas of the plant could cause electrical cable damage that could cause spurious closure of one or more of the RCP seal injection valves. The same fire could cause thermal barrier heat exchanger cooling also to be lost. In its letter dated January 28, 2010, the licensee stated that:
The WCGS Probabilistic Safety Assessment (PSA) models the RCP seal injection valves only for a failure in the closed position. These valves are not
- 5 modeled as containment isolation valves and are postulated to remain open during any accident scenario.
The WCGS design of the seal injection penetration and isolation valves does not strictly meet the above criteria. However, the NRC staff accepted the WCGS design for this system in NUREG-0881, "Safety Evaluation Report related to the Operation of Wolf Creek Generating Station, Unit No.1," Section 6.2.3, "Containment Isolation System" (ADAMS Legacy Accession No. 8204220539), based on NUREG-0830, "Safety Evaluation Report related to the operation of Callaway Plant, Unit NO.1" (ADAMS Legacy Accession No. 8110280580), for Callaway Plant, Unit NO.1 (Callaway). The designs of WCGS and Callaway are mostly the same (NUREG0881 refers to NUREG-0830 for the evaluation). NUREG-0830, Section 6.2.3, states, in part:
The containment isolation system meets the explicit requirements of GDC 55 except in cases where remote-manual isolation valves are used instead of automatic isolation valves and in cases where automatic isolation valves fail "as-is" versus failing closed upon loss of power to the valve operators.
The cases where remote-manual isolation valves are used instead of automatic isolation valves include the reactor coolant pump seal water supply lines, the emergency core cooling system (ECCS) lines discharging to the reactor, and the residual heat removal system (RHRS) shutdown lines. The reactor coolant pump (RCP) seal water supply lines and the ECCS lines discharging to the reactor are classified as essential, and provisions have been made to detect possible leakage from these lines outside containment, thereby allowing remote-manual instead of automatic isolation valves.
As noted above, the NRC staff accepted the design of the portion of the WCGS containment isolation system that falls under the requirements of GDC 55, recognizing that there are some exceptions to the requirements.
In its letter dated January 28, 2010, the licensee stated:
The CVCS contains three charging pumps, one normal pump and two standby pumps. The standby pumps will automatically start and provide safety injection and seal injection following any accident signal. The CVCS, therefore, is able to continuously supply seal injection to all four RCPs under all plant conditions.
Seal water supply flow rate is controlled by manually throttled valves to a total of nominally 32 gpm [gallons per minute]. Due to the high-pressure inflow, an automatic signal to close the seal injection valves is not required.
The following four emergency operating procedures call for closure of the seal injection valves:
EMG ES-02, "Reactor Trip Response" EMG FR-11, "Response to High Pressurizer Level" EMG FR-12, "Response to Low Pressurizer Level" EMG FR-13, "Response to Voids in Reactor Vessel"
-6 In all cases, the reason for closing the seal injection valves is to restore RCP seal injection flow following a loss of all RCP seal cooling. With no flow to the RCP seals, the seals will heat up and if a charging pump is started with the seal injection valves open, the colder CVCS flow could thermal shock the RCP seals.
However, none of these procedures require closure of the seal injection valves in a specified time frame.
The NRC staff had previously reviewed the licensee's designation of essential fluid systems penetrating the containment [under NUREG-0881 (April 1982)], and has determined that the seal injection lines are considered essential following a LOCA and have no automatic isolation function. Therefore, the RCP seal injection valves require no automatic closure signals and require no closure time by design. It is the staff's determination that operation with the power removed to the seal injection valves is acceptable since automatic closure of the valves is not required for containment isolation. Furthermore, plant operators can energize the breakers remotely and remote-manually close the valves from the control room when required by plant procedures.
In its letter dated January 28, 2010, the licensee further stated that:
NUREG 0800, Branch Technical Position (BTP) 8-4, "Application of the Single Failure Criterion to Manually Controlled Electrically Operated Valves,"
establishes the acceptability of disconnecting power to electrical components of a fluid system as one means of designing against a single failure that might cause an undesirable component action. Paragraph B.2 of that document states, in part: "When it is determined that failure of an electrical system component can cause undesired mechanical motion of a valve or other fluid system component, and this motion results in loss of the system safety function, it is acceptable, in lieu of design changes that also may be acceptable, to disconnect power to the electric systems of the valve or other fluid system component." The proposed change is consistent with this statement.
In this case, the single failure that might cause an undesirable component action was identified to be spurious closure of the RCP seal injection valves due to fire damage on control cables. If the valves were left in the open position with the electrical power removed from the motor operators, a fire could not spuriously cause the valves to close, which would minimize the risk of RCP seal damage due to fire.
In its letter dated January 28, 2010, the licensee stated that:
Paragraph B.4 of BTP 8-4 states, "When the single failure criterion is satisfied by removal of electrical power from valves described in items 2 and 3, above [items 2 and 3 of the BTP-4], these valves should have redundant position indication in the main control room, and the position indication system should, itself, meet the single failure criterion." Opening the breakers for the seal injection valves will remove power to the position indication circuits, so the valves will not have any
-7 direct position indication in the control room. However, each seal injection line has a flow indicator in the control room associated with the line which provides clear indication of the status of the valve position. A low flow alarm is provided that will alert the operator in the control room if flow is lost, indicating that the valve is closed rather than open. In addition, a single flow indicator in the control room provides indication of total seal injection flow. A reduction of flow by 25%
will indicate that one of the seal injection valves is closed rather than open. This arrangement provides an acceptable alternative to the requirement of having redundant position indication in the main control room.
Based on the discussion above, the NRC staff reviewed the licensee's designation of essential fluid systems penetrating the containment under NUREG-0881 (April 1982) and determined that the RCP seal injection lines at WCGS are considered essential following a LOCA requiring no automatic isolation function. However, in the existing design, the RCP seal injection valves are considered operable only with power available. The licensee identified a condition at WCGS that could cause spurious closure of one or more of the RCP seal injection valves due to cable damage caused by fire in multiple areas. However, as proposed by the licensee, if the valves are left in open position, with the power removed, the RCP seal injection valves could not spuriously close due to the postulated fire. This eliminates the risk of RCP seal damage due to a fire.
As stated earlier, opening the breakers for the seal injection valves will remove power to the position indication circuits, resulting in loss of position indication in the control room. However, each seal injection line has a flow indicator in the control room associated with the line, which provides indication of the status of the valve position. A low-flow alarm will also alert the operator about the status of the valve in the control room. This satisfies the requirements of NUREG-0800 BTP 8-4. Therefore, the NRC staff concludes that the proposed change meets the requirements of 10 CFR 50.36, 10 CFR 50, Appendix A, GDC 55, and NUREG-0800, BTP 8-4 and is acceptable.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Kansas State official was notified of the proposed issuance of the amendment. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on March 23,2010 (75 FR 13792). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
-8 Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
The 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 amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: Brian E. Lee, SCVBIDSS/NRR Date: November 3, 2010
ML102170335 *e-mail concurrence OFFICE NRR/LPL4/PM NRR/LPL4/LA DIRS/ITSB/BC DSS/SCVB/BC OGC NRR/LPL4/BC NRRlLPLR/PM LSubin (NLO, NAME BSingal JBurkhardt RElliott RDennig* w/comments) MMarkley BSingal DATE 10/25/10 9/13/10 9/15/10 10/20/10 9/20/10 11/3/10 11/3/10