ML102990074

License Amendment, Issuance of Amendments to Revised Technical Specifications to Resolve an Oversight Regarding the Operability Requirements for the Intermediate Range Neutron Flux Channels (TS-09-05)

ML102990074
Person / Time
Site:	Sequoyah
Issue date:	12/21/2010
From:	Siva Lingam Plant Licensing Branch II
To:	Krich R Tennessee Valley Authority
Lingam, S NRR/DORL 415-1564
References
TAC ME3262, TAC ME3263
Download: ML102990074 (16)

Text

\.~p.f\ REGU, _ UNITED STATES

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December 21, 2010

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• • • • i' Mr. Rodney M. Krich Vice President, Nuclear Licensing Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS TO REVISE TECHNICAL SPECIFICATIONS TO RESOLVE AN OVERSIGHT REGARDING THE OPERABILITY REQUIREMENTS FOR THE INTERMEDIATE RANGE NEUTRON FLUX CHANNELS (TS-09-05) (TAC NOS. ME3262 AND ME3263)

Dear Mr. Krich:

The Nuclear Regulatory Commission has issued the enclosed Amendment No. 328 to Facility Operating License No. DPR-77 and Amendment No. 321 to Facility Operating License No. DPR-79 for the Sequoyah Nuclear Plant, Units 1 and 2, respectively. These amendments are in response to your application dated January 26, 2010. The proposed Technical Specification (TS) change revises TS Table 3.3-1, "Reactor Trip System Instrumentation," Functional Unit 5, "Intermediate Range, Neutron Flux," to resolve an oversight regarding the operability requirements for the intermediate range neutron flux channels.

A copy of the safety evaluation is also enclosed. A notice of issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

~-cL ~.~

Siva P. Lingam, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-327 and 50-328

Enclosures:

1. Amendment No. 328 to DPR-77

2. Amendment No. 321 to DPR-79

3. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-327 SEQUOYAH NUCLEAR PLANT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 328 License No. DPR-77

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

A. The application for amendment by Tennessee Valley Authority (the licensee) dated January 26, 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 Title 10 of the Code of Federal Regulations, Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordarce with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

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2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Facility Operating License No. DPR-77 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment 1\10. 328 ,are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance, to be implemented no later than 60 days after issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Douglas A. Broaddus, Chief Plant Licensing Branch 11-2 Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License and Technical Specifications Date of Issuance: December 21, 2010

ATTACHMENT TO LICENSE AMENDMENT NO. 328 FACILITY OPERATING LICENSE NO. DPR-77 DOCKET NO. 50-327 Replace Page 3 of Operating License DPR-77 with the attached page 3.

Replace the following pages of the Appendix A Technical Specifications with the attached pages.

The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 3/43-2 3/4 3-2 3/4 3-8 3/4 3-8

\

TABLE 3.3-1 REACTOR TRIP SYSTEM INSTRUMENTATION TOTAL NO. MINIMUM OF CHANNELS CHANNELS APPLICABLE FUNCTIONAL UNIT CHANNELS TO TRIP OPERABLE MODES ACTION

1. Manual Reactor Trip 2 1 2 1,2, and

• 1

2. Power Range, Neutron 4 2 3 1,2 2 Flux

3. Power Range, Neutron 4 2 3 1,2 2 Flux High Positive Rate

4. Power Range, Neutron 4 2 3 1,2 2 Flux, High Negative Rate

5. Intermediate Range, 2 1 2 1,2, and

• 3,17 Neutron Flux

6. Source Range, Neutron Flux A. Startup 2 1 2 2##, and

• 4 B. Shutdown 2 0 1 3,4 and 5 5

7. Overtemperature dT Four 4 2 3 1,2 6 Loop Operation

8. Overpower dT Four Loop 4 2 3 1,2 6 Operation

9. Pressurizer Pressure-Low 4 2 3 1,2 6

10. Pressurizer Pressure- 4 2 3 1,2 *6 High

11. Pressurizer Water 3 2 2 1,2 6 Level-High SEQUOYAH - UNIT 1 3/4 3-2 Amendment Nos. 41,141,301, 328

TABLE 3.3-1 (Continued)

ACTION 11 With the number of OPERABLE channels one less than the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided that within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, for the affected protection set, the Steam Generator Water Level Low-Low (EAM) channels trip setpoint is adjusted to the same value as Steam Generator Water Level - Low-Low (Adverse).

ACTION 12 With the number of channels OPERABLE one less than required by the Minimum Channels OPERABLE requirement, be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; however, one channel may be bypassed for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing per Specification 4.3.1.1.1 provided the other channel is OPERABLE.

ACTION 13 Deleted ACTION 14 With the number of channels OPERABLE one less than required by the Minimum Channels OPERABLE requirement, be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

ACTION 15 With one of the diverse trip features (undervoltage or shunt trip attachment) inoperable, restore it to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or declare the breaker inoperable and apply ACTION 12. The breaker shall not be bypassed while one of the diverse trip features is inoperable except for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for performing maintenance to restore the breaker to OPERABLE status.

ACTION 16 With the number of OPERABLE channels one less than the minimum channels operable requirement, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or open the reactor trip breakers within the next hour.

ACTION 17 With the number of OPERABLE channels two less than the minimum channels OPERABLE requirement and with the THERMAL POWER level above 10% of RATED THERMAL POWER, the provisions of Specification 3.0.3 are not applicable SEaUOYAH - UNIT 1 3/4 3-8 Amendment No. 54, 141, 328 213

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-328 SEOUOYAH NUCLEAR PLANT, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 321 License No. DPR-79

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

A. The application for amendment by Tennessee Valley Authority (the licensee) dated January 26, 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 Title 10 of the Code of Federal Regulations (10 CFR)

Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

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2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Facility Operating License No. DPR-79 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 321 ,are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance, to be implemented no later than 60 days after issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Douglas A. Broaddus, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License and Technical Specifications Date of Issuance: December 21, 2010

ATTACHMENT TO LICENSE AMENDMENT NO. 321 FACILITY OPERATING LICENSE NO. DPR-79 DOCKET 1\10. 50-328 Replace Page 3 of Operating License DPR-79 with the attached page.

Replace the following pages of the Appendix A Technical Specifications with the attached pages.

The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 3/4 3-2 3/4 3-2 3/4 3-8 3/4 3-8

TABLE 3.3-1 REACTOR TRIP SYSTEM INSTRUMENTATION TOTAL NO. MINIMUM OF CHANNELS CHANNELS APPLICABLE FUNCTIONAL UNIT CHANNELS TO TRIP OPERABLE MODES ACTION

1. Manual Reactor Trip 2 1 2 1,2, and

• 1

2. Power Range, Neutron Flux 4 2 3 1,2 2

3. Power Range, Neutron Flux 4 2 3 1,2 2 High Positive Rate

4. Power Range, Neutron 4 2 3 1,2 2 Flux, High Negative Rate

5. Intermediate Range, 2 1 2 1,2, and

• 3, 17 Neutron Flux

6. Source Range, Neutron Flux 2 1 2 2##, and

• 4 A. Startup B. Shutdown 2 0 1 3,4 and 5 5

7. Overtemperature ~ T 4 2 3 1,2 6 Four Loop Operation

8. Overpower ~T 4 2 3 1,2 6 Four Loop Operation

9. Pressurizer Pressure-Low 4 2 3 1,2 6

10. Pressurizer Pressure-High 4 2 3 1,2 6

11. Pressurizer Water Level- 3 2 2 1,2 6 High SEQUOYAH - UNIT 2 3/4 3-2 Amendment No. 33, 132,290, 321

TABLE 3.3-1 (Continued)

ACTION 10 - With the number of OPERABLE channels one less than the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided that within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, for the affected protection set, the Trip Time Delays (T5 and T M) threshold power level for zero seconds time delay is adjusted to 0% RTP.

ACTION 11 - With the number of OPERABLE channels one less than the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided that within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, for the affected protection set, the Steam Generator Water Level

- Low-Low (EAM) channels trip setpoint is adjusted to the same value as Steam Generator Water Level - Low-Low (Adverse).

ACTION 12 - With the number of OPERABLE channels one less than required by the Minimum Channels OPERABLE requirement, be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; however, one channel may be bypassed for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing per Specification 4.3.1.1.1 provided the other channel is OPERABLE.

ACTION 13, - Deleted ACTION 14 - With the number of channels OPERABLE one less than required by the Minimum Channels OPERABLE requirement, be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

ACTION 15 - With one of the diverse trip features (undervoltage or shunt trip attachment) inoperable, restore it to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or declare the breaker inoperable and apply ACTION 12. The breaker shall not be bypassed while one of the diverse trip features is inoperable except for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for performing maintenance to restore the breaker to OPERABLE status.

ACTION 16 - With the number of OPERABLE channels one less than the minimum channels operable requirement, restore the inoperable channel to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or open the reactor trip breakers within the next hour.

ACTION 17 With the number of OPERABLE channels two less than the minimum channels OPERABLE requirement and with the THERMAL POWER level above 10% of RATED THERMAL POWER, the provisions of Specification 3.0.3 are not applicable.

SEQUOYAH - UNIT 2 3/4 3-8 Amendment No. 46, 132,203, 321

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 328 TO FACILITY OPERATING LICENSE NO. DPR-77 AND AMENDMENT NO. 321 TO FACILITY OPERATING LICENSE NO. DPR-79 TENNESSEE VALLEY AUTHORITY SEOUOYAH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328

1.0 INTRODUCTION

By letter dated January 26, 2010 (Agencywide Documents Access and Management System Accession No. ML100290024), Tennessee Valley Authority (TVA or the licensee) submitted a license amendment request for the Sequoyah Nuclear Plant (SON), Units 1 and 2, to revise the Technical Specification (TS) Table 3.3-1 to resolve an oversight regarding the operability requirements for the intermediate range neutron flux channels. TVA proposes to add an action to TS Table 3.3-1 to define that the provisions of Specification 3.0.3 are not applicable above 10 percent of thermal rated power with the number of operable intermediate range neutron flux channels two less than the minimum channels operable requirement. This proposed change applies to SON, Units 1 and 2, TS Table 3.3-1 "Reactor Trip System Instrumentation," Functional Unit 5, "Intermediate Range, Neutron Flux."

In the current version of the TS Table 3.3-1, it does not provide an action that addresses the declaration of two intermediate range neutron flux channels inoperable in Mode 1 with power above 10 percent of thermal rated power, (i.e., the P-1 0 setpoint). As a result, TS 3.0.3 would apply. TVA believes that this requirement is unnecessarily restrictive, because the intermediate range neutron flux channels do not provide a protection function above the P-10 setpoint. Above the P-1 0 setpoint, the power range neutron flux trip and the power range neutron flux high positive rate trip provide core protection for a rod withdrawal accident.

In order to resolve this issue, TVA proposed in the license amendment that the following action be added to TS Table 3.3-1 for SON, Units 1 and 2:

ACTION 17 - With the number of OPERABLE channels two less than the minimum channels OPERABLE requirement and with the THERMAL POWER level above 10% of RATED THERMAL POWER, the provisions of Specification 3.0.3 are not applicable.

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2.0 REGULATORY EVALUATION

Section 182a of the Atomic Energy Act (the "Act") requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The Commission's regulatory requirements related to the content of TSs are set forth in Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.36. In particular, 10 CFR 50.36(c)(3), "Surveillance requirements," states:

Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

In the "Regulatory Evaluation" section of the licensee's January 26, 2010, submittal, the licensee stated that "This proposed change does not change regulatory requirements. The proposed change is consistent with the intent of NUREG-1431, Revision 3, "Standard Technical Specifications [STS] Westinghouse Plants," which establishes that the mode of applicability for the intermediate range neutron flux function in Mode 1 is when the thermal power is below the P1 0 (Power Range Neutron Flux) interlocks as depicted in Table 3.3.1-1, Function 4, Applicable Modes."

3.0 TECHNICAL EVALUATION

In the "Technical Evaluation" section of the submittal, the licensee stated that the intermediate range neutron flux trip function provides protection against an uncontrolled rod cluster control assembly bank withdrawal accident from a subcritical condition during startup. This trip function provides redundant protection to the power range, neutron flux low setpoint trip function.

Section 7.2.1.1.2.1.b of the SON Updated Final Safety Analysis Report (UFSAR) states, "The intermediate range high neutron flux trip circuit trips the reactor when one out of the two intermediate range channels exceed the trip setpoint. This trip, which provides protection during reactor startup, can be manually blocked if two out of four power range channels are above approximately 10 percent power (P-1 0). Three out of the four power range channels below this value automatically reinstates the intermediate range high neutron flux trip. The intermediate range channels (including detectors) are separate from the power range channels. The intermediate range channels can be individually bypassed at the nuclear instrumentation racks to permit channel testing at any time under prescribed administrative procedures and only under the direction of authorized supervision. This bypass action is annunciated on the control board."

The licensee further stated that the intermediate range neutron flux trip must be operable in Mode 1 below the P-10 setpoint and in Mode 2 when there is a potential for an uncontrolled rod withdrawal accident during reactor startup. Above the P-1 0 setpoint, the power range neutron flux high setpoint trip and the power range neutron flux high positive rate trip provide core protection for a rod withdrawal accident. Since the power range detectors perform the monitoring and protection functions above the P-10 setpoint, the intermediate range is not required above the P-10 setpoint. Therefore, the provisions of TS 3.0.3 should not be for two inoperable intermediate range neutron flux channels above the P-1 0 setpoint.

-3 The Nuclear Regulatory Commission (NRC) staff reviewed the licensee's submittal and related documentation (e.g., TS, UFSAR, STS). The NRC staff noted the statement in Section 7.2.1.121.b of the SON UFSAR, Revision 20, 'The intermediate range high neutron flux trip circuit trips the reactor when one out of the two intermediate range channels exceed the trip setpoint. This trip, which provides protection during reactor startup, can be manually blocked if two out of four power range channels are above approximately 10 percent power (P-1 0)." The NRC staff also reviewed the proposed change versus the Table 3.3.1-1, "Reactor Trip System Instrumentation," Function 4, of the STS for the Westinghouse plants, and concluded that the proposed change is consistent with the intent of the NRC approved STS, which requires that the mode of applicability for the intermediate range neutron flux function in Mode 1 is when the thermal power is below the P-1 0 (Power Range Neutron Flux) interlocks. The NRC staff, therefore, concluded that with the number of operable channels, two less than the minimum channels operable requirement, and with the thermal power level above 10% of rated thermal power, the provisions of TS 3.0.3 are not applicable for the intermediate range neutron flux channels. The proposed change is in accordance with the UFSAR reactor trips and accident analysis, as discussed in Chapter 15 of the UFSAR.

The proposed license amendment request was evaluated by the NRC staff to determine whether applicable regulations and requirements continue to be met. The proposed change meets the intent of NUREG-1431, Revision 3. The intermediate range neutron flux function is applicable in Mode 1 for thermal power below 10 percent. For thermal power above 10 percent, the power range neutron flux trips provide core protection for rod withdrawal accident. Since the intermediate range neutron flux channels do not provide a protective function above the P-10 setpoint, the NRC staff finds this license amendment request acceptable. Further, applicable regulatory requirements will continue to be met, adequate defense-in-depth will be maintained, and sufficient safety margins will be maintained.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Tennessee State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (75 FR 13791, March 23, 2010). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

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

Principal Contributor: IVI. Razzaque Date: December 21, 2010

December 21, 2010 Mr. Rodney M. Krich Vice President, Nuclear Licensing Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 -ISSUANCE OF AMENDMENTS TO REVISE TECHNICAL SPECIFICATIONS TO RESOLVE AN OVERSIGHT REGARDING THE OPERABILITY REQUIREMENTS FOR THE INTERMEDIATE RANGE NEUTRON FLUX CHANNELS (TS-09-05) (TAC NOS. ME3262 AND ME3263)

Dear Mr. Krich:

The Nuclear Regulatory Commission has issued the enclosed Amendment No. 328 to Facility Operating License No. DPR-77 and Amendment No. 321 to Facility Operating License No. DPR-79 for the Sequoyah Nuclear Plant, Units 1 and 2, respectively. These amendments are in response to your application dated January 26, 2010. The proposed Technical Specification (TS) change revises TS Table 3.3-1, "Reactor Trip System Instrumentation," Functional Unit 5, "Intermediate Range, Neutron Flux," to resolve an oversight regarding the operability requirements for the intermediate range neutron flux channels.

A copy of the safety evaluation is also enclosed. A notice of issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, IRA!

Siva P. Lingam, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-327 and 50-328

Enclosures:

1. Amendment No. 328 to DPR-77

2. Amendment No. 321 to DPR-79

3. Safety Evaluation cc w/encls: Distribution via Listserv Distribution:

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DATE 10/28/10 10/29/10 10/7110 11/9/10 11/9/10 11/5/10 12/21/10 OFFICIAL RECORD COPY