ML110030328

Corrections for Commitment Audit Report

ML110030328
Person / Time
Site:	Sequoyah
Issue date:	01/19/2011
From:	Siva Lingam Plant Licensing Branch II
To:	Krich R Tennessee Valley Authority
Lingam, S NRR/DORL 415-1564
References
TAc ME5170
Download: ML110030328 (15)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 19, 2011 Mr. R. M. Krich Vice President, Nuclear Licensing Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 SUB~IECT: SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 - CORRECTIONS FOR COMMITMENT AUDIT REPORT (TAC NOS. ME5170 AND ME5171)

Dear Mr. Krich:

On December 30, 2010, the Nuclear Regulatory Commission (NRC) issued a report on the audit of the management of regulatory commitments by Tennessee Valley Authority for the Sequoyah Nuclear Plant (SQN), Units 1 and 2. This report was in response to NRC staff's audit conducted on December 15-16, 2010, at SQN site. It was discovered that page 3 of the attachment was missing from this report. This was an administrative oversight on our part and does not affect the NRC staff's conclusions associated with this report.

Enclosed is the complete report including the above-mentioned missing page. We regret any inconvenience this may have caused.

Sincerely, s~ 'Yo ~"j~

Siva P. Lingam, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-327 and 50-328

Enclosure:

Corrected Audit Report cc w/encl: Distribution via Listserv

AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS SEOUOYAH NUCLEAR PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-327 AND 50-328

1.0 INTRODUCTION AND BACKGROUND

The Office of Nuclear Reactor Regulation (NRR) of the U.S. Nuclear Regulatory Commission (NRC) has published NRR Office Instruction L1C-105, "Managing Regulatory Commitments Made by Licensees to the NRC." L1C-105 provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made to the NRC staff by licensees for commercial nuclear reactors. The guidance is consistent with the industry guidance issued by the Nuclear Energy Institute (NEI) in NEI 99-04, "Guidance for Managing NRC Commitment Changes." The current revision to L1C-105 is publicly available electronically through the Agencywide Documents Access and Management System (ADAMS), at the Electronic Reading Room of the NRC web site (ADAMS Accession Number ML090640415).

According to L1C-105, which cites the definition from NEI-99-04, a "regulatory commitment" is an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC. L1C-105 further directs the NRR Project Manager to "audit the licensee's commitment management program by assessing the adequacy of the licensee's implementation of a sample of commitments made to the NRC in past licensing actions (amendments, reliefs, exemptions, etc.) and activities (bulletins, generic letters, etc.)."

The audit is to be performed every 3 years.

2.0 AUDIT PROCEDURE AND RESULTS An audit of Sequoyah Nuclear Plant's (SON's) commitment management program was performed at SON in Soddy Daisy, TN during the period December 15-16,2010. The audit reviewed commitments made since the previous NRC audit report dated November 7,2007 (ADAMS Accession Number ML072990038). The audit consisted of two major parts:

(1) verification of the licensee's implementation of NRC commitments that have been completed and (2) verification of the licensee's program for managing changes to NRC commitments.

2.1 Verification of Licensee's Implementation of NRC Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented commitments made to the NRC as part of past licensing actions/activities. For commitments not yet implemented, the NRC staff should determine whether they have been captured in an effective program for future implementation.

2.1.1 Audit Scope The audit addressed most of the commitments made during the review period. The audit focused on regulatory commitments (as defined above) made in writing to the NRC as a result of past licensing actions or licensing activities. Commitments made in Licensee Event Reports Enclosure

-2 or in response to Notices of Violation may be included in the audit but the review will be limited to verification of restoration of compliance, not the specific methods used.

The NRC staff audited commitments that involved orders, exemptions, responses to generic letters and bulletins, and licensee event reports. During the audit, the NRC staff reviewed documents generated by processes in effect during the scope of the audit, and other documents related to the commitments. The audit excluded the following types of commitments that are internal to licensee processes:

(1) Commitments made on the licensee's own initiative among internal organizational components.

(2) Commitments that pertain to milestones of licensing actions/activities (e.g., respond to an NRC request for additional information by a certain date). Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed.

(3) Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, technical specifications, and updated final safety analysis reports. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.

2.1.2 Audit Results Before the audit, the NRC staff searched ADAMS for the licensee's submittals during the last 3 years and selected most of the commitments for verification, however, all the commitments made since October 17, 2007, were reviewed during this audit. The licensee provided the documentation to support the NRC staff's audit in each of these commitments. The licensee's documentation included summary sheets providing the status of the commitment and appropriate backup documentation, as needed (e.g., plant procedures, examination records, and/or other plant documentation). The NRC staff found that the licensee's commitment tracking programs had captured the regulatory commitments that had been identified by the NRC staff prior to the audit.

Additionally, the NRC staff reviewed plant procedures that had been revised as a result of commitments made by the licensee to the NRC. The NRC staff found that the procedures had been revised in accordance with the commitments made to the NRC. The attached table summarizes the licensee's commitments that were audited by the NRC staff and the current status of the licensee's commitments.

2.2 Verification of Licensee's Program for Managing NRC Commitment Changes The primary focus of this part of the audit is to verify that the licensee has established administrative controls for modifying or deleting commitments made to the NRC. The NRC staff compared the licensee's process for controlling regulatory commitments to the guidelines in NEI 99-04, which the NRC has found to be an acceptable guide for licensees to follow for managing and changing commitments. The audit reviewed most of the commitment changes that included changes that were or will be reported to the NRC, and changes that were not or

-3 will not be reported to the NRC. The audit also verifies that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation. This ensures that licensee personnel are able to recognize that future proposed changes to the affected design features or operating practices require evaluation in accordance with the commitment change control process.

2.2.1 Audit Results The process used at SON for managing commitments is contained in Nuclear Power Group (NPG) document NPG-SPP-03.3, "NRC Commitment Management." Revision 1 of NPG-SPP 03.3 included the guidance prescribed in NEI 99-04; and it requires SON Nuclear Licensing to identify and track commitments using a process similar to that of NEI 99-04. Appendix C to NPG-SPP-03.3 provides an evaluation process to aid in the decision making process regarding scope changes to a commitment. This process is identical to the guidance provided as figure A 1 in NEI 99-04. Scope changes must be evaluated, and justified by the responsible organization within NPG. Form NPG-SPP-03.3-1 is then forwarded to SON Nuclear Licensing for appropriate notification and tracking.

Additionally, the NRC staff reviewed most of SaN's commitments for the period of October 17, 2007 to December 16, 2010. The NRC staff found that the basis/justification provided for the change to each commitment was acceptable; and that the changes were managed effectively, in accordance with plant procedures.

3.0 CONCLUSION

The NRC staff concludes, based on the above audit, that (1) SON has implemented commitments in a timely basis, or is tracking them for future implementation; and (2) SON has implemented an effective program to manage regulatory commitment changes.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Zachary Kitts, SON Site Licensing Engineer Principal Contributor: Siva P. Lingam

Attachment:

Summary of Audit Results

SUMMARY

OF RESULTS AND REGULATORY COMMITMENTS INCLUDED IN AUDIT AT SEQUOYAH NUCLEAR PLANT PERFORMED DURING DECEMBER 15 AND DECEMBER 16, 2010 Item Commitment Commitment Description of Commitment Status Method of Closure No. No. LetterlDate 1 NC010172296 SQN-TS-09-02 TVA will include in Steam Generator Tube closed Surveillance Instruction (SI) 2 9/29/09 Inspection Report (SGTIR) any flaws that SI-SXI-068-114.3, Appendix D, are identified during the inspection of the 1.0 I and 1.0 J reflected the clod legs. The SGTIR will report tUbes commitment requirements.

where slippage has occurred and will include any tube where the bottom of the WEXTEX expansion is greater than 2.88 inches below the top of the tubesheet (Commitment No.4).

2 NC010172473 SQN-TS-09-02 TVA will revise the Steam Generator closed SI 2-SI-SXI-068-114.3, Section 9/29/09 Program (SGP) to confirm that the bottom of 6.2 [9] reflected the the cold leg expansion transition for all commitment requirements.

tubes is below the top of tubesheet and that the bottom of the transition is no more than 2.88 inches from the top of tubesheet. The 2.88 inches accounts for an uncertainty of 0.12 inch. If the WEXTEX expansion is greater than 2.88 inches below the top of the tubesheet, then the examination will be extended into the tubesheet to ensure at least 7.5 inches (plus measurement uncertainty) of non-flawed tube is inspected (Commitment No.1)

-2 Item Commitment Commitment Description of Commitment Status Method of Closure No. . No. LetterlDate 3 NC010172631 SQN-TS-09-02 TVA will revise the SGP to inspect the +2/ closed In SI 2-SI-SXI-068-114.3, 9/29/09 10.5 inches of the cold leg tubesheets in 20 Section 6.1.C.3.c (3) was percent of the open tubes in each steam added, 6.1.D.3.a and 6.2 [8]

generator. If a crack-like indication is were revised, and 6.1.D.7.b discovered in this area of a steam generator and 6.1.D.7.c were added to the 100 percent of that steam generator's reflect the commitment cold leg tubesheets will be inspected. If the requirements.

expanded sample identifies a crack-like indication in the +2/-1 0.5-inches region then 100 percent of the tubesheets in each of the steam generators will be inspected (Commitment No.3).

4 NC010173263 SQN-TS-09-02 TVA will revise the SGP to require the closed In SI 2-SI-SXI-068-114.3, 9/29/09 following assumed leakage methodology: If Appendix F, items U and V cold leg indications are not detected (i.e., a were added, Appendix I data 20 percent sample is performed), then in the sheet was revised, to reflect faulted SG, TVA will assume a total of four the commitment requirements.

top of tubesheet indications exist in the non-examined tubes at the top-of-tubesheet region (i.e., 0.1 inch to 1 inch below WEXTEX Transition) at an assumed leakage of 0.05 gallons per minute (gpm) per tube plus the inservice Row 1 tubes that have had plugs removed will be assumed to leak at 0.00009 gpm. If cold leg indications are detected, then the hot leg W*

methodology will be applied to the cold leg (except 10 percent of the total cumulative quantity of indications in the cold leg region o to 10.5 inches below the top of tubesheet will be assumed in the cold leg region 10.5 to 12 inches and multiplied by 0.0045 gpm).

(Commitment No.2)

-3 Item Commitment Commitment Description of Commitment Status Method of Closure No. No. Letter/Date 5 NC0070007001 Inspection & Complete inspections of pressurizer butt closed Mitigation of the butt welds mitigation of welds at SON Unit 1 by end of Cycle 15 was accomplished per Design pressurizer outage. Perform leakage monitoring prior to Change Notice (DCN) No. D butt welds inspection/mitigation (Commitment Nos. 1 22063-A for SON-1. Leakage 02/27/07 and 2). monitoring was incorporated into Surveillance Instruction 0 SI-OPS-068-137.0.

6 NC0070007003 Inspection &

• Report the inspection results of any closed TVA references mitigation of unmitigated weld examinations S64070227800 and pressurizer within 60 days of unit restart. L4407013007 provided the butt welds

• Report any corrective or mitigative commitment responses.

02/27/07 actions taken within 60 days of unit restart.

• Report BMV inspection results within 60 days of unit restart.

(Commitment No.3) 7 NC0070009001 Enhancement Sequoyah and Watts Bar will revise the closed Revised Extended Station of the capability back-up generator procedure(s) to include Blackout procedure O-MA of the supplying one train of containment REM-000-001.0, and issued containment hydrogen igniters per unit, and train training letter STL-0739 to hydrogen personnel to the procedure revision, by close the commitment.

igniters December 31,2007.

03/06/07 8 NC0070011001 Attachment 3 Commitments for Mitigating Strategy closed All B.5.b items are complete.

NC0070011011 to letter dated Assessments for Phase 1, 2 and 3.

02/26/07 9 NC0070016001 Ultimate heat The proposed Bases paragraph, paragraph closed Revised Bases pages.

sink 4 in section titled, "ACTIONS" will be temperature removed following NRC approval and as increase part of TVA's TS implementation process.

TS 06-03 08/14/07

-4 Item Commitment I Commitment Description of Commitment Status Method of Closure No. No. LetterlDate 10 NC0070017001 SON-TS-06-03 TVA design configuration controls will closed The calculation MDO 000 067 8/14/07 ensure that the new minimum essential raw 2003 142 was revised and cooling water (ERCW) design flow to each issued as Revision 3, emergency diesel generator heat exchanger incorporating TEMA values is at least 400 gallons per minute (including and references. The 5 percent measurement uncertainties). The calculation includes ERCW supporting diesel calculation MDO 000 067 minimum flow at 522 gpm at 2003 142 will be revised to capture the 87F and is greater than 400 revised values and Tubular Exchanger gpm plus 5% flow Manufacturers Association (TEMA) measurement uncertainties.

references.

11 NC008000200 1 Probability of TVA will revise SON's steam generator closed Unit 2 Surveillance Instruction prior cycle program to incorporate the methodology for 2-SI-SXI-068-114.3 associated detection implementation of POPCD as described in with SG tubing lSI and (POPCD) TSC Enclosure 1 of this submittal. The program augmented inspections was 06-06 01/08/08 revision will be completed within 45 days revised adding source note following NRC approval of the SON Unit 2 C.28.

POPCD TS Change 06-06.

12 NC0080021003 GL 2008-01 Complete the detailed walkdowns of SON closed Completed piping surveys of 06/06/08 inaccessible piping sections of GL 2008-01 SI and RHR cold leg injection subject systems prior to startup after the piping inside containment up next refueling outage for each unit (Unit 1 to the seconadary check valve.

Cycle 16, Unit 2 Cycle 16). Also completed void volume calculation for suspect piping segments in the SI piping. All measurements reviewed for accuracy and potentially voided segments of a sizable volume.

-5 Item Commitment I Commitment Description of Commitment Status Method of Closure No. No. LetterlDate 13 NC0080021 004 GL 2008-01 Complete evaluations of GL 2008-01 closed Evaluated void potential 06/06/08 subject systems using results of the detailed volume using walkdown data walkdowns of inaccessible piping sections obtained and spreadsheet and submit supplemental responses to NRC calculations (PER 138112 and documenting completion of the walkdowns FE 42912).

and any impact upon the GL 2008-01 response as a result of completed evaluation within 90 days following startup from the listed refueling outages (Unit 1 Cycle 16, unit 2 Cycle 16).

14 NC0080021 005 GL 2008-01 Complete evaluations of GL 2008-01 closed Completed data reduction for 06/06/08 subject systems using results of the detailed Unit 1 piping surveys and walkdowns of inaccessible piping sections spreadsheet calculations (PER and submit supplemental responses to NRC 138112 and FE 42912).

documenting completion of the walkdowns and any impact upon the GL 2008-01 response as a result of completed evaluation within 90 days following startup from the listed refueling outages (Unit 1 Cvcle 16, unit 2 Cvcle 16).

15 NC0080021 006 GL 2008-01 GL 2008-01 adverse conditions discovered closed Talked with WBN personnel 06/06/08 at WBN will be entered into the Corrective and reviewed WBN PER Action Program and evaluated for database.

applicability at SON due to their design and construction similarities.

16 NC0081007001 TSC 08-06 Implement SON station procedures closed Revised Sequoyah Nuclear requiring the inspection of each ice Plant Abnormal Operating condenser within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of experiencing a Procedure AOP-N.05, seismic event greater than or equal to an "Earthquake." Added specific Operating Basis Earthquake (OBE) within guidance regarding the the five (5) week period after the completion required inspections.

of ice basket replenishment.

-6 Item Commitment I Commitment Description of Commitment Status Method of Closure No. No. LetterlDate 17 NC0090002001 Confirmatory TVA will ensure that site security closed Revised site security Order (NRC procedures for all TVA nuclear sites are procedures at all three sites to Office Of revised such that original documents comply with the commitment Investigation required to be maintained by site security (SON SSI 17.1)

Report No. 2 procedures are not destroyed, and are 2007-025) retained in accordance with regulatory 01/05/09 requirements.

18 NC0090002002 Confirmatory As part of first-line supervisory training for closed Training completed.

Order (NRC security supervisors, TVA will provide fleet-Office Of wide training related to Civil Investigation Treatment/Ethics, Roles of the Supervisor, Report No. 2 Communication in the Workplace, 2007-025) Standards of Conduct, Coaching and 01/05/09 Counseling Employees, Operational Issues

& Operating Experience, Leadership, Administration, Client Interface/service, Regulatory reporting requirements, safety, &

Security Observation Program. Upon completion of TVA's transition to an in house security force, TVA will ensure that security supervisors receive training consistent with first-line supervisors in other disciplines.

19 NC0090002003 Confirmatory TVA will ensure that security personnel at closed Training completed.

Order (NRC all TVA nuclear sites receive annual training Office Of on the use of TVA's internal programs for Investigation resolution of issues/deficiencies (e.g.,

Report No. 2 Corrective Action Program, Employee 2007-025) Concerns program), consistent with training 01/05/09 received by TVA personnel requiring unescorted access to the TVA nuclear sites.

-7 Item Commitment I Commitment Description of Commitment Status Method of Closure No. No. Letter/Date 20 NC0090002004 Confirmatory TVA will conduct a minimum of 15 closed TVA conducted several Order (NRC observations of Sequoyah security activities observations from 1/1/09 to Office Of each month, until TVA transitions to an in 7/16/09.

Investigation house security force.

Report No. 2 2007-025) 01/05/09 21 NC0090002005 Confirmatory During TVA's transition to an in-house closed Conducted meeting twice a Order (NRC security force, each TVA nuclear site will month during transition.

Office Of conduct meetings at a minimum of twice Investigation each month with the security contractor, to Report No. 2 monitor the status of the corrective actions 2007-025) associated with the Security Independent 01/05/09 Evaluation.

22 NC0090002006 Confirmatory TVA will assess the effectiveness of the closed Completed on June 30, 2010.

Order (NRC corrective actions and enhancements Verified PERs 146528 and Office Of identified in its Security Independent 208856, and Service Request Investigation Evaluation, and the results of this follow-up 201793.

Report No. 2 assessment will be factored into the TVA 2007-025) Corrective action Program. TVA agrees to 01/05/09 complete the assessment of the effectiveness of the corrective actions and enhancements no later than June 30, 2010.

23 NC0090002007 Confirmatory Follow-up response to NRC Confirmatory closed TVA letter dated July 30, 2010, Order (NRC Order (Item h) was issued satisfying the NRC Office Of Confirmation Order.

Investigation Report No. 2 2007-025) 01/05/09

-8 Item Commitment I Commitment Description of Commitment Status Method of Closure No. No. Letter/Date 24 NC0090009001 Unit 1 Cycle 16 SON failed to properly substitute a weld for closed TVA submitted the RR on 90-day lSI an inaccessible weld during the Unit 1 Cycle August 28, 2009.

Summary 16 refueling outage. A relief request (RR) is report with a being prepared to request an extension to Relief Request the first period of the third interval.

(07/24/09) 25 NC0090003001 GL 2004-02 TVA will complete the SON in-vessel in progress (02/23/09) downstream effects evaluation following issuance of the final NRC Safety Evaluation report (SER) for Topical Report No. WCAP 16793-NP, "Evaluation of Long-Term Cooling Considering Particulate, Fibrous, and Chemical Debris in the Recirculating Fluid." Following completion of the evaluation the results will be submitted to NRC.

26 NC0111 05331 9-1 Confirmatory Through calendar year 2013, TVA shall closed To resolve NRC Confirmatory Order (NRC conduct "Town Hall'-type meetings at least (part 1) Order, TVA generated a Office Of annually at Sequoyah Nuclear plant with commitment dividing into 4 Investigation TVA and contractor employees which parts. On May 19 and 20, Report Nos. 2 address topics of interest including a 2010, the Station updates 2006-025 & 2 discussion on TVA's policy regarding were conducting at Sequoyah 2009-003) fostering a safety conscious work by the Site Vice President.

12/22/09 environment (SCWE). In the event of the Part of the meetings discussed transfer of the operating license of a facility TVA's and Sequoyah's policy to another entity, if any, the commitments regarding the fostering of a for such facility shall survive any transfer of healthy SCWE practice. All ownership. employees and contractors were invited and given the opportunity to ask questions.

No significant issues or concerns were raised during these meetings.

-9 Item Commitment I Commitment Description of Commitment Status Method of Closure No. No. LetterlDate 27 NC0111053319-2 Confirmatory Through calendar year 2013, TVA shall in progress PERs 212256 and 230725 Order (NRC conduct "Town Hall'-type meetings at least (part 2) keep track of this commitment.

Office Of annually at Sequoyah Nuclear plant with Investigation TVA and contractor employees which Report Nos. 2 address topics of interest including a 2006-025 & 2 discussion on TVA's policy regarding 2009-003) fostering a safety conscious work 12/22/09 environment (SCWE). In the event of the transfer of the operating license of a facility to another entity, if any, the commitments for such facility shall survive any transfer of ownership.

28 NC0111053319-3 Confirmatory Through calendar year 2013, TVA shall in progress PERs 212256 and 230725 Order (NRC conduct "Town Hall'-type meetings at least (part 3) keep track of this commitment.

Office Of annually at Sequoyah Nuclear plant with Investigation TVA and contractor employees which Report Nos. 2 address topics of interest including a 2006-025 & 2 discussion on TVA's policy regarding 2009-003) fostering a safety conscious work 12/22/09 environment (SCWE). In the event of the transfer of the operating license of a facility to another entity, if any, the commitments for such facility shall survive any transfer of ownership.

- 10 Item Commitment I Commitment Description of Commitment Status Method of Closure No. No. LetterlDate 29 NC0111053319-4 Confirmatory Through calendar year 2013, TVA shall in progress PERs 212256 and 230725 Order (NRC conduct Town Hall'-type meetings at least (part 4) keep track of this commitment.

Office Of annually at Sequoyah Nuclear plant with Investigation TVA and contractor employees which Report Nos. 2 address topics of interest including a 2006-025 & 2 discussion on TVA's policy regarding 2009-003) fostering a safety conscious work 12/22/09 environment (SCWE). In the event of the transfer of the operating license of a facility to another entity, if any, the commitments for such facility shall survive any transfer of ownership.

January 19, 2011 Mr. R. M. Krich Vice President, Nuclear Licensing Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

SEOUOYAH NUCLEAR PLANT, UNITS 1 AND 2 - CORRECTIONS FOR COMMITMENT AUDIT REPORT (TAC NOS. ME5170 AND ME5171)

Dear Mr. Krich:

On December 30, 2010, the Nuclear Regulatory Commission (NRC) issued a report on the audit of the management of regulatory commitments by Tennessee Valley Authority for the Sequoyah Nuclear Plant (SON), Units 1 and 2. This report was in response to NRC staffs audit conducted on December 15-16, 2010, at SON site. It was discovered that page 3 of the attachment was missing from this report. This was an administrative oversight on our part and does not affect the NRC staffs conclusions associated with this report.

Enclosed is the complete report including the above-mentioned missing page. We regret any inconvenience this may have caused.

Sincerely, IRA!

Siva P. Lingam, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-327 and 50-328

Enclosure:

Corrected Audit Report cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC LPL2-2 RIF RidsNrrDorlLpl2-2 RidsNrrLACSola (paper copy) RidsOgcRp RidsAcrsAcnw_MailCTR RidsRgn2MailCenter Ridsl'JrrPMSequoyah SlVIeighan, NRR ADAMS Accession No: ML110030328 (ML103610353 Audit Report with missing page 3)

OFFICE LPL2-2/PM LPL2-2/LA LPL2-2/BC LPL2-2/PM NAME SLingam CSoia DBroaddus SLingam (TOrf for)

DATE 01/03/11 01/03/11 01/19/11 01/19/11 OFFICIAL RECORD COpy