ML112790370

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Non-proprietary, Audit of Calculations Supporting Extended Power Uprate Regarding Steam Dryer Replacement (TAC No. ME4679) (Public Version)
ML112790370
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 10/19/2011
From: Wang A
Plant Licensing Branch IV
To:
Entergy Operations
Wang A, NRR/DORL/LPL4, 301-415-1445
References
TAC ME4679
Download: ML112790370 (16)


Text

OFFICIAL USE ONLY PROPRIETARY INFORMATION ~ ~~

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 19, 2011 Vice President, Operations Entergy Operations, Inc.

Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150

SUBJECT:

GRAND GULF NUCLEAR STATION, UNIT 1 - AUDIT OF CALCULATIONS RELATED TO EXTENDED POWER UPRATE (TAC NO. ME4679)

Dear Sir or Madam:

By letter dated September 8, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. Ml1002660403), Entergy Operations, Inc. (Entergy, the licensee),

proposed an amendment to increase the maximum reactor power operating limit authorized in the Facility Operating License No. NPF-29 from 3,898 MWt to 4,408 MWt. In support of the proposed extended power uprate (EPU) amendment, Entergy will replace the steam dryer at Grand Gulf Nuclear Station (GGNS), Unit 1. This replacement steam dryer was designed by General Electric Hitachi (GEH). The fluctuating pressure loading on the steam dryer is based on GEH's Plant Based load Evaluation (PBlE) methodology and in-plant measurements. An audit of the GEH calculations supporting the changes to the steam dryer was held at the Nuclear Energy Institute and General Electric Company offices in Washington, D.C., on September 19 and 20, 2011, respectively. The audit was needed as GEH stated that the calculations the U.S. Nuclear Regulatory Commission (NRC) staff were interested in reviewing were proprietary and voluminous.

The NRC staff's proprietary version of the Audit Report is provided in Enclosure 1 and a non proprietary version is provided in Enclosure 2. In addition, the NRC staff has determined additional information is needed to complete this review. The request for additional information is provided in the audit report. Entergy has stated it will respond by October 10, 2011.

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- 2 If you have any questions regarding the Audit Report, please contact me at (301) 415-1445.

Sincerely, Alan B. Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-416

Enclosures:

1. Audit Report (Proprietary)
2. Audit Report (Non-Proprietary) cc w/Enclosure 2: Distribution via Ustserv OFFICIAL USE ONLY

~'ROPRIETARY INFORMATION

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~\\b ENCLOSURE 2 AUDIT OF STEAM DRYER CALCULATIONS SUPPORTING PROPOSED EXTENDED POWER UPRA TE FOR GRAND GULF NUCLEAR STATION, UNIT 1 (NON-PROPRI ETARY)

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OFFICIAL USE ONLY - PROPRIETARY INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555'()()01 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION AUDIT OF THE STEAM DRYER CALCULATIONS ENTERGY OPERATIONS. INC.

GRAND GULF NUCLEAR STATION, UNIT 1 DOCKET NO. 50-416 In support of the proposed extended power uprate (EPU) amendment, Entergy Operations, Inc.

(Entergy, the licensee), will replace the steam dryer at Grand Gulf Nuclear Station, Unit 1 (GGNS). This replacement steam dryer was designed by General Electric Hitachi (GEH). The fluctuating pressure loading on the steam dryer is based on GEH's Plant Based load Evaluation (PBLE) methodology and in-plant measurements obtained from main steam line (MSl) strain gauges. GGNS is the first operating nuclear plant to use the PBlE methodology. The Nuclear Regulatory Commission (NRC) staff, supported by its contractors identified on the cover page, performed an audit of GEH's evaluations pertaining to acoustic and structural finite element (FE) models of the GGNS steam dryer. The audit was held at the Nuclear Energy Institute (NEI) and General Electric Company (GE) offices in Washington, D.C., on September 19 and 20, 2011, respectively.

1.0 PURPOSE The purpose of the audit was to examine and evaluate documents proprietary to GEH.

2.0 AUDIT DETAilS The agenda for the audit is provided in Section 2.3 of this report. Other documents that will be submitted by the licensee on the docket were also examined. A list of documents examined and/or discussed during the audit is provided in Attachment 1 of this report. The action items resulting from the audit are included in Section 3.0 of this report.

2.1 Audit locations Monday, September 19, 2011 NEI Main Office, 1776 "Eye" ("I") Street, NW, Washington, D.C. 20006 Tuesday, September 20, 2011 General Electric Office. 1299 Pennsylvania Avenue. NW, Washington, D.C. 20004 OFFICIAL USE ONLY - PROI:tRIETARY INFORMATION

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- 2 2.2 Audit Attendees NRC:

Chakrapani Basavaraju, Terri Spicher, and Alan Wang NRC Contractors:

Vik Shah (Argonne National laboratory) and Steve Hambric (Penn State)

Entergy:

Jerry Burford and Mike Withrow GEH:

Patricia Campbell, Tim Niggel, Mark Blue, Dan Pappone, Michael James, and Tao Wu Betti Engineering/GEH: Enrico Betti 2.3 Audit Agenda The NRC staff and its contractors discussed and evaluated the seven agenda items listed below with members of GEH and Entergy. This discussion is summarized in Section 2.4 of this report.

The discussion regarding two additional items is summarized in Section 2.4 of this report.

The agenda for audit of the GGNS EPU documents associated with the GEH boiling-water reactor (BWR) steam dryer methodology is provided below.

While preparing the safety evaluation for the Grand Gulf extended power uprate license amendment request, the NRC staff has determined the need for clarification and additional information in order to complete its review regarding the steam dryer evaluations. The NRC staff, with support from its contractors, would like to conduct an audit on September 19-21, 2011. The NRC staff will be focusing on the following items associated with the GEH BWR steam dryer methodology:

In-plant MSl measurements, Acoustic modeling of steam in the MSls, the reactor pressure vessel (RPV), and the steam dryer, Mapping of aco'ustic loads onto structural models of the steam dryers, Filtering of MSl measurements, dryer pressure loads, and dryer stresses, Structural FE modeling, including submodeling of high-stress regions, End-to-end bias errors and uncertainties, and Corrective Action Requests for the last 3 years.

The NRC staff, therefore, requests an audit of the GEH PBlE methodology, the GEH steam dryer FE modeling methodology, the interface between the PBlE and FE models, the in-plant MSl measurements, and all associated bias errors and uncertainties, specifically associated with the GGNS EPU application.

The NRC staff requests that GEH arrange for all medels and data associated with its Quad Cities Nuclear Power Station, Unit 2 (QC2) and Susquehanna Steam Electric Station (SSES),

Units 1 and 2 benchmarks, as well as its GGNS replacement dryer analyses, to be available

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- 3 digitally during the audit, as well as technically cognizant personnel to answer technical questions associated with the models and data. Computers with Matlab and Microsoft Excel should be made available to the NRC staff to examine the data with support from GEH personnel.

"rhe NRC staff's audit will focus on the following specific items. GEH is requested to make available the following items during the audit:

1.

Raw MSL measurements (time histories and frequency spectra) from the QC2 and SSES benchmarking studies and the GGNS plant, as well as any subsequent 'filtering and final filtered signals, along with methods used to confirm correct and accurate measurements.

2.

Acoustic models of the MSLs (with branch lines and safety relief valves), RPV, and dryers of the QC2, SSES, and GGNS plants, including any additional models used to establish accuracy and convergence, and evidence of consistent modeling procedures between the benchmark and GGNS models. The models should be accompanied by easy to interpret drawings of the RPVs and MSLs, including critical dimensions (RPV

diameter, L entry geometries and downstream eometries, SRV location entries and
3.

Software used to map acoustic loads on to the dryers, as well as plots and comparisons of oscillatory pressures in the acoustic models and structural models along the dryer/steam interface, on both the interior and exterior of the dryers. Verification and validation documents for the software.

4.

Structural FE models of the QC2, SSES, and GGNS steam dryers including transition from shell to solid element modeling, along with mesh convergence studies, and evidence of consistent modeling procedures between the benchmark and GGNS models. Submodels, when used to reduce peak stresses, should also be available for examination.

5.

Unfiltered frequency spectra and time histories of measured dryer pressures, strains, and accelerations for the QC2 and SSES benchmarks, along with any filtering procedures used to adjust the spectra, and the final filtered spectra and time histories.

Simulated unfiltered data to compare directly to the measured data (time series and spectra) and how it was su filtered and to determine the final PBLE bias errors and uncertainties

6.

Unfiltered frequenc!!MIctra and time histories of calculated GGNS dryer stresses, based on unfiltered and PBLE/FE models, along with any filtering or exclusions and subsequent rnal Iitered results.

7.

Corrective Action Reports (CARs) generated during the last 3 years pertaining to GGNS and Economic Simplified Boiling Water Reactor (ESBWR) steam dryer design and

?>J OFFICIAL USE ONLY - PROPRIETARY INFORMATION f' ~

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-4 evaluation methodology including the aC2 and SSES benchmarking. The licensee's technical evaluation (corrective action program evaluations and engineering evaluations).

2.4 Audit Discussion on Agenda Items The focus of the audit is GEH's PBLE procedure, as applied to the GGNS replacement steam dryer. The NRC and its contractors initiated the audit by working with GEH to find and evaluate all CARs associated with the replacement steam dryer flow-induced vibration analyses. The NRC team combined the information found in these CARs with the items from the audit agenda.

Matlab and Sysnoise software were also made available by GEH during the audit. Listed below is a summary along with the action items. A consolidated list of the action items is presented in Section 3.0.

1.

MSL measurements which is aC2 MSL Signals are filtered to remove _

Hz, but also use rolls off input als above Hz. HOWe'ver, Since no conservative since It is noted that the

2.

Acoustic models

a.

Consistency of geometry, acoustic models and structural models for aC2, SSES, and GGNS has been verified within GEH.

b.

Mesh resolution issues:

i.

~

criterion leading to higher loads, with the still applied, the _

aC2.....".'.......,....

ii.

The initial GGNS acoustic mesh did not ~

I and ignored the_ (CAR 52126).

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-5 However, this was assessed in the submisSion, with higher loads due to a included as a bias error.

c.

The acoustic models of QC2, SSES, and GGNS have ____

inaccuracies (CARs 53032 - SSES and 53060 - QC2)~

determine if the errors led to conservative or non-conservative dryer loads and stresses.

submit quantitative assessment of the impact of the.

on the GGNS dryer loads.

d.

The NRC staff and contractors examined peak drive frequencies (caused by RPV and dryer volume acoustic modes) am of the nozzle to dryer transfer functions nA""",,,n,- are reasonable, and are fairly consistent plant to plant.

NRC did not find any significant issues with the transfer functions.

i.

acoustic mesh (less than gradient regions) 1.

NOZZlllia:

.. asm

2.

Peaks at frequen Hz.

3.

Amplitudes between

a.

Divide by actiliiiiiiiisure/volume velocities ranging from Palm3/s.

ii.

SSES

1.

Nozzle area:

m2 modeled.

2.

Peaks at frequencies Hz.

3.

Amplitudes between Palmls

a.

Divide by act~surelvolume velocities ranging from _

Palm3/s.

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-6 iii.

GGNS - original

1.

Nozzle area: _

m2 as modeled.

2.

loc;atlo,n ~p

3.

Amplitudes between Palm/s

a.

Divide by act~sure/volume velocities ranging from _

Palm3/s.

4.

Peak in GGNS transfer function amplifies

.. Hz SRV tones (conservative).

iv.

GGNS - refined - added drain channel volumes and refined mesh

1.

Nozzle area: _

m 2 as modeled.

2.

Peaks at frequencies

_Hz.

3.

Same amplitude range, but peaks increase at _

and_

Hz significantly.

e.

-based on SSES and GGNS

i.

and" above" ii.

iii.

due to initial bug in was approved during ESBWR.

1.

O....'lln"* nrnl,/ln.:. a write-up on why using for all other dryers SER.

3.

Load mapping - structural vs. acoustic models - QC2. SSES, GGNS

a.

The audit team viewed the low frequency (LF) and high frequency (HF) comparisons for SSES and GGNS, which looked fine, but do not give a quantitative assessment of load mapping errors over key regions and _

frequency ranges,

. b;>

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b.

A review of the CAR 49314 shows that the load mapping procedure leads to errors in of the dryer model in the GGNS original to the GGNS replacement dryer, the CAR indicates that the overall procedure which may apply to QC2, SSES, and GGNS.

i.

GEH showed contour plots over several views for each narrow frequency band used in bias error and uncertainty calculations. which seem fine for low and high frequency regions.

ii.

GEH action: Show integrated total forces and moments over selected dryer regions, and _

and regions used in Bias and Uncertainty Factor (BUF) calculations).

c.

Ensure acoustic and structural models are aligned.

i.

QC2 - not based on an Inventor model. GEH and its subcontractors had to manually ensure the models were aligned. There might be some mismatch (gap) between the models.

ii.

SSES - both models are based on a common 'inventor' CAD model, and therefore must be aligned.

iii.

GGNS - both models are based on a common 'inventor' CAD model, and therefore must be aligned.

4.

Structural FE models - QC2. SSES. GGNS

a.

Methodology for choosing and assessing locations of peak stresses.

b.

Need to ensure that any changes in meshing/modeling procedures for GGNS are conservative with respect to benchmark meshing (CAR 53718).

i.

GEH action: provide a write-up on FE structural meshing procedure, justification that GGNS meshing procedures are conservative with respect to SS ES benchmarks

c.

Global modeling - GEH described the sheil element-to-solid element transition methodology used in the finite element mc,deling of the dryer. (CAR 51627).

The methodology is technically sound and therefore, acceptable.

as function of frequency (same frequencies

i.

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d.

Submodeling

i.

Confirm that the linear path selected to determine the stresses for each of the GGNS submodels (using solid elements) provides the I which will, in turn, result into the

5.

Measured dryer pressures. strains. accelerations; bias errors and uncertainties

a.

____ PBlE bias errors and uncertainties are defined in MFN 09-509,

~nce 3 to Appendix F of the GGNS submission [1], and previously approved by the NRC in the ESBWR SER.

b.

subm

_(CAR

i.
c.

Examination of the SSES dryer strains and accelerations reveals the dominant signals are due to tones at

i.

GEH action:

......-willbe

~nd GGNS in-plant measurement.

6.

The SSES2 steam dryer has recently experienced some cracking which might be due to fatigue. The licensee is requested to provide any preventive measures or design changes to GGNS dryer in light of the cracking observed in SSES2.

The NRC staff requests that Entergy submit a report after the evaluation of SSES2 steam dryer cracking is completed, explaining whether there are any areas of the GGNS replacement dryer that need to be modified or further analyzed based on the final results and conclusions of the SSES evaluations.

a.
i.

GEH action: explain any GGNS dryer deSign changes to prevent the cracking observed in SSES2. Selme of this might be covered in an RAI response.

explain how tones from OFFICI~l USE ONLY PROPRIETARY INFORMATION

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7.

Calculated GGNS dryer stresses - time histories and Spectra

a.

CAR 50169 (lug stresses)

GEH provided a checklist and procedure (DRF 0000-0109-0408, Section 0000-0112-3093 RO) and compliance Table Revision 1 - Steam Dryer Regulatory Requirements for Dryer Analyses (52 pages). The checklist was

~nsive and would avoid errors in the dryer analysis. The table mentions pounds per square inch (psi) (instead of_ psi) as an acceptance criterion for fatigue assessment of the steam dryer components that may generate loose parts. However, this criterion is used for the ESBWR design and not the GGNS replacement dryer design. This observation was communicated to the GEH staff.

b.

GEH action: provide that the range of peak stress intensity is assumed to be over time history (this was cited in the conservatism introduced by this assumption is quantified for the GGNS and/or SSES dryers.

c.
i.

GEH action: assess the impact of this modeling error on stresses

d.

The NRC reviewed GEH's stress reduction factor justifications, including the one which reduces the stresses to_ of those in main model (a region offairly low stress). However, this was noi""i'heTimiting location. This topic is discussed above under 4 d (i).

i.

GEH action: Provide a summary of the GGNS reanalysis of the replacement steam dryer stresses. Include a list of changes made for the reanalysis and provide a comparison with the relevant stresses calculated in the original analysis submitted to the NRC.

8.

Corrective Action Reports and DRFs Based on NRC's request, GEH conducted a keyword search for all CARs of interest.

The NRC audit team identified follow-on actions (as described above) associated with several CARs.

During the audit, the NRC staff was informed by Entergy that GEH has reanalyzed the GGNS replacement dryer. 8£tl.Qn: The licensee was requested to explain whether the reanalysis led to any changes in the design c,f the replacement dryer.

Also, the audit team requested for several DRFs related to the replacement dryer original analysis (submitted September 2010) and reanalysis (yet to be submitted). Most OFFICIAL USE ONLY PROPRIETARY INFORMATION

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- 10 of these are related to items not included on our original audit list, including trending of stresses to EPU conditions. GEH provided the following documents for review.

Document Section DRF-OOOO-O109-0408 0120-8682 DRF-0000-OO93-5727 0106-2262 DRF-0000-OO93-5727 0121-479 DRF-0000-0109-0408 0114-1149,0119-7952,0120-3881,0120-8539,0120-9020

! DRF-0000-0125-1506 DRF-0000-0126-8302 DRF-0000-0128-9666 DRF-0000-0129-7181 DRF-0000-0130-0842 DRF-0000-0130-9183 DRF-OOOO-O131-0351 DRF-0000-0131-1235 DRF-0000-0132-3474 DRF-0000-0128-5076

9.

During the audit, GEH stated that there is some conservatism in its GGNS dryer stress assessment, which is not quantified.

a.

GEH action: provide a list of conservatisms and approximate quantification (if available) in the GEH GGNS and/or SSES steam dryer stress evaluation.

3.0 ACTION ITEMS

1.

The licensee is requested to submit qu assessment of the impact of the errors on the GGNS dryer loads.

2.

justification on is conservative for all other nn/ClrC!

3.

Load macping - structural vs. acoustic models: The licensee is requested to show integrated total forces and moments over selected dryer regions, and _. as function of frequency (for the same frequencies and regions used in Bias and Uncertainty Factor (BUF) narrow-band calculations).

4.

Structural FE models: The licensee is requested to provide a write-up on FE structural meshing procedure and a justification that GGNS meshing procedures are conservative with respect to SSES benchmarks.

5.

Structural FE models: The licensee is requested to nrrnllng methodology, including a description of how the for transition from OFFIOIAL USE ONLY - PROPRIETARY INFORMATION

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6.
7.

~estedto will be accounted for in GGNS.

co comparison of SSES and GGNS in-plant measurements.

8.

Consideration of the dryer cracking eXR§rience from SSES2: The licensee is requested to provide any preventive measures or design changes to GGNS dryer in light of the cracking observed in SSES2 steam dryer.

The NRC staff also requests that ENTERGY submit a report after the evaluation of SSES2 steam dryer cracking is completed, explaining whether there are any areas of the GGNS replacement dryer that need to be modified or further analyzed based on the final results and conclusions of the SSES evaluations.

9.

GGNS dryer stresses: The licensee is requested to provide confirmation that the range of peak stress intensity is assumed to be over time history (this was cited in calculations. The licensee is also requested to explain whether the conservatism introduced by this assumption is quantified for the GGNS and/or SSES dryers.

ryer

10.

of

11.

GGNS steam dryer stresses: The licensee is requested to provide a summary of the GGNS reanalysis of the replacement steam dryer stresses. This summary should include a list of changes made for the reanalysis and a comparison of the relevant stresses from reanalysis with those calculated in the original analysis submitted to the NRC. The licensee is also requested to explain whether the reanalysis led to any changes in the design of the replacement dryer.

12.

Conservatism in steam dryer stresses: The licensee is requested to provide a list of conservatisms and approximate quantification where appropriate in the GGNS and/or SSES steam dryer stress evaluations performed by GEH.

4.0 CONCLUSION

S

1.

During the audit, the NRC staff was informed by the licensee that GEH has reanalyzed the GGNS replacement dryer. The staff was also informed by GEH that the conclusion OFFICIAL U&& ONLY PROPRIETARY INFORMATION f-\\ ~~

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- 12 reached in the original steam dryer,analysis regarding the acceptability of the GGNS replacement steam dryer for the EPU operation is not affected.

The licensee is requested to explain whether the reanalysis led to any changes in the design of the replacement dryer.

2.

There are sufficient errors and omissions in the originally submitted analysis requiring the licensee to submit a summary of its reanalysis of the GGNS replacement i

(1) 5.0 DOCUMENTS REVIEWED Documents requested and made available by GEH during the audit:

DRF-OOOO-O1 09-0408 DRF-0000-0129-7181 DRF-0000-0093-5727 DRF-0000-0130-0842 DRF-0000-0093-5727 DRF-0000-0130-9183 DRF-OOOO-O1 09-0408 DRF-OOOO-O131-0351 DRF-OOOO-O125-1506 DRF -0000-0131-1235 DR F -0000-0126-8302 DRF-OOOO-0132-3474 DRF-0000-0128-9666 DRF-0000-0128-5076 GEH Corrective Action Reports (CARs)

CAR 49314 CAR 50169 CAR 51627 CAR 52126 CAR 53032 CAR 53060 CAR 53718 Principal Contributor:

Date: October 19, 2011 OFFICIAL USE ONLY - PROPRIETARY INFORMATION

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- 2 If you have any questions regarding the Audit Report, please contact me at (301) 415-1445 or Alan. Wang@nrc.gov.

Docket No. 50-416

Enclosures:

1. Audit Report (Proprietary)
2. Audit Report (Non-Proprietary) cc w/Enciosure 2: Distribution via Listserv DISTRIBUTION:

NONPUBLIC/PLlBLIC LPLIV r/f RidsAcrsAcnw_MailCTR Resource RidsNrrDorlLpl4 Resource RidsNrrDeEmcb Resource RidsNrrLA~IBurkhardt Resource Sincerely, IRAI Alan B. Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation RidsNrrPMGrandGulf Resource RidsOgcRp Resource RidsRgn4MailCenter Resource CBasavaraju, NRRIDE/EMCB TSpicher, NROIDE/EMB1 ADAMS Accession Nos. ML112730341 (proprietary) and ML112790370 (non-proprietary, redacted)

OFFICE NRR/LPL4/PM NAME ABWang DATE 1017/11

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NRR/LPL4/LA NRR/DE/EMCB/BC NRR/LPL4/BC NRR/LPL4/PM

~IBurkhardt MMurphy MMarkley ABWang 1017/11 10/11/11 10/14/11 10/19/11

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