ML113210594
| ML113210594 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 12/02/2011 |
| From: | Billoch-Colon A Plant Licensing Branch III |
| To: | Exelon Generation Co |
| Billoch-Colon A, NRR/DORL, 301-415-3302 | |
| Shared Package | |
| ML113210598 | List: |
| References | |
| TAC ME7495, TAC ME7496 | |
| Download: ML113210594 (17) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 2, 2011 LICENSEE:
Exelon Generating Company, LLC FACILITY:
LaSalle County Station, Units 1 and 2
SUBJECT:
SUMMARY
OF NOVEMBER 2,2011, MEETING WITH EXELON GENERATION COMPANY, LLC AND NUCLEAR ENERGY INSTITUTE, TO DISCUSS APPLICATION OF THE NUCLEAR ENERGY INSTITUTE PILOT FOR PRESUBMITTAL MEETINGS FOR LASALLE COUNTY STATION, UNITS 1 AND 2 EXTENDED POWER UPRATE (TAC NO. ME7495 AND ME7496)
On November 2, 2011, a Category 1 public meeting was held among the U.S. Nuclear Regulatory Commission (NRC) staff, representatives of Exelon Generation Company, LLC (Exelon, the licensee), and the Nuclear Energy Institute (NEI), at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. The purpose of the meeting was to discuss the application of the NEI pilot for presubmittal meetings for the LaSalle County Station (LSCS), Units 1 and 2, Extended Power Uprate (EPU) submittal.
The purpose of the NEI pilot for presubmittal meetings is for licensees and the NRC staff to reach common understanding on the regulatory criteria and standards to be applied in the review of significant licensing actions. A presubmittal meeting will be recommended for licensing actions where significant changes or new analytical approaches are applied which deviate from existing licensing basis, precedents, or current review standards and require prior NRC staff review and approval.
The NEI pilot establishes the rules of engagement between licensees and NRC staff and a mechanism to receive clear regulatory expectations on current NRC staff practices. The licensee will define the scope and the regulatory basis for the proposed licensing action through application of the presubmittal guidance checklist. The presubmittal guidance checklist includes the proposed and detailed description of the licensing action, date for the planned submittal and requested approval, preliminary bases for the proposed change, proposed licensing basis, precedent(s), and the regulatory organization interface.
The licensee will submit a docketed presubmittalletter with the goals and expectations for the presubmittal meeting, the presubmittal guidance checklist, key participants from the licensee, and handout materials so that the NRC staff have adequate time to review and prepare for the presubmittal meeting; thus, enhancing the NRC staff efficiency and effectiveness when the proposed licensing action is submitted.
At the time of the presubmittal meeting, NRC staff and the licensee will discuss the basis for the proposed licensing action. Both parties will have the opportunity to discuss the plant-specific licensing basis and the proposed bases that support the change using the presubmittal guidance checklist. The technical review will commence after the NRC staff has received the licensing action request and it is found to be acceptable for docketing.
-2 In addition, the Exelon and the NRC staff discussed the logistics for the LSCS, Units 1 and 2, EPU presubmittal meeting scheduled for December 7, 2011.
The meeting notice and agenda are available under (Agencywide Documents Access and Management System (ADAMS) Accession No. ML112911409). The public was invited to observe the meeting. No members of the public were in attendance. Public Meeting Feedback forms were not received.
Please direct any inquiries to me at 301-415-3302.
Araceli T. Billoch Colon, Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-373 and 50-374
Enclosures:
- 1. List of Attendees
- 2. NEI Internal Preliminary Planning and Approval
- 3. Presubmittal Guidance Checklist Instruction Sheet
- 4. Presubmittal Guidance Checklist cc w/encls: Distribution via Listserv
LIST OF ATTENDEES FOR NOVEMBER 2. 2011.
MEETING WITH EXELON GENERATION COMPANY. LLC.
AND THE NUCLEAR ENERGY INSTITUTE PRESUBMITTAL MEETING TO DISCUSS THE APPLICATION OF THE NUCLEAR ENERGY INSTITUTE PILOT FOR PRESUBMITTAL MEETINGS FOR LASALLE COUNTY STATION.
UNITS 1 AND 2. EXTENDED POWER UPRATE NAME ORGANIZATION John Rommel Exelon Generation Company, LLC Vikram Shah Exelon Generation Company, LLC Phil Lashley Exelon Generation Company, LLC Kevin Borton Exelon Generation Company, LLC Julie Keys NEI Michele Evans U.S. Nuclear Regulatory Commission Louise Lund U.S. Nuclear Regulatory Commission Jacob Zimmerman U.S. Nuclear Regulatory Commission Tom Alexion U.S. Nuclear Regulatory Commission Sheldon Stuchell U.S. Nuclear Regulatory Commission Araceli T. Billoch Colon U.S. Nuclear Regulatory Commission Joel Wiebe U.S. Nuclear Regulatory Commission Pete Hernandez U.S. Nuclear Regulatory Commission
Internal Preliminary Planning and Approval Various activities, issues, conditions, and events at nuclear power plants result in the consideration of the need for a change to a plant's licensing basis as a possible resolution path, corrective action, or cost-beneficial initiative. In those circumstances, licensees have developed internal project and design control processes to support the evolution of the proposed change from initial concept, design, submittal, through implementation.
For regulatory processes, 10 CFR 50.59 focuses on the effects of proposed activities on the safety analyses that are contained in the updated FSAR (UFSAR) and are a cornerstone of each plant's licensing basis. In addition to 10 CFR 50.59 control of changes affecting the safety analyses, there are several other complementary processes for controlling activities that affect other aspects of the licensing basis, including:
- Amendments to the operating license (including the technical specifications) are sought and obtained under 10 CFR 50.90.
- Where changes to the facility or procedures are controlled by more specific regulations (e.g., quality assurance, security and emergency preparedness program changes controlled under 10 CFR 50.54(a), (p) and (q), respectively; Off-site Dose calculation Manual changes controlled by technical specifications), 10 CFR 50.59 states that the more specific regulation applies.
Changes that require an exemption from a regulation are processed in accordance with 10 CFR 50.12.
Guidance for controlling changes to licensee commitments is provided by NEI 99-04, Guideline for Managing NRC Commitment Changes.
Together, these processes form a framework of complementary regulatory controls over the licensing basis.
For the subset of those licensee actions that will require regulatory approval, and represent a significant facility project or Significant departure from the current plant licensing basis or current NRC review standards/precedent, the initial regulatory planning for the submittal must begin well in advance of the actual submittal. The initial regulatory scoping of a submittal should begin during the initial project scoping or conceptual design phase of the project when budget and resources are being evaluated. This may occur years before the actual planned submittal.
The intent of an NRC pre-submittal meeting is for licensees and the NRC to reach common understanding on the regulatory criteria and standards to be applied in the NRC's review of changes to the licensing basis and other license-required documents and programs that require prior NRC review and approval. It is not a pre-approval meeting. It establishes the rules of engagement. The pre-submittal meeting established a mechanism to receive clear regulatory expectations on current staff practices in implementing the Standard Review Plan (SRP). The presubmittal meeting is not a venue for the NRC staff to make a determination on whether a proposed licensing action has followed the regulatory guidance. That technical review will be performed after the NRC staff has received the proposed licensing action.
Few licensing actions, specifically those in which there are few deviations from current licensing basis or current NRC review standards, will require a presubmittal meeting. A presubmittal meeting is recommended for those licensing actions in which the scope of the action is significant or where substantive changes or new analytical approaches are applied which deviate from existing licensing
basis, precedent or current review standards. In addition, voluntary licensing actions in which previously approved methods may be challenged based on new information of standards are also appropriate for presubmittal meetings.
The timing of the presubmittal will vary dependent upon the risk, scope and cost associated with the proposed licensing action, but could be a year or two prior to the actual submittal, dependent upon project risk, scope and cost. The NRC staff encourages a presubmittal meeting before expending significant resources on methods and approaches that may not be acceptable to the staff. In some cases, for evolving technical topics, a pre-presubmittal meeting (e.g., prior to the vendor award phase of a project) would be beneficial to better highlight those technical challenging areas and methods acceptable to the staff for resolution.
For these types of projects, initial discussions with the NRC Project Manager at the project conceptual stage are recommended. The discussions should primarily serve to establish periodic communication channels and maintain project awareness. However, preliminary discussion on the project scope and timing, as well as, identification of branch involvement, and key technical or analytical methods should occur. At this early conceptual phase, many of the questions regarding proposed analytical or design approaches cannot be answered, yet a preliminary review will highlight the risk or uncertainty that some of those decisions may incur. Communications at this early stage can also identify opportunities for lead plant or pilot plant applications.
Internal Licensee Presubmittal Preparations With the project scope defined and the preliminary regulatory interface/presubmittal plan established, the next phase is the detailed development of the licensing basis of the submittal which can be accomplished through the application of the presubmittal guidance checklist.
The preliminary bases for the proposed change must be established. Within the framework of a licensee's project management and change control processes, licensees should determine:
- The need and the technical basis for the change to the licensing basis or other license-required document or program
- Compliance
- Cost benefit
- The preliminary development of safety basis for change
- Regulatory requirements
- Operating experience
- Identification, and applicability determination, of precedent
- CUIPfTm
- The preliminary determination of safety/security interface
- The preliminary determination of significant hazards determination
- The preliminary determination of environmental consequences Identify precedent and justify applicability to the proposed licensing action. Identify and justify deviations between the approved precedent and the proposed licensing action. For
-3 the use of older precedentl provide justification that the precedent meets current NRC regulatory standards. Refer to NEI 06-021 Section 2.1 Identification of Precedence. For consolidated line item improvements (CUIPs)1 identify any potential deviations between the model CUIP and the proposed licensing action.
Review the Standard Review Plan (SRP) and applicable licensing precedent to identify potential technical branch and NRC organizational interfaces for the proposed licensing action. Reconcile the evaluation with the NRC project manager. Provide supporting bases for the conclusions reached, if not self-explanatory.
Identify the NRC regulatory guidancel generic communicationsl facility specific licensing basis and industry guidance and standards that establish the current licensing basis as related to the scope of the proposed licensing action. Identify the proposed changes to each of these documents that will establish the new basis for the proposed licensing action. Evaluate the differences. Similarly evaluate deviations, if anYI from the most current versions of the NRC guidance documents.
Identify specific computer codes and industry standards to be used, including revision level. Include NRC approval status of any documents. Provide sufficient detail to establish the concise licensing basis of the proposed licensing actions that highlights departures from the current plant licensing basis or current NRC review standards. Efforts should be focused on highlighting those areas on the checklist where precedent or experience would indicate the potential for deviation from current NRC guidance.
The development of the presubmittal guidance checklist will be iterative. Interface with the NRC project manager after the initial completion. Identify the key technical branches and NRC organizations that will be involved in the proposed licensing action review. This will help to identify required participants in the presubmittal meeting. If poSSible, get feedback from the technical branches through the project manager on the key licensing basis assumptions to focus the agenda of the presubmittal meeting.
Once general alignment is achieved, establish a target date for the presubmittal meeting ensuring all key technical branches can be represented. The timing of the actual presubmittal meeting will varyl depending on the scope and complexity of the licensing action, as well as the regulatory certainty.
Presubmittal meeting can occur just prior to submittal of the licensing action to as many as two years prior to the submittal.
Docketed Presubmittal Letter The licensee should work with the NRC project manager to determine the timing for submission of presubmittal meeting materials, including the presubmittal guidance checklist to allow for the information to be placed in the NRC's Agency wide Document Access and Managements System (ADAMS). This allows the NRC staff and members of the public partiCipating by teleconference to view the materials prior to the presubmittal meeting. Ideally, handout materials should be provided prior to the preparation of the meeting announcement so that the NRC project manager and technical staff have adequate time to review and prepare for the meeting and align on the meeting agenda.
The materials should be submitted to the NRC project managerl via docketed correspondence. The associated cover letter should be clear in the goals and expectations from the meeting. Clearly state the expectation for the meeting, such as alignment on applicable review criteria1 guidance on level of detail, justification required for use of a new analytical method, applicability of a precedent, feasibility of a desired schedule, etc. It should identify anticipated key participants from the licensee and the NRC technical branches.
-4 Presubmittal Meeting The licensee should work closely with the NRC project manager prior to the presubmittaI meeting to ensure that a" necessary staff attends. The licensee should request the Branch Chief of the key NRC technical organization(s) for the submittal to ensure continuity if there is a subsequent change in reviewer.
Keep the presubmittal meeting on the agenda to ensure that all key aspects of the licensing action are addressed. The NRC has indicated that it is helpful to identify the plant-specific licensing basis requirements related to the submittal and the specific findings that must be made. The presubmittal meeting must be thorough and specific in defining the plant specific licensing basis. Use the presubmittal guidance checklist to present the complete picture of the licensing basis and the proposed bases that support the change.
It is important to ask questions of the NRC staff. Do not assume that no questions mean NRC staff alignment. However, while pre-submittal meetings are useful for determining reasonable and acceptable approaches to a planned license amendment request, licensees should take care to not ask questions that seek a determination from the NRC on an appropriate course of action.
At the end of the meeting, have a thorough closing in which all parties concur with the results of the meeting. Clearly document the results of the meeting, including any outstanding issues by updating the presubmittal guidance checkliSt. Work with the NRC project manager to issue a meeting summary, by resubmitting the revised presubmittal guidance checklist. Include meeting minutes as applicable. In the subsequent submittal, refer to the pre-submittal meeting and any documented meeting summary.
Presubmittal Guidance Checklist Instruction Sheet Proposed Licensing Action: Provide a short, descriptive title of the proposed licensing action.
Licensee/Plant: Self explanatory.
Submittal Type Check Boxes: Self explanatory.
Detailed Description of Proposed licensing Action: Provide a short paragraph or bulletized list of proposed change(s). Attach additional information as needed. This section should specifically identify the governing regulation, operating license or plant technical specification section affected.
The purpose is to provide sufficient detail prior to the meeting for the NRC to independently review the proposed licensing action prior to the presubmittal meeting to identify relevant points of agreement/disagreement or areas for discussion. The detail should be sufficient for the NRC to identify the technical branches or organizations that will be involved in the licensing action and the potential presubmittal meeting.
Planned Submittal Date and Basis: Self explanatory.
Requested Approval Date It Basis: Identify linkage to specific plant conditions or outage and the associated basis.
Other: Provide any additional information that is necessary for understanding of the proposed licensing action. Summarize any specific considerations as they relate to other regulations such as 10 CFR 50.54(a), (p) or (q), 50.55a or 50.59. Discuss the potential impact of the proposed licensing action on other ongoing licensing actions, including any potential for consideration as linked licensing actions. As applicable, provide considerations regarding bundling of related submittals.
Preliminary Bases for the Proposed Change: Provide summaries of the applicable bases for the proposed licensing action.
- Technical: Summarize the purpose of the proposed change and the associated technical basis.
- Safety: Summarize the preliminary safety bases of the proposed change.
- Security: Summarize the preliminary security bases of the proposed change.
- No Significant Hazards Consideration: Identify the elements of the analysis that will be key to support the final determination. Identify key assumptions.
- Environmental: Summarize the planned approach (i.e., categorical exclusion, environmental assessment, etc.) and bases for the environmental review. Identify key assumptions.
Precedent: Identify precedent and justify applicability to the proposed licensing action. Identify and justify deviations between the approved precedent and the proposed licensing action. For the use of older precedent, provide justification that the precedent meets current NRC regulatory standards. For consolidated line item improvements (CUIPs), identify any potential deviations between the model CUIP and the proposed licensing action. Refer to NEI 06-02, Section 2.1 Identification of Precedence.
Regulatory Organization Interface: Review the Standard Review Plan (SRP) and applicable licensing precedent to identify potential technical branch and NRC organizational interfaces for the proposed licensing action. Reconcile the evaluation with the NRC project manager. Attach supporting bases for the conclusions reached, if not self-explanatory.
-2 Proposed Licensing Basis: The specific evaluations of the licensing basis of the proposed submittal should be developed early in the conceptual phase of the proposed licensing action. If a presubmittal meeting is determined to be necessary, the details provided in the following sections will establish the bulk of the agenda for the presubmittal meeting discussion. Differences between the proposed licensing basis and the current licensing basis and/or the NRC's current review criteria must be highlighted. Identify specific codes and industry standards to be used, including revision level. Include NRC-approval status of any documents. Identify deviations from NRC standards and establish the basis for the proposed deviation. Provide sufficient detail to establish the concise licensing basis of the proposed licensing actions that highlights departures from the current plant licensing basis or current NRC review standards. In some cases, decisions will not have been made regarding specific licensing bases, computer codes, etc. In those cases, at a minimum, the current licensing basis or analytical method should be identified and contrasted to current NRC review standards. Proposed options should be identified. The following sections are broken down in general compliance with regulatory classifications defined in NEI 07-06: The Nuclear Regulatory Process.
NRC Regulatory Guidance and Staff Interpretations: The NRC interprets and clarifies NRC regulatory requirements in generiC guidance documents (e.g., NUREGs, regulatory guides, and branch technical positions). NRC guidance is used to communicate approaches acceptable to the NRC staff for meeting NRC reqUirements. However, as opposed to NRC regulations, the NRC's regulatory guidance and staff interpretations do not (in and of themselves) have the force of legally binding requirements. Because NRC guidance documents are not the equivalent of NRC rules, the staff interpretations in these documents may be subject to challenge. Methods and solutions different from those set out in the NRC guidance documents may be acceptable to the NRC based upon plant-specific review.
In this section, identify the NRC regulatory guidance that establishes the current licensing basis as related to the scope of the proposed licensing action. Identify the regulatory guidance documents that will be used for the proposed licensing action. Evaluate the differences, if any, between the proposed guidance documents and the guidance documents used in the current licensing basis. Similarly evaluate deViations, if any, from the most current versions of the NRC guidance documents.
NRC Generic Communications: Generic communications address generic concerns that evolve from nuclear reactor operating experience and regulatory initiatives that have broad applicability. These generic communications do not, in and of themselves impose new requirements. However, through the regulatory process may become part of the facility licensing basis.
In this section, identify the NRC generiC communications that establish the current licensing basiS as related to the scope of the proposed licensing action. Identify the NRC generic communications that will be applied to the proposed licensing action. Evaluate the differences, if any, between the proposed application of the generic communications and the generic communications established in the current licensing basis. Similarly evaluate deviations, if any, from the most current versions of the NRC generic communications.
-3 Facility Specific Licensing Basis: The facility specific licensing basis is comprised of information exchanged between the licensee and the NRC relating to design features, equipment descriptions, operating practices, site characteristics, programs and procedures, and other factors that describe a plant's design, construction, maintenance, and operation.
Facility specific licensing basis information is contained in a variety of document types (e.g.,
final safety analysis report, license amendments, regulatory commitments, NRC SERs, etc.).
In this section, identify the facility specific licensing basis documents that establish the current licensing basis as related to the scope of the proposed licensing action. Identify and evaluate any changes to those documents that will be required for the proposed licensing action.
Industry Guidance: Industry guidance in the form of codes and standards, topical reports and other guidance (NEI, EPRI, etc), has historically been developed to address operational, technical and regulatory issues. Application of such industry guidance is typically voluntary.
However, specific facility endorsement of these documents can establish part of the licensing basis. Note that these documents will have different levels of industry and NRC, endorsement, review and approval. Some may have specifically been assessed and documented by the NRC in the form of a Safety Evaluation (SE) report or in a regulatory gUide, etc.
Identify the specific industry guidance, codes and standards, etc. that establish the current licenSing basis as related to the scope of the proposed licensing action. Identify and evaluate proposed changes. Evaluate the proposed application of industry guidance as it relates to the most current industry guidance. Identify the NRC review and approval level, if any, or past precedent of application.
Key Topical Areas: A proposed licensing action may have key technical topics and/or applied methods that are central to the NRC review and acceptance of the request. These topical areas may have been identified above in the review of the proposed licenSing basis.
Examples would include use of new calculation methodologies or acceptance criteria, new codes or standards, new computer codes, new applications of Topical Reports, etc. The purpose of this section is to highlight those key topical areas by identifying the specific technical methods that will be applied along with their associated bases and acceptance criteria.
It is not intended that all technical areas be presented in this section, but only those where there is potential deviation from established standards, precedent or current NRC expectations. By its nature this determination is subjective, but should be based on consideration of deviations from established NRC regulatory guidance, generiC communications, plant specific licensing basis or industry guidance.
-4 NOTE The above presubmittal guidance checklist information should be developed early in the conceptual phase of a proposed licensing action and can be completed for any proposed licensing action regardless of scope. The completion of the checklist, the associated evaluation and associated dialogue with the NRC project manager will help determine the potential need for, and the timing of, a presubmittal meeting.
It is expected that few licensing actions, specifically those in which there are few deviations from current licensing basis or current NRC review standards, will require a presubmittal meeting. For those licensing actions in which the scope of the action is Significant or where substantive changes from existing licensing basis or current review standards are identified, then a presubmittal meeting is encouraged.
If a presubmittal meeting is determined to be required, then the following sections should be completed.
Meeting Actions! Agreements: Document any additional actions or agreements made in the meeting including any schedule to resolve identified issues.
Presubmittal Meeting Attendees: All meeting attendees should be identified, specifically identifying the branch or technical organization represented.
The NRC will issue meeting minutes for public presubmittal meetings. The NRC should attach this checklist to the meeting minutes or at a minimum ensure that all key points of agreement as noted in this checklist are identified. Licensees should ensure that this presubmittal guidance checklist is revised to reflect the outcome of the meeting and resubmitted to the NRC for inclusion in the minutes.
Presubmittal Guidance Checklist Page 1 of5 Proposed Licensing Action:
Licen see/Plant:
License Amendment Request 0 I Relief Request 0 Detailed Description of the Proposed Licensing Action:
I Exemption Request 0 I Other 0 Planned Submittal Date:
Requested Approval Date & Basis:
Other:
Preliminary Bases for the Proposed Licensing Action:
f---~
Technical:
Safety:
Security:
No Significant Hazards Consideration:
Environmental:
I
Presubmittal Guidance Checklist Page 2 of5 Proposed Licensing Action:
Licensee/Plant:
Precedent and Date Relevance and Deltas to Proposed Licensing Action:
Regulatory Organization Interface:
o Reactor Systems o Accident Dose o Security o Electrical o Probabilistic Risk Assessment o Emergency Planning o Instrument and Controls o Fire Protection o Technical Specifications
,------~~
o Mechanical and Civil
~-~
o Piping and NDE o Special Projects c~~
~_~
o Balance of Plant o Steam Generator Tube Integrity o Health Physics o Containment and Ventilation o Component and Performance Testing o DORL - Projects o NMSS o Environmental o OE o NSIR
-~~
-~~
o OGC
-~
0
-~~
NRC Regulatory Guidance and Staff Interpretations:
Current Proposed Comments Standard Review Plan Branch Technical Positions Review Standards Regulatory Guides NUREGs Interim Staff Guidance Other
-~~
Presubmittal Guidance Checklist Page 3 of5 Proposed Licensing Action:
Licensee/Plant:
NRC Generic Communications:
Current Proposed Comments NRC Bulletins NRC Generic Letters Regulatory Information Summaries NRC Information Notices Other Facility Specific Licensing Basis:
Current Proposed Comments Updated Final Safety Analysis Report Technical Specifications Bases Technical Requirements Manual Fire Hazards Analysis Report NRC Safety Evaluation Reports NRC Correspondence Regulatory Commitments Other I
Industry Guidance:
Current Proposed Comments Codes and Standards Topical Reports Industry Initiatives and Guidelines Other
Key Topical Areas Analytical Methods Acceptance Criteria Comments Presubmittal Guidance Checklist Proposed Licensing Action:
Licensee/Plant:
Page 4 of 5
Presubmittal Guidance Checklist Page 5 of 5 Proposed Licensing Action:
Licensee/Plant:
Meeting Actions/Agreements:
- 1.
- 2.
- 3.
- 4.
- 5.
Presubmittal Meeting Attendees:
Contact Information:
AffiliatlonlTitle:
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PKG ML113210598 Mtg. N' ML112911409 Mt Summary: ML113210594 NRC-001 otlce:
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OFFICE NRRlLPL3-21PM N RRlLPL3-2/PM N RRlLPL3-2/LA NRRlLPL3-2/BC NRRlLPL3-2/PM NAME PHemandez ABillochCol6n SRohrer(BTully for)
JZimmerman ABillochCol6n DATE 12102/11 12/02/11 12/02/11 12/02/11 12/02/11