ML120820057

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G20120155/LTR-12-0084/EDATS: SECY-2012-0113 - Response to Senator Christine Kehoe Regarding San Onofre Nuclear Generating Station, Units 2 and 3 - Oversight Issues
ML120820057
Person / Time
Site: San Onofre  
Issue date: 04/09/2012
From: Leeds E
Office of Nuclear Reactor Regulation
To: Kehoe C
State of CA, Senate
Hall, J R, NRR/DORL/LPL4, 301-415-4032
Shared Package
ML120820048 List:
References
G20120155, LTR-12-0084, SECY-2012-0113
Download: ML120820057 (1)
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Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 April 9, 2012 The Honorable Christine Kehoe California Senate Sacramento, CA 95814

Dear Ms. Kehoe:

On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your letter to Chairman Gregory B. Jaczko, dated February 13, 2012, about safety and equipment concerns at the San Onofre Nuclear Generating Station (SONGS).

You stated that you share the same concerns that U.S. Senator Barbara Boxer expressed in her letter to the Chairman dated February 8, 2012. A copy of the Chairman's response to Senator Boxer, dated March 13,2012, is provided in Enclosure 1 for your information.

Senator Boxer expressed concern about the recent steam generator tube issues identified at SONGS Units 2 and 3, which you also discussed in your letter. As described in the Chairman's response to Senator Boxer, the NRC continues to closely monitor the actions of the licensee, Southern California Edison Company (SCE), as it performs additional tests and analyses to determine the cause of the leaking tube in one of the Unit 3 steam generators, and the cause(s) of the significant wear observed in some of the tubes in the steam generators of both Units 2 and 3.

On March 14, 2012, the licensee's additional testing activities in one of the Unit 3 steam generators identified three tubes that failed their pressure tests, which indicates they would be more likely to fail during certain plant events. The integrity of steam generator tubes is important because the tubes provide an additional barrier inside the containment building to prevent an inadvertent release of radioactivity. As a result of these test failures, on March 15, 2012, the NRC initiated an augmented inspection team (AIT) inspection at SONGS. The NRC typically uses an AIT to promptly review the circumstances surrounding a significant issue. In this case, the NRC is also using the AIT to make sure we understand the cause(s) of the degraded steam generator tubes at SONGS, and take appropriate actions based on our assessment of the inspection results. The NRC team, comprised of experts from the NRC Headquarters office in Rockville, Maryland, and the Region IV office in Arlington, Texas, will review information associated with the design, construction, shipping, operation, and testing of the Unit 3 steam generators. Through the AIT and related inspection activities, the NRC will continue to closely follow the licensee's evaluation of the root cause(s) of the steam generator tube problems, and the corrective actions taken to ensure that the units can be safely returned to power.

On March 27,2012, the NRC issued a Confirmatory Action Letter (CAL) to SCE, identifying those specific actions the licensee has committed to take prior to returning Units 2 and 3 to power operation. Each unit will remain shut down until the NRC has reviewed the licensee's written evaluations and responses to the CAL items for that unit, and the NRC concludes that the unit can be operated without undue risk to public health and safety, and the environment.

C. Kehoe

- 2 These determinations will be transmitted to SCE in written correspondence. A copy of the CAL is provided for your information as Enclosure 2.

The agency's response to the current steam generator issues at SONGS is part of the NRC's broader inspection program, which includes both routine and reactive inspections. Two full-time NRC resident inspectors are assigned to SONGS. Their daily inspection activities are supplemented through additional inspections performed by inspectors from our Region IV office, and other NRC offices. The NRC continuously assesses the licensee's performance at SONGS through the agency's formal Reactor Oversight Process, by analyzing the findings from all inspections and the performance indicator data reported by the licensee.

The NRC communicates its assessment of plant performance in letters to licensees, which typically are issued semi-annually. The most recent NRC annual assessment of performance at SONGS, for calendar year 2011, was documented in a letter to the licensee dated March 5,2012. A copy of that letter is provided as Enclosure 3 for your information.

Thank you for your interest in these matters.

~7/~

/

Eric J. Leeds, Director Office of Nuclear Reactor Regulation Docket Nos. 50-361 and 50-362

Enclosures:

1. Letter to Senator Boxer
2. Confirmatory Action Letter
3. Annual assessment letter

ENCLOSURE 1 Chairman Jaczko's letter to Senator Boxer dated March 13, 2012 ADAMS Accession Number ML12053A440

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 CHAIRMAN March 13, 2012 The Honorable Barbara Boxer Chairman, Committee on Environment and Public Works United States Senate Washington, D.C. 20510

Dear Madam Chairman:

On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your letter of February 8, 2012, regarding recent events at the San Onofre Nuclear Generating Station (SONGS). The specific concerns you cited related to the Unit 2 and Unit 3 steam generators, a worker fall during refueling, and an ammonia leak.

The NRC requires licensees to implement a steam generator inspection program to ensure tube integrity. In accordance with this program, a 100 percent inspection of all steam generator tubes was conducted (approximately 10,000 tubes per steam generator), during a scheduled refueling outage at Unit 2 that began on January 10, 2012. Wear (tube thinning) was observed at various locations along the tube lengths, similar to what has been observed in steam generators that are similar to those at SONGS. A limited number of unexpected wear indications were observed at a particular support structure that is unique to steam generators fabricated by Mitsubishi. These wear indications were large enough to warrant additional testing, which was performed and confirmed the structural integrity of the tubes.

Following completion of the steam generator tube testing, six tubes were plugged based on an established plugging criteria for removing tubes from service. Plugging is a method that prevents reactor water from entering a tube, thus removing it from service and stopping it from leaking to the non-radioactive portion of the steam generator. Precautionary plugging of 186 additional tubes where unexpected wear was identified also was completed NRC specialist inspectors and an NRC steam generator expert have been observing licensee actions during this testing as part of our normal inspection program. They also will verify that the licensee's actions meet NRC regulations and review the licensee procedures to ensure the steam generators will perform their function safely through the next operating cycle.

Unit 3 had been operating for approximately one year following replacement of the steam generators when operators in the control room received alarms on January 31, 2012, indicating that reactor cooling water was leaking into one of the steam generator's secondary, or non-radioactive side. The leak was unexpected, and the licensee responded in accordance with its procedures to perform a rapid shutdown, as a precautionary measure. The estimated leak rate was 75 gallons per day, about half the rate that would require action by the licensee.

- 2 The first indications of the leak were radiation alarms from monitors that continuously sample a vent stack for the purpose of rapidly identifying steam generator tube leaks. The small amount of radioactivity that was released through this vent stack, confirmed by NRC inspectors, was much smaller than is allowed by NRC regulations.

SONGS operators brought the unit into cold shutdown on February 2, 2012, and began steam generator tube inspections on February 12, 2012. The inspection confirmed the location of the leak was limited to one tube. NRC staff is continuing to review the licensee's evaluation of the cause of the leaking tube and the licensee's inspection of 100 percent of the tubes in both steam generators. As in Unit 2, the steam generator tubes will be pressure tested to evaluate their integrity. The root cause of the tube leak has not yet been determined. For both Units 2 and 3, SONGS will evaluate the results of their inspections to determine the appropriate length of time before the next inspection. NRC approval is not required for the licensee to restart Units 2 and 3. NRC inspectors will perform an independent evaluation of the licensee's operational assessment report and preliminary cause evaluation prior to startup.

Regarding the contract worker who fell into the refueling cavity at Unit 2 during refueling activities, he was adjusting the position of a pole-mounted light used to illuminate the refueling cavity at Unit 2 when he lost his balance and fell into the reactor cavity. At the time of the incident, all of the reactor fuel had already been removed and was in the spent fuel pool.

Since the cavity was completely flooded, it was only a one-foot fall, and the flotation vest the individual was wearing prevented him from submerging more than a few feet into the water.

He did not suffer any injuries.

The licensee evaluated the individual's dose as a result of falling into the water.

Although the water is filtered, it does contain low levels of radioactive contamination. The licensee found small amounts of contamination on the worker's skin, which was easily removed by soap and water. The licensee also used bioassay techniques (including urine testing) to estimate any internal contamination. The total dose to the individual was estimated at less than five miJlirem. The allowed dose for plant workers is 5,000 millirem per year.

Finally, as a result of an ammonia leak from a tank in the turbine building, on November 1, 2011, operators at SONGS declared an alert, in accordance with the plant's approved procedures. Operators exited the alert after approximately three hours, when the leak had been isolated and ammonia levels in the turbine building had reduced sufficiently to allow personnel access. Ammonia is used for maintaining the water chemistry in the secondary water (steam cycle side) of the power plant.

The cause of the leak was attributed to operators failing to promptly find and stop a slowly rising level in the ammonia tank, which eventually resulted in the tank overflowing. The ammonia was contained within a berm around the tank; however, the ammonia vapors quickly flowed into the turbine building, causing the building to be evacuated.

- 3 Since that time, the licensee has improved the procedure related to ammonia tank level problems and improved the general maintenance performed in the secondary parts of the plant.

The ammonia spill was not large enough to affect individuals offsite.

In all of these cases, there has been extensive engagement by NRC staff with the licensee, and our inspection efforts have been closely coordinated. If the NRC determines that there are any generic issues of interest resulting from these events, we will not hesitate to share that information widely through our operating experience program.

Thank you for your interest in this matter. Please contact me or Ms. Rebecca Schmidt, Director of the Office of Congressional Affairs, at (301) 415-1776, if you have any questions or would like to discuss this further.

Sincerely, IRA!

Gregory B. Jaczko

ENCLOSURE 2 Confirmatory Action Letter for San Onofre NucleaJ Generating Station dated March 27, 2012 ADAMS Accession Number ML12087A323

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 EAST LAMAR BLVD ARLINGTON, TEXAS 76011-4511 March 27,2012 CAL 4-12-001 Mr. Peter Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128

SUBJECT:

CONFIRMATORY ACTION LETTER - SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3, COMMITMENTS TO ADDRESS STEAM GENERATOR TUBE DEGRADATION

Dear Mr. Dietrich:

On January 31, 2012, your staff at San Onofre Nuclear Generating Station (SONGS) Unit 3 performed a rapid shutdown because of indications of a steam generator tube leak on the 3E88 steam generator. Following extensive testing of 100 percent of the steam generator tubes in both Unit 3 steam generators, your staff identified unexpected wear caused by steam generator tubes rubbing against each other, as well as against retainer bars. Additional in-situ pressure testing of 129 steam generator tubes was performed for the tubes that exhibited the most wear.

Your staff identified that eight steam generator tubes in the Unit 3 3E88 steam generator had failed the pressure test. Failure of the in-situ pressure test is an indication that, for certain design basis events, such as a main steam line break, these steam generator tubes may not be able to maintain design structural integrity. You are continuing to evaluate these results to develop corrective actions for the Unit 3 steam generators.

SONGS Unit 2 was shutdown at the time of this event for a regularly scheduled refueling outage, and planned testing of 100 percent of the steam generator tubes was already in progress. Testing results on Unit 2 showed unexpected wear at retainer bars similar to the Unit 3 results, but did not show any wear from tubes rubbing against each other. Based on these results, your staff identified 6 tubes requiring plugging, and 186 additional tubes that were plugged as a precautionary measure. Evaluation for additional plugging or other corrective actions is continuing for Unit 2, based on ongoing evaluations of Unit 3 testing results.

P. Dietrich

-2 For both Units 2 and 3, this was the first cycle of operation with new replacement steam generators. Unit 2 replaced its steam generators in January 2010, and Unit 3 in January 2011.

Each steam generator has 9,727 steam generator tubes.

On March 23, 2012, you sent NRC a letter describing the actions you were committing to take prior to returning Units 2 and 3 to power operation (Agencywide Documents Access and Management System (ADAMS) Accession Number ML12086A182). In a phone conversation on March 26, 2012, I confirmed with you the commitments as described in your letter. This Confirmatory Action Letter (CAL) confirms that SONGS Unit 2 will not enter Mode 2, and SONGS Unit 3 will not enter Mode 4 (as defined in the technical specifications), until the NRC has completed its review of your actions listed below. The permission to resume power operations will be formally communicated to you in written correspondence.

Actions for Unit 2

1.

Southern California Edison Company (SCE) will determine the causes of the tube-to-tube interactions that resulted in steam generator tube wear in Unit 3, and will implement actions to prevent loss of integrity due to these causes in the Unit 2 steam generator tubes. SCE will establish a protocol of inspections and/or operational limits for Unit 2, including plans for a mid-cycle shutdown for further inspections.

2.

Prior to entry of Unit 2 into Mode 2, SCE will submit to the NRC in writing the results of your assessment of Unit 2 steam generators, the protocol of inspections and/or operational limits, including schedule dates for a mid-cycle shutdown for further inspections, and the basis for SCE's conclusion that there is reasonable assurance, as required by NRC regulations, that the unit will operate safely.

Actions for Unit 3

3.

SCE will complete in-situ pressure testing of tubes with potentially significant wear indications in accordance with the Electric Power Research Institute (EPRI) Steam Generator In-situ Pressure Test Guidelines and will plug tubes in accordance with those guidelines.

4.

SCE will plug all tubes with wear indications in excess of your Steam Generator Program Requirements (SGPR) and EPRI guidelines as well as perform preventive plugging or take other corrective actions to address retainer bar-related tube wear in Unit 3.

5.

SCE will determine the causes of tube-to-tube interaction and implement actions to prevent recurrence of loss of integrity in the Unit 3 steam generator tubes while operating.

6.

SCE will establish a protocol of inspections and/or operational limits for Unit 3, including plans for a mid-cycle shutdown for inspections. The protocol is intended to minimize the progression of tube wear, and ensure that tube wear will not progress to the point of degradation that could cause tubes not to meet leakage and structural strength test criteria.

P. Dietrich

- 3

7.

Prior to entry of Unit 3 into Mode 4, SCE will submit to the NRC in writing the results of your assessment of Unit 3 steam generators, the protocol of inspections and/or operational limits, including schedule dates for a mid-cycle shutdown for further inspections, and the basis for SCE's conclusion that there is a reasonable assurance, as required by NRC regulations, that the unit will operate safely.

This CAL will remain in effect until the NRC has (1) reviewed your response to the actions above, including responses to staff's questions and the results of your evaluations, and (2) the staff communicates to you in written correspondence that it has concluded that SONGS Units 2 and 3 can be operated without undue risk to public health and safety, and the environment.

Issuance of this CAL does not preclude the issuance of an order formalizing the above commitments or requiring other actions on the part of SCE; nor does it preclude the NRC from taking enforcement actions for violations of NRC requirements that may have prompted the issuance of this letter. Failure to take the actions as described in this CAL may also result in an order if the NRC determines that failure to meet that action would result in a loss of reasonable assurance of the protection of public health and safety, and the environment.

Pursuant to Section 182 of the Atomic Energy Act of 1954, as amended (42 U.S.C. 2232), you are required to:

(1)

Notify me immediately if your understanding differs from that set forth above; (2)

Notify me if for any reason you cannot complete the actions and your proposed alternatives; and (3)

Notify me in writing when you have completed the actions addressed in this Confirmatory Action Letter.

In accordance with 10 CFR 2.390 of the NRC's regulations a copy of this letter, and any response will be made available electronically for public inspection in the NRC Public Document Room or from the ADAMS, accessible from the NRC Web site at http://www.nrc.gov/readingrm/adams.html. To the extent pOSSible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

P. Dietrich

- 4 Please contact Ryan Lantz at (817) 200-1173 if you have any questions concerning this letter.

Sincerely, IRA!

Elmo E. Collins Regional Administrator Docket No.: 50-361, 50-362 License No.: NPF-10, NPF-15 cc: Electronic Distribution

ENCLOSURE 3 Annual Assessment Letter for San Ono'fre Nuclear Generating Station dated March 5, 2012 ADAMS Accession Number ML120610641

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 EAST LAIYAR BLVD ARLINGTON, TEXAS 76011-4511 March 5, 2012 Mr. Peter Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 SUB~IECT:

ANNUAL ASSESSMENT LETTER FOR SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 (REPORT 05000361;362/2011001)

Dear Mr. Dietrich:

On February 15, 2012, the NRC completed its end-of-cycle performance review of San Onofre Nuclear Generating Station (SONGS), Units 2 and 3. The NRC reviewed the most recent quarterly performance indicators (Pis) in addition to inspection results and enforcement actions from January 1, 2011 through December 31, 2011. This letter informs you of the NRC's assessment of your facility during this period and its plans for future inspections at your facility.

This performance review and enclosed inspection plan do not include security information. A separate letter will include the NRC's assessment of your performance in the Security Cornerstone and its security-related inspection plan.

The NRC determined that overall, SONGS, Units 2 and 3, operated in a manner that preserved public health and safety and met all cornerstone objectives. The NRC determined the performance at SONGS, Units 2 and 3 during the most recent quarter was within the Licensee Response Column of the NRC's Reactor Oversight Process (ROP) Action Matrix because all inspection findings had very low (Le., green) safety significance, and all Pis indicated that your performance was within the nominal, expected range (Le., green). Therefore, the NRC plans to conduct ROP baseline inspections at your facility.

The substantive cross-cutting issue (SCCI) in human performance, decision-making 'Component, associated with the aspect of conservative assumptions in decision-making [H.1 (b)] was originally opened following the mid-cycle assessment of 2009. The facility has demonstrated effective corrective actions in addreSSing this SCCI, as determined by our inspections as well as a decreasing trend in the number of findings with this aspect. Therefore, the NRC determined that this SCCI in human performance [H.1 (b)] is closed.

A new theme was identified in the human performance area, resources component, associated with the aspect of procedure quality H.2(c). You have taken several actions to address this new theme, including a thorough evaluation of corrective actions resulting in identification of new as well as revisions to past corrective actions, and completion of a common cause evaluation to

P. Dietrich

-2 look for other potentially affected areas. The NRC is not opening a new SCCI in Human Performance H.2(c) based on your efforts to address this new theme.

NRC issued a chilling effect letter to Southern California Edison in March 2010. Multiple inspections, including two focused Problem Identification and Resolution inspections in January and May 2011, as well as public meetings, were conducted to review your corrective actions to address the issues identified in the chilling effect letter. Based on the inspection results, the overall results of your safety conscious work environment assessments and associated corrective actions, the NRC closed the chilling effect letter on September 6,2011, and informed you that NRC will continue to monitor your efforts to improve the safety conscious work environment at the site through baseline inspection efforts.

The enclosed inspection plan lists the inspections scheduled through June 30, 2013. Routine inspections performed by resident inspectors are not included in the inspection plan. The inspections listed during the last nine months of the inspection plan are tentative and may be revised at the mid-cycle performance review. The NRC provides the inspection plan to allow for the resolution of any scheduling conflicts and personnel availability issues. The NRC will contact you as soon as possible to discuss changes to the inspection plan should circumstances warrant any changes.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.htrnl (the Public Electronic Reading Room).

Please contact me at (817) 200-1173 with any questions you have regarding this letter.

Sincerely, IRAI Ryan E. Lantz. Chief Reactor Projects, Branch D Division of Reactor Projects Docket Nos.: 50-361, 50-362 License Nos.: NPF-10, NPF-15

Enclosure:

San Onofre Nuclear Generating Station Inspection Activity Plan cc w/Enciosure: Electronic Distribution

02129/2012 Page 1 of2 Report 22

!lJi1jt' I Number 2,3 2,3 2,3 2,3 2,3 2,3 2,3 2,3 2,3 2,3 2,3 2,3 2,3 2,3 2,3 2,3 2,3 2,3 2

3 2

3 2,3 2,3 San Onofre 07:28:40 Inspection 1Activity Plan 04/01/2012 - 06/30/2013 Planned Dates Start End Title 03/01/2012 12/3112012 04/08/2012 0411412012 05/24/2012 0513112012 06/18/2012 0613012012 06/18/2012 0613012012 06/18/2012 06/3012012 06/18/2012 06/30/2012 06/25/2012 06/29/2012 06/25/2012 06/29/2012 06/25/2012 06/29/2012 06/25/2012 06/29/2012 06/25/2012 0612912012 06/2512012 06/2912012 07/23/2012 07/27/2012 07/23/2012 07/27/2012 07/23/2012 07/27/2012 07/23/2012 07/27/2012 07/30/2012 08/03/2012 09110/2012 09/14/2012 09/10/2012 09/14/2012 10/15/2012 10/19/2012 10/15/2012 10/1912012 01/01/2013 06/30/2013 05/20/2013 0512412013 TI*182 IP 2515/182 TSB-52B IP 71152B EB1-07T IP 7111107T EB1-17T IP 7111117T

- UNDERGROUND PIPING PHASE 1 2

Review of the Implementation of the Industry Initiative to Control Degradation of Underground Piping

- BIENNIAL PI&R INSPECTION 7

Problem Identification and Resolution

- HEAT SINK PERFORMANCE 1

Heat Sink Performance

  • 50.59 & PERM PLANT MODS 4

Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications IP 7111117T-chng/tst changeltest/evaluations IP 7111117T -eva Is evaluations IP 7111117T -permmod permanent mods Ep*1

  • RADIATION SAFETY TEAM INSPECTION 4

Radiation Monitoring Instrumentation Radioactive Gaseous and Liquid Effluent Treatment Radiological Environmental Monitoring Program Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation

- BRQ INSPECTION 2

Licensed Operator Requalification Program

  • INITIAL OPERATOR EXAM 6

INTIAL EXAM UNIT 2-SONGS (01/01/2012)

INTIAL EXAM FOR SONGS, UNIT 3, START DATE (01/01/2012)

INTIAL EXAM UNIT 2-SONGS (01/01/2012)

INTIAL EXAM FOR SONGS, UNIT 3, START DATE (0110112012)

- UNDERGROUND PIPING PHASE 1 2

Review of the Implementation of the Industry Initiative to Control Degradation of Underground Piping

- BIENNIAL EXERCISE INSPECTION 4

Exercise Evaluation This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

1

Page 2 of 2 San Onofre 0212912012 07:28:40 Inspection I Activity Plan Report 22 0410112012 - 06/3012013 Planned Dates Start End Title EB2-05T

- TRIENNIAL FIRE PROTECTION INSPECTION 4

2,3 06/10/2013 06/14/2013 IP 7111105T Fire Protection [friennial]

2,3 0612412013 06/28/2013 IP 7111105T Fire Protection [Triennial]

This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

PackaQe: ML120820048, Incoming ML12068A279, ResJ)onse M 120820057 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA QTE*

OGC NAME JHall JBurkhardt JDougherty EWiliiamson - NLO DATE 03/27/12 03/26/12 03/30/12 04/04/12 OFFICE NRR/DORL/LPL4/BC NRR/DORLID NRR/D NAME MMarkley(KKalyanam for) MEvans (AHowe for)

ELeeds DATE 03/30/12 04/04/12 04/09/12

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