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MONTHYEARML11256A0512011-09-0909 September 2011 Application for Consent to Proposed License Transfers: Request for Threshold Determination Project stage: Request ML1201000752012-02-14014 February 2012 Partial Acceptance of Requested Licensing Action Application for Consent to Proposed License Transfers; Request for Threshold Determination Project stage: Acceptance Review ML1201005082012-02-15015 February 2012 Notice of Consideration of Approval of Application Regarding Proposed Acquisition and Opportunity for a Hearing Project stage: Request ML1201004982012-02-15015 February 2012 Notice of Consideration of Approval of Application Regarding Proposed Acquisition and Opportunity for a Hearing - Millstone Power Station, Unit No. 3 Project stage: Other ML1206602302012-03-30030 March 2012 Request for Additional Information Regarding Proposed License Transfers; Request for Threshold Determination Project stage: RAI ML12100A0172012-04-0606 April 2012 Connecticut Yankee, and Yankee Atomic, Response to Nrc'S Request for Additional Information Regarding Proposed License License Transfers Request for Threshold Determination Project stage: Request ML1213004722012-06-15015 June 2012 Order Approving Application Regarding Merger of Central Vermont Public Service Corporation and Gaz Metro Limited Partnership and Resultant Indirect Transfer of License Project stage: Other ML12165A5082012-06-15015 June 2012 MS3-Threshold Attachment Project stage: Other ML12205A0302012-07-19019 July 2012 Central Vermont Public Service Corporation, Supplemental Information Project stage: Supplement ML12207A1242012-07-23023 July 2012 Conforming License Amendment Request Project stage: Request 2012-03-30
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Category:Letter
MONTHYEARIR 05000336/20234022024-01-30030 January 2024 Security Baseline Inspection Report 05000336/2023402 and 05000423/2023402 (Cover Letter Only) ML24030A7522024-01-30030 January 2024 Technical Specification Bases Pages ML23341A0172024-01-12012 January 2024 Issuance of Amendment No. 288 Revision to Applicability Term for Reactor Coolant System Heatup and Cooldown Pressure-Temperature Limitations Figures ML24025A0392024-01-12012 January 2024 Independent Spent Fuel Storage Installation, Property Insurance Coverage IR 05000336/20234402024-01-11011 January 2024 Special Inspection Report 05000336/2023440 and 05000423/2023440 (Cover Letter Only) ML23342A0972024-01-0909 January 2024 Connecticut Yankee Atomic Power Company - Independent Spent Fuel Storage Installation Security Inspection Plan ML23342A1112024-01-0909 January 2024 Company - Independent Spent Fuel Storage Installation Security Inspection Plan ML24004A1052024-01-0404 January 2024 Request for Information for a Biennial Problem Identification and Resolution Inspection; Inspection Report 05000336/2024010 & 05000423/2024010 ML23361A0942023-12-21021 December 2023 Response to Request for Additional Information Regarding Proposed License Amendment Request to Revise Technical Specifications for Reactor Core Safety Limits, Fuel Assemblies and Core Operating Limits Report . ML23361A0312023-12-20020 December 2023 Intent to Pursue Subsequent License Renewal ML23283A3052023-12-20020 December 2023 Review of Appendix F to DOM-NAF2, Qualification of the Framatome ORFEO-GAIA and ORFEO-NMGRID CHF Correlations in the Dominion Energy VIPRE-D Computer Code (EPID L-2022-LLT-0003) (Nonproprietary) ML23352A0202023-12-18018 December 2023 Senior Reactor and Reactor Operator Initial License Examinations CY-23-014, Biennial Update of the CYAPCO Quality Assurance Program for the Haddam Neck ISFSI2023-12-0404 December 2023 Biennial Update of the CYAPCO Quality Assurance Program for the Haddam Neck ISFSI ML23334A2242023-11-30030 November 2023 Request for Exemption from Enhanced Weapons Firearms Background Checks, and Security Event Notifications Implementation ML23324A4222023-11-20020 November 2023 Reactor Vessel Internals Inspections Aging Management Program Submittal Related to License Renewal Commitment 13 ML23324A4302023-11-20020 November 2023 Alloy 600 Aging Management Program Submittal Related to License Renewal Commitment 15 ML23317A2702023-11-13013 November 2023 Core Operating Limits Report, Cycle 23 IR 05000336/20230032023-11-0606 November 2023 Integrated Inspection Report 05000336/2023003 and 05000423/2023003 ML23298A1652023-10-26026 October 2023 Requalification Program Inspection IR 05000336/20234202023-10-0404 October 2023 Security Inspection Report 05000336/2023420 and 05000423/2023420 IR 07200031/20234012023-10-0404 October 2023 Yankee Atomic Electric Company - Independent Spent Fuel Storage Security Inspection Report 07200031/2023401 ML23230A0502023-10-0202 October 2023 5 of the Quality Assurance Topical Report - Review of Program Changes ML23226A0052023-09-26026 September 2023 Issuance of Amendment No. 287 Supplement to Spent Fuel Pool Criticality Safety Analysis IR 05000245/20230012023-09-19019 September 2023 Safstor Inspection Report 05000245/2023001 IR 05000336/20230102023-09-0808 September 2023 Commercial Grade Dedication Report 05000336/2023010 and 05000423/2023010 IR 05000336/20230052023-08-31031 August 2023 Updated Inspection Plan for Millstone Power Station, Units 2 and 3 (Report 05000336/2023005 and 05000423/2023005) ML23248A2132023-08-30030 August 2023 Response to Request for Additional Information Regarding Proposed License Amendment Request to Revise the Applicability Term for Reactor Coolant System Heatup and Cooldown Pressure-Temperature. ML23242A0142023-08-30030 August 2023 Operator Licensing Examination Approval ML23223A0552023-08-18018 August 2023 Request for Withholding Information from Public Disclosure for License Amendment Request to Revise Technical Specifications for Reactor Core Safety Limits, Fuel Assemblies, and COLR Related to Framatome Gaia Fuel ML23223A0482023-08-18018 August 2023 Request for Withholding Information from Public Disclosure for License Amendment Request to Use Framatome Small Break and Realistic Large Break LOCA Evaluation Methodologies for Establishing COLR Limits IR 05000336/20230022023-08-0909 August 2023 Integrated Inspection Report 05000336/2023002 and 05000423/2023002 ML23188A0432023-07-31031 July 2023 Authorization and Safety Evaluation for Alternative Request No. IR-04-11 ML23208A0922023-07-26026 July 2023 Request for Approval of Appendix F of Fleet Report DOM-NAF-2-P Qualification of Framatome ORFEO-GAIA and OORFE-NMGRID CHF Correlations in the Dominion Energy Vipre-D Computer Code Response ML23207A1102023-07-26026 July 2023 NRC Regulatory Issues Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations ML23188A0202023-07-26026 July 2023 Closeout of Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors IR 05000336/20234012023-07-17017 July 2023 Material Control and Accounting Program Inspection Report 05000336/2023401 and 05000423/2023401 - (Cover Letter Only) ML23175A0052023-07-12012 July 2023 Alternative Request P-07 for Pump Periodic Verification Testing Program for Containment Recirculation Spray System Pumps 2024-01-09
[Table view] Category:Safety Evaluation
MONTHYEARML23341A0172024-01-12012 January 2024 Issuance of Amendment No. 288 Revision to Applicability Term for Reactor Coolant System Heatup and Cooldown Pressure-Temperature Limitations Figures ML23283A3052023-12-20020 December 2023 Review of Appendix F to DOM-NAF2, Qualification of the Framatome ORFEO-GAIA and ORFEO-NMGRID CHF Correlations in the Dominion Energy VIPRE-D Computer Code (EPID L-2022-LLT-0003) (Nonproprietary) ML23230A0502023-10-0202 October 2023 5 of the Quality Assurance Topical Report - Review of Program Changes ML23226A0052023-09-26026 September 2023 Issuance of Amendment No. 287 Supplement to Spent Fuel Pool Criticality Safety Analysis ML23188A0432023-07-31031 July 2023 Authorization and Safety Evaluation for Alternative Request No. IR-04-11 ML23175A0052023-07-12012 July 2023 Alternative Request P-07 for Pump Periodic Verification Testing Program for Containment Recirculation Spray System Pumps ML23072A0892023-05-0101 May 2023 (Amendments 346 & 286), North Anna 1 & 2 (Amnds 294 & 277), Surry 1 & 2 (Amnds 311 & 311), and Summer 1 (Amd 225) - Issuance of Amendments to Revise TSs to Adopt TSTF-554 Revise Reactor Coolant Leakage Requirements ML23058A4542023-03-16016 March 2023 Issuance of Amendment Nos. 345 and 285 Regarding Adoption of Technical Specification Task Force-359, Increase Flexibility in Mode Restraints ML21320A0072022-09-0707 September 2022 Review of Appendix E to DOM-NAF-2, Qualification of the Framatome BWU-I CHF Correlation in the Dominion Energy VIPRE-D Computer Code (EPID L-2021-LLT-0000) (Non-Proprietary) ML22201A5082022-07-28028 July 2022 Authorization and Safety Evaluation for Alternative Request No. IR-04-09 ML22095A1072022-07-11011 July 2022 Issuance of Amendment Nos. 120, 344, & 284, 293 & 276, & 307 & 307 to Relocate Requirements to the QAPD ML22039A3392022-03-0303 March 2022 Request for Alternative Frequency to Supplemental Valve Position Verification Testing Requirements in the Fourth 10-year Valve Inservice Testing Program ML22041A0102022-03-0101 March 2022 V.C. Summer 1, Issuance of Amendment Nos. 283 (Millstone), 291 and 274 (North Anna), and 221 (Summer) to Revise TSs to Adopt TSTF-569 Revision of Response Time Testing Definition ML22007A1512022-02-16016 February 2022 Issuance of Amendment No. 282 Regarding Shutdown Bank Technical Specification Requirements and Alternate Control Rod Position Monitoring Requirements ML21326A0992022-01-0707 January 2022 Issuance of Amendment No. 281 Regarding Revised Reactor Core Safety Limit to Reflect Topical Report WCAP-177642-P-A, Revision 1 ML21262A0012021-11-0909 November 2021 Issuance of Amendment No. 280 Regarding Measurement Uncertainty Recapture Power Uprate ML21284A0062021-10-29029 October 2021 Authorization and Safety Evaluation for Alternative Request No. RR-05-04 and IR-4-02 ML21227A0002021-10-0505 October 2021 Issuance of Amendment No. 279 Regarding Addition of Analytical Methodology to the Core Operating Limits Report for a Large Break Loss-of-Coolant Accident ML21222A2302021-09-0909 September 2021 Issuance of Amendment No. 343 Revision to Technical Specifications for Steam Generator Inspection Frequency (L-2020-LLA-0227) ML21174A0202021-08-0202 August 2021 Relief Request for Limited Coverage Examinations Performed in the Fourth 10-Year Inservice Inspection Interval ML21167A3552021-07-16016 July 2021 Authorization and Safety Evaluation for Alternative Request No. RR-05-06 ML21167A2112021-06-30030 June 2021 Relief Request for Limited Coverage Examinations Performed in the Third 10-Year Inservice Inspection Interval (EPID L-2020-LLR-0081 Through L-2020-LLR-0088) ML21075A0452021-03-26026 March 2021 Request to Utilize Code Case N-885 ML21043A1622021-03-25025 March 2021 Issuance of Amendment No. 278 Regarding Revision to Battery Surveillance Requirements ML21026A1422021-02-23023 February 2021 Issuance of Amendment No. 342 Revision to Technical Specification Table 3.3-11, Accident Monitoring Instrumentation ML20312A0022020-12-10010 December 2020 Relief Request for Limited Coverage Examinations Performed in the Third 10-Year Inservice Inspection Interval (EPID L-2020-LLR-0027 Through L-2020-LLR-0032) ML20312A0012020-12-10010 December 2020 Relief Requests for Limited Coverage Examinations Performed in the Fourth 10-Year Inservice Inspection Interval ML20287A4712020-10-20020 October 2020 Proposed Alternative RR-05-05 to the Requirements of the ASME Code Containment Unbonded Post-Tensioning System Inservice Inspection Requirements ML20275A0002020-10-14014 October 2020 Issuance of Amendment No. 277 to Revise Technical Specification 6.8.4.g to Allow a One-Time Deferral of the Steam Generator Inspections ML20237H9952020-09-29029 September 2020 Issuance of Amendment No. 341 Revision to Technical Specification 6.25, Pre-Stressed Concrete Containment Tendon Surveillance Program ML20252A0072020-09-15015 September 2020 Request to Use a Provision of a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI ML20191A0042020-08-0707 August 2020 Issuance of Amendment No. 340 Revised Technical Specification Limits for Primary and Secondary Coolant Activity ML20189A2062020-07-16016 July 2020 Relief Request IR-4-03 Concerning Non-Code Methodology to Demonstrate Structural Integrity of Class 3 Moderate-Energy Piping ML20161A0002020-07-15015 July 2020 Issuance of Amendment No. 276 Regarding Revision to the Integrated Leak Rate Type a and Type C Test Intervals ML20140A3692020-06-24024 June 2020 Issuance of Amendment No. 339 Extension of Technical Specification 3.8.1.1, A.C. Sources - Operating, Allowed Outage Time ML20080K5082020-03-24024 March 2020 Alternative Request RR-05-03 for the Fifth 10-Year Inservice Inspection Interval ML19340A0252020-01-30030 January 2020 Issuance of Amendment No. 337 Regarding Adoption of 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structure, Systems, and Components of Nuclear Power Reactors ML19305D2482019-12-31031 December 2019 Issuance of Amendments Adoption of Emergency Action Level Schemes Per NEI 99-01, Rev. 6 ML19340A0012019-12-18018 December 2019 Proposed Alternative Request IR-4-01 Use of Encoded Phased Array Ultrasonic Examination Techniques in Lieu of Radiography ML19338G3722019-12-18018 December 2019 Alternative Requests RR-05-01 and RR-05-02 for the Fifth 10-Year Inservice Inspection Interval ML19340A0002019-12-13013 December 2019 Relief Request IR-3-39, Proposed Alternative to ASME Code Weld Preheat Requirements ML19126A0002019-05-28028 May 2019 Issuance of Amendment No. 273 Regarding Technical Specification Changes for Spent Fuel Storage and New Fuel Storage ML19098A0342019-04-30030 April 2019 Units 1 and 2; Limerick, Units 1 and 2; Peach Bottom, Units 2 and 3, and Quad Cities, Units 1 and 2 - Revision to Approved Alternative to Use BWR Vessel and Internal Proj Guidelins ML19042A2772019-03-21021 March 2019 Issuance of Amendment No. 272 Regarding Revision to Technical Specification Action Statement for Loss of Control Building Inlet Ventilation Radiation Monitor Instrumentation Channels ML18290A6022018-11-13013 November 2018 Alternative Requests Related to the Fifth and Fourth 10-Year Interval Pump, Valve, and Snubber Inservice Testing Programs, Respectively (EPID L-2018-LLR- 0012 Through EPID L-2018-LLR-0022) ML18275A0122018-10-0404 October 2018 Alternative Request P-06 for the 'C' Charging Pump Test Frequency ML18246A0072018-09-25025 September 2018 Issuance of Amendment No. 335 Regarding Revision to the Integrated Leak Rate Type a and Type C Test Intervals ML18252A0032018-09-17017 September 2018 Alternative Requests RR-04-27 and IR-3-38 for the Use of Encoded Phased Array Ultrasonic Examination Techniques in Lieu of Radiography ML18225A0202018-08-29029 August 2018 ISFSI; North Anna 1 & 2 Isfsls, and Unit 3; Surry Power 1 & 2, and Isfsls); Dominion Energy Kewaunee, Inc. (Kewaunee Power Station and Isfsi): Request for Threshold Determination Under 10 CFR 50.80 ML18038B2002018-02-26026 February 2018 Issuance of Amendment Nos. 118, 334, and 271 to Revise Licensee'S Name (CAC Nos. MF9844, MF9845, and MF9848; EPID L-2017-LLA-0245 and EPID L-2017-LLA-0346) 2024-01-12
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June 15, 2012 Mr. Dale A. Rocheleau Senior Vice President, General Counsel
& Corporate Secretary Central Vermont Public Service Corporation 77 Grove St.
Rutland, VT 05701
SUBJECT:
REQUEST FOR THRESHOLD DETERMINATION UNDER 10 CFR 50.80 -
THE PROPOSED MERGER BETWEEN CVPS AND GAZ MÉTRO INVOLVING MINORITY COMMON STOCK OWNERSHIP IN MAINE YANKEE ATOMIC COMPANY, CONNECTICUT YANKEE ATOMIC COMPANY, AND YANKEE ATOMIC ELECTRIC COMPANY (TAC NO. ME7127)
Dear Mr. Rocheleau:
By application dated September 9, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML11256A051), Central Vermont Public Service Corporation (CVPS) and Gaz Métro Limited Partnership (Gaz Métro) notified the U.S. Nuclear Regulatory Commission (NRC) of a proposed merger between the two companies that would result in a transfer of interests involving NRC licensed facilities. The Application requested that the NRC staff make a threshold determination that the proposed transfer of CVPS interests in Maine Yankee Atomic Power Company (Maine Yankee), Connecticut Yankee Atomic Power Company (Connecticut Yankee), and Yankee Atomic Electric Company (Yankee Atomic) (collectively, the Yankee Companies) to Gaz Métro would not constitute a direct or indirect transfer of the licenses that would require NRC approval pursuant to Title 10 of the Code of Federal Regulations (10 CFR) CFR 50.80, Transfer of licenses.
The NRC staff completed its review of the facts and information as set forth in the application, and concludes that the proposed merger between CVPS and Gaz Métro will not constitute a direct or indirect transfer of control of the Maine Yankee, Connecticut Yankee or Yankee Atomic licenses. Therefore, neither Maine Yankee, Connecticut Yankee, nor Yankee Atomic require the NRCs approval under Section 184 of the Atomic Energy Act of 1954, as amended, and 10 CFR 50.80, with respect to the licenses currently held by them in connection with the proposed merger between CVPS and Gaz Metro.
Enclosure 3
D. Rocheleau Please contact James Kim at 310-415-4125 if you have any questions.
Sincerely,
/RA/
Louise Lund, Acting Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-423
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR THRESHOLD DETERMINATION OF THE PROPOSED MERGER BETWEEN CVPS AND GAZ MÉTRO INVOLVING MINORITY COMMON STOCK OWNERSHIP IN MAINE YANKEE ATOMIC COMPANY, CONNECTICUT YANKEE ATOMIC COMPANY, AND YANKEE ATOMIC ELECTRIC COMPANY DOCKET NOS. 50-309, 72-30; 50-213, 72-39;50-029; 72-31
1.0 INTRODUCTION
By application dated September 9, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML11256A051), Central Vermont Public Service Corporation (CVPS) and Gaz Métro Limited Partnership (Gaz Métro) notified the U.S. Nuclear Regulatory Commission (NRC) of a proposed merger between the two companies that would result in a transfer of interests involving NRC licensed facilities. The application requested that the NRC make a threshold determination whether a proposed transfer of CVPS interests in Maine Yankee Atomic Power Company (Maine Yankee), Connecticut Yankee Atomic Power Company (Connecticut Yankee), and Yankee Atomic Electric Company (Yankee Atomic) (collectively, the Yankee Companies) to Gaz Métro would constitute a direct or indirect transfer of the licenses that would require NRC approval pursuant to Title 10 of the Code of Federal Regulations (10 CFR) CFR 50.80, Transfer of licenses.
2.0 BACKGROUND
By application dated September 9, 2011 (ML11256A051), as supplemented by letters dated November 4, 2011 (ML11311A148), April 6, 2012 (ML12100A017), and May 4, 2012 (ML12128A433), (collectively, the application), Central Vermont Public Service Corporation (CVPS) and Gaz Métro Limited Partnership (Gaz Métro) requested that the U.S. Nuclear Regulatory Commission (NRC) consent, pursuant to 10 CFR 50.80, to the indirect transfer of control of CVPS 1.7303% interest in the license for Millstone Power Station, Unit 3 (MPS 3),
resulting from the acquisition of CVPS by Gaz Métro.
According to the application, CVPS also owns, through equity investment, 2% of the outstanding common stock of Maine Yankee Atomic Power Company, 2% of the outstanding common stock of Connecticut Yankee Atomic Power Company, and 3.5% of the outstanding common stock of Yankee Atomic Electric Company (collectively, the Yankee Companies). CVPS and Gaz Métro requested that the NRC staff make a threshold determination that the above requested license transfer transaction does not involve the direct or indirect transfer of control of the NRC licenses held by the Yankee Companies pursuant to 10 CFR 50.80.
CVPS is a Vermont corporation and the largest electric utility in Vermont. CVPS engages in the purchase, production, transmission, distribution and sale of electricity.
Gaz Métro is a Canadian energy company.
3.0 EVALUATION The NRC staff reviewed the application submitted by CVPS and Gaz Métro in order to make a threshold determination on whether the proposed merger between CVPS and Gaz Métro would involve a direct or indirect control of the NRC licenses held by the Yankee Companies that would require approval pursuant to 10 CFR 50.80. The regulation at 10 CFR 50.80 states:
No license for a production or utilization facility (including, but not limited to, permits under this part and part 52 of this chapter, and licenses under parts 50 and 52 of this chapter), or any right thereunder, shall be transferred, assigned, or in any manner disposed of, either voluntarily or involuntarily, directly or indirectly, through transfer or control of the license to any person, unless the Commission gives its consent in writing.
According to the application, CVPS interest in the Yankee Companies is as a shareholder only.
Each Yankee Company holds a Part 50 license and a general Part 72 license for an Independent Spent Fuel Storage Installation (ISFSI) and is the sole licensee for its facility.
CVPS has no operational authority for the Yankee Companies licensed ISFSIs. In addition, CVPS is not a party to any voting agreement or arrangement with any of the owners or licensees of the Yankee Companies that could give it voting rights that are greater than those associated with its minority shareholder interests in the companies. It does not have other financial interests that would allow it to participate in the management and operation of the licensee. Accordingly, the result of the proposed merger between CVPS and Gaz Métro, and the associated interests in the Yankee Companies, does not result in a transfer of control with respect to the Yankee Companies and the Yankee Company licenses.
Regarding foreign ownership, control, or domination, Section 103d of the Atomic Energy Act of 1954, as amended provides in part:
No license may be issued to an alien or any corporation or other entity if the Commission know or has reason to believe it is owned, controlled, or dominated by an alien, a foreign corporation or a foreign government. In any event, no license may be issued to any person within the United States if, in the opinion of the Commission, the issuance of a license to such a person would be inimical to the common defense and security or to the health and safety of the public.
The NRCs regulation 10 CFR 50.38 contains language to implement this statutory prohibition.
As stated, the result of the proposed merger between CVPS and Gaz Métro, and the associated interests in the Yankee Companies, does not result in a transfer of control with respect to the Yankee Companies and the Yankee Company licenses, and does not provide CVPS or Gaz Metro with any responsibility over spent fuel, access to restricted data, or right of participation, whether or not exercised, in the management and operation of the licensees. Additionally, as a result of the afore-mentioned indirect license transfer for Millstone 3 (ML121300466), CVPS is implementing a Negation Action Plan (NAP) to ensure that any foreign ownership, control, or domination of Millstone 3 and the Yankee Companies is negated. NRC staff reviewed and
approved this NAP as part of the safety evaluation for the indirect license transfer. Furthermore, in an unrelated licensing action, a NAP has been implemented for each of the Yankee Companies via confirmatory orders issued by the NRC (ML12124A372, ML12124A373, ML12124A374), which negate foreign ownership, control, or domination of the Yankee Companies.
4.0 CONCLUSION
The NRC staff conducted a threshold review of the facts and information as set forth in the application, and has considered how the proposed merger between CVPS and Gaz Métro will be implemented as described in the application. The NRC staff concludes that the proposed merger will not result in a transfer of control with respect to the Yankee Companies, and, thus, CVPS and Gaz Métro do not require the NRCs approval under Section 184 of the Atomic Energy Act of 1954, as amended, and 10 CFR 50.80 with respect to the afore-mentioned licenses. In addition, based on the application, the NRC concludes that the foreign ownership, control, or domination of the Yankee Company licensees has been negated by existing Negation Action Plans.
Principal Contributor: Shawn Harwell Date: June 15, 2012