Letter Sequence RAI |
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Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request
- Acceptance
- Supplement, Supplement, Supplement, Supplement, Supplement, Supplement
Results
Other: 3F0112-11, Corrections to the Extended Power Uprate LAR 309 Vendor Affidavit and Technical Report, 3F0113-08, Attachment D: ANP-3195(NP), Revision 0, Response for Crystal River Unit 3, EPU Licensing Amendment Report NRC Reactor Systems Branch Requests for Additional Information (Non-Proprietary) and Attachment E: Location of Reactor Systems RAI Re, 3F0712-03, Attachment E to 3F0712-03, Technical Report, ANP-3052, Rev. 2, CR-3 EPU Feedwater Line Break Analysis with Failure of First Safety Grade Trip, 3F0912-01, ANP-3156 Np, Crystal River 3 EPU Boric Acid Precipitation RAI Responses, Attachment C, 3F1011-08, ANP-3052, Rev. 0, CR-3 EPU Feedwater Line Break Analysis with Failure of First Safety Grade Trip, 3F1112-02, 17877-0001-100, Rev. 1, CR-3 Inadequate Core Cooling Mitigation System Reliability Assessment, Task 1, Page 174 of 250 Through Page 250 of 250, ML11259A012, ML11300A226, ML11342A195, ML12031A032, ML12053A231, ML12107A068, ML12202A734, ML12205A357, ML12205A358, ML12240A119, ML12255A409, ML12262A385, ML12314A391, ML12314A392, ML12314A393, ML13032A540, ML13170A215
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MONTHYEARML11167A1072011-05-0606 May 2011 Request for Additional Information Required for the Development of Confirmatory LOCA and non-LOCA Models for the CR-3 Extended Power Uprate Project stage: Request 3F0611-02, Attachments 1, 2 & 3, 4 & 6 Crystal River Unit 3, License Amendment Request 309, Revision 0 Attachment 1, Description of Proposed Change, Background, Justification for the Request, Determination of No Significant Hazards Considerations2011-06-15015 June 2011 Attachments 1, 2 & 3, 4 & 6 Crystal River Unit 3, License Amendment Request 309, Revision 0 Attachment 1, Description of Proposed Change, Background, Justification for the Request, Determination of No Significant Hazards Considerations Project stage: Request 3F0711-07, Clarifications for Trace Confirmatory Model Development for Extended Power Uprate2011-07-0505 July 2011 Clarifications for Trace Confirmatory Model Development for Extended Power Uprate Project stage: Request 3F0811-04, Response to Request for Additional Information to Support NRC Probabilistic Risk Assessment Licensing Branch Acceptance Review of the CR-3 Extended Power Uprate LAR2011-08-11011 August 2011 Response to Request for Additional Information to Support NRC Probabilistic Risk Assessment Licensing Branch Acceptance Review of the CR-3 Extended Power Uprate LAR Project stage: Response to RAI 3F0811-02, Response to Request for Additional Information to Support NRC Balance of Plant Branch Acceptance Review of the CR-3 Extended Power Uprate LAR2011-08-11011 August 2011 Response to Request for Additional Information to Support NRC Balance of Plant Branch Acceptance Review of the CR-3 Extended Power Uprate LAR Project stage: Response to RAI 3F0811-01, Response to Request for Additional Information to Support NRC Instrumentation and Controls Branch Acceptance Review of the CR-3 Extended Power Uprate LAR2011-08-18018 August 2011 Response to Request for Additional Information to Support NRC Instrumentation and Controls Branch Acceptance Review of the CR-3 Extended Power Uprate LAR Project stage: Response to RAI 3F0811-03, Response to Request for Additional Information to Support NRC Mechanical and Civil Branch Acceptance Review of the CR-3 Extended Power Uprate LAR2011-08-25025 August 2011 Response to Request for Additional Information to Support NRC Mechanical and Civil Branch Acceptance Review of the CR-3 Extended Power Uprate LAR Project stage: Response to RAI ML11259A0122011-09-14014 September 2011 NRR E-mail Capture - Clarification for August 25 Emcb RAI Acceptance Review Letter Project stage: Other ML11286A0922011-10-11011 October 2011 Response to Request for Additional Information to Support NRC Reactor Systems Branch Acceptance Review of the CR-3 Extended Power Uprate LAR Project stage: Response to RAI ML11300A2262011-10-25025 October 2011 Feedwater Line Break Overpressure Protection Analysis to Support NRC Reactor Systems Branch Acceptance Review of the CR-3 Extended Power Update LAR and LAR Approval Schedule Project stage: Other 3F1011-08, ANP-3052, Rev. 0, CR-3 EPU Feedwater Line Break Analysis with Failure of First Safety Grade Trip2011-10-25025 October 2011 ANP-3052, Rev. 0, CR-3 EPU Feedwater Line Break Analysis with Failure of First Safety Grade Trip Project stage: Other ML11286A0842011-11-21021 November 2011 Acceptance for Review of License Amendment Request for Extended Power Uprate Project stage: Acceptance Review ML11326A2312011-12-0707 December 2011 Request for Additional Information for Extended Power Uprate License Amendment Request Project stage: RAI 3F1211-05, Response to Request for Additional Information to Support NRC Health Physics and Human Performance Branch Technical Review of the CR-3 Extended Power Uprate LAR2011-12-15015 December 2011 Response to Request for Additional Information to Support NRC Health Physics and Human Performance Branch Technical Review of the CR-3 Extended Power Uprate LAR Project stage: Response to RAI ML12205A3572011-12-15015 December 2011 Attachment a to 3F0712-03, CR-3 LOCA Summary Report - EPU/ROTSG/Mark-B-HTP, Revision 4 Project stage: Other 3F1211-06, Response to Request for Additional Information to Support NRC Vessels and Internals Integrity Branch Technical Review of the CR-3 Extended Power Uprate LAR2011-12-15015 December 2011 Response to Request for Additional Information to Support NRC Vessels and Internals Integrity Branch Technical Review of the CR-3 Extended Power Uprate LAR Project stage: Response to RAI 3F1211-10, Response to Request for Additional Information to Support NRC Fire Protection Branch Technical Review of the CR-3 Extended Power Uprate LAR2011-12-21021 December 2011 Response to Request for Additional Information to Support NRC Fire Protection Branch Technical Review of the CR-3 Extended Power Uprate LAR Project stage: Response to RAI ML12030A2092012-01-0505 January 2012 Response to Request for Additional Information to Support NRC Instrumentation and Control Branch Technical Review of the CR-3 Extended Power Uprate LAR Project stage: Response to RAI 3F0112-04, Response to Request for Additional Information to Support NRC Steam Generator Tube Integrity and Chemical Engineering Branch Technical Review of the CR-3 Extended Power Uprate LAR2012-01-0505 January 2012 Response to Request for Additional Information to Support NRC Steam Generator Tube Integrity and Chemical Engineering Branch Technical Review of the CR-3 Extended Power Uprate LAR Project stage: Response to RAI ML11342A1952012-01-0606 January 2012 Notice of Consideration of Issuance of Amendment to Facility Operating License and Opportunity for a Hearing and Order Imposing Procedures for Document Access to Sensitive Unclassified Non-safeguards Information Project stage: Other ML12024A3002012-01-19019 January 2012 Response to Request for Additional Information to Support NRC Component Performance and Testing Branch Technical Review of the CR-3 Extended Power Uprate LAR Project stage: Response to RAI 3F0112-06, Response to Request for Additional Information to Support NRC Piping and NDE Branch Technical Review of the CR-3 Extended Power Uprate LAR2012-01-19019 January 2012 Response to Request for Additional Information to Support NRC Piping and NDE Branch Technical Review of the CR-3 Extended Power Uprate LAR Project stage: Response to RAI 3F0112-11, Corrections to the Extended Power Uprate LAR 309 Vendor Affidavit and Technical Report2012-01-31031 January 2012 Corrections to the Extended Power Uprate LAR 309 Vendor Affidavit and Technical Report Project stage: Other ML12003A2172012-02-0808 February 2012 Nuclear Generating Plant - Request for Additional Information for Extended Power Uprate License Amendment Request Project stage: RAI 3F0212-01, Complex - Environmental Protection Plan Report 2011 Sea Turtle Rescue and Recovery Summary Report2012-02-0808 February 2012 Complex - Environmental Protection Plan Report 2011 Sea Turtle Rescue and Recovery Summary Report Project stage: Request ML1205505612012-03-0202 March 2012 Request for Additional Information for Extended Power Uprate License Amendment Request Project stage: RAI ML12053A2312012-03-0202 March 2012 Request for Withholding Proprietary Information from Public Disclosure Related Extended Power Uprate Technical Report Project stage: Other ML12052A1302012-03-0202 March 2012 Request for Additional Information for Extended Power Uprate License Amendment Request Project stage: RAI 3F0312-02, Response to Second Request for Additional Information to Support NRC Instrumentation and Controls Branch (Eicb) Technical Review of the CR-3 Extended Power Uprate LAR2012-03-19019 March 2012 Response to Second Request for Additional Information to Support NRC Instrumentation and Controls Branch (Eicb) Technical Review of the CR-3 Extended Power Uprate LAR Project stage: Request 3F0312-01, Response to Request for Additional Information to Support NRC PRA Licensing Branch Technical Review of the CR-3 Extended Power Uprate LAR2012-03-22022 March 2012 Response to Request for Additional Information to Support NRC PRA Licensing Branch Technical Review of the CR-3 Extended Power Uprate LAR Project stage: Response to RAI ML12031A0322012-03-26026 March 2012 Request for Withholding Proprietary Information from Public Disclosure Related to Extended Power Uprate Technical Report Project stage: Other ML1208300282012-04-0202 April 2012 Nuclear Generating Plant - Request for Additional Information for Extended Power Uprate License Amendment Request Project stage: RAI 3F0412-05, Response to Second Request for Additional Information to Support NRC Health Physics and Human Performance Branch (Ahpb) Technical Review of the CR-3 Extended Power Uprate LAR2012-04-0404 April 2012 Response to Second Request for Additional Information to Support NRC Health Physics and Human Performance Branch (Ahpb) Technical Review of the CR-3 Extended Power Uprate LAR Project stage: Request 3F0412-04, Response to Request for Additional Information to Support NRC Mechanical and Civil Engineering Branch (Emcb) Technical Review of the CR-3 Extended Power Uprate LAR2012-04-0404 April 2012 Response to Request for Additional Information to Support NRC Mechanical and Civil Engineering Branch (Emcb) Technical Review of the CR-3 Extended Power Uprate LAR Project stage: Response to RAI ML12107A0682012-04-0404 April 2012 NRR E-mail Capture - Crystal River, Unit 3 EPU LAR - Clarifications for Component Performance & Testing Branch (Eptb) Project stage: Other 3F0412-07, Response to Request for Additional Information to Support NRC Containment and Ventilation Branch (Scvb) Technical Review of the CR-3 Extended Power Uprate LAR2012-04-12012 April 2012 Response to Request for Additional Information to Support NRC Containment and Ventilation Branch (Scvb) Technical Review of the CR-3 Extended Power Uprate LAR Project stage: Response to RAI 3F0412-06, Response to Request for Additional Information to Support NRC Electrical Systems Branch (Eeeb) Technical Review of the CR-3 Extended Power Uprate LAR2012-04-16016 April 2012 Response to Request for Additional Information to Support NRC Electrical Systems Branch (Eeeb) Technical Review of the CR-3 Extended Power Uprate LAR Project stage: Response to RAI 3F0412-09, Response to Request for Additional Information to Support NRC Accident Dose Branch (Aadb) Technical Review of the CR-3 Extended Power Uprate LAR2012-04-26026 April 2012 Response to Request for Additional Information to Support NRC Accident Dose Branch (Aadb) Technical Review of the CR-3 Extended Power Uprate LAR Project stage: Response to RAI ML1208300382012-05-0404 May 2012 Nuclear Generating Plant - Request for Additional Information for Extended Power Uprate License Amendment Request Project stage: RAI ML12102A0442012-05-0404 May 2012 Request for Additional Information for Extended Power Uprate License Amendment Request Project stage: RAI ML12205A3582012-05-31031 May 2012 Attachment D to 3F0712-03, Technical Report, ANP-3114(NP), Rev. 0, CR-3 EPU - Feedwater Line Break Analysis Sensitivity Studies Project stage: Other ML12314A3912012-05-31031 May 2012 17877-0002-100, CR-3 Inadequate Core Cooling Mitigation System Reliability Assessment 2 Project stage: Other 3F0612-05, Response to Request for Additional Information to Support NRC Nuclear Performance and Code Review Branch (Snpb) Technical Review of the CR-3 Extended Power Uprate LAR2012-06-18018 June 2012 Response to Request for Additional Information to Support NRC Nuclear Performance and Code Review Branch (Snpb) Technical Review of the CR-3 Extended Power Uprate LAR Project stage: Response to RAI ML12206A3372012-06-29029 June 2012 Response to Second Request for Additional Information to Support NRC Accident Dose Branch (Aadb) Technical Review of the CR-3 Extended Power Uprate LAR Project stage: Request 3F0712-03, Attachment E to 3F0712-03, Technical Report, ANP-3052, Rev. 2, CR-3 EPU Feedwater Line Break Analysis with Failure of First Safety Grade Trip2012-06-30030 June 2012 Attachment E to 3F0712-03, Technical Report, ANP-3052, Rev. 2, CR-3 EPU Feedwater Line Break Analysis with Failure of First Safety Grade Trip Project stage: Other ML12184A3442012-07-0202 July 2012 NRR E-mail Capture - Crystal River, Unit 3 EPU LAR - Discussion/Clarification of Emcb Draft RAIs Project stage: Draft Other ML12171A3472012-07-0505 July 2012 Request for Additional Information for Extended Power Uprate License Amendment Request Project stage: RAI ML12174A2922012-07-0505 July 2012 Request for Additional Information for Extended Power Uprate License Amendment Request Project stage: RAI ML12194A4172012-07-17017 July 2012 Generating Plant - Request for Additional Information for Extended Power Uprate License Amendment Request Project stage: RAI 3F0712-06, Response to Second Request for Additional Information to Support NRC Steam Generator Tube Integrity and Chemical Engineering Branch (Esgb) Technical Review of the CR-3 Extended Power Uprate LAR2012-07-17017 July 2012 Response to Second Request for Additional Information to Support NRC Steam Generator Tube Integrity and Chemical Engineering Branch (Esgb) Technical Review of the CR-3 Extended Power Uprate LAR Project stage: Request 2012-02-08
[Table View] |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 28, 2012 Mr. Jon A. Franke Vice President Crystal River Nuclear Plant (NA2C)
ATIN: Supervisor, Licensing and Regulatory Programs (NA 1 B) 15760 W. Power Line Street Crystal River, FL 34428-6708
SUBJECT:
CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT - REQUEST FOR ADDITIONAL INFORMATION FOR EXTENDED POWER UPRATE LICENSE AMENDMENT REQUEST (TAC NO. ME6527)
Dear Mr. Franke:
By letter dated June 15, 2011, as supplemented by letters dated July 5, 2011, August 11, 2011 (two letters), August 18, 2011, August 25, 2011, October 11,2011, October 25, 2011, December 15, 2011 (two letters), December 21, 2011, January 5, 2012 (two letters),
January 19, 2012 (two letters), January 31,2012, March 19,2012, March 22,2012, April 4, 2012 (two letters), April 12, 2012, April 16, 2012, April 26, 2012, June 18, 2012, June 29, 2012, July 17, 2012 (two letters), July 31, 2012 (two letters), and August 21, 2012 (two letters), Florida Power Corporation, doing business as Progress Energy Florida, Inc., submitted a license amendment request for an extended power uprate to increase thermal power level from 2609 megawatts thermal (MWt) to 3014 MWt for Crystal River Unit 3 Nuclear Generating Plant.
The U.S. Nuclear Regulatory Commission staff is reviewing the submittal and has determined that additional information is required to complete its evaluation. This request was discussed with Mr. Dan Westcott of your staff on August 23, 2012, and it was agreed that a response to the enclosed request for additional information would be provided within 45 days from the date of this letter.
If you have any questions regarding this matter, I can be reached at 301-415-1564.
Sincerely,
~<f'~
Siva P. Lingam, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor licenSing Office of Nuclear Reactor Regulation Docket No. 50-302
Enclosure:
Request for Additional Information cc w/encl: Distribution via Listserv
REQUEST FOR ADDITIONAL INFORMATION REGARDING EXTENDED POWER UPRATE TO INCREASE THERMAL POWER LEVEL FROM 2609 MEGAWATIS THERMAL TO 3014 MEGAWATTS THERMAL CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT DOCKET NO. 50-302 By letter dated June 15, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML112070659), as supplemented by letters dated July 5, 2011, August 11, 2011 (two letters), August 18, 2011, August 25, 2011, October 11, 2011, October 25,2011, December 15,2011 (two letters), December 21,2011, January 5,2012 (two letters), January 19, 2012 (two letters), January 31,2012, March 19,2012, March 22,2012, April 4, 2012 (two letters), April 12, 2012, April 16, 2012, April 26, 2012, June 18, 2012, June 29,2012, July 17, 2012 (two letters), July 31,2012 (two letters), and August 21,2012 (two letters) (ADAMS Accession Nos. ML112010674, ML11228A032, ML11234A051, ML11234A427, ML11242A140, ML112860156, ML113040176, ML11354A232, ML11354A233, ML11361A460, ML12011A035, ML12030A209, ML12024A300, ML12024A301, ML12032A280, ML12081A293, ML12086A107, ML120970114, ML12097A246, ML12107A216, ML12114A002, ML12118A498, ML12173A391, ML122060421, ML122050452, ML12205A268, ML12216A354, ML12216A355, ML12240A009, and ML12240A010, respectively), Florida Power Corporation (the licensee),
doing business as Progress Energy Florida, Inc., submitted a license amendment request (LAR) for an extended power uprate (EPU) to increase thermal power level from 2609 megawatts thermal (MWt) to 3014 MWt for Crystal River Unit 3 Nuclear Generating Plant (Crystal River 3 or CR-3). Portions of the letters dated June 15, 2011, August 11, 2011 (ADAMS Accession No. ML11228A032), January 31,2012, June 18, 2012, and July 17, 2012 (ADAMS Accession No. ML122050452), contain sensitive unclassified non-safeguards information and, accordingly, those portions have been withheld from public disclosure. In order to complete its review of the above documents, the U.S. Nuclear Regulatory Commission (NRC) staff requests additional information originating from its Instrumentation and Controls Branch (EICB):
EICB REQUEST FOR ADDITIONAL INFORMATION
- 1.
In order to comply with the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Sections 50.55a(a)(1), 10 CFR 50.55a(h),
10 CFR 50.34(f)(2)(xxii) [II.K.2.9], and the general design criteria related to the control systems of a LAR, the licensee is required to complete appropriate analyses, such as independence and diversity analyses, and failure modes and effects analyses, for balance-of-plant control systems that were modified due to the replacement of components and control logics that could either increase challenges to the initiation of plant safety systems or otherwise impact the ability of plant systems to respond to events.
The licensee submitted the original LAR of CR-3 EPU on June 15, 2011. Section 2.4.4.2, "Integrated Control System (lCS)" of the Attachment 5 of the original LAR describes the ICS modifications. However, this section does not demonstrate how the licensee's analysis Enclosure
- 2 results verify that the modifications of the control systems will not impact the safety system functions or impact the ability of plant control systems to respond to the transient or accident events.
For the instrumentation and controls system and other balance-of-plant control system modifications that were implemented as part of the EPU, please provide a summary of analyses that were performed to ensure that:
a) the failure of any control system component or any auxiliary supporting system for control systems, such as loss of power sources, does not cause plant conditions more severe than those described in the analysis of anticipated operational occurrences in Chapter 15 of the safety analyses report (SAR).
b) the consequential effects of anticipated operational occurrences and accidents do not lead to control system failures that would result in consequences more severe than those described in the analysis in Chapter 15 of the SAR.
c) the independence of the normal control systems from safety system functions has been verified.
d) the design of the control system limits the potential for inadvertent actuation and challenges to safety systems.
e) the control systems are appropriately designed and are of sufficient quality to minimize the potential for challenges to safety systems.
f)
ICS modifications do not change any conclusion of the original failure mode and effect analyses.
- 2.
In various places (e.g., the last paragraph of page 2.4.2.3-1) of the Attachment 5 of the original LAR, the licensee mentions that Inadequate Core Cooling Monitoring System (lCCMS) receives inputs from "incore thermocouples" or "incore thermocouple temperatures," but the proposed CR-3 Improved Technical Specification Table 3.3.19-1 "Inadequate Core Cooling Monitoring System (ICCMS) Instrumentation," FUNCTIONS 1 d, 2c, and 3c (Attachments 2 and 3 of the original LAR) uses the term "Core Exit Thermocouples (CETs)" as ICCMS inputs.
Are those two terms the same? If they are the same, which one is the proper term to use?
If they are different, please explain in detail.
- 3.
During a loss of subcooling margin (LOSCM) event concurrent with a reactor trip, ICCMS will automatically trip the reactor coolant pumps within one minute and will additionally raise the steam generator (SG) secondary side water level to the inadequate subcooling margin setpoint within 10 minutes. How does the licensee ensure that the system meets these two response time requirements?
- 3
- 4.
During a LOSCM event concurrent with inadequate high-pressure injection (HPI) flow, the existing emergency operating procedures direct the operator to manually perform a rapid primary system cooldown via SG pressure reduction. This action is being automated with the installation of the ICCMS and fast cooldown system (FCS). For EPU, FCS actuation is required within 10 minutes of LOSCM if HPI flow is inadequate. How does the licensee ensure that the system meets this response time requirement?
- 5.
Clause 5.8.3 of the Enclosure 3, "IEEE 603-1991 and IEEE 279-1971 Compliance Matrix" of the licensee's supplemental letter dated August 18, 2011, states:
"System Spec 5.9.2.1 Fifteen (15) TRIP/AUTO/BYPASS Switches shall be provided to allow bypassing or tripping each output trip function in each initiation channel and bypassing or tripping each output trip function in each actuation train. The TRIP/AUTO/BYPASS Switches shall be located in the channel enclosure."
a) Where are channel cabinets located?
b) What controls and indications are available to the operator?
c) Please provide detailed description of the initiation channel TRIP/AUTO/BYPASS switches (including diagrams, function, and operation).
August 28, 2012 Mr. Jon A. Franke Vice President Crystal River Nuclear Plant (NA2C)
ATTN: Supervisor, Licensing and Regulatory Programs (NA 1 B) 15760 W. Power Line Street Crystal River, FL 34428-6708
SUBJECT:
CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT - REQUEST FOR ADDITIONAL INFORMATION FOR EXTENDED POWER UPRATE LICENSE AMENDMENT REQUEST (TAC NO. ME6527)
Dear Mr. Franke:
By letter dated June 15, 2011, as supplemented by letters dated July 5, 2011, August 11, 2011 (two letters), August 18, 2011, August 25, 2011, October 11, 2011, October 25, 2011, December 15,2011 (two letters), December 21, 2011, January 5, 2012 (two letters),
January 19, 2012 (two letters), January 31,2012, March 19,2012, March 22, 2012, April 4, 2012 (two letters), April 12, 2012, April 16, 2012, April 26, 2012, June 18,2012, June 29,2012, July 17,2012 (two letters), July 31,2012 (two letters), and August 21,2012 (two letters), Florida Power Corporation, doing business as Progress Energy Florida, Inc., submitted a license amendment request for an extended power uprate to increase thermal power level from 2609 megawatts thermal (MWt) to 3014 MWt for Crystal River Unit 3 Nuclear Generating Plant.
The U.S. Nuclear Regulatory Commission staff is reviewing the submittal and has determined that additional information is required to complete its evaluation. This request was discussed with Mr. Dan Westcott of your staff on August 23, 2012, and it was agreed that a response to the enclosed request for additional information would be provided within 45 days from the date of this letter.
If you have any questions regarding this matter, I can be reached at 301-415-1564.
Sincerely, IraJ Siva P. Lingam, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-302
Enclosure:
Request for Additional Information cc w/encl: Distribution via Listserv DISTRIBUTION:
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