ML12333A222

Summary of Pre-Application Meeting with Entergy Nuclear Operations, Inc., Regarding the Proposed License Amendment Request to Revise the Vermont Yankee Licensing Basis for Station Blackout Diesel Generator

ML12333A222
Person / Time
Site:	Vermont Yankee
Issue date:	11/30/2012
From:	Richard Guzman Plant Licensing Branch 1
To:
Guzman R
Shared Package
ML12333A207	List: ML12333A222
References
TAC ME9836
Download: ML12333A222 (23)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 30, 2012 Entergy Nuclear Operations, Inc.

Entergy Nuclear Vermont Yankee, LLC FACILITY: Vermont Yankee Nuclear Power Station

SUMMARY

OF NOVEMBER 13, 2012, PRE-APPLICATION MEETING WITH ENTERGY NUCLEAR OPERATIONS, INC. REGARDING THE PROPOSED STATION BLACKOUT DIESEL GENERATOR LICENSE AMENDMENT REQUEST FOR VERMONT YANKEE NUCLEAR POWER STATION (TAC NO.

ME9836)

On November 13, 2012, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Entergy Nuclear Operations, Inc.

(Entergy, the licensee) at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. The purpose of the meeting was to discuss Entergy's planned submittal of a license amendment request to revise the Vermont Yankee Nuclear Power Station (VYNPS) licensing basis to replace the Vernon Hydroelectric Station with an onsite diesel generator as the source of alternate AC power credited for compliance with Title 10 of the Code of Federal Regulations, Section 50.63, "Loss of all alternating current power."

A member of the public was in attendance. Public Meeting Feedback forms were not received. is a list of meeting attendees and Enclosure 2 is a copy of the licensee's handouts presented at the meeting (Agencywide Documents Access and Management System Accession No. ML123310056).

Please direct any inquiries to me at 301-415-1030 or Richard.Guzman@nrc.gov Sincerely, Richard V. Guzman, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-271

Enclosures:

1. List of Attendees

2. Licensee's Handouts cc w/encls: Distribution via Listserv

LIST OF A TIENDEES NOVEMBER 13, 2012, PRE-APPLICATION MEETING WITH ENTERGY NUCLEAR OPERATIONS, INC. (ENTERGY)

REGARDING THE PROPOSED STATION BLACKOUT DIESEL GENERATOR LICENSE AMENDMENT REQUEST FOR VERMONT YANKEE NUCLEAR POWER STATION (VYNPS)

NAME ORGANIZATION George Wilson NRC Jim Andersen NRC Rich Guzman NRC Vijay Goel NRC Bob Wolfgang NRC Tom Setzer* NRC Beth Keighley* NRC Scott Rutenkroger* NRC Neil Sheehan* NRC Robert Wanczyk Entergy Phil Couture Entergy Scott Lyford Entergy George Thomas Entergy Paul Johnson Entergy Sarah Hoffmann Vermont Public Service Department

• by telephone Enclosure 1

MEETING HANDOUTS Enclosure 2

Summary Description In accordance with 10CFR50.90, Vermont Yankee (VY) is proposing to revise the licensing basis for satisfying the requirements of 10 CFR 50.63 "Loss of all alternating current power".

VY is an Alternate AC (AAC) plant and currently relies to the Vernon Hydroelectric Station (VHS) as the source of AAC power. This proposed amendment would revise the VY licensing basis to replace the VHS with an onsite diesel generator as the source of AAC power credited for compliance with 10 CFR 50.63.

Background Discussion:

The VHS is the AAC power source that is credited for compliance with 10 CFR 50.63 (Station Blackout) following the loss of all AC power to Vermont Yankee (VY). The VHS is designated as a black-start facility under arrangements with Independent System Operator-New England (ISO-NE), the regional grid operator, which requires that the facility be capable of being black-started within 90 minutes after TransCanada, the owner of the facility, is notified.

Power from the VHS is provided via a 13.2kV underground feeder cable (VHS tie line) from the VHS switchyard that is connected to a 13.2kV I 4.16kV transformer located near the VY cooling towers. The transformer secondary is connected by underground cable to breaker 3V4 located in safety bus 3.

Breaker 3V4, in turn, is connected to breaker 3V, located in safety bus 3, and breaker 4V, located in safety bus 4.

As a result of a forthcoming change to the ISO-NE system restoration strategy, the contract between ISO-NE and TransCanada for black-start of the Vernon Hydro Station will expire on September 1, 2013 and will not be renewed. Additionally. TransCanada will not enter into a contractual agreement with Entergy to supply black-start power to allow VY to meet the requirements of 10 CFR 50.63. VY is planning to install a new Station Blackout (SBO) Diesel Generator (DG) unit and associated equipment to function as the AAC power source required by 10 CFR 50.63. The proposed configuration of the new SBO DG system is shown in Figure 1.

Although the VHS will no longer be credited as the VY AAC power source. the VHS tie line will remain continuously energized from the VHS through the Vernon 69kV switchyard and the Vernon 13.2 kV switchyard and will be available to provide power to VY. The VHS tie line will normally be aligned to provide power to the new 4, 160VAC bus being installed along with the new SBO DG unit. The new 4,160VAC bus will normally provide power to the SBO DG system auxiliaries (such as battery chargers and heaters) that are required to maintain the SBO DG system equipment in a ready-to-operate condition.

Current Licensing Basis VY is an AAC power source plant and relies on the VHS as the source of AC power in the unlikely event of a station blackout. In Reference 1, the NRC accepted the determination that VY is an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> coping plant with a target Emergency Diesel generator (EDG) reliability of 0.95. No changes to the station coping duration or credited EDG reliability are proposed in the amendment. Additional NRC review of VY's compliance with 10 CFR 50.63 is documented in References 2 - 4.

VY analysis demonstrates that the station can cope for two hours to allow for placing the AAC power source into service. The VHS is capable of being black-started in the event of a grid-wide blackout and agreements are currently in place to ensure that the VHS power is available to VY when needed. The NRC reviewed the current Station Blackout (SBO) licensing basis during the Extended Power Uprate (EPU) application review as documented in Reference 5.

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As discussed above, VY learned that as of September 1, 2013 the VHS will no longer be credited as a black-start facility and based on this will not be able to be credited for 10 CFR 50.63 compliance. The VHS tie line will remain normally energized, however, there will no longer be a guarantee that it will be available within the required timeframe following a grid wide blackout that requires the VHS to be black started. The VHS tie line is also credited for compliance with 10 CFR 50 Appendix R and for allowable Technical Specification (TS) configurations. These functions are not affected by this change.

As described in Reference 6 and UFSAR Section 8.3.3, VY has a commitment to perform a timed startup, alignment and rated load capacity test of the AAC power source once every third refueling outage.

This proposed amendment would revise the VY licensing basis to replace the VHS with an onsite SBa DG as the source of AAC power credited for compliance with 10 CFR 50.63.

Affected Licensing Basis Documents The renewed facility operating license is not affected by this proposed change.

There are no TS affected by this proposed change.

TS Bases 3.10.A and UFSAR Sections 8.1.1,8.3.3,8.3.4,8.4.5.1 and 8.5.5.1 will need to be revised upon approval of the amendment to reflect that the SBa DG, not the VHS, is credited for SBa compliance.

Preliminary Bases for the Proposed Licensing Action and Applicable Regulatory Criteria The on-site SBa DG will satisfy the regulatory criteria contained in Appendix B of NUMARC 87-00 (Reference 7), Regulatory Guide 1.155 (Reference 8), portions of Standard Review Plan Section 8.4 (Reference 9) and 10 CFR 50.2 as discussed in the following technical evaluation.

Comparison of Proposed Design to AAC Power Source Design Criteria (Appendix B of NUMARC B7 00, Rev. 1)

B.1 The AAC system and its components need not be designed to meet Class 1E or safety system requirements. If a Class 1E EDG is used as an Alternate AC power source, this existing Class 1E EDG must continue to meet all applicable safety-related criteria.

The SBa DG and its auxiliary equipment will not be classified as Class 1E, nor will it be designed to meet Class 1E safety system requirements. The AAC system components will meet the quality assurance guidance contained in Regulatory Guide 1.155, as further described on pages 12-14 of this submittal.

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B.2 Unless otherwise provided in these criteria, theAAC system need not be protected against the effects of:

(a) failure or misoperation of mechanical equipment, including (i) fire, (ii) pipe whip, (iii) jet impingement, (iv) water spray, (v) flooding from a pipe break, (vi) radiation, pressurization, elevated temperature or humidity caused by high or medium energy pipe break, and (vii) missiles resulting from the failure of rotating equipment or high energy systems; or (b) seismic events.

The SBa DG and its auxiliary equipment will not be protected against the effects of seismic events, nor will it be protected against the effects of failure or misoperation of mechanical equipment, as discussed in section B.2(a).

B.3 Components and subsystems shall be protected against the effects of likely weather related events that may initiate the loss of off-site power event. Protection may be provided by enclosing AAC components within structures that conform with the Uniform Building Code, and burying exposed electrical cable run between buildings (i.e.,

connections between the AAC power source and the shutdown buses).

The SBa DG and its auxiliary equipment will be located within enclosures that conform to the International Building Code (IBC), which superseded the Uniform Building Code. The electrical cables that connect the SBa DG to the shutdown buses are located within buried conduit or concrete reinforced duct banks to provide protection against events that may initiate the loss of off-site power event The enclosures will be physically located a considerable distance (at least 1000 feet) from the high-voltage switchyard, which, in conjunction with the features described above, provides reasonable protection against the effects of likely weather-related events that may initiate the loss of off-site power event to VY.

B.4 Physical separation of AAC components from safety related components or equipment shall conform with the separation criteria applicable for the unit's licensing basis.

The SBa DG and its auxiliary equipment will be physically separated from safety-related components. The equipment will be installed within dedicated enclosures located away from plant structures containing safety-related equipment. Additionally, the power and control cables for the SBa DG and its auxiliary equipment will be installed to meet VY's electrical separation requirements.

B.S Failure of AAC components shall not adversely affect Class 1E AC power systems.

A failure of the SBa DG or its auxiliary equipment will not adversely affect Class 1E AC power systems. The SBa DG system will be physically separated from Class 1E AC power systems by a considerable distance, so mechanical failure of the SBa DG system will not impact the Class 1E AC power systems. The SBa DG is not connected to the Class 1E AC power system except during an actual SBa or for periodic testing to demonstrate the ability to supply the load on a single emergency bus (once per cycle). Additionally, protective relaying will be provided to automatically isolate the SBa DG electrical system upon failure of the SBa DG such that an electrical fault will not propagate to the Class 1E AC power systems. The same interlocks that exist for the connection of the VHS tie line to the Class 1E power system will be used to control the connection of the SBa DG to the Class 1E power system. These interlocks permit connection of the VHS tie line to only one Class 1E bus at a time and the interlocks prevent Page 3 of 19

connection of the tie to the bus unless all sources of power (normal bus feed and emergency diesel generator) are disconnected. These interlocks assure failure of MC components do not adversely affect the Class 1E AC power systems.

B.6 Electrical isolation of AAC power shall be provided through an appropriate isolation device. If the MC source is connected to Class 1E buses, isolation shall be provided by two circuit breakers in series (one Class 1E breaker at the Class 1E bus and one non-Class 1E breaker to protect the source).

The sse DG will be electrically connected to a new non-Class 1E 4,160VAC bus located in an enclosure installed adjacent to the sse DG enclosure and will not be directly connected to a Class 1E bus. A circuit breaker isolation device is located within the new bus to provide protection for the sse DG and the bus. The new bus, in turn, will be connected to an existing non-Class 1E circuit breaker (breaker 3V4) installed in safety-related 4, 160VAC Sus 3.

Additional Class-'I E breakers (3V and 4V) allow the sse DG to be aligned to either Sus 3 or Sus 4. This configuration provides the electrical Isolation required by section S.6.

B.7 The MC power source shall not normally be directly connected to the preferred or onsite emergency AC power system for the unit affected by the blackout. In addition, the MC system shall not be capable of automatic loading of shutdown equipment from the blacked-out unit unless licensed with such capability.

The sse DG will normally be isolated from the 4,160VAC preferred and onsite emergency AC power systems by at least two circuit breakers installed in series, including non-Class 1E breaker 3V4 installed In safety-related 4,160VAC Sus 3, a new non-Class 1E breaker installed in the new sse DG bus, and Class-1E breakers 3V and 4V. The 3V and 4V breakers are each electrically interlocked to prevent closure when the corresponding normal bus feeder breaker or EDG output breaker is closed. This prevents direct connection of the MC power source to the preferred or onsite emergency AC power systems.

The auxiliary equipment needed to start and operate the sse DG (e.g. battery chargers, DG heaters, etc.) will normally be powered from the 4, 160VAC sse DG bus, which will normally be energized via the VHS tie line connection from the Vernon Hydro Station switchyard. The VHS tie line is not classified as a preferred, Class 1E, or onsite emergency AC power system. A manually-operated transfer switch will be installed to allow the auxiliary equipment to be energized from the non-safety-related portion of the VY station auxiliary AC power system during those times that the normal AC power source (VHS tie line) is unavailable due to a planned or unplanned outage. The intent of this secondary feed is to maximize the availability of the MC power source when the VHS tie line is unavailable by maintaining the sse DG in a standby state. The use of the transfer switch will be procedurally controlled, and requires manual operator actions to initiate the transfer.

The SBe DG will not be capable of automatic loading of shutdown equipment. Manual operator actions will be required to align the sse DG to Class 1E Sus 3 or Sus 4.

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8.8 There shall be minimal potential for common cause failure ofthe AAC power source(s).

The following system features provide assurance that the minimal potential for common cause failure has been adequately addressed.

(a) The AAC power system shall be equipped with a DC power source that is electrically independent from the blacked-out unit's preferred and Class 1E power system.

The SBO DG system will be equipped with independent DC battery systems for operation of the DG and associated 4, 160VAC circuit breakers in the SBO DG bus. AC power to the DC system battery chargers will normally be provided from the 4,160VAC SBO DG bus, which will normally be energized via the VHS tie line connection from the Vernon Hydro Station switchyard. The VHS tie line is not classified as a preferred, Class 1E, or onsite emergency AC power system.

As discussed in section B.7, a manually-operated transfer switch will be installed to allow the DC system battery chargers to be energized from the non-safety-related portion of the VY station auxiliary AC power system during those times that the normal AC power source (VHS tie line) is unavailable. The use of the transfer switch will be procedurally controlled.

(b) The AAC power system shall be equipped with an air start system, as applicable, that is independent of the preferred and the blacked-out unit's preferred and Class 1E power supply. (NOTE: SRP Section 8.4 contains the following wording: The AAC power system is equipped with a starting system (and motive energy source for starting) that is independent from the blacked-out unit's preferred and Class 1E ac power systems.)

The SSO DG will not include an air start system, but does include redundant electric starting motors (DC). As discussed above, the SSO DG system will be equipped with independent DC battery systems for operation of the DG and the 4, 160VAC circuit breakers in the SBO DG bus. AC power to the DC system battery chargers will normally be provided from a source that is independent of the preferred and Class 1E power system. AC power is not required to be available to start the SBO DG or operate the SSO DG bus breakers necessary to align the AAC power source to the plant shutdown buses; the DC battery systems provide power to start and operate the SSO DG and to operate the SSO DG bus breakers.

(c) The AAC power system shall be provided with a fuel oil supply, as applicable, that is separate from the fuel oil supply for the onsite emergency AC power system. A separate day tank supplied from a common storage tank is acceptable provided the fuel oil is sampled and analyzed consistent with applicable standards prior to transfer to the day tank.

The SSO DG will include a dedicated fuel oil storage tank with a capacity sufficient for operation of the DG at 100% rated load for at least 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, which provides significant margin over the existing design basis eight hours coping time. This dedicated fuel oil storage tank will be separate from the fuel oil supply for the onsite emergency AC power system. Capability to refill the SSO DG fuel oil storage tank from the onsite EDG fuel oil storage tank will be available using a portable tank or a temporary connection between the tanks, but there will be no permanent connections between the two storage tanks.

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The fuel oil for the SSO DG will be procured to the same requirements as the fuel oil for the onsite emergency diesel generators and will be subject to sampling at a similar frequency. The fuel quality requirements for the new SBO DG were reviewed to confirm acceptability of the fuel.

(d) If the AAC power source is an identical machine to the emergency onsite AC power source, active failures of the emergency AC power source shall be evaluated for applicability and corrective action taken to reduce subsequent failures.

The SBO DG will not be an identical machine to the emergency onsite AC power source.

The SBO DG will be a different manufacturer (Caterpillar) than the onsite EDG manufacturer (Fairbanks-Morse).

(e) No single point vulnerability shall exist whereby a likely weather-related event or single active failure could disable any portion of the onsite emergency AC power sources or the preferred power sources, and Simultaneously fail the AAC power source(s).

The SBO DG and its auxiliary equipment will be located within enclosures that conform to the International Building Code (IBC), which superseded the Uniform Building Code.

The electrical cables that connect the SBO DG to the shutdown buses are located within buried conduit or concrete reinforced duct banks to provide protection against events that may initiate the loss of off-site power event.

As discussed previously, the enclosures will be physically located a considerable distance (at least 1000 feet) from the high-voltage switchyard, which, in conjunction with the features described above, provides reasonable protection against the effects of likely weather-related events that may initiate the loss of off-site power event to VY. The SBO DG will also be installed separate from the onsite emergency AC power sources (EDG units), so there is no postulated weather-related event that could disable the onsite EDG units concurrently with the SBO DG.

The SBO DG will be physically isolated from the onsite emergency AC and preferred power sources, so a single active failure will not disable the AAC power source concurrently with the onsite emergency AC or preferred power sources.

The SBO DG will normally be electrically isolated from the onsite emergency AC and preferred offsite power sources, so no single electrical failure will disable the SBO DG concurrently with the onsite emergency or the preferred power sources.

As discussed in Section B.7, a manually-operated transfer switch will be installed to allow the auxiliary equipment to be energized from the non-safety-related portion of the VY station auxiliary AC power system during those times that the normal AC power source (VHS tie line) is unavailable due to a planned or unplanned outage. In this configuration, a single active failure will not disable the AAC power source concurrently with the onsite emergency AC or preferred power sources. An electrical failure initiated at the AAC power source, emergency AC power source, or preferred power sources will be isolated by tripping of circuit breakers prior to propagating to the other AC sources.

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(f) The MC power system shall be capablltof operating during and after a station blackout without any support systems powered from the preferred power supply, or the blacked-out unit's Class 1E power sources affected by the event.

The SBa DG will be designed to operate during and after a station blackout without any support systems powered from the preferred, Class 1E, or emergency AC power sources.

The SBa DG system will be equipped with independent DC battery systems for operation and control of the DG and bus equipment. AC power is not required to be available to start the SBa DG or operate the SBa DG bus breakers necessary to align the AAC power source to the plant shutdown buses; the DC battery systems provide power to start and operate the SBa DG and to operate the SBa DG bus breakers.

The DC battery systems will normally be powered from the 4,160VAC SBa DG bus, which will normally be energized via the VHS tie line connection from the Vernon Hydro Station switchyard. The VHS tie line is not classified as a preferred, Class 1E, or onsite emergency AC power system. ance the SBa DG is started, AC power to the DC system battery chargers will be provided from the SBa DG, ensuring that the equipment can continue to operate during and after a station blackout.

(g) The portions of the MC power system subjected to maintenance activities shall be tested prior to returning the MC power system to service.

Post-maintenance testing of the AAC power system will be performed and controlled in accordance with Entergy procedures which ensure that portions of the AAC power system subject to maintenance activities are appropriately tested prior to returning the AAC power system to service.

B.9 The MC power system shall be sized to carry the required shutdown loads for the required coping duration determined in Section 3.2.5, and be capable of maintaining voltage and frequency within limits consistent with established industry standards that will not degrade the performance of any shutdown system or component. At a multi-unit site, except for 1/2 shared or 2/3 emergency AC power configurations, an adjacent unit's Class 1E power source may be used as an AAC power source for the blacked-out unit if it is capable of powering the required loads at both units.

The SBa DG will be rated for continuous operation at 3,OOOkW, which is greater than the continuous rating of the onsite emergency AC power sources (EDG unit), which is 2,750kW as specified in UFSAR Section 8.5. As discussed in section B.8(c), the SBa DG will include a dedicated fuel oil storage tank with a capacity sufficient for operation of the DG at 100% rated load for at least 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, which provides significant margin over the existing deSign basis eight hours coping time. The SBa DG will be capable of maintaining operating voltage and frequency within the limits established for shutdown system components, as demonstrated by calculation and acceptance testing.

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B.10 Unless otherwise governed by technical specifications, the AAC power source shall be started and brought to operating conditions that are consistent with its function as an AAC source at intervals not longer than three months, following manufacturer's recommendations or in accordance with plant-developed procedures. Once every refueling outage, a timed start (within the time period specified under blackout conditions) and rated load capacity test shall be performed.

The SBa DG equipment will be started and brought to approximately rated load capacity (3,000kW) at least four times per year at intervals not longer than 100 days in accordance with plant-developed procedures and preventive maintenance work order tasks established in accordance with manufacturer recommendations and industry guidance. The electrical load for the SBa DG for this test will be provided by a permanently installed 3,OOOkW resistive load bank located adjacent to the SBa DG enclosure.

ance every refueling outage, a timed start will be performed to demonstrate that the MC power source can be started and aligned to one of the plant shutdown buses within two (2) hours consistent with the VY coping duration.

ance every third refueling outage, the SBa DG will be demonstrated by test to be capable of starting the largest motor on safety Bus 3 or safety Bus 4.

VY is currently committed to perform a timed startup, alignment and rated load capacity test of the MC power source once every third refueling outage, as described in UFSAR Section 8.3.3.

B.11 Unless otherwise governed by technical specifications, surveillance and maintenance procedures for the AAC system shall be implemented considering manufacturer's recommendations or in accordance with plant-developed procedures.

Surveillance and maintenance for the new SBa DG will be implemented considering manufacturer's recommendations in accordance with plant-developed procedures and preventive maintenance work order tasks.

B.12 Unless otherwise governed by technical specifications, the AAC system shall be demonstrated by initial test to be capable of powering required shutdown equipment within one hour of a station blackout event.

VY performed a coping analysis assuming EPU conditions and submitted it to the NRC by letter dated March 24, 2005. Based on the results of the analysis, VY concluded that the plant is able to safely cope with a total loss of AC power for a minimum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> from the onset of the SBa to the restoration of offsite AC power to a 4160-volt emergency bus. The NRC documented a review of the analysis in the EPU safety evaluation, dated March 2, 2006.

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The SBO DG will be maintained in a "ready to operate' condition such that it can be started and connected to one of the safety buses (Bus 3 or Bus 4) in a timely manner. Following installation of the new AAC power source, initial testing will be performed to demonstrate that power can be made available up to existing circuit breaker 3V4 within two hours of the onset of station blackout consistent with the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> coping duration. Energization of Bus 3 or Bus 4 from the AAC power source is not practical due to interlocks associated with circuit breakers 3V and 4V preventing closure of the breakers while the buses are energized from their normal sources (preferred power source). The actions required to complete alignment of the AAC power source to Bus 3 or Bus 4 include closure of two circuit breakers from the VY control room (3V4 and either 3V or 4V, depending on which bus is being energized). Once the AAC power source is energized up to 3V4, it takes very little time to align loads from the control room (less than 10 minutes). Therefore, energizing the AAC power source up to circuit breaker 3V4 within two hours satisfactorily demonstrates that the AAC power source can be made available to power Bus 3 or Bus 4 within the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> coping duration.

Initial testing will also be performed to load the SBO DG to its rated output (3,000kW) using the permanently installed resistive load bank. This demonstrates that the AAC power source can provide the power required to operate the required shutdown equipment.

6.13 The Non-Class 1E AAC system should attempt to meet the target reliability and availability goals specified below, depending on normal system state. In this context, reliability and availability goals apply to the overall AAC system rather than individual machines, where a system may comprise more than one AAC power source.

VY has established a reliability target of 0.95 for the SBO DG AAC power system in accordance with the Entergy Emergency Diesel Generator Program (EN-DC-198), which includes the guidance in NUMARC 87-00, Appendix D. The SBO DG AAC power system will also be included in the scope of the VY Maintenance Rule Program (EN-DC-203), which will ensure that the AAC power system maintains the reliability target.

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Comparison of proposed design to Regulato'¥. Guide 1.155 Section 3.3.5.

1. The AAC power source should not normally be directly connected to the preferred or the blacked-out unit's onsite emergency ac power system.

The SBO DG will normally be isolated from the 4,160VAC preferred and onsite emergency AC power systems by at least two circuit breakers installed in series, including non-Class 1E breaker 3V4 installed in safety-related 4,160VAC Bus 3, a new non-Class 1E breaker installed in the new SBO DG bus, and Class-1 E breakers 3V and 4V. The 3V and 4V breakers are each electrically interlocked to prevent closure when the corresponding normal bus feeder breaker or EDG output breaker is closed. This prevents direct connection of the AAC power source to the preferred or onsite emergency AC power systems.

The auxiliary equipment needed to operate the SBO DG (e.g. battery chargers, DG heaters, etc.) will normally be energized from the 4,160VAC SBO DG bus, which will normally be energized via the VHS tie line connection from the Vernon Hydro Station switchyard. The VHS tie line is not classified as a preferred, Class 1E, or onsite emergency AC power system. A manually-operated transfer switch will be installed to allow the auxiliary equipment to be energized from the non-safety-related portion of the VY station auxiliary AC power system during those times that the normal AC power source (VHS tie line) is unavailable due to a planned or unplanned outage. The intent of this secondary feed is to maximize the operability of the AAC power source when the VHS tie line is unavailable by keeping a full charge on the SBO DG system batteries and maintaining the equipment in standby status. The use of the transfer switch will be procedurally controlled.

2. There should be a minimum potential for common cause failure with the preferred or the blacked-out unit's onsite emergency ac power sources. No single-point vulnerability should exist whereby a weather-related event or single active failure could disable any portions of the blacked-out unit's onsite emergency ac power sources or the preferred power sources and simultaneously fail the AAC power source.

As discussed previously, the SBO DG system will be physically located a considerable distance (at least 1000 feet) from the high-voltage switchyard, which will provide protection against the effects of likely weather-related events that may initiate the loss of off-site power event. The SBO DG will also be located away from the onsite emergency AC power sources (EDG units),

so there is no postulated weather-related event that could disable the onsite EDG units concurrently with the SBO DG.

The SBO DG will be physically isolated from the onsite emergency AC and preferred power sources, so a single active mechanical failure will not disable the AAC power source concurrently with the onsite emergency AC or preferred power sources.

The SBO DG will normally be electrically isolated from the onsite emergency AC and preferred power sources. As discussed in Section B.7, a manually-operated transfer switch will be installed to allow the auxiliary equipment to be energized from the non-safety-related portion of the VY station auxiliary AC power system during those times that the normal AC power source (VHS tie line) is unavailable due to a planned or unplanned outage. In this configuration, a single active failure will not disable the AAC power source concurrently with the onsite emergency AC or preferred power sources. An electrical failure initiated at the AAC power source, emergency AC power source, or preferred power sources will be isolated by automatic tripping of circuit breakers prior to propagating to the other AC sources.

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3. The AAC power source should be available in a timely manner after the onset of station blackout and have provisions to be manually connected to one or all of the redundant safety buses as required. The time required for making this equipment available should not be more than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> as demonstrated by test. If the AAC power source can be demonstrated by test to be available to power the shutdown buses within 10 minutes of the onset of station blackout, no coping analysis is required.

The SBa DG will be maintained in a "ready to operate" condition such that it can be started and connected to one of the safety buses (Bus 3 or Bus 4) in a timely manner. Following installation of the new AAC power source, initial testing will be performed to demonstrate that power can be made available up to existing circuit breaker 3V4 within two hours of the onset of station blackout. The actions required to complete alignment of the AAC power source to Bus 3 or Bus 4 include closure of two circuit breakers from the VYNPS control room (3V4 and either 3V or 4V, depending on which bus is being energized). ance the AAC power source is energized up to 3V4, it takes very little time to align loads from the control room. Therefore, energizing the AAC power source up to circuit breaker 3V4 within two hours satisfactorily demonstrates that the AAC power source can be made available to power Bus 3 or Bus 4 within two hours.

VY performed a coping analysis assuming EPU conditions and submitted it to the NRC by letter dated March 24, 2005. Based on the results of the analysis, VY concluded that the plant is able to safely cope with a total loss of AC power for a minimum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> from the onset of the SBa to the restoration of offsite AC power to a 4160-volt emergency bus. The NRC documented a review of the analysis in the EPU safety evaluation, dated March 2,2006.

The testing performed for the new AAC power source will demonstrate that the AAC power source can be aligned to one of the safety buses within two hours; therefore, the existing coping analysis is bounding.

4. The AAC power source should have sufficient capacity to operate the systems necessary for coping with a station blackout for the time required to bring and maintain the plant in safe shutdown.

The SBa DG wi" be rated for continuous operation at 3,000kW, which is greater than the continuous rating of the onsite emergency AC power sources (EDG unit), which is 2,750kW as specified in UFSAR Section 8.5; therefore, the SBa DG has sufficient capacity to operate the systems necessary to bring the plant to a safe shutdown condition. As discussed in section B.8(c), the SBa DG wi" include a dedicated fuel oil storage tank with a capacity sufficient for operation of the DG at 100% rated load for at least 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, which provides significant margin over the existing design basis eight hours coping time and is sufficient time to maintain the plant in a safe shutdown condition.

5. The AAC power system should be inspected, maintained, and tested periodically to demonstrate operability and reliability. The reliability of the AAC power system should meet or exceed 95 percent as determined in accordance with NSAC-108 (Ref. 11) or equivalent methodology.

The SBa DG equipment wi" be started and brought to approximately rated load capacity (3,000kW) at least four times per year at intervals not longer than 100 days in accordance with plant-developed procedures and preventive maintenance work order tasks established in accordance with manufacturer recommendations and industry guidance. The electrical load for the SBa DG for this test wi" be provided by a permanently installed 3,OOOkW resistive load bank located adjacent to the SBa DG enclosure.

Page 11 of 19

Once every refueling Qutage, a timed start will be performed to demonstrate that the AAC power source can be started and aligned to bne of the plant shutdown buses within two (2) hours consistent with the VY coping duration.

Once every third refueling outage. the SBO DG will be demonstrated by test to be capable of starting the largest motor on safety Bus 3 or safety Bus 4.

VY is currently committed to perform a timed startup, alignment and rated load capacity test of the AAC power source once every third refueling outage. as described in UFSAR Section 8.3.3.

VY has established a reliability target of 0.95 for the standby AAC power system in accordance with the Entergy Emergency Diesel Generator Program (EN-DC-198). which includes the guidance in NUMARC 87-00, Appendix D. The AAC power system will also be included in the scope of the VY Maintenance Rule Program (EN-DC-203). which will ensure that the AAC power system maintains the reliability target.

QA Requirements for sao Equipment that is not Safe tv-Related (Regulator Guide 1.155 Appendix AJ

1. Design Control and Procurement Documents Control Measures should be established to ensure that all design-related guidelines used in complying with § 50.63 are included in design and procurement documents, and that deviations therefrom are controlled.

The AAC power source will be designed, procured and installed in accordance with Entergy's fleet procedures.

2. Instructions, Procedures, and Drawings Inspections, tests, administrative controls, and training necessary for compliance with § 50.63 should be prescribed by documented instructions, procedures, and drawings and should be accomplished in accordance with these documents.

The AAC power source will be installed and operated in accordance with approved installation and testing documents and operating procedures generated in accordance with Entergy's quality assurance program. Design drawings will be entered into the VY drawing database in accordance with Entergy's fleet design change procedures.

3. Control of Purchased Material, Equipment. and Services Measures should be established to ensure that purchased material, equipment, and services conform to the procurement documents.

Procurement of material, equipment and services will be controlled in accordance with a Critical Procurement Plan (CPP) generated per Entergy's fleet procedures. The CPP provides a mechanism to ensure that all applicable requirements are met for the material, equipment, and services being procured.

Page 12 of 19

4. Inspection A program for independent inspection of activities required to comply with § 50.63 should be established and executed by (or for) the organization performing the activity to verify conformance with documented installation drawings and test procedures for accomplishing the activities.

Peer inspections will be performed for critical installation and testing steps, as documented in the initial testing documents generated in accordance with Entergy's fleet design change process.

In-process witness and acceptance testing is specified by contract and in the CPP.

5. Testing and Test Control A test program should be established and implemented to ensure that testing is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. The tests should be performed in accordance with written test procedures; test results should be properly evaluated and acted on.

The AAC power source will be periodically tested in accordance with procedures developed in accordance with Entergy's quality assurance program. Initial testing will be performed using Engineering Change Test procedure(s) generated in accordance with Entergy's fleet design change process.

6. Inspection. Test and Operating Status Measures should be established to identify items that have satisfactorily passed required tests and inspections.

The AAC power source will be periodically tested in accordance with procedures developed in accordance with Entergy's quality assurance program. Initial testing will be performed using Engineering Change Test procedure(s) generated in accordance with Entergy's fleet design change process. Preventive maintenance work order tasks will be established in accordance with manufacturer recommendations and industry guidance.

7. Non Conforming Items Measures should be established to control items that do not conform to specified requirements to prevent inadvertent use or installation.

Non conforming items will be segregated and controlled in accordance with the corrective action program.

8. Corrective Action Measures should be established to ensure that failures, malfunctions, deficiencies, deviations, defective components, and non conformances are promptly identified, reported, and corrected.

Conditions adverse to quality will be entered into the corrective action program.

9. Records Records should be prepared and maintained to furnish evidence that the criteria enumerated above are being met for activities required to comply with § 50.63.

Records documenting the quality related activities will be retained in accordance with the quality records program.

Page 13 of 19

10. Audits .. .. . ... . /. . . . . .... c.,

Audits should be 'conducted and documented to verify*compliance with design and procurement documents, instructions, procedures, drawings, and inspection and test activities developed to comply with § 50.63.

Station Blackout is included in the quality master audit plan as an element that can be selected for audit.

Control Room Monitoring (from SRP Section 8.4)

Plant staff in the control room monitor the performance of the AAC power source. As a minimum, monitoring should include the voltage, current, frequency, and circuit breaker position.

An operator interface panel (OIP) will be installed in the VY Control Room to provide monitoring and control capability for the AAC power system when it is in service. The OIP will provide information on the critical operating parameters for the SBO DG and its associated bus, including system voltage, current, frequency, and circuit breaker position, as well as any alarm conditions that impact the operation of the AAC power system. The OIP is powered from Vital AC, which will remain energized through a station blackout event, allowing the SBO DG to be started and the critical operating parameters monitored from the Control Room.

An existing spare annunciator window on existing Control Room Panel 9-8 will be configured to alert operators to any alarm condition from the AAC power system. This annunciator window is separate from the OIP installed in the Control Room.

Operating Procedures and Training (from SRP Section 8.4)

Procedures need to:

A. Cope with the occurrence of an SBO for the specified coping duration during aU modes of plant operation and include actions necessary to place MC power sources in service and maintain acceptable environmental conditions for equipment necessary to mitigate the event. Procedures developed to cope with an SBO should be integrated with the plant specific technical guidelines and emergency operating procedures developed using the emergency operating procedure upgrade program established in response to Supplement 1 of NUREG-0737. The task analysis portion of the emergency operating procedure upgrade program should include an analysis of instrumentation adequacy during an SBO.

Procedures meeting these criteria are in place to allow the plant to cope with a SBO for the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> coping duration. EOPs are symptom based and do not address specifically SBO.

B. Restore standby (Class 1E) power sources when the EAC power system is unavailable.

Procedures contain the necessary direction to restore the Class 1E power sources in service if the emergency AC power system becomes unavailable.

Page 14 of 19

C. Restore offsite power sQurces.and use of nearby power sources (which may include nearby or onsite gas turb.ne generators, portable generators, hydrogenerators. and black start fossil power plants) in the event of a LOOP.

As a minimum, the following potential causes for a LOOP should be considered:

i. Grid undervoltage and collapse.

ii. Weather-induced power loss.

iii. Preferred power distribution system faults that could result in the loss of normal power to essential switchgear buses. This includes such failures as distribution system hardware, switching and maintenance errors, and lightning-induced faults.

Procedures contain direction to contact the regional grid (ISO-NE) and transmission (Vermont Electric Power Company (VELCO>> operators to restore offsite power to the plant in the event of a LOOP. Guidance is also included to contact equipment vendors to supply portable generators which can be connected to energize vital equipment. The priority of establishing reliable power to nuclear generators is contained in ISO-NE procedure OP-6, Appendix A (System Restoration Guidelines).

D. Actions necessary to restore normal long-term core cooling/decay heat removal once ac power is restored.

Site procedures direct operators to commence a cool down and establish long term core cooling/decay heat removal once conditions allow. The proposed sao DG will be capable of commencing a cool down and establishing long term core cooling / decay heat removal.

E. The procedure should specify actions necessary to assure that shutdown equipment (including support systems) necessary in an seo can operate without ac power.

Procedures are in place to assure that shutdown equipment (including support systems) necessary in an sao can operate without ac power. Procedures require reduction of nonessential loads in an sao to maximize the capability of backup DC power sources.

F. The procedure should recognize the importance of decay heat removal systems (auxiliary feedwater, high-pressure coolant injection, high-pressure core spray, reactor core isolation cooling) during the early stages of the event and direct operators to invest appropriate attention to ensuring their continued reliable operation throughout the event.

Procedures recognize the importance and direct operations of necessary decay heat removal systems during a station blackout event. The procedures direct the required cool down rates for an event and actions to conserve DC power to ensure the reactor core isolation cooling and high pressure coolant injection systems maintain reliable operation throughout the event.

G. Plant operating procedures should identify the sources of potential inventory loss and specify actions to prevent or limit significant loss.

Symptom-based site approved procedures do not specifically address potential inventory loss.

Page 15 of 19

H. Plant operating procedures should ensure the prompt establishment of a flowpath for makeup flow from the Condensate Storage Tank (CST) to the steam generator/nuclear boiler and identify 8.4-18 Revision 1- May 2010 backup sources to the CST in order of intended use.

In addition, plant operating procedures should specify clear criteria for transferring to the next preferred source of water.

Emergency procedures identify make up sources of water and ensure the prompt establishment of a flowpath from the CST to the nuclear boiler. Procedures contain direction and precautions/administrative limits for transferring water sources supplies when required.

I. The procedure should identify individual loads that need to be stripped from the plant dc buses (both Class 1E and non-Class 1E) to conserve dc power.

Site procedures identify securing of DC loads, as plant conditions allow, to conserve DC power.

J. Plant operating procedures should specify actions to permit appropriate containment isolation and safe-shutdown valve operations while ac power is unavailable.

Site procedures will identify actions to maintain operation of containment isolation/safe shutdown valve operation while AC power is unavailable.

K. Plant operating procedures should identify the portable lighting necessary for ingress and egress to plant areas containing shutdown or AAC equipment requiring manual operation.

A plant procedure lists the Appendix R lighting installed in the plant that will automatically illuminate in the event of a loss of normal power. Since the SBa DG can be operated from the Control Room, access to the SBa DG is not normally required to support its operation.

L. Plant operating procedures should consider the effects of ac power loss on area access, as well as the need to gain entry to other locked areas where remote equipment operation is necessary.

The SBa DG can be operated from the Control Room. Access to the SBa DG does not rely on AC power. Access to other vital areas can be gained by use of issued keys.

M. Plant operating procedures should consider the effects of a loss of ac power on communications capabilities, including the potential for a loss of communications with offsite agencies.

Plant procedures describe the communications available during emergencies, including the loss of AC power. Communications systems are being re-evaluated as part of Fukushima-related activities.

N. Plant operating procedures should consider the loss of heat tracing effects for equipment necessary to cope with an SBO.

The SBa DG will not contain a heat trace system. The loss of existing site heat tracing has no impact on the SBa DG.

O. To provide assurance that the Nuclear Power Plant (NPP) operator will be kept aware of changes in the plant switchyard and offsite power grid, plant or site procedures should establish appropriate communication protocols between the NPP and its transmission system operator. With regard to SBO, these protocols should aid the operator in determining the following:

Page 16 of 19

i. The performance of grid.risk-sensitive maintenance activities (such as surveillances, post maintenance testing, and preventive and corrective maintenance) that could increase the likelihood of an SBO or impact the plant's ability to cope with an SBO, such as out.of-service risk-significant equipment (e.g., an EDG, a battery, a steam driven pump, an AAe power source).

ii. The availability of local power sources and transmission paths that could be made available to resupply the plant following a LOOP event.

Agreements are in place between Entergy, VELCO and ISO-NE to communicate grid-risk-sensitive maintenance testing and preventative and corrective maintenance that could increase the likelihood of a SBO event. The agreement includes restoring power to the plant in priority based ISO rules.

The priority of establishing reliable power to nuclear generators is contained in ISO-NE procedure OP-6, Appendix A (System Restoration Guidelines).

Comparison of Proposed Design to 10 CFR 50.2 Definition of Alternate AC Source Alternate ac source means an alternating current (ac) power source that is available to and located at or nearby a nuclear power plant and meets the following requirements:

1. Is connectable to but not normally connected to the offsite or onsite emergency ac power systems;

2. Has minimum potential for common mode failure with offsite power or onsite emergency ac power sources;

3. Is available in a timely manner after onset of station blackout; and

4. Has sufficient capacity and reliability for operation of all systems required for coping with station blackout and for the time required to bring and maintain the plant in safe shutdown (non-design basis accident).

The SBO DG will be located within the VY protected area boundary.

1. The SBO DG will be connectable to but not normally connected to the onsite emergency ac power sources. VY does not utilize an offsite emergency ac power source. This is discussed in section B.7 of the comparison to the NUMARC 87-00 criteria and section 1 of the comparison to the Regulatory Guide 1.155 criteria.

2. The SBO DG has minimum potential for common mode failure with onsite emergency ac power sources. This is discussed in section B.8 of the comparison to the NUMARC 87-00 criteria and section 2 of the comparison to the Regulatory Guide 1.155 criteria.

3. The SBO DG will be available in a timely manner after onset of station blackout. This is discussed in section B.12 of the comparison to the NUMARC 87-00 criteria and section 3 of the comparison to the Regulatory Guide 1.155 criteria.

4. The SBO DG will have sufficient capacity and reliability for operation of all systems required for coping with station blackout and for the time required to bring and maintain the plant in safe shutdown. This is discussed in section B.9 of the comparison to the NUMARC 87-00 criteria and section 4 of the comparison to the Regulatory Guide 1.155 criteria.

Preliminary Significant Hazards and Environmental Considerations The proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92{c), and, accordingly, a finding of "no significant hazards consideration" can be justified.

The proposed change meets the eligibility criteria for categorical exclusion as set forth in 10CFR51.22{c)(9). Pursuant to 10CFR51.22{b). no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

Page 17 of 19

Precedence The NRC found the use of a non safety-related DG as the MC power source at Calvert Cliffs Nuclear Power Plant (Reference 10) and Pilgrim Nuclear Power Station (References 11 and 12) to be acceptable.

REFERENCES

1. Letter, USNRC to VY, Supplemental Safety Evaluation of Vermont Yankee Nuclear Power Station, Station Blackout Rule (10 CFR 50.63) (TAC No. M68620), dated September 1,1992, NVY 92-163

2. Letter, USNRC to Vy, Vermont Yankee Station Blackout Analysis (TAC No. 68620), dated June 5, 1991

3. Letter, USNRC to VY, Supplemental Safety Evaluation Vermont Yankee Station Blackout Analysis (TAC No. M85981), dated June 18,1993

4. Letter, USNRC to VY, Supplemental Safety Evaluation of Station Blackout Analysis - Vermont Yankee Nuclear Power Station (TAC No. M87808)

5. Letter, USNRC to Entergy Nuclear Operations, Inc., Vermont Yankee Nuclear Power Station Issuance of Amendment Re: Extended Power Uprate (TAC No. MC0761), dated March 2,2006, NVY 06-028

6. Letter, VY to USNRC, Update on Vermont Yankee Program Commitments Relative to Periodic Testing of Alternate AC Source, dated August 14, 2008, BVY 08-043

7. NUMARC 87-00, Revision 1, Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors, dated August 1991

8. Regulatory Guide 1.155, Station Blackout, dated August 1988

9. NUREG-0800, Standard Review Plan, Section 8.4 Station Blackout, Revision 1, dated May 2010

10. Letter, USNRC to Calvert Cliffs Nuclear Power Plant, Alternate AC Power Source Design Report - Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 (TAC Nos. M89086 & M89087),

dated October 3, 1994

11. Letter, USNRC to Pilgrim Nuclear Power Station, Safety Evaluation of the Pilgrim Nuclear Power Station Response to the Station Blackout Rule (TAC No. 68585), dated February 13, 1991

12. Letter, USNRC to Pilgrim Nuclear Power Station, Supplemental Safety Evaluation (SSE) of the Pilgrim Nuclear Power Station Response to the Station Blackout Rule (TAC No. 68585), dated January 15,1992 Page 18 of 19

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November 30, 2012 LICENSEE: Entergy Nuclear Operations, Inc.

Entergy Nuclear Vermont Yankee, LLC FACILITY: Vermont Yankee Nuclear Power Station

SUMMARY

OF NOVEMBER 13, 2012, PRE-APPLICATION MEETING WITH ENTERGY NUCLEAR OPERATIONS, INC. REGARDING THE PROPOSED STATION BLACKOUT DIESEL GENERATOR LICENSE AMENDMENT REQUEST FOR VERMONT YANKEE NUCLEAR POWER STATION (TAC NO.

ME9836)

On November 13, 2012, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Entergy Nuclear Operations, Inc.

(Entergy, the licensee) at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. The purpose of the meeting was to discuss Entergy's planned submittal of a license amendment request to revise the Vermont Yankee Nuclear Power Station (VYNPS) licensing basis to replace the Vernon Hydroelectric Station with an onsite diesel generator as the source of alternate AC power credited for compliance with Title 10 of the Code of Federal Regulations, Section 50.63, "Loss of all alternating current power."

A member of the public was in attendance. Public Meeting Feedback forms were not received. is a list of meeting attendees and Enclosure 2 is a copy of the licensee's handouts presented at the meeting (Agencywide Documents Access and Management System Accession No. ML123310056).

Please direct any inquiries to me at 301-415-1030 or Richard.Guzman@nrc.gov Sincerely, IRA!

Richard V. Guzman, Senior Project Manager Plant licensing Branch 1-1 Division of Operating Reactor licensing Office of Nuclear Reactor Regulation Docket No. 50-271

Enclosures:

1. List of Attendees

2. Licensee's Handouts cc w/encls: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsN rrDorlLpl1-1 Resource RidsAcrsAcnw_MailCTR Resource VGoel, NRR RidsOgcRp Resource NRRLPL1-1 Branch Reading RidsNrrLAKGoldstein Resource TSetzer, RI RidsNrrDeEeeb Resource RidsRgn1MailCenter Resource RidsNrrPmVermontYankee RWolfgang, NRR ADAMS Accession No. PKG ML12333A207, Meeting Notice ML12298A088, Mee f ,"g Summary ML12333A222, P u bl'IC Han d ou t s ML123310056 OFFICE DORULPL1-1/PM DORULPL 1-1/LA DORULPL1-1/BC DORULPL1-1/PM NAME RGuzman KGoldstein GWilson RGuzman DATE 11/29/12 11/29/12 11/30/12 11/30/12 OFFICIAL RECORD COpy