Text

Issuance of License Amendment No. 171 Regarding Restoration Period Before Declaring Average Power Range Monitors Inoperable When Surveillance Requirement 3.3.1.1.2 Is Not Met
	ML12339A035
Person / Time
Site:	Monticello
Issue date:	01/25/2013
From:	Beltz T; Plant Licensing Branch III
To:	Schimmel M; Northern States Power Co
	Beltz T
References
	TAC ME8571
	Download: ML12339A035 (14)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 25, 2013 Mr. Mark A. Schimmel Site Vice President Monticello Nuclear Generating Plant Northern States Power Company - Minnesota 2807 West County Road 75 Monticello, MN 55362-9637

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT - ISSUANCE OF AMENDMENT REGARDING THE RESTORATION PERIOD BEFORE DECLARING AVERAGE POWER RANGE MONITORS INOPERABLE (TAC NO. ME8571)

Dear Mr. Schimmel:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 171 to Renewed Facility Operating License No. DPR-22 for the Monticello Nuclear Generating Plant.

The amendment consists of changes to the technical specifications (TSs) in response to your application dated May 8,2012.

The amendment changes the restoration period before declaring the average power range monitors (APRMs) inoperable when TS surveillance requirement (SR) 3.3.1.1.2 is not met. The change allows a time period for restoration when the absolute difference between the APRM channel power and calculated thermal power exceeds the limit of TS SR 3.3.1.1.2, before declaring the channels inoperable.

A copy of our related safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

~~~4_~

Terry A. Beltz, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-263

Enclosures:

1. Amendment No. 171 to DPR-22

2. Safety Evaluation cc w/encls: Distribution via ListServ

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 NORTHERN STATES POWER COMPANY DOCKET NO. 50-263 MONTICELLO NUCLEAR GENERATING PLANT AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 171 License No. DPR-22

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Northern States Power Company (NSPM, the licensee), dated May 8, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2. C.2 of Renewed Facility Operating License No. DPR-22 is hereby amended to read as follows:

-2 Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 171, are hereby incorporated in the license. NSPM shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 90 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

~~-----

Robert D. Carlson, Chief Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Operating License DPR-22 and Technical Specifications Date of Issuance: January ,2013

ATTACHMENT TO LICENSE AMENDMENT NO. 171 RENEWED FACILITY OPERATING LICENSE NO. DPR-22 DOCKET NO. 50-263 Replace the following page of Renewed Facility Operating License DPR-22 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

REMOVE INSERT 3 3 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain a marginal line indicating the area of change.

REMOVE INSERT 3.3.1.1-1 3.3.1.1-1 3.3.1.1-2 3.3.1.1-2

-3

2. Pursuant to the Act and 10 CFR Part 70, NSPM to receive, possess, and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operations, as described in the Final Safety Analysis Report. as supplemented and amended, and the licensee's filings dated August 16, 1974 (those portions dealing with handling of reactor fuel) and August 17, 1977 (those portions dealing with fuel assembly storage capacity);

3. Pursuant to the Act and 10 CFR Parts 30, 40 and 70, NSPM to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required;

4. Pursuant to the Act and 10 CFR Parts 30, 40 and 70, NSPM to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and

5. Pursuant to the Act and 10 CFR Parts 30 and 70, NSPM to possess, but not separate, such byproduct and special nuclear material as may be produced by operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission, now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

1. Maximum Power Level NSPM is authorized to operate the facility at steady state reactor core power levels not in excess of 1775 megawatts (thermal).

2. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 171, are hereby incorporated in the license. NSPM shall operate the facility in accordance with the Technical Specifications.

3. Physical Protection NSPM shall implement and maintain in effect all provisions of the Commissioned-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Renewed License No. DPR-22 Amendment No. ~ 171

RPS Instrumentation 3.3.1.1 3.3 INSTRUMENTATION 3.3.1.1 Reactor Protection System (RPS) Instrumentation LCO 3.3.1.1 The RPS instrumentation for each Function in Table 3.3.1.1-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.1.1-1.

ACTIONS

NOTE----------------------------------------------------------

1. Separate Condition entry is allowed for each channel.

2. When the Function 2.b and 2.c channels are not within the limit of SR 3.3.1.1.2 due to APRM indication not within limits, entry into associated Conditions and Required Actions may be delayed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months if the APRM is indicating a lower power value than the calculated power, and for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if the APRM is indicating a higher power value than the calculated power.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Place channel in trip. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months channels inoperable.

OR A.2 --------------NOTE------------ 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Not applicable for Functions 2.a, 2.b, 2.c, 2.d or 2.f.

Place associated trip system in trip.

B. -----------NOTE----------- 8.1 Place channel in one trip 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Not applicable for system in trip.

Functions 2.a, 2.b, 2.c, 2.d or 2.f. OR One or more Functions B.2 Place one trip system in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months with one or more trip.

required channels inoperable in both trip systems.

Monticello 3.3.1.1-1 Amendment No. 146, 159, 171

RPS Instrumentation 3.3.1.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more Functions C.1 Restore RPS trip capability. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months with RPS trip capability not maintained.

D. Required Action and D.1 Enter the Condition Immediately associated Completion referenced in Time of Condition A, B, Table 3.3.1.1-1 for the or C not met. channel.

E. As required by Required E.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Action D.1 and POWER to:s; 45% RTP.

referenced in Table 3.3.1.1-1.

F. As required by Required F.1 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action D.1 and referenced in AND Table 3.3.1.1-1.

F.2 --------------N 0 TE ------------

Only applicable to Function 5.

Reduce reactor pressure to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

< 600 psig.

G. As required by Required G.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Action D.1 and referenced in Table 3.3.1.1-1.

H. As required by Required H.1 Initiate action to fully insert Immediately Action D.1 and all insertable control rods in referenced in core cells containing one or Table 3.3.1.1-1. more fuel assemblies.

Monticello 3.3.1.1-2 Amendment No. 146, 159, 171

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 171 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-22 NORTHERN STATES POWER COMPANY MONTICELLO NUCLEAR GENERATING PLANT DOCKET NO. 50-263

1.0 INTRODUCTION

By letter to the U.S. Nuclear Regulatory Commission (NRC or Commission) dated May 8, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12131A406), Northern States Power Company - Minnesota (the licensee) submitted a license amendment request for the Monticello Nuclear Generating Plant (MNGP). The proposed amendment would change the required restoration period before declaring the average power range monitors (APRMs) inoperable when technical specification (TS)

Surveillance Requirement (SR) 3.3.1.1.2 is not met. The proposed amendment allows a time period for restoration when the absolute difference between the APRM channel power and calculated thermal power exceeds the limit of SR 3.3.1.1.2 before declaring the channels inoperable.

2.0 REGULATORY EVALUATION

The APRMs provide the primary indication of neutron flux within the core and respond almost instantaneously to neutron flux increases. The APRM channels receive input signals from local power range monitors in the reactor core to provide an indication of the power distribution and local power changes. The APRM system is divided into four APRM channels that provide inputs to each of the four 2-out-of-4 voter channels, which in turn provide inputs to the reactoi protection system (RPS) trip systems. Three of the four APRM channels, and all four of the voter channels, are required to be OPERABLE to ensure that no single-failure precludes a scram on a valid signal.

The APRMs are calibrated at a Frequency of once per 7 days in accordance with SR 3.3.1.1.2.

If the APRM functions of APRM Flow Biased Simulated Thermal Power - Upscale (Function 2.b) and APRM Fixed Neutron Flux - High (Function 2.c) are declared inoperable, REQUIRED ACTION A,1 and C.1 of TS 3.3.1.1, "Reactor Protection System (RPS) Instrumentation," are entered. Required action a.1 requires placing the channel in trip within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and if RPS trip capability is not met, required action c.1 allows one hour to restore RPS trip capability. If trip capability cannot be restored within one hour, then a plant shutdown must commence. The proposed change will modify the ACTIONS by allowing a delay for up to two hours if the APRM Enclosure 2

-2 is indicating a lower power value than the calculated power (non-conservative case), and provide for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if the APRM is indicating a higher power value than the calculated value (conservative case).

The NRC staff considered the following regulatory requirements:

Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36, "Technical specifications," in which the Commission established its regulatory requirements related to the contents of the TS. Specifically, 10 CFR 50.36(a)(1) states that "Each applicant for a license authorizing operation of a production or utilization facility shall include in its application proposed technical specifications in accordance with the requirements of this section."

In 10 CFR 50.36(c)(3) it states that, "Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be met."

Appendix A to 10 CFR Part 50, "General Design Criteria [GOC] for Nuclear Power Plants,"

was published in 1971. The MNGP was constructed prior to the 1971 publication of Appendix A, and was not licensed to the Appendix A, GOCs.

The MNGP Updated Safety Analysis Report (USAR), Section 1.2, lists the principal design criteria for the deSign, construction and operation of the plant. Appendix E of the USAR provides a plant comparative evaluation with the GOC for Nuclear Power Plant Construction Permits proposed by the Atomic Energy Commission for public comment in July 1967.

Therefore, MNGP conforms to the intent of the Appendix A GOCs.

The applicable 10 CFR Part 50, Appendix A, GOCs are discussed below:

Criterion 13 - Instrumentation and control. Instrumentation shall be provided to monitor variables and systems over their antiCipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems. Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges.

Criterion 20 - Protection system functions. The protection system shall be designed (1) to initiate automatically the operation of appropriate systems, including the reactivity control systems, to assure that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences and (2) to sense accident conditions and to initiate the operation of systems and components important to safety.

Criterion 21 - Protection system reliability and testability. The protection system shall be designed for high functional reliability and inservice testability commensurate with the safety functions to be performed. Redundancy and independence designed into the protection

-3 system shall be sufficient to assure that (1) no single-failure results in loss of the protection function and (2) removal from service of any component or channel does not result in loss of the required minimum redundancy unless the acceptable reliability of operation of the protection system can be otherwise demonstrated. The protection system shall be designed to permit periodic testing of its functioning when the reactor isin operation, including a capability to test channels independently to determine failures and losses of redundancy that may have occurred.

Criterion 22 - Protection system independence. The protection system shall be designed to assure that the effects of natural phenomena, and of normal operating, maintenance, testing, and postulated accident conditions on redundant channels do not result in loss of the protection function, or shall be demonstrated to be acceptable on some other defined basis. Design techniques, such as functional diversity or diversity in component design and principles of operation, shall be used to the extent practical to prevent loss of the protection function.

Criterion 29 - Protection against anticipated operational occurrences. The protection and reactivity control systems shall be designed to assure an extremely high probability of accomplishing their safety functions in the event of anticipated operational occurrences.

3.0 TECHNICAL EVALUATION

3.1 Background The NRC staff reviewed the following proposed changes pertaining to SR 3.3.1.1. 2:

1. Section 3.3.1.1 of the TS discusses the applicability and the actions for limiting condition of operation (LCO) 3.3.1.1, "Reactor Protection System (RPS) Instrumentation." The following changes were proposed under notes related to actions:

The existing note which was not previously numbered has been added as Note 1.

Note 2 was added which states, "When the Function 2.b and 2.c channels are not within the limit of SR 3.3.1.1.2 due to APRM indication not within limits, entry into associated Conditions and Required Actions may be delayed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months if the APRM is indicating a lower power value than the calculated thermal power, and for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if the APRM is indicating a higher power value than the calculated thermal power."

2. The provision above is applicable for the following average power range monitoring functions:

2.b APRM Flow Biased Simulated Thermal Power - Upscale

2.c APRM Fixed Neutron Flux - High

-4 3.2 Staff Evaluation The licensee proposed the addition of Note 2 to the ACTIONS under TS Section 3.3.1.1.

Currently, there is only one note which is not numbered, and with the addition of the proposed new note, the licensee has proposed that the existing Note be designated as Note 1. A new Note will be added and designated as Note 2, with the following wording:

"When the Function 2.b and 2.c channels are not within the limit of SR 3.3.1.1.2 due to APRM indication not within limits, entry into associated Conditions and Required Actions may be delayed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months if the APRM is indicating a lower power value than the calculated thermal power, and for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if the APRM is indicating a higher power value than the calculated thermal power."

For Function 2.b, Simulated Thermal Power - High, and Function 2.c, Neutron Flux - High, three channels are required for the trip channels to be operable. If one or more required channels are inoperable, Condition A requires that the channel(s) be placed in tripped condition within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . If one or more Functions with RPS trip capability are not met, then Condition C applies. Condition C states that if one or more Functions with RPS trip capability are not maintained, then required Action C.1 is entered, which requires RPS trip capability to be restored within the completion time of one hour. If trip capability is not restored within one hour, then a plant shutdown must commence. The plant is to be placed in Mode 2 (Hot Shutdown) within six hours, pursuant to Condition F.

The APRMs are calibrated every seven days as required by SR 3.3.1.1.2. If the difference between the calculated thermal core power and the average APRM power is found to be greater than 2 percent, then the gain factors are adjusted to bring the APRM indicated power within the allowable limits.

If APRM power is indicating less than calculated core thermal power, then this represents the non-conservative case for RPS actuation. When APRM power is indicating higher than the calculated core thermal power, then this represents the conservative case RPS actuation. The absolute allowable difference in either case is 2 percent of the rated thermal power (RTP).

Currently, there is no provision in the TS for any delay time to calibrate/fix/repair the channel.

The licensee stated that when the APRM value is more conservative than the calculated thermal power, then it can only generate a trip at less than the allowable flux value, which does not challenge plant safety. Furthermore, should one channel read more conservative and a second channel read less conservative, then it is safe to allow a longer time to place the channel within the required calibration range.

When Functions 2.b and 2.c are not within the limits of SR 3.3.1.1.2, by adding Note 2 to TS Section 3.3.1.1 allows the licensee a delay of two hours prior to entering associated Conditions and Required Actions if the APRM indicates a lower power than the calculated thermal power and a delay of up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if the APRM indicates a higher power than the calculated thermal power.

-5 The licensee cited the safety evaluation (SE) issued by the NRC staff for LaSalle County Station (LaSalle), Units 1 and 2 (ADAMS Accession No. ML021120212). The LaSalle SE is relevant because the MNGP APRM system is similar in functional to that of LaSalle. The LaSalle SE, in part, states the following:

"Commonwealth Edison has requested three clarifying changes to Technical Specifications 3.2.2 and 3/4.3.1 for La Salle Units 1 & 2. The primary proposed change concerns the interpretation and intent of a footnote, (d), in Table 4.3.1.1-1 relating to the weekly calibration of the APRMs, This footnote presently indicates that the calibration shall consist of an adjustment of the APRM channel to conform to the heat balance power determination (above 25 percent power) when the absolute difference in the two is greater than 2 percent. No time limit is given for making the adjustment. The proposed change makes a distinction between cases where the APRM reading is greater or less than the thermal power determination, a distinction based on operating power level, and provides time limits for required adjustments.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months time for GAF [Gain Adjustment Factor] > 1 is the same as that used in Specification 3.2.2 and 3.3.1 for comparable operation conditions and is reasonable and acceptable. For GAF < 1, the high reading of the APRM is conservative, and it is reasonable to allow a larger time for the adjustment. The proposed 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for this adjustment is compatible with the surveillance times given in Specifications 3.2.1 and 3.2.2 and is reasonable and acceptable."

The justification for a 2-hour time frame is based on other sections of the LaSalle TSs (e.g.,

Section 3.2.2, restoration of minimum critical power ratio within limits in two hours) which represent comparable operating conditions and the two hour time limit was deemed reasonable.

A time period of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months was deemed reasonable for the more conservative case when the GAF is < 1, and was compatible with surveillance times given in specifications 3.2.2.

The immediacy of the action to commence the shutdown of the plant in one hour if the channel cannot be put in service is not warranted. In addition, a review of the TSs for LaSalle, Dresden, and Quad Cities - other boiling water reactors - found similar notes in Section 3.3.1.1, with the same time frames and very similar language as that proposed by MNGP.

3.3 Summary The NRC staff reviewed the licensee's amendment request and finds it to be acceptable based on the following considerations:

(a) The proposed changes continue to meet the requirements of 10 CFR 50.36(a} and 50.36(c)(3);

(b) The proposed changes continue to conform to the MNGP Criterion 13, Criterion 20, Criterion 21, Criterion 22, and Criterion 29; and

- 6 (c) The licensee justified the need for the change and provided a reasonable time to correct the average APRM power when it is found outside the normal deviation range of 2 percent.

The regulatory requirements pertaining to the TSs and the GDCs continue to meet the existing design basis. The addition of Note 2 represents a change which is very similar to that made for LaSalle and other plants, cited above, and does not adversely affect plant safety due to a very short delay time and the fact that when the APRM reading is more conservative it will result in a earlier plant trip which is a safe mode for plant operation. The NRC staff, therefore, finds that a delay of two hours for the non-conservative case, and a delay of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for the conservative case, to be acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Minnesota State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the use of facility components located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (77 FR 43378, dated July 24, 2012).

Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: Gursharan Singh, NRR Date of issuance: January 25,2013

.. Ml12339A035 ** With Comments Attached OFFICE LPL3-1/PM IlPL3-1/LA EICB/BC

STSB/BC OGC LPL3-1/BC LPL3-1/PM NAME TBeitz -'Thorp RElliott BMizuno RCarlson TBeitz DATE 12111112 112111112 11/08/12 12/1 12121112 01/24/13 01/25/13

v t e Letter Sequence Approval
TAC:ME8571, (Approved, Closed)
Initiation Request Acceptance... Administration Questions Answers Results Approval Other: ML12165A304
MONTHYEAR2012-06-13 [Table View]

ML12339A035