ML13030A495
| ML13030A495 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/30/2013 |
| From: | Karwoski K Division of Engineering |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| Shared Package | |
| ML13030A494 | List: |
| References | |
| RAS 24063, 50-361-CAL, 50-362-CAL, ASLBP 13-924-01-CAL-BD01 | |
| Download: ML13030A495 (12) | |
Text
January 30, 2013 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
SOUTHERN CALIFORNIA EDISON CO. ) Docket Nos. 50-361-CAL, 50-362-CAL
)
)
(San Onofre Nuclear Generating Station, Units )
2 and 3) )
AFFIDAVIT OF MR. KENNETH J. KARWOSKI CONCERNING FOES CLAIMS REGARDING STAFFS MARCH 27, 2012 CAL ISSUED TO SCE I, Kenneth J. Karwoski, do hereby state as follows:
- 1. I am employed as the Senior Level Advisor for Steam Generator Integrity and Materials Inspection, Division of Engineering, Office of Nuclear Reactor Regulation, at the U.S.
Nuclear Regulatory Commission (NRC). A statement of my professional qualifications is attached. My responsibilities include providing technical advice and assistance to the Division of Engineering on a variety of technical, regulatory and policy issues related to steam generators and materials engineering, including advising Staff who are reviewing steam generator issues at San Onofre Nuclear Generating Station, Units 2 and 3.
- 2. This affidavit is prepared in response to Friends of the Earths (FOE) January 11, 2013 Opening Brief in the San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 Confirmatory Action Letter (CAL) proceeding. 1 1
See Opening Brief of Petitioner Friends of the Earth (Jan. 11, 2013) (ADAMS Accession No. ML13011A303(public)) (FOEs Opening Brief). FOEs Opening Brief included 4 attachments: 1) Affidavit of John Large (ADAMS Accession No. ML13011A304 (non-public)); 2) Curriculum Vitae and Affidavit of Arnold Gundersen (ADAMS Accession No. ML13011A306 (public)); 3) Hirsch Report (ADAMS Accession No. ML13011A305 (public)); and 4) FOEs June 18, 2012 Petition to Intervene (ADAMS Accession No. ML13011A307 (public)).
- 3. Among other duties, I am the NRC's technical contact for NRC Generic Letter 2006-01, "Steam Generator Tube Integrity and Associated Technical Specifications" (January 20, 2006). I am familiar with the Technical Specification Task Force (TSTF) TSTF-449, Steam Generator Tube Integrity, and Nuclear Energy Institute (NEI) 97-06, Steam Generator Program Guidelines. Technical Specifications based upon these documents are performance-based in that they focus on ensuring the tubes satisfy performance criteria that are commensurate with assurance of adequate tube integrity. This approach can be readily adapted to new or unexpected degradation mechanisms and advances in nondestructive examination technology.
This approach includes programmatic elements to ensure that tubes are adequately monitored and maintained relative to the structural and leakage performance criteria.
- 4. The technical specifications for SONGS Units 2 and 3, are, like most pressurized water reactors, modeled on TSTF-449, and are consistent with NEI 97-06.
- 5. I have reviewed the NRC's March 27, 2012, Confirmatory Action Letter (CAL), 2 which confirmed the information in the licensee's March 23, 2012, "Steam Generator Return-to-Service Action Plan" (SCEs Return to Service Plan). 3
- 6. I have reviewed FOEs Opening Brief and the attachments thereof, in which FOE claims that the March 27, 2012 CAL issued to SCE constitutes a de facto license amendment. I have also reviewed NRDCs amicus brief dated January 18, 2013. 4 2
Letter from Elmo E. Collins, Regional Administrator, Region IV, USNRC, to Peter T. Dietrich, Senior Vice President and Chief Nuclear Officer, Southern California Edison Company, subject:
Confirmatory Action Letter - San Onofre Nuclear Generating Station, Units 2 and 3, Commitments to Address Steam Generator Tube Degradation, (Mar. 27, 2012) (ADAMS Accession No. ML12087A323)
(CAL).
3 Letter from Peter T. Dietrich, Senior Vice President & Chief Nuclear Officer, Southern California Edison Company to Elmo E. Collins, Regional Administrator, Region IV, USNRC, subject: Docket Nos.
50-361 and 50-362, Steam Generator Return-to-Service Action Plan, San Onofre Nuclear Generating Station (March 23, 2012) (ADAMS Accession No. ML12086A182) (SCEs Return to Service Plan).
Affidavit of Mr. Kenneth J. Karwoski
- 7. In this declaration, I present my views with respect to the purpose and effect of the March 27, 2012 CAL issued to SCE.
- 8. The March 27, 2012 CAL confirmed actions that SCE proposed to take under its existing license. Specifically, the CAL confirmed actions listed in SCEs March 23, 2012 submittal. Attachment 1 to this Affidavit, Comparison of SCE's March 23 Return-to-Service Action Plan with NRC's March 27 Confirmatory Action Letter and Existing Licensing Bases for San Onofre Nuclear Generating Station, Units 2 and 3 (Attachment 1), dated January 30, 2013, demonstrates that the March 27, 2012 CAL did not contemplate any action beyond SCEs existing license.
- 9. As Attachment 1 makes clear, SCE's actions listed in the NRC's CAL, which confirmed the information in the SCEs Return to Service Plan, may all be performed as part of the existing steam generator program. No change to the technical specifications is needed to perform the steps outlined in the CAL. Moreover, SONGS Units 2 and 3 must continue to meet the technical specifications tabulated in Attachment 2 to this Affidavit, Summary of Relevant Technical Specifications for San Onofre Nuclear Generating Station, Units 2 and 3 dated January 30, 2013.
- 10. In light of the foregoing, I conclude that the March 27, 2012 CAL has no effect on SCEs licensing authority. The CAL is not an order, suspension, exemption, or amendment, and does not give SCE any additional authority under its existing license. Specifically, the CAL did not change any of the requirements associated with SONGS Units 2 and 3 steam generator programs and associated technical specifications, including all surveillance requirements and limiting conditions for operation.
(. . .continued) 4 Natural Resources Defense Councils Amicus Response in Support of Friends of the Earth (Jan.
18, 2013) (ADAMS Accession No. ML13018A445) (NRDCs Amicus Brief).
Affidavit of Mr. Kenneth J. Karwoski
- 11. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge, information and belief.
Executed in Accord with 10 CFR 2.304(d)
Kenneth J. Karwoski Senior Advisor for Steam Generator Integrity and Materials Inspection Branch U.S. Nuclear Regulatory Commission Mail Stop O-9 H6 Washington, DC 20555-0001 (301) 415-2752 Kenneth.Karwoski@nrc.gov Executed in Rockville, Maryland this 30th day of January 2013 Affidavit of Mr. Kenneth J. Karwoski
January 28, 2013 Karwoski Statement of Professional Qualifications Kenneth J. Karwoski Senior Level Advisor for Steam Generator Integrity and Materials Inspection Division of Engineering Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Summary Mr. Kenneth J. Karwoski, is the Senior Level Advisor for Steam Generator Integrity and Materials Inspection in the Division of Engineering, Office of Nuclear Reactor Regulation, U.S.
Nuclear Regulatory Commission (NRC), in Washington, District of Columbia (DC). His academic credentials include a Bachelors of Science degree in chemistry and a Bachelor of Science degree in computer science. Mr. Karwoski also qualified as an Engineering Officer of the Watch in the U.S. Navys nuclear power program. His technical background includes extensive involvement in several materials engineering issues related to safe nuclear power plant operations including welding and steam generator integrity issues. Mr. Karwoski has numerous publications and has extensive experience in making presentations to a variety of technical and public audiences, including the Advisory Committee on Reactor Safeguards. Mr.
Karwoski has been a participant in the American Society of Mechanical Engineers (ASME)
Working Group on Welding and Special Repair Processes, the subgroup on Repair and Replacement Activities, and the Board on Nuclear Codes and Standards. Mr. Karwoski is also the NRCs Dam Safety Officer.
Education:
Wayne State University (Detroit, Michigan), Chemistry, BS, 1985 University of Maryland University College (College Park, Maryland), Computer Science, BS, 1993 Experience:
United States Nuclear Regulatory Commission July 2001 to Present:
Senior Level Advisor for Steam Generator Integrity and Materials Inspection Division of Engineering / Office of Nuclear Reactor Regulation This position involves providing advice and guidance to management, division and higher, related to steam generator integrity issues. My official responsibilities include the technical, safety, and regulatory compliance reviews of a variety of steam generator submittals. I provide advice to management, supervisors and staff to support the activities of the division, including review of license renewal applications. This included providing advice and guidance to the staff related to adoption of new steam generator technical specification requirements contained in TSTF-449, Revision 4, Steam Generator Tube Integrity. It also included preparing U.S.
Nuclear Regulatory Commission Generic Letter 2006-01, Steam Generator Tube Integrity and Associated Technical Specifications, to facilitate adoption of these new technical specification requirements at all pressurized water reactors in the U.S. and peer reviewing/reviewing most of the plant-specific submittals adopting these new technical specification requirements.
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January 28, 2013 Karwoski January 2001 to July 2001 Assistant Branch Chief Engineering Research and Applications Branch / Office of Nuclear Regulatory Research This position included supervising a multi-disciplined group of approximately 15 engineers and scientists responsible for research in the areas of mechanical, civil, structural, geotechnical, and electrical (instrumentation and control) engineering.
April 2000 to October 2000 Acting Assistant Branch Chief Materials Engineering Branch / Office of Nuclear Regulatory Research This position included supervising approximately 15 individuals responsible for evaluating issues associated with pressurized thermal shock, environmentally assisted corrosion, steam generator tube integrity, electrical engineering (cable degradation), and dry cask integrity.
April 1999 to April 2000 and October 2000 to January 2001 Technical Assistant Division of Engineering / Office of Nuclear Reactor Regulation This position involved assisting the Division Director on administrative and technical tasks including developing and implementing an Operating Plan for use by Division management.
This position also involved coordinating and developing the Divisions response on various generic licensing and policy issues.
October 1991 to April 1999 Materials Engineer Materials and Chemical Engineering Branch / Office of Nuclear Reactor Regulation This position involved reviewing plant-specific steam generator tube integrity issues. In addition, it involved writing or being a significant contributor to Information Notices and Generic Letters that informed stakeholders of recent events and trends. This position also involved providing guidance to junior members of the branch, briefing senior management on safety-significant issues, and participating in NRC inspection activities of licensees steam generator tube inspections.
DuPont August 1990 to October 1991 Area Consultant Deepwater, New Jersey This position involved ensuring product quality met customer specifications and supervising numerous technical projects. The primary focus was making my business unit more cost effective while maintaining safety. Specific projects included upgrading analog instrumentation 2
January 28, 2013 Karwoski to digital, improving the mechanical utility of a waste water treatment system, developing the design for dilution facilities and chemical emissions control systems, developing techniques for operators use to ensure optimal performance of the product line, and designing and constructing a waste water treatment system.
U.S. Navy Lieutenant July 1984 to June 1990 This position involved serving as the Chemistry and Radiological Controls Assistant and Main Propulsion Assistant on-board a nuclear submarine and supervising approximately 35 highly trained technical specialists in both a refueling overhaul and operational environment ensuring the proper operation and maintenance of the reactor coolant system, steam generating system, steam propulsion plant, and associated auxiliaries. Specific accomplishments included revising and writing numerous technical procedures, supervising the initial criticality of a new reactor core in a highly scrutinized and political environment, directing at-sea testing of propulsion plant equipment following a refueling overhaul, and formally instructing and certifying all mechanical watchstanders.
Honors/Awards:
NRC Performance Awards: 2012, 2011, 2010, 2009, 2008, 2007, 2006, 2004, 2003, 2002 NRC High Quality Increase / Special Act Awards: 2007, 2006, 2004, 1998 (2), 1996, 1994, 1992 Certificates of Appreciation: 2012 U.S. Navy Achievement Medal: 1990 Commander Submarine Group Six Commendation: 1989 Admiral A.I. McKee Award: 1987 Publications:
Author, co-author, peer reviewer of hundreds of NRC reviews/documents, including:
NUREG-1841, U.S. Operating Experience with Thermally Treated Alloy 690 Steam Generator Tubes, August 2007 NUREG-1771, U.S. Operating Experience with Thermally Treated Alloy 600 Steam Generator Tubes, April 2003 NUREG-1604, Circumferential Cracking of Steam Generator Tubes, April 1997 U.S. Nuclear Regulatory Commission Regulatory Issue Summary 2009-04, Steam Generator Tube Inspection Requirements, April 3, 2009, ML083470557 U.S. Nuclear Regulatory Commission Regulatory Issue Summary 2007-20, Implementation of Primary-to-Secondary Leakage Performance Criteria, August 23, 2007, ML070570297 3
January 28, 2013 Karwoski U.S. Nuclear Regulatory Commission Generic Letter 2006-01, Steam Generator Tube Integrity and Associated Technical Specifications, January 20, 2006, ML060200385 U.S. Nuclear Regulatory Commission Generic Letter 2004-01, Requirements for Steam Generator Tube Inspections, U.S. Nuclear Regulatory Commission Generic Letter 95-03, Circumferential Cracking of Steam Generator Tubes, April 28, 1995 U.S. Nuclear Regulatory Commission Information Notice 2012-07, Tube-to-Tube Contact Resulting in Wear in Once-Through Steam Generators, July 17, 2012, ML120740578 U.S. Nuclear Regulatory Commission Information Notice 2010-21, Crack-Like Indication in the U-Bend Region of a Thermally Treated Alloy 600 Steam Generator Tube, October 6, 2010, ML102210244 U.S. Nuclear Regulatory Commission Information Notice 2010-05, Management of Steam Generator Loose Parts and Automated Eddy Current Data Analysis, February 3, 2010, ML093640691 U.S. Nuclear Regulatory Commission Information Notice 2008-07, Cracking Indications in Thermally Treated Alloy 600 Steam Generator Tubes, April 24, 2008, ML080040353 U.S. Nuclear Regulatory Commission Information Notice 2007-37, Buildup of Deposits in Steam Generators, November 23, 2007, ML072910750 U.S. Nuclear Regulatory Commission Information Notice 2005-09, Indications in Thermally Treated Alloy 600 Steam Generator Tubes and Tube-to-Tubesheet Welds, April 7, 2005, ML050530400 U.S. Nuclear Regulatory Commission Information Notice 2004-16, Tube Leakage Due to a Fabrication Flaw in a Replacement Steam Generator, August 3, 2004, ML041460357 U.S. Nuclear Regulatory Commission Information Notice 2004-10, Loose Parts in Steam Generators, May 4, 2004, ML041170480 U.S. Nuclear Regulatory Commission Information Notice 2002-02, Supplement 1, Recent Experience with Plugged Steam Generator Tubes, July 17, 2002, ML021980191 U.S. Nuclear Regulatory Commission Information Notice 2002-02, Recent Experience with Plugged Steam Generator Tubes, January 8, 2002, ML013480327 U.S. Nuclear Regulatory Commission Information Notice 9749, "B&W Once-Through Steam Generator Tube Inspection Findings," July 10, 1997 U.S. Nuclear Regulatory Commission Information Notice 9638, "Results of Steam Generator Tube Examinations," June 21, 1996.
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January 30, 2013 Attachment 1 Comparison of SCE's March 23 Return-to-Service Action Plan with NRC's March 27 Confirmatory Action Letter and Existing Licensing Bases for San Onofre Nuclear Generating Station, Units 2 and 3 SONGS Unit/ Description Examples of Relevant RTS Plan (from RTS Action Plan Commitment List1) Authority or Licensing Action #/ Information2 Corresponding CAL Action #
Unit 2 The mechanisms causing steam generator tube 10 CFR 50, Appendix B, RTS Plan 1 wear in Unit 2 have been identified, and all tubes Criterion XVI, Corrective for which testing indicated wear in excess of Action, CAL Action SGPR and EPRI guidelines have been plugged. TS 3.4.17, "Steam N/A SCE also plugged all tubes adjacent to the Generator (SG) Tube retainer bars, whether worn or not, as a Integrity, preventive measure. SCE has documented SR 3.4.17.2 (verify tubes these issues in its Corrective Action Program are plugged when criteria (CAP) for analysis and resolution met)
TS 5.5.2.11, "Steam Generator Program."
Unit 2 SCE will determine the cause(s) of the tube-to- 10 CFR 50, Appendix B, RTS Plan 2 tube interactions that resulted in steam generator Criterion XVI, Corrective tube wear in Unit 3, and will implement actions in Action, CAL Action 1 accordance with the CAP to prevent loss of TS 3.4.17, "Steam integrity due to these potential causes in the Unit Generator (SG) Tube 2 steam generator tubes. Once these actions Integrity, have been determined, SCE will establish a TS 5.5.2.11, "Steam protocol of inspections and/or operational limits Generator Program."
for Unit 2, including plans for a mid-cycle shutdown for further inspections.
1 Attachment 1 to Letter from Peter T. Dietrich, Senior Vice President & Chief Nuclear Officer, Southern California Edison Company to Elmo E. Collins, Regional Administrator, Region IV, USNRC, subject: Docket Nos. 50-361 and 50-362, Steam Generator Return-to-Service Action Plan, San Onofre Nuclear Generating Station (March 23, 2012) (ADAMS Accession No. ML12086A182) (SCEs Return to Service Plan).
2 No regulations, TS, or license conditions prohibit the actions. The cited authority either affirmatively directs that such actions occur (e.g. Criterion XVI), or shows that such actions are a contemplated part of the licensee's actions (e.g. Unit 3 TS 3.4.17 requires plugging in accordance with the Steam Generator Program).
SONGS Unit/ Description Examples of Relevant RTS Plan (from RTS Action Plan Commitment List1) Authority or Licensing Action #/ Information2 Corresponding CAL Action #
Unit 2 Prior to entry of Unit 2 into Mode 2, SCE will, in a 10 CFR 50, Appendix B, RTS Plan 3 joint meeting, provide the NRC the results of our Criterion XVI, Corrective assessment of Unit 2 steam generators, the Action, CAL Action 2 protocol of inspections and/or operational limits TS 3.4.17, "Steam including schedule dates for a mid-cycle Generator (SG) Tube shutdown for further inspections, and the basis Integrity, for SCE 's conclusion that there is reasonable TS 5.5.2.11, "Steam assurance, as required by NRC regulations, that Generator Program."
the unit will operate safely. LCO 3.4.17.B (requiring Mode 5 if SG Tube integrity not maintained)
LCO 3.0.4 (Prohibiting Mode Changes in Specified Circumstances)
Unit 2 Both prior to and after entry of Unit 2 into Mode 10 CFR 50, Appendix B, RTS Plan 4 2, the protocol and inspection time frames Criterion XVI, Corrective described in Action 2 above will be adjusted, as Action, CAL Action necessary, to account for the results of ongoing TS 3.4.17, "Steam N/A inspections and analyses of the causes of tube- Generator (SG) Tube to-tube interactions in the Unit 3 steam Integrity, generators. NRC will be notified of any proposed TS 5.5.2.11, "Steam changes to this protocol. Generator Program."
Unit 3 SCE will complete in-situ pressure testing of 10 CFR 50, Appendix B, RTS Plan 5 tubes with potentially significant wear indications Criterion XVI, Corrective in accordance with the EPRI Steam Generator Action, CAL Action 3 In-Situ Pressure Test Guidelines and will plug TS 3.4.17, "Steam tubes in accordance with those guidelines Generator (SG) Tube Integrity, TS 5.5.2.11, "Steam Generator Program."
Unit 3 SCE will plug all tubes with wear indications in 10 CFR 50, Appendix B, RTS Plan 6 excess of SGPR and EPRI guidelines as well as Criterion XVI, Corrective perform preventive plugging or take other Action, CAL Action 4 Corrective Action to address retainer bar-related TS 3.4.17, "Steam tube wear in Unit 3. Generator (SG) Tube Integrity, SR 3.4.17.2 (verify tubes are plugged when criteria met)
TS 5.5.2.11, "Steam Generator Program."
SONGS Unit/ Description Examples of Relevant RTS Plan (from RTS Action Plan Commitment List1) Authority or Licensing Action #/ Information2 Corresponding CAL Action #
Unit 3 SCE will determine the cause(s) of tube-to-tube 10 CFR 50, Appendix B, RTS Plan 7 interaction and implement actions in accordance Criterion XVI, Corrective with the Corrective Action Program to prevent Action, CAL Action 5 recurrence of loss of integrity in the Unit 3 steam TS 3.4.17, "Steam generator tubes while operating. Generator (SG) Tube Integrity, TS 5.5.2.11, "Steam Generator Program."
Unit 3 SCE will establish a protocol of inspections 10 CFR 50, Appendix B, RTS Plan 8 and/or operational limits for Unit 3, including Criterion XVI, Corrective plans for a mid-cycle shutdown for inspections. Action, CAL Action 6 The protocol is intended to minimize the TS 3.4.17, "Steam progression of tube wear, and ensure that tube Generator (SG) Tube wear will not progress to the point of degradation Integrity, that could cause tubes to not meet leakage and TS 5.5.2.11, "Steam structural strength test criteria. Generator Program."
Unit 3 Prior to entry of Unit 3 into Mode 4, SCE will, in a 10 CFR 50, Appendix B, RTS Plan 9 joint meeting, provide the NRC the results of our Criterion XVI, Corrective assessment of Unit 3 steam generators, the Action, CAL Action 7 protocol of inspections and/or operational limits TS 3.4.17, "Steam including schedule dates for a mid-cycle Generator (SG) Tube shutdown for further inspections, and the basis Integrity, for SCE's conclusion that there is reasonable TS 5.5.2.11, "Steam assurance, as required by NRC regulations, that Generator Program."
the unit will operate safely.3 LCO 3.4.17.B (requiring Mode 5 if SG Tube integrity not maintained)
LCO 3.0.4 (Prohibiting Mode Changes in Specified Circumstances) 3 CAL Action 7 did not discuss a joint meeting, but stated that the results were to be provided "in writing."
January 30, 2013 Attachment 2 Summary of Relevant Technical Specifications for San Onofre Nuclear Generating Station, Units 2 and 3 TS paragraph Requirement1 Table 1.1-2 Defines modes of operation from Mode 1 (Power Operation) through (Modes) Mode 6 (Refueling)
LCO 3.0.4 Prohibits changing into a Mode if continued operation is not (LCO Applicability) permitted under the Mode.
SR 3.0.4 Prohibits changing into a Mode if associated surveillance (SR Applicability) requirements are not met.
3.4.17 Maintain SG tube integrity and plug tubes that meet the repair criteria (SG Tube Integrity) in the SG program (i.e. TS 5.5.2.11.c) unless in Operational Mode 5 (Cold Shutdown) or 6 (Refueling).
LCO 3.4.17.B If SG tube integrity not maintained, go to Mode 5.
(SG Tube Integrity)
SR 3.4.17.1 Verify SG tube integrity in accordance with the Steam Generator (SG Tube Integrity) Program.
TS 5.5.2.11.a Steam Generator Program Provisions for condition monitoring (SG Program) assessments. Includes evaluation of the "as-found" condition of SG tubing to confirm that the performance criteria for structural integrity and accident induced leakage are met.
TS 5.5.2.11.b Steam Generator Program Performance Criteria for SG Tube (SG Program) Integrity TS 5.5.2.11.b.1 Steam Generator Program Structural integrity performance criterion.
(SG Program) The criterion states in part that all in-service steam generator tubes shall retain structural integrity over the full range of normal operating conditions and design basis accidents, including retaining a safety factor of 3.0 against burst under normal steady state full power operation primary-to-secondary pressure differential.
TS 5.5.2.11.b.2 Steam Generator Program Accident induced leakage performance (SG Program) criterion.
TS 5.5.2.11.b.3 Steam Generator Program Operational LEAKAGE performance (SG Program) criterion (which is located in LCO 3.4.13, "RCS Operational LEAKAGE).
TS 5.5.2.11.c Steam Generator Program Provisions for SG tube repair criteria.
(SG Program) This provision states when tubes are to be plugged.
TS 5.5.2.11.d Steam Generator Program Provisions for SG tube inspections.
(SG Program)
TS 5.5.2.11.e Steam Generator Program Provisions for monitoring operational (SG Program) primary to secondary leakage.
TS 5.7.2 Requires submission of a Special Report of the results of the SG (Special Reports) program inspection.
1 The listed requirements are not all-inclusive but represent some license requirements regarding SGs.