ML13316A555

Relief Request Number 5 for Examination of Cold Leg Dissimilar Metal Welds

ML13316A555
Person / Time
Site:	Saint Lucie
Issue date:	12/11/2013
From:	Jessie Quichocho Plant Licensing Branch II
To:	Nazar M Florida Power & Light Co
Lingam S
References
TAC MF0675
Download: ML13316A555 (10)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 11, 2013 Mr. Mana Nazar Executive Vice President and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420

SUBJECT:

ST. LUCIE PLANT, UNIT NO. 1 -RELIEF REQUEST NO. 5 FOR EXAMINATION OF COLD LEG DISSIMILAR METAL WELDS (TAC NO. MF0675)

Dear Mr. Nazar:

By letter dated February 4, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13046A101), as supplemented by letters dated July 30 and August 22, 2013 (ADAMS Accession Nos. ML13219A254 and ML13235A309, respectively),

Florida Power & Light Company (the licensee) requested relief from Title 10 of the Code of Federal Regulations (1 0 CFR), Part 50, Section 50.55a(g)(6)(ii)(F) at the St. Lucie Plant, Unit No. 1 (St. Lucie Unit 1). This part of the regulation mandates and imposes conditions on the use of American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) Case N-770-1, "Alternative Examination Requirements and Acceptance Standards for Class 1 PWR [Pressurized-Water Reactor] Piping and Vessel Nozzle Butt Welds Fabricated With UNS N06082 or UNS W86182 Weld Filler Material With or Without Application of Listed Mitigation Activities." This ASME Code Case and the conditions require essentially 100-percent coverage be achieved for the baseline volumetric examinations of nickel-based Alloy 82/182 dissimilar metal welds (DMWs).

Specifically, pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee requested to use the proposed alternative in Relief Request No. 5 on the basis that compliance with the specified ASME requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Relief Request No. 5 proposes an alternative to the required examination coverage for the subject DMWs at reactor coolant pump (RCP) nozzles at St. Lucie Unit 1. The relief request is applicable to the fourth 10-year in service inspection interval.

On September 25, 2013, the U.S. Nuclear Regulatory Commission (NRC) staff verbally authorized (as documented in ADAMS Accession No. ML13268A510) the use of Relief Request No. 5 at St. Lucie Unit 1 for 64 months of plant operation at normal operating temperature (i.e.,

at Modes 1, 2, and 3) from the previous inspection of the RCP welds, which was last conducted in April 2010.

M. Nazar The NRC staff determines that the proposed alternative provides reasonable assurance of structural integrity and leak tightness of the subject welds for 64 months of operation in Modes 1, 2, and 3 from April 2010. The NRC staff finds that complying with ASME Code Case N-770-1 as conditioned in 10 CFR 50.55a(g)(6)(ii)(F) would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii) and is in compliance with the requirements of the ASME Code,Section XI for which relief was not requested. Therefore, the NRC staff authorizes the use of Relief Request No. 5 at the St. Lucie Unit 1 for a time period of 64 months from April 2010 at a plant operating condition of Modes 1, 2, and 3.

All other requirements of ASME Code,Section XI and 10 CFR 50.55a(g)(6)(ii)(F) for which relief has not been specifically requested and approved in this relief request remain applicable, including third party review by the Authorized Nuclear lnservice Inspector.

If you have any questions, please contact the Project Manager, Mr. Siva P. Lingam by phone at 301-415-1564 or via e-mail at Siva.Lingam@nrc.gov.

Sincerely, Docket No. 50-335

Enclosure:

Safety Evaluation cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST NO. 5 EXAMINATION OF COLD LEG DISSIMILAR METAL WELDS FLORIDA POWER AND LIGHT COMPANY, ET AL.

ST. LUCIE PLANT, UNIT NO. 1 DOCKET NO. 50-335

1.0 INTRODUCTION

By letter dated February 4, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13046A101 ), as supplemented by letters dated July 30 and August 22, 2013 (ADAMS Accession Nos. ML13219A254 and ML13235A309, respectively),

Florida Power & Light Company (the licensee) requested relief from Title 10 of the Code of Federal Regulations (1 0 CFR), Part 50, Section 50.55a(g)(6)(ii)(F) at the St. Lucie Plant, Unit No. 1 (St. Lucie Unit 1). This part of the regulation mandates and imposes conditions on the use of American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) Case N-770-1, "Alternative Examination Requirements and Acceptance Standards for Class 1 PWR [Pressurized-Water Reactor] Piping and Vessel Nozzle Butt Welds Fabricated With UNS N06082 or UNS W86182 Weld Filler Material With or Without Application of Listed Mitigation Activities." This ASME Code Case and the conditions require essentially 100-percent coverage be achieved for the baseline volumetric examinations of nickel-based Alloy 82/182 dissimilar metal welds (DMWs).

Specifically, pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee requested to use the proposed alternative in Relief Request No. 5 on the basis that compliance with the specified ASME requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Relief Request No. 5 proposes an alternative to the required examination coverage for the subject DMWs at reactor coolant pump (RCP) nozzles at St. Lucie Unit 1. The relief request is applicable to the fourth 10-year inservice inspection (lSI) interval.

On September 25, 2013, the U.S. Nuclear Regulatory Commission (NRC) verbally authorized (as documented in ADAMS Accession No. ML13268A510) the use of Relief Request No. 5 at St. Lucie Unit 1 for 64 months of plant operation at normal operating temperature (i.e., at Modes 1, 2, and 3) from the previous inspection of the RCP welds, which was last conducted in April 2010. This safety evaluation documents the NRC staffs technical basis for the verbal authorization.

Enclosure

2.0 REGULATORY EVALUATION

Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) must meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, "Rules for lnservice Inspection (lSI) of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code, incorporated by reference in 10 CFR 50.55a(b ), 12 months prior to the start of the 120-month interval, subject to the conditions listed therein.

Section 50.55a(g)(6)(ii) of 10 CFR Part 50 states that the Commission may require the licensee to follow an augmented lSI program for systems and components for which the Commission deems that added assurance of structural reliability is necessary. Section 50.55a(g)(6)(ii)(F) of 10 CFR Part 50 requires, in part, augmented in service volumetric inspection of Class 1 piping and nozzle DMWs.

Section 50.55a(g)(6)(ii)(F)(1) of 10 CFR Part 50 requires licensees of existing, operating pressurized water reactors as of July 21, 2011, implement the requirements of ASME Code Case N-770-1, subject to the conditions specified in 10 CFR 50.55a(g)(6)(ii)(F)(2) through 10 CFR 50.55a(g)(6)(ii)(F)(1 0), by the first refueling outage after August 22, 2011.

Section 50.55a(g)(6)(ii)(F)(3) of 10 CFR Part 50 states that the baseline examinations for welds in ASME Code Case N-770-1, Table 1, Inspection Item B, " ... shall be completed by the end of the next refueling outage after January 20, 2012. Previous examinations of these welds can be credited for baseline examinations if they were performed within the re-inspection period for the weld item in Table 1 using Section XI, Appendix VIII requirements and met the ASME Code required examination volume of essentially 100 percent. Other previous examinations that do not meet these requirements can be used to meet the baseline examination requirement, provided NRC approval of alternative inspection requirements in accordance with paragraphs

[1 0 CFR 50.55a] (a)(3)(i) or (a)(3)(ii) of this section is granted prior to the end of the next refueling outage after January 20, 2012 ... "

Section 50.55a(g)(6)(ii)(F)(4) of 10 CFR Part 50 states that the axial examination coverage requirements of ASME Code Case N-770-1, Section 2500(c), may not be considered to be satisfied unless essentially 100-percent (i.e., greater than 90-percent) coverage is achieved.

Section 50.55a(a)(3) of 10 CFR Part 50 states, in part, that alternatives to the requirements of paragraph (g) of 10 CFR 50.55a may be authorized by the NRC if the licensee demonstrates that: (i) the proposed alternative provides an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Based on the above, subject to the following technical evaluation, the NRC staff finds that regulatory authority exists to authorize the alternative proposed by the licensee.

3.0 Technical Evaluation 3.1 The Licensee's Relief Request No. 5 The affected components are the eight ASME Code Class 1 DMWs located at the RCP nozzles as identified in Table 1 of the relief request. The DMWs contain nickel-based Alloy 82/182 and are identified in ASME Code Case N-770-1, Table 1, Examination Categories, Inspection Item B, as unmitigated butt weld at cold leg operating temperature. Each RCP contains a 30-inch inside diameter inlet and outlet nozzles. Each DMW joins mill-clad SA-516, Grade 70 carbon steel pipe with SA-240-304L stainless steel cladding to an SA-351, Grade CF8M cast stainless steel safe end.

The ASME Code and NRC regulatory requirements applicable to the examinations of the affected welds are as follows:

Section 2410 of ASME Code Case N-770-1, as conditioned by 10 CFR 50.55a(g)(6)(ii)(F)(4),

requires that unmitigated dissimilar metal butt welds at cold leg operating temperatures greater than 525 degrees Fahrenheit (°F) and less than 580 °F, under inspection Item B, be examined with ( 1) bare metal visual examination once per interval, (2) essentially 100-percent volumetric examination for axial and circumferential flaws in accordance with the applicable requirements of ASME Section XI, Appendix VIII, every second inspection period not to exceed 7 years, and (3) baseline examinations by the end of the next refueling outage after January 20, 2012.

As defined by ASME Code Case N-460, Alternative Examination Coverage for Class 1 and Class 2 Welds,Section XI, Division 1, essentially 100 percent means greater than 90 percent of the examination volume of each weld where reduction in coverage is due to interference by another component or part geometry.

ASME Section XI, Appendix VIII, Supplement 10, Qualification Requirements for Dissimilar Metal Piping Welds, is applicable to DMWs without cast materials. ASME Section XI, Appendix VIII, states that the supplement for the examination of cast stainless steel is in the course of preparation.

The licensee requested relief from the examination requirements of 10 CFR 50.55a(g)(6)(ii)(F)(3) and 10 CFR 50.55a(g)(6)(ii)(F)(4) and proposed two alternatives. First, in lieu of the baseline examination requirements of 10 CFR 50.55a(g)(6)(ii)(F)(3), the licensee proposed to use the ultrasonic examinations performed in accordance with Material Reliability Program (MRP)-139, Material Reliability Program: Primary System Piping Butt Weld Inspection and Evaluation Guideline, Revision 1, EPRI [Electric Power Research Institute}, Palo Alto, CA 2008, 1015009, during the 2010 (SL 1-23) Refueling Outage. Second, in lieu of the examination coverage requirements of 10 CFR 50.55a(g)(6)(ii)(F)(4), the licensee proposed to use the examination coverage achieved in the 2010 examination.

The licensee stated that during the 2010 Refueling Outage, it examined the eight subject RCP inlet/outlet welds from the carbon steel side using a manual non-encoded phased array ultrasonic testing (UT) technique that was qualified in accordance with the requirements of ASME Section XI, Appendix VIII, Supplement 10, as implemented through the Performance

Demonstration Initiative (PDI) program. The licensee did not find any indications in the subject welds.

As part of the proposed alternative, the licensee has performed the following: (1) periodic system pressure tests in accordance with ASME Section XI Examination Category 8-P, Table IWB-2500-1; (2) ultrasonic examinations to the maximum extent possible; (3) walk downs of Class 1 systems inside containment during refueling outages to look for system anomalies that could affect plant performance; and (4) bare metal visual examinations of the subject welds in accordance with ASME Code Case N-722-1, "Additional Examinations for PWR Pressure Retaining Welds in Class 1 Components Fabricated With Alloy 600/82/182 MaterialsSection XI, Division 1."

The licensee stated that because the examination of the RCP inlet/outlet configuration is included in the PDI sample set, a site specific mock-up was not applicable for these weld examinations. The licensee was able to achieve essentially 100-percent examination coverage of the susceptible material in all eight welds for circumferential flaws. However, due to the weld taper and the examination from the cast austenitic stainless steel (CASS) safe-end side of the welds is not qualified, the licensee achieved less than essentially 100-percent examination volume coverage for axial flaws as shown in Table 1 of the relief request.

The licensee stated that the critical circumferential flaw length for an RCP outlet weld is 33.2 inches, which is approximately 29 percent of the weld circumference. The licensee stated that the largest limitation due to examination obstruction is 9.85 inches long, or 8. 7 percent of the outer diameter circumference. The weld volume associated with 4.15 inches of the obstructed length of 9.85 inches was identified as having 0 percent of coverage. The licensee explained that a circumferential flaw of this size, if it exists, would take over 15 years to grow to through-wall depth and over 100 years for a leaking through-wall flaw to grow to a critical crack length due to the cold leg operating temperature.

The licensee stated that as an added measure of safety, it has improved its Reactor Coolant System (RCS) leak detection capability by standardizing RCS leak rate measurement. The enhanced leak rate monitoring and detection procedure monitor specific values of unidentified leakage, 7-day rolling average, and baseline means. Action levels are initiated as low as when the unidentified leak rate exceeds 0.1 gallon per minute. The licensee stated that the enhanced leak detection capability provides an increased level of safety such that if a flaw were to grow through-wall, it would be detected prior to growing to a safety significant size, which the licensee clarified in an email (ADAMS Accession No. ML13338A694) to the NRC to essentially mean the critical flaw size that could result in a break. The NRC staff notes that the St. Lucie Unit 1 Technical Specification (TS) Limiting Condition for Operation (LCO) 3.4.6.2 limits unidentified RCS leakage to 1 gallon per minute before additional actions specified in the TSs are required.

The licensee requested the approval of the relief request for the fourth 10-year lSI interval. The code of record for the fourth 10-year lSI interval is the ASME Code,Section XI, 2001 edition through the 2003 addenda. The fourth 10-year lSI interval began February 11, 2008, and ends February 10, 2018.

3.2 NRC Staff Evaluation Section 50.55a(g)(6)(ii)(F)(3) of 10 CFR Part 50 requires the licensee performing a baseline examination for the subject welds. The licensee examined the subject welds in accordance with EPRI MRP-139 in April 2010. The NRC staff notes that the licensee used a manual, non-encoded phased-array single-sided UT technique from the outside diameter of the ferritic side of the welds in both the circumferential and axial directions. The NRC staff further notes that the licensee used a POl UT procedure that met the requirements of ASME Code Section XI Appendix VIII, Supplement 10, as limited by the procedure qualification due to the existence of a CASS safe end. The NRC finds that the licensee's ultrasonic examinations of the subject welds performed in April 2010 are acceptable as an alternative in lieu of the baseline examination required by 10 CFR 50.55a(g)(6)(ii)(F)(3) because the licensee used a qualified UT technique.

The second proposed alternative is that the licensee proposed to use the examination coverage achieved in the 2010 examination as shown in Table 1 of the relief request in lieu of the essentially 100-percent examination coverage as required by 10 CFR 50.55a(g)(6)(ii)(F). The licensee noted two reasons for not meeting the essentially 100-percent examination coverage.

First, the cold leg nozzles are welded to a safe end that is made of CASS. Currently, the ASME Code,Section XI, does not have a qualified ultrasonic examination procedure to examine CASS material; therefore, the CASS material that is part of the required examination volume cannot be credited for the coverage calculation. Second, the individual weld configuration and/or obstructions prevent essentially 100-percent examination coverage.

On the basis of the examination coverage diagrams presented in the relief request, the NRC staff recognizes the difficulty with which the licensee encountered attempting to achieve essentially 100-percent coverage of the subject welds. The NRC staff requested Pacific Northwest National Laboratory (PNNL) perform a more precise coverage calculation to verify the licensee's examination coverage for the axial scan because the axial scans had the most difficulties in achieving required coverage. The NRC staff selected two welds, RC-124-7-504 and RC-121-6-504, for the investigation because they have the least examination coverage.

PNNL modeled the UT transducer response for axial scans performed from the weld crown of these two welds. The PNNL evaluation included theoretical modeling of the sound beams based on actual phased-array design parameters and component geometry provided by the licensee. PNNL simulated the phased-array ultrasonic examination with focal laws defined to produce steered beams from 0 to 80 degrees and at 1-degree increments. PNNL's simulations have confirmed that the licensee's examination coverage for welds RC-121-6-504 and RC-124-7-504 in 2010 is the maximum coverage that can be achieved because of weld configuration and obstructions.

Because the licensee was not able to examine some volumes of the subject eight welds, the NRC staff is concerned that a flaw may exist in the unexamined volume and may grow to the unacceptable size (i.e., 75-percent through pipe wall thickness) within the inspection interval, which is every 7 years. The NRC staff finds the condition unacceptable if a potential flaw could grow to the unacceptable size in less than 7 years because this would challenge the structural integrity and leak tightness of the subject welds. Therefore, the NRC staff requested the licensee evaluate any potential flaw growth.

In the July 30, 2013, letter, the licensee reported that its flaw analyses showed that a postulated circumferential flaw with an initial depth of 40-percent through wall would grow to the

unacceptable flaw size in 139 months and a postulated axial flaw with an initial depth of 12.47-percent through wall would grow to the unacceptable flaw size in 64.3 months.

To verify the licensee's flaw analyses, the NRC staff has performed independent flaw growth analyses using the licensee's proposed axial flaw size of 12.7-percent through wall and a PNNL-recommended circumferential flaw size of 50-percent through wall. The NRC staff assumed a larger, initial circumferential flaw size (50-percent vs. the licensee's 40-percent through-wall depth} because PNNL's model indicated that a circumferential flaw must grow to approximately 50-percent through wall before it can be detected.

The NRC staff finds that the postulated circumferential flaw of 50-percent through wall would not grow to the unacceptable flaw size within 7 years. The NRC staff finds that the postulated axial flaw of 12.47 percent would grow to the unacceptable flaw size at about 64 months. Given that the 64-month period is less than the 7-year inspection interval required by ASME Code Case N-770-1 for the subject welds, the NRC staff finds that the 64-month time period is limiting and must be used as the inspection interval for the subject welds in lieu of 7 years. Considering that primary water stress corrosion cracking would most likely occur at high operating temperature, the NRC staff finds that the licensee may apply the 64 months when the plant is operated during Modes 1, 2, and 3.

Although the postulated axial flaw would grow to the unacceptable size within 64 months, the NRC finds that the licensee has defense-in-depth measures to monitor the structural integrity and leak tightness of the subject welds. The NRC staff finds that the St. Lucie Unit 1 has adequate RCS leakage detection systems should any of the subject welds develop a leaking through-wall flaw because the licensee will initiate actions if the leakage reaches 0.1 gallons per minute as compared to the allowable leak rate of 1 gallon per minute in accordance with TS LCO 3.4.6.2. In the July 30, 2013, letter, the licensee stated that the primary method for quantifying and characterizing RCS identified and unidentified leakage is by means of a reactor coolant water inventory balance that is performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The leakage detection systems include the reactor cavity (containment) sump inlet flow monitoring system, containment atmosphere radiation gas monitoring system, and containment atmosphere radiation particulate monitoring system. These systems have high level and alert status alarms in the control room. These systems also have Technical Specification (TS) required monitoring (TS 3/4.4.6.2.a and b) at least once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The containment sump alarm response is also highly variable based on the location of the leak, how much vapor condenses, and where it condenses. All drains entering the sump are routed first to a measurement tank. When the water level corresponding to 1 gallon per minute or more into the tank is reached, a sump level alarm is actuated in the control room. If a leak does occur, the operator will be notified and take corrective actions before the structural integrity of the pipe is challenged. In addition, the licensee performs periodic system pressure tests in accordance with ASME Section XI Examination Category 8-P, Table IWB-2500-1, walks down the piping systems during refueling outages, and performs bare metal visual examinations of the subject welds in accordance with ASME Code Case N-722-1.

As part of the submittal, the licensee discussed the hardship of complying with the regulations.

During the 2010 Refueling Outage, the licensee ground and contoured the subject welds to improve examination volume coverage to meet the examination requirements of the ASME

Section XI, Appendix VIII, Supplement 10. The licensee stated that further contouring is limited by the required pipe minimum wall thickness. The licensee further stated that to obtain acceptable surface contour conditions for axial flaw examinations, weld build up, additional contouring, and construction code radiographic testing would be required. To obtain additional circumferential coverage in the area of obstruction from the spray nozzles would require pipe replacement to relocate the spray nozzles. The licensee explained that this additional effort to improve examination coverage would be a hardship that would not result in an increase of health and safety to the public.

The NRC staff has examined the examination coverage drawings submitted by the licensee and finds that achieving essentially 100-percent coverage of the subject welds would require extensive modifications. The NRC staff also recognizes that the weld could be examined from the inside diameter but the inside diameter interrogation would be accompanied by a significant radiological dose. The NRC staff finds that attaining the essentially 100-percent examination coverage for the subject eight welds would present a hardship or unusual difficulty without a compensating increase in the level of quality and safety.

In summary, the NRC staff finds that the licensee has performed a baseline examination of the subject welds in accordance with the ASME Code,Section XI, as limited by the procedure qualification due to the existence of a CASS safe end. For the weld volumes that were not inspected, the licensee has performed adequate flaw evaluations to demonstrate that the subject welds would maintain their structural integrity and leak tightness for at least 64 months.

The NRC staff finds that the proposed alternative in Relief Request No. 5 provides reasonable assurance of structural integrity and leak tightness of the subject welds within 64 months of April 2010 because (1) the licensee's 2010 examination did not detect any indications, and (2) the NRC staff's independent evaluation verifies that the licensee's flaw evaluations demonstrate an acceptable operating period of at least 64 months.

4.0 CONCLUSION

As set forth above, the NRC staff determines that the proposed alternative provides reasonable assurance of structural integrity and leak tightness of the subject welds for 64 months of operation in Modes 1, 2, and 3 from April 2010. The NRC staff finds that complying with ASME Code Case N-770-1 as conditioned in 10 CFR 50.55a(g)(6)(ii)(F) would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii) and is in compliance with the requirements of the ASME Code,Section XI for which relief was not requested. Therefore, the NRC staff authorizes the use of Relief Request No. 5 at the St. Lucie Unit 1 for a time period of 64 months from April 2010 at a plant operating condition of Modes 1, 2, and 3.

All other requirements of ASME Code,Section XI and 10 CFR 50.55a(g)(6)(ii)(F) for which relief has not been specifically requested and approved in this relief request remain applicable, including third party review by the Authorized Nuclear lnservice Inspector.

Principal Contributor: John Tsao Date: December 11, 2013

ML13316A555 *via e-mail OFFICE LPL2-2/PM LPL2-2/LA DE/EPNB/BC* LPL2-2/BC NAME Slingam BCiayton Tlupold JQuichocho DATE 11/14/13 11/13/13 11/7/13 12/11/13