ML14016A487

Issuance of Amendment Revise the Fermi 2 Licensing Basis Concerning Protection from Tornado-Generated Missiles

ML14016A487
Person / Time
Site:	Fermi
Issue date:	03/10/2014
From:	Thomas Wengert Plant Licensing Branch III
To:	Plona J DTE Electric Company
Wengert T
References
TAC MF0497
Download: ML14016A487 (12)

Text

Mr. Joseph H. Plana Senior Vice President and Chief Nuclear Officer DTE Electric Company Fermi 2-210 NOC 6400 North Dixie Highway Newport, Ml 48166 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 10, 2014

SUBJECT:

FERMI 2-ISSUANCE OF AMENDMENT RE: REVISE THE FERMI 2 LICENSING BASIS CONCERNING PROTECTION FROM TORNADO-GENERATED MISSILES (TAC NO. MF0497)

Dear Mr. Plana:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 197 to Facility Operating License No. NPF-43 for the Fermi 2 facility. The amendment consists of changes to the Updated Final Safety Analysis Report (UFSAR) in response to your application dated January 11, 2013, as supplemented by letter dated September 27, 2013.

The amendment revises the Fermi 2 UFSAR to describe the methodology and results of the analysis performed to evaluate the protection of the plant's structures, systems and components from tornado-generated missiles. The analysis utilized a probabilistic approach implemented through the application of the TORMIS computer code.

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

Docket No. 50-341

Enclosures:

1. Amendment No. 197 to NPF-43

2. Safety Evaluation cc w/encls: Distribution via ListServ Sincerely, Thomas J. Wengert, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DTE ELECTRIC COMPANY DOCKET NO. 50-341 FERMI2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 197 License No. NPF-43

1.

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

A.

The application for amendment by the DTE Electric Company (the licensee) dated January 11, 2013, as supplemented by letter dated September 27, 2013, 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, by Amendment No. 197, the license is amended to authorize revision to the Updated Final Safety Analysis Report (UFSAR), as set forth in the application dated January 11, 2013. The licensee shall update the UFSAR to incorporate the changes described in the licensee's application dated January 11, 2013, as supplemented by letter dated September 27, 2013, and the NRC staff's safety evaluation attached to this amendment, and shall submit the revised description authorized by the amendment with the next update of the UFSAR.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance. The UFSAR changes shall be implemented in the next periodic update to the UFSAR in accordance with 10 CFR 50.71(e).

Date of Issuance: March 10, 2014 FOR THE NUCLEAR REGULA TORY COMMISSION Robert D. Carlson, Chief Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 197 TO FACILITY OPERATING LICENSE NO. NPF-43 DTE ELECTRIC COMPANY FERMI2 DOCKET NO. 50-341

1.0 INTRODUCTION

By letter dated January 11, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13011A377), as supplemented by letter dated September 27, 2013 (ADAMS Accession No. ML13273A467), DTE Electric Company (the licensee) requested the U.S. Nuclear Regulatory Commission's (NRC) approval of a license amendment request to revise the Fermi 2 licensing bases for protection from tornado-generated missiles. The proposed license amendment would modify the Fermi 2 plant licensing bases by revising the Updated Final Safety Analysis Report (UFSAR) to describe the methodology and results of the analysis performed to evaluate the protection of the plant's structures, systems and components (SSCs) from tornado generated missiles. This analysis utilized a probabilistic approach implemented through the application of the TORMIS computer code.

The Electric Power Research Institute (EPRI) TORMIS methodology employs Monte Carlo techniques in order to propagate the transport of tornado-generated missiles and to assess the probability of missile strikes causing damage to unprotected, safety-related SSCs. TORMIS estimates the mean annual probability of missiles striking and damaging individual target SSCs and groups of target SSCs.

The supplement dated September 27, 2013, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination noticed in the Federal Register on March 19, 2013 (78 FR 16880).

2.0 REGULATORY EVALUATION

The current licensing basis for tornado missile protection is contained in Section 3.1.2.1.2 of the Fermi 2 UFSAR, Revision 18, "Criterion 2-Design Bases for Protection Against Natural Phenomena." The licensing basis for tornado missile protection, described in UFSAR Section 3.1.2.1.2, states, in part, that:

Structures, systems, and components important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes, tornados, [... ]

without loss of capability to perform their safety functions [... ]

Criterion 2 Conformance -The design bases enumerated in this criterion are incorporated into the design of structures, systems, and components of Fermi 2.

[... ]

The typical method used to comply with this criterion is to provide positive protection features such as locating required equipment in structures designed.for tornado missiles and providing barriers designed for tornado missiles. The licensee is requesting a change to the Fermi 2 licensing bases to allow certain components to not be protected from tornado missiles based on probability analysis.

The NRC requires that nuclear power plants be designed to withstand the effects of tornado and high-wind-generated missiles so as not to adversely impact the health and safety of the public in accordance with the requirements of General Design Criterion (GDC) 2, "Design Bases for Protection against Natural Phenomena," and GDC 4, "Environmental and Dynamic Effects Design Bases," of Appendix A, "General Design Criteria for Nuclear Power Plants," to Title 10 of the Code of Federal Regulations (1 0 CFR) Part 50, "Domestic Licensing of Production and Utilization Facilities."

Sections 3.5.1.4 and 3.5.2 of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants" (SRP), contain the current acceptance criteria governing tornado missile protection. These criteria generally specify that SSCs that are important to safety be provided with sufficient, positive tornado missile protection (i.e., barriers) to withstand the maximum credible tornado threat. The appendix to Regulatory Guide (RG) 1.117, "Tornado Design Classification," Revision 1, issued April1978 (Reference.1), lists the types of SSCs that should be protected from design basis tornadoes. However, SRP Section 3.5.1.4 permits relaxation of the above deterministic criteria if it can be demonstrated that the probability of damage to unprotected essential safety-related features is sufficiently small. To use this probabilistic criterion, the EPRI developed the tornado missile probabilistic methodology described in two topical reports, EPRI NP-768 and NP-769, "Tornado Missile Risk Analysis and Appendices," issued May 1978, (References 2 and 3) and EPRI NP-2005, "Tornado Missile Risk Evaluation Methodology," Volumes I and II, issued August 1981 (Reference 4). These topical reports document the TORMIS computer code methodology. The EPRI methodology employs Monte Carlo techniques to assess the probability that tornado missile strikes will cause unacceptable damage to safety-related plant features.

The NRC staff concluded in a safety evaluation report (SER), dated October 26, 1983 (ADAMS Accession No. ML080870291 ), (Reference 5) that the EPRI TORMIS methodology can be used in lieu of the deterministic methodology when assessing the need for positive tornado missile protection for specific safety-related plant features in accordance with the criteria of SRP Section 3.5.1.4. The SER further stated that the use of the EPRI methodology, or any tornado missile probabilistic study, should be limited to the evaluation of specific plant features that involve additional costly tornado missile protective barriers or alternative systems.

In June 16, 2008, the NRC issued Regulatory Issue Summary (RIS) 2008-14, "Use of TORMIS Computer Code for Assessment of Tornado Missile Protection," (Reference 6). This RIS addresses: (1) the NRC staff position on the use of the TORMIS computer code for assessing nuclear power plant tornado missile protection, (2) issues identified in previous license amendment requests to use the TORMIS computer code, and (3) information needed in license amendment applications using the. TORMIS computer code.

Although the TORMIS methodology utilizes acceptance criteria for the probability of tornado-induced loss of system function, the NRC approval for implementation of TORMIS is not a risk-informed approach. As such, approval of TORMIS allows an alternate method for meeting regulatory requirements under very specific circumstances with respect to the evaluation of specific plant features where additional costly tornado missile protective barriers or alternate systems are under consideration. A licensee may submit a license amendment application utilizing a risk-informed change process consistent with the guidelines of RG 1.17 4, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decision on Plant-Specific Changes to the Licensing Basis." If a risk-informed process was proposed, it would have to meet the five key principles of risk-informed regulation described in RG 1.17 4.

3.0 TECHNICAL EVALUATION

3.1 Background

In 1983, the NRC staff issued an SER approving the use of the EPRI-developed "Tornado Missile Risk Evaluation Methodology" (TORMIS methodology). The licensee had previously.

included an analysis using the TORMIS methodology in the Fermi 2 UFSAR. However, the NRC subsequently determined that this analysis had been improperly incorporated into the UFSAR and issued a non-cited violation (NCV) in NRC Inspection Report 05000341/2008-004 (NCV 05000341/2008004-03) (Reference 7). In response to the finding, the Fermi 2 licensee revised the TORMIS analysis and submitted it to the NRC for review and approval.

The NRC staff's acceptance of a licensee's application using TORMIS is subject to the appropriate resolution of five specific concerns identified in the SER on the EPRI TORMIS methodology (Reference 5). These specific concerns are related to the assumptions used in the input parameters for the risk analysis (e.g., locations and numbers of potential missiles presented at a specific site, wind speed, wind speed near the ground, etc.). The staff reviewed the submittal with respect to: (1) the five specific concerns related to the NRC approval of the

. TORMIS methodology, and (2) the acceptability of the TORMIS analysis for calculating the appropriate mean strike and damage probabilities and of the TORMIS results against the guidance provided in the SER on EPRI TORMIS methodology and RIS 2008-14.

3.2 Implementation of the TORMIS Methodology The SER approving the TORMIS methodology requires licensees using the methodology to consider and address five points in their applications. The five points and the licensee's responses are summarized below:

1. Data on tornado characteristics should be employed for both broad regions and small areas around the site. The most conservative values should be used in the risk analysis or justification provided for those values selected.

UFSAR Section 2.3.1.3.2 estimates the probability of a tornado strike to be 4.075 x 1 o-5 per year. The licensee performed a site-specific analysis to generate a tornado hazard curve data set for the TORMIS analysis. The analysis used data from the National Climatic Center Storm Events Data Base (NCDC 2006) for the years 1950 - 2006 to analyze broad and small regions around the site to identify a suitable sub-region for the site. Statistical tests were performed to identify suitably homogeneous sub-regions. Historical records of tornado occurrences within the sub-region were used to establish the tornado occurrence rate, Enhanced Fujita (EF)-scale intensities, and other inputs for use in the TORMIS analysis. Over the 56-year period, statistical analysis established a mean occurrence rate of

3. 1 x 1 o-4 per square mile per year. Following the TORMIS methodology, based on the 30-year backwards averaging, the licensee estimated a de-trended occurrence rate of 4.002 x 1 o-4 per year. This is higher than the probability estimated in the UFSAR. Therefore, the NRC staff concludes that this is acceptable.

2. The EPRI study proposes a modified tornado classification, F'-scale, for which the velocity ranges are lower by as much as 25 percent than the velocity ranges originally proposed in the Fujita, F-scale. Insufficient documentation was provided in the studies in support of the reduced F'-scale. The F-scale tornado classification should therefore be used in order to obtain conservative results.

The licensee stated that the original Enhanced Fujita scale wind speeds were utilized in the analysis. The NRC adopted the EF scale in the positions of Regulatory Guide 1.76, Revision 1, that are based on NUREG/CR-4461, Revision 2. The NRC staff concludes that the use of the EF scale is acceptable.

3. Reductions in tornado wind speed near the ground due to surface friction effects are not sufficiently documented in the EPRI study. Such reductions were not consistently accounted for when estimating tornado wind speeds at 33 feet above grade on the basis of observed damage at lower elevations. Therefore, users should calculate the effect of assuming velocity profiles with ratios Vo (speed at ground level) I V33 (speed at 33 feet elevation) higher than that in the EPRI study. Discussion of sensitivity of the results to changes in the modeling of the tornado wind speed profile near the ground should be provided.

To address the reductions in tornado missile speed near the ground due to surface friction effects that are not sufficiently documented in the EPRI study, the licensee stated that the TORMIS rotational velocity Profile 3 was used. This profile has increased wind speeds over the TORMIS Profile 5 values used in the 1981 EPRI TORMIS reports. A sensitivity study was conducted by running the original EPRI profiles and comparing the results. The Profile 3 study (enhanced near-ground wind speeds below 33 feet) resulted in damage probabilities that were greater than the Profile 5 results. The use of Profile 3 with higher near-ground wind speeds is conservative when compared to Profile 5. The NRC staff concludes that this is acceptable.

4. The assumptions concerning the locations and numbers of potential missiles presented at a specific site are not well established in the EPRI studies. However, the EPRI methodology allows site specific information on tornado missile availability to be incorporated in the risk calculation. Therefore, users should provide sufficient information to justify the assumed missile density based on site specific missiles sources and dominant tornado paths of travel.

The licensee performed walkdowns of the Fermi 2 site prior to refueling outages to characterize missile sources and plant configuration. Missile sources were catalogued and modeled to a distance of approximately 2,500 feet. Performing the site surveys prior to refueling outages maximized the estimated potential missile sourc~s. More than 75,000 missiles were postulated. This is a reasonable missile density in comparison to some other plants that use 25,000 to 74,000. Therefore, the NRC staff finds that the postulated missile density is acceptable.

5. Once the EPRI methodology has been chosen, justification should be provided for any deviations from the calculational approach.

The licensee stated that the TORMIS code, a legacy FORTRAN computer code, has been updated to modern computers. The updates and enhancements include: porting the legacy.

code from the mainframe to minicomputer to PC computers; post processing data routines; updating the random number generation; updating the aerodynamic tip loss function, and addressing compiler differences and numerical round-off issues in various functions from the legacy code. Code changes have been checked and verified through comparisons to the preceding versions.

An enhanced method was used for evaluating missiles passing through openings such as pipe penetrations in concrete walls, in addition to the standard TORMIS hit probability for such targets. This provides supplemental outputs intended to cover special cases of missiles going through wall openings.

The NRC staff concludes that these changes to the original TORMIS methodology are reasonable and acceptable.

As part of the NRC staff's review, several requests for additional information (RAis) were submitted to the licensee. The licensee's responses, contained in,the September 27, 2013, supplement, are summarized below:

In RAI-1, the staff requested the licensee to describe what Fermi 2 has done to address the potential for damage that non-safety related equipment struck by a tornado missile could cause to safety-related equipment. In its response, the licensee identified a number of components that could be damaged by tornado missiles and that could possibly damage safety-related equipment. For these plant components, the licensee has implemented various plant, modifications to address the potential weaknesses.

In RAI-2, the staff requested the licensee to provide the basis for the "2,500 feet" in Section 3.0, page 6, of the application, in describing the maximum distance to which missile sources (buildings, houses, storage areas, vehicles, etc.) were catalogued and modeled. In its response, the licensee stated that this distance was derived from EPRI NP-769, Section 2.3.3, Off-Site Missile Assessment.

In RAI-3, that staff asked the licensee if the emergency diesel generator (EDG) fuel oil tank vents and the EDG exhaust stacks were protected from* horizontally traveling missiles. In its response, the licensee provided a description of how the vents and exhaust stacks are protected from horizontal tornado missiles.

The NRC staff concludes that the licensee's responses to the RAis are acceptable.

3.3 Results of the Fermi 2 TORMIS Analysis In Section 3:5.1.3.2.3 of the proposed revised UFSAR, the licensee states that a limited number of Seismic Category I safety-related systems and components required for safe shutdown, which are located outside of buildings designed to resist the impact of tornado-generated missiles (or otherwise not protected), are evaluated based on a probabilistic missile damage analysis. These unprotected targets are identified in the submittal. The licensee states that the results of the TORMIS analysis predict a site mean aggregate tornado missile damage.

probability of 6.82 X 1 0"7 per year for the identified SCOpe of safety-related targets.

In "Position On ttie Use of Probabilistic Risk Assessment In Tornado Missile Protection Licensing Actions," (ADAMS Accession No. ML080870287) the NRC staff states that the guidance of SRP Section 2.2.3, "Evaluation of Potential Accidents," (ADAMS Accession No. ML070460336) is applicable to tornado missiles. This guidance, which is used in probabilistic tornado missile reviews, states that an expected rate of occurrence of potential exposures in excess of the 10 CFR 100 guidelines of approximately 1 x 1 o*6 per year is acceptable if, when combined with reasonable qualitative arguments, the risk can be expected*

to be lower.

Based on review of the submittal, the NRC staff finds that because of not requiring unique tornado missile protection for identified targets, which have been analyzed by the TORMIS code, the probability of a malfunction of equipment important to safety will slightly increase.

However, the probability of a tornado-generated missile damaging these targets is less than 1 x 1 o-6 per year and meets the guidance described in the SRP Section 2.2.3.

In the NRC staff's RAI-4, the staff asked whether the methodology used in the submittal for calculating the mean aggregate tornado missile damage probability uses any logic (e.g., "AND" gates) that requires damaging multiple targets simultaneously for establishing a damaged state.

In its September 27, 2013, response, the licensee stated that no "AND" Boolean operations, which require damage to multiple targets in the same tornado event, were used for the TORMIS analysis of the targets that were included in the analysis. Therefore, the aggregated value of 6.82 x 1 o*7 per year is a summation over all targets and does not consider any redundancy or "AND" Boolean operations. The NRC staff finds that not requiring damage to multiple targets in the same tornado event is conservative and acceptable. Furthermore, statistical convergence of the results is achieved and the statistical confidence bounds of the results are estimated.

Therefore, tlie NRC staff concludes that the licensee's TORMIS analysis for calculating the mean strike and damage probabilities is consistent with the SER on TORMIS methodology and RIS 2008-14, and the results obtained from the analysis meet the SRP guidance.

3.4 Conclusion Based on the foregoing evaluation, the NRC staff concludes that the licensee has adequately addressed the items identified in the NRC SER approving the TORMIS methodology and also concludes that the EPRI TORMIS methodology is implemented appropriately in accordance with the guidance provided in the 1983 TORMIS SER and RIS 2008-14. Furthermore, the staff concludes that the reported results comply with the NRC guidance and are acceptable.

Therefore, the NRC staff finds that the revisions to Section 3.5.1.3.2.3 of UFSAR appropriately reflect Fermi 2 compliance with the NRC guidance and the use of NRC-approved methodology for TORMIS analysis.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Michigan 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 installation or use of a facility component 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 (March 19, 2013. (78 FR 16880). 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:

7.0 REFERENCES

1. Regulatory Guide 1.117, Tornado Design Classification," Revision 1, issued April 1978

2. Electric Power Research Institute Topical Report NP-768, "Tornado Missile Risk Analysis,"

May 1978.

3. Electric Power Research Institute Topical Report NP-769, 'Tornado Missile Risk Analysis and Appendices," May 1978.

4. Electric Power Research Institute Topical Report NP-2005 Volumes, I & II, "Tornado Missile Risk Evaluation Methodology," August 1981

5. NRC Safety Evaluation Report-Electric Power Research Institute (EPRI) Topical Reports Concerning Tornado Missile Probabilistic Risk Assessment (PRA) Methodology, dated October 26, 1983 (ADAMS Accession No. ML080870291)

6. NRC Regulatory Issue Summary 2008..,14, "Use of TORMIS Computer Code for Assessment

• of Tornado Missile Protection," dated June 16, 2008 (ADAMS Accession No. ML080230578)

7. NRC Inspection Report 05000341/2008-004, "Fermi Power Plant, Unit 2, Integrated Inspection Report," dated November 12, 2008 (ADAMS Accession No. ML083171034)

8. NUREG/CR-4461, Revision 2, "Tornado Climatology of the Contiguous United States" (ADAMS Accession No. ML070810400)

9. U.S. Nuclear Regulatory Commission Regulatory Guide*1.76, "Design-Basis Tornado and Tornado Missiles for Nuclear Power Plants," Revision 1, March 2007 (ADAMS Accession No. ML070360253)

Principal Contributors: Edward Smith Mehdi Reisi-Fard Date: March 10, 2014

)

Mr. Joseph H. Plona Senior Vice President and Chief Nuclear Officer DTE Electric Company Fermi 2-210 NOC 6400 North Dixie Highway Newport, Ml 48166 March 10, 2014

SUBJECT:

FERMI 2 - ISSUANCE OF AMENDMENT RE: REVISE THE FERMI 2 LICENSING BASIS CONCERNING PROTECTION FROM TORNADO-GENERATED MISSILES (TAC NO. MF0497)

Dear Mr. Plona:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 197 to Facility Operating License No. NPF-43 for the Fermi 2 facility. The amendment consists of changes to the Updated Final Safety Analysis Report in response to your application dated January 11, 2013, as supplemented by letter dated September 27, 2013.

The amendment revises the Fermi 2 UFSAR to describe the methodology and results of the analysis performed to evaluate the protection of the plant's structures, systems and components from tornado-generated missiles. The analysis utilized a probabilistic approach implemented through the application of the TORMIS computer code.

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

Docket No. 50-341

Enclosures:

1. Amendment No. 197 to NPF-43

2. Safety Evaluation Sincerely,

/RAJ Thomas J. Wengert, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation cc w/encls: Distribution via ListServ DISTRIBUTION:

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OGC/NLO NAME TWengert MHenderson GCasto HHamzehee DRoth DATE 02/20/14 02/20/14 12/05/13 11/14/13 02/26/14 02/21/14 reconcur OFFICIAL RECORD COPY RidsNrrPMFermi2 Resource ESmith, NRR/SBPB MReisi-Fard, NRRIAPLA LPL3-1/BC LPL3-1/PM RCa rison TWengert 03/07/14 03/10/14