ML14296A666
| ML14296A666 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island (DPR-042, DPR-060) |
| Issue date: | 11/19/2014 |
| From: | Scott Wall Plant Licensing Branch III |
| To: | Davison K Northern States Power Co |
| Wall S | |
| References | |
| TAC MF1891, TAC MF1892 | |
| Download: ML14296A666 (17) | |
Text
Mr. Kevin K. Davison Site Vice President UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 19, 2014 Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota 1717 Wakonade Drive East Welch, MN 55089
SUBJECT:
PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2, ISSUANCE OF LICENSE AMENDMENTS REGARDING NUCLEAR METHODOLOGY REFERENCES (TAC NOS. MF1891 AND MF1892)
Dear Mr. Davison:
The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment Nos. 211 and 199, to Renewed Facility Operating License Nos. DPR-42 and DPR-60 for Prairie Island Nuclear Generating Plant, Units 1 and 2, respectively. The amendments consist of changes to the technical specifications (TSs) in response to your application dated May 23, 2013, as supplemented by letters dated March 25, June 26, and October 20, 2014. The amendment revises TS 5.6.5, "CORE OPERATING LIMITS REPORT (COLR)," to add the methodology of topical report WCAP-16045-P-A, "Qualification of the Two-Dimensional Transport Code PARAGON," and WCAP-16045-P-A, Addendum 1-A, "Qualification of the NEXUS Nuclear Data Methodology," to determine core operating limits.
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.
Docket Nos. 50-282, and 50-306
Enclosures:
- 1. Amendment No. 211 to DPR-42
- 2. Amendment No. 199 to DPR-60
- 3. Safety Evaluation cc: Distribution via Listserv Sincerely, Scott P. Wall, 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 NORTHERN STATES POWER COMPANY-MINNESOTA DOCKET NO. 50-282 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 211 Renewed License No. DPR-42
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Northern States Power Company - Minnesota (NSPM, the licensee), dated May 23, 2013, as supplemented by letters dated March 25, June 26, and October 20, 2014, 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 Title 10 of the Code of Federal Regulations (1 0 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-42 is hereby amended to read as follows:
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 211, are hereby incorporated in the license. NSPM shall operate the facility in accordance with the Technical Specifications.
- 3.
This license amendment is effective as its date of issuance and shall be implemented within 90 days from the date of issuance.
Attachment:
Changes to the Renewed Facility Operating License No. DPR-42 and Technical Specifications Date of Issuance: November 19, 2014 LEAR REGULATORY COMMISSION
ATTACHMENT TO LICENSE AMENDMENT NO. 211 RENEWED FACILITY OPERATING LICENSE NO. DPR-42 DOCKET NO. 50-282 Replace the following page of Renewed Facility Operating License No. DPR-42 with the attached revised page. The change area is identified by a marginal line.
REMOVE INSERT Replace the following page of Appendix A, Technical Specifications, with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the area of change.
REMOVE INSERT 5.0-37 5.0-37 (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 and equipment calibration or associated with radioactive apparatus or components; (5)
Pursuant to the Act and 10 CFR Parts 30 and 70, NSPM to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility; (6)
Pursuant to the Act and 1 0 CFR Parts 30 and 70, NSPM to transfer byproduct materials from other job sites owned by NSPM for the purpose of volume reduction and decontamination.
C.
This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter 1:
Part 20, Section 30.34 of Part 30, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; 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 1677 megawatts thermal.
(2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 211, are hereby incorporated in the renewed operating license. NSPM shall operate the facility in accordance with the Technical Specifications.
(3)
Physical Protection NSPM shall fully implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Renewed Operating License No. DPR-42 Amendment No. 211 I
Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)
Prairie Island Units 1 and 2
- 29. Caldon Engineering Report ER-157P, "Supplement to Topical Report ER-80P: Basis for a Power Uprate with the LEFM or LEFM CheckPlus System";
- 30. WCAP-12610-P-A, "VANTAGE+ Fuel Assembly Reference Core Report";
- 31. WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO TM,;
- 32. Commencing Unit 1 Cycle 30 and Unit 2 Cycle 30, this reference shall be used in lieu of reference 23: WCAP-16045-P-A, "Qualification of the Two-Dimensional Transport Code PARAGON', August 2004; and
- 33. Commencing Unit 1 Cycle 30 and Unit 2 Cycle 30, this reference shall be used in lieu of reference 23: WCAP-16045-P-A, Addendum 1-A, "Qualification of the NEXUS Nuclear Data Methodology", August 2007.
- c.
The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal-mechanicallimits, core thermal-hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.
- d.
The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.
Unit 1 -Amendment No. -l-9-7 -l-99 211 5.0-37 Unit 2-Amendment No. -l-86 -l-8-7 199
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 NORTHERN STATES POWER COMPANY-MINNESOTA DOCKET NO. 50-306 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 199 Renewed License No. DPR-60
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Northern States Power Company - Minnesota (NSPM, the licensee), dated May 23, 2013, as supplemented by letters dated March 25, June 26, and October 20, 2014, 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 Title 1 0 of the Code of Federal Regulations (1 0 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-60 is hereby amended to read as follows:
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 199, 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 from the date of issuance.
Attachment:
Changes to the Renewed Facility Operating License No. DPR-60 and Technical Specifications R REGULATORY COMMISSION David L. Pelton, Chief Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: November 19, 2014
ATTACHMENT TO LICENSE AMENDMENT NO. 199 RENEWED FACILITY OPERATING LICENSE NO. DPR-60 DOCKET NO. 50-306 Replace the following page of Renewed Facility Operating License No. DPR-60 with the attached revised page. The change area is identified by a marginal line.
REMOVE INSERT Replace the following page of Appendix A, Technical Specifications, with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the area of change.
REMOVE INSERT 5.0-37 5.0-37 (3)
Pursuant to the Act and 1 0 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 and equipment calibration or associated with radioactive apparatus or components; (5)
Pursuant to the Act and 10 CFR Parts 30 and 70, NSPM to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility; (6)
Pursuant to the Act and 10 CFR Parts 30 and 70, NSPM to transfer byproduct materials from other job sites owned by NSPM for the purpose of volume reduction and decontamination.
C.
This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter 1:
Part 20, Section 30.34 of Part 30, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; 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 1677 megawatts thermal.
(2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 199, are hereby incorporated in the renewed operating license.
NSPM shall operate the facility in accordance with the Technical Specifications.
(3)
Physical Protection NSPM shall fully implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 1 0 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Renewed Operating License No. DPR-60 Amendment No. 199 I
Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)
Prairie Island Units 1 and 2
- 29. Caldon Engineering Report ER-157P, "Supplement to Topical Report ER-80P: Basis for a Power Uprate with the LEFM or LEFM CheckPlus System";
- 30. WCAP-12610-P-A, "VANTAGE+ Fuel Assembly Reference Core Report";
- 31. WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO '";
- 32. Commencing Unit 1 Cycle 30 and Unit 2 Cycle 30, this reference shall be used in lieu of reference 23: WCAP-16045-P-A, "Qualification of the Two-Dimensional Transport Code PARAGON', August 2004; and
- 33. Commencing Unit 1 Cycle 30 and Unit 2 Cycle 30, this reference shall be used in lieu of reference 23: WCAP-16045-P-A, Addendum 1-A, "Qualification of the NEXUS Nuclear Data Methodology", August 2007.
- c.
The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal-mechanicallimits, core thermal-hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.
- d.
The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.
Unit 1 -Amendment No. -l-9-7 -l-99 211 5.0-37 Unit 2-Amendment No. 86 -+/--81199
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 211 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-42 AND AMENDMENT NO. 199 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-60 NORTHERN STATES POWER COMPANY-MINNESOTA PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-282 AND 50-306
1.0 INTRODUCTION
By application dated May 23, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13144A750), as supplemented by letters dated March 25, June 26, and October 20, 2014 (ADAMS Accession Nos. ML14085A228, ML14177A476, and ML14293A744, respectively), Northern States Power Company-Minnesota (NSPM, the licensee), doing business as Xcel Energy, Inc., requested changes to the technical specifications (TSs) for Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2.
The proposed changes would revise TS 5.6.5, "CORE OPERATING LIMITS REPORT (COLR),"
to add the references of Westinghouse Electric Company LLC (Westinghouse) topical report WCAP-16045-P-A, "Qualification of the Two-Dimensional Transport Code PARAGON," dated August 2004, and WCAP-16045-P-A, Addendum 1-A, "Qualification of the NEXUS Nuclear Data Methodology," dated August 2007 (ADAMS Accession Nos. ML042250345 and ML072570352, respectively). These two reports are collectively referred to as WCAP-16045-P-A and addendum, and are intended to replace the PHOENIX-P methodology, described in WCAP-11596-P-A, "Qualification of the PHOENIX-P/ANC Nuclear Design System for Pressurized Water Reactor Cores (ADAMS Accession No. ML080630391 ).
The supplements dated March 25, June 26, and October 20, 2014, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC) staff's original proposed no significant hazards consideration determination as published in the Federal Register on August 20, 2013 (78 FR 51229).
2.0 REGULATORY EVALUATION
The guidance in NRC Generic Letter (GL) 88-16, "Removal of Cycle-Specific Parameter Limits from Technical Specifications," indicates that it is acceptable for licensees to control reactor physics parameter limits by specifying an NRC-approved calculation methodology. These parameter limits may be removed from the TS and placed in a cycle-specific COLA, which is defined in the TS and required to be submitted to the NRC every operating cycle or each time it is revised. As recommended by GL 88-16, the PINGP TS includes a list of references for the NRC-approved calculation methodologies used to generate the cycle-specific operating limits.
The TS changes requested by NSPM are changes to this reference list.
Since WCAP-16045-P-A and addendum comprise a nuclear data methodology, there are no directly applicable regulatory requirements. The NRC safety evaluations (SEs) that provide generic approval for use of WCAP-16045-P-A and addendum cite Title 1 0 of the Code of Federal Regulations (1 0 CFR) Part 50, Section 50.34, "Contents of Applications; Technical Information" as their regulatory basis. This is appropriate, as accurate nuclear analysis forms an integral part of the safety analysis required to be provided by licensees and applicants.
Similarly, these safety analyses are used to establish the limiting safety system settings (LSSS) and Limiting Conditions for Operation (LCOs) contained in the TS. Therefore, 10 CFR 50.36, "Technical Specifications," also applies; without an accurate nuclear analysis it cannot be established that the LCOs and LSSS provide for the safe operation of the facility.
3.0 TECHNICAL EVALUATION
The NRC staff considered the technical and regulatory bases for the generic approvals of the WCAP-16045-P-A and addendum in its present review, in order to establish that the nuclear code suite is appropriate for use at the PINGP and that the proposed changes to the TSs maintained the affected TSs consistent with the provisions in GL 88-16.
3.1 PARAGON and NEXUS Code Descriptions The PARAGON code, as described in WCAP-16045-P-A, is a neutron transport code intended to replace PHOENIX-P for use in providing cross section data to the Westinghouse proprietary Advanced Nodal Code (ANC), a core simulator code. NEXUS, as described in WCAP-16045-PA, Addendum 1-A, is an improvement to the PARAGON/ANC code system that changes the method of transmitting the nuclear data output from PARAGON to ANC. Rather than using boron letdown curves, NEXUS accounts for variations in the neutron spectrum by parameterizing the PARAGON cross section output and reconstructing it within the ANC. As discussed in the NRC staff's SEdated July 17, 2013, approving the use of PARAGON and NEXUS at Farley (ADAMS Accession No. ML13149A354), the NEXUS methodology provides a link between PARAGON and ANC without replacing either, and therefore still requires the use of both older codes.
Both WCAP-16045-P-A and addendum are NRC-approved, and the staff has previously determined that they have been extensively validated and verified using a variety of experiments and plant data that account for a wide range of differences in operating conditions.
In Addendum 1-A, the verification was expanded to include the comparison of NEXUS results for critical boron concentration to those obtained using the previous PARAGON methodology, 3.2 Applicability to PINGP The NRC staff reviewed the Updated Safety Analysis Report (USAR) for PINGP Units 1 and 2 to verify that the fuel in use at Prairie Island is covered by the verification and validation database for PARAGON and NEXUS. The PINGP USAR Chapter 3, "Reactor," indicates that the unit uses 14x14 Westinghouse 400 and 422 VANTAGE+ fuel with enriched annular blankets and U02-Gd20 3 burnable poison rods. The staff concluded that all of the design features of the fuel in use at PINGP are represented in the database described in Section 3.1 of this SE and that the PARAGON/NEXUS system is acceptable for use at PINGP.
A single limitation imposed by the SEs for both PARAGON and NEXUS precludes their use tor mixed oxide (MOX) cores. To verify that the limitation would be satisfied for PINGP, the NRC staff evaluated PINGP TS 4.2.1, "Fuel Assemblies," which states:
The reactor shall contain 121 fuel assemblies. Each assembly shall consist of a matrix of Zircaloy, ZIRLO', or Optimized ZIRLOTM fuel rods with an initial composition of natural or slightly enriched uranium dioxide (U02) as fuel material.
... A limited number of lead test assembles that have not completed representative testing may be placed in nonlimiting core regions.
The NRC staff determined from this evaluation that the use of MOX in a full core reload capacity would prompt additional technical review in other areas and the limitation is therefore inherently satisfied for Prairie Island.
In conclusion, the NRC staff has determined that the NRC-approved methodologies described in WCAP-16045-P-A and addendum are applicable to PINGP, Units 1 and 2. This satisfies the GL 88-16 requirement for licensees to use NRC-approved methods to determine core operating limits. Furthermore, the applicability of the generic qualification helps to establish that nuclear design analyses performed for PINGP using the methods described in WCAP-16045-P-A and addendum will be accurate, consistent with the 1 0 CFR 50.34 requirements for safety analyses.
Accuracy of the nuclear analysis also helps ensure the adequacy of the TS LCOs and LSSS to provide for the safe operation of the facility, consistent with the requirements of 1 0 CFR 50.36.
3.3 Additional Review Topics As originally proposed, the licensee would have added references to WCAP-16045-P-A and amendment without removing the existing reference to WCAP-11596-P-A, "Qualification of the PHOENIX-P/ANC Nuclear Design System for Pressurized Water Reactor Cores," which WCAP-16045-P-A and amendment are intended to replace. This is because of an "unavoidable transition period" during which PINGP Unit 1 would be using the proposed methodology and PINGP Unit 2 would be using the existing methodology. Due to the lack of specificity in the TS regarding which methodology would be used to determine the core operating limits, the NRC staff was unable to determine that the requirements of GL 88-16 were met. In their supplemental response to the NRC staff's request for additional information dated March 25, 2014, and October 20, 2014, NSPM added a note clarifying that WCAP-11596-P-A would no longer be used at each unit after implementation of WCAP-16045-P-A and amendment at that plant. The staff determined that this change helped bring the proposed amendment in line with the requirements of GL 88-16 and was therefore acceptable.
3.4 Summary The NRC staff determined that the proposed TS changes required to replace the PHOENIX-P code system with the PARAGON/NEXUS code system are acceptable for PINGP. This determination is based on the following considerations: (1) that PARAGON and NEXUS are NRC-approved methods which have been determined to be applicable to the PINGP units; and (2) that the proposed TS revisions specifically delineate which topical reports will be used to perform nuclear calculations for each unit. The staff determined, based on these considerations, that the proposed TS revision is consistent with the guidance provided in GL 88-16, and that the generic qualification and robust validation of the PARAGON-NEXUS/ANC system satisfies the requirements of 10 CFR 50.34 and 10 CFR 50.36.
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 relates to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding 78 FR 51229. 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 NRC staff 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 amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: R. Anzalone, NRR M. Hardgrove, NRR Date: November 19, 2014
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