Text

Comment (72) of Gene Nelson of Californians for Green Nuclear Power Supporting Renewal of the License Application for Diablo Canyon Power Plant
	ML15287A437
Person / Time
Site:	Diablo Canyon
Issue date:	05/11/2015
From:	Nelson G; Californians for Green Nuclear Power
To:	; Rules, Announcements, and Directives Branch
References
	80FR37664 00072
	Download: ML15287A437 (16)
	v • d • e

9/1/2015 9/1/015N RC-2009-0552- DRAFT-0065.htmlI As of: 9/1/15 4:54 PM Reeeived: Aurnust 29_ 2015 PUBLIC SUBMISSION status: PendingPost Tracking No. ljz-8ku0-kux0 Comments Due: August 31, 20115 Submission Type: Web Docket: NRC-2009-0552 Notice of Receipt and Availability of Application for Renewal of Diablo Canyon Nuclear Power Plant License Comment On: NRC-2009-0552-0026 DiablOsttmnCanyon Power Plant, Units 1 and 2; Notice of Intent ~/*fto Prepare_an B ental. Impact Document: NRC-2009-0552-DRAFT-0065 Comment on FR Doc # 2015-15921 ,Ot_" 2 :;.

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Submitter Information -!- - ,,

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Name: Gene Nelson i-T]

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General Comment I Gene Nelson, Ph.D. serve as the Government Liaison for Californians for Green Nuclear Power http://www.CGNP.org. Attached find a relevant file in support of the renewal of the license application for Diablo Canyon Plant, Units 1 and 2.

The Docket Number is NRC-2009-05 52.

Attachments Gene_NelsonPhD_Comments_Summary of CGNP_Filings in_Docket_1 5-IEPR- 12 05 11 15 SUNSI Review Complete Template = ADM - 013 E-RIDS= ADM-03 Add=

file:IllC:/UsersICAG/D ownl oads/N RC- 2009- 0552- DRAFT- 0065.html 1/1

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http:lldocketpublic.energy. ca.govlPublicDocuments/115-1EPR-1 21/

ITN204588_2015051 1T153044_.Gene_.Nelson PhD Comments_.SummaryofCGNPFilings inDocket_151E.pdf Archived 05 11 15 by Gene A.Nelson, Ph.D.I D OCKETED Docket 15-IEPR- 12 F Number:

Project

Title:

Nuclear Power Plants TNI#: 204588 Document

Title:

1Gene Nelson, Ph.D. Comments: Summary of Californians for Green Nuclear Power Filings in Support of DCPP

Description:

N/A-_ _ _

Filer: System~ - ___ _ _ _ -

-_Organization: iGene Nelson, Ph.D. ____-

Submitter Role: .IPublic, Submission 5/11/2015 3:30:45 PM Date: __ _ _ _ __ _ _ _ ______ _

Docketed Date: ] 5/11/2015

Comment Received From: Gene Nelson, Ph.D.

Submitted On.: S/i11/2015 Docket Number: 15-IEPR-12 Summary of CGNP Filings in Docket 15-IEPR-12 in Support of DCPP For the convenience of the California Energy Commission, a tabular summary of all of the 231 pages of comments to date made by Californians for Green Nuclear Power (CGNP) http://www.CGNP org in response to CEC Docket 15-IEPR- 12 is found in the first five pages. A spreadsheet follows with live links to each of the comments. Both the table and spreadsheet are sorted by the order in which the docket entries were made.

Additional submitted attachment is included below.

15-1EPR-12 Docket Log Summary for submissions by Gene Nelson, Ph.D. and Californians for Green Nuclear Power (CGNP) as of 11 May 2015 TN 203964, Docketed 26 March 2015: 2 page summary of CGNP advocacy for Diablo Canyon Power Plant (DCPP) once-through-cooling (OTC) alternative compliance by utilizing the SWRCB "Appendix A" amendments TN 204274, Docketed 21 April 2015: 2 page summary including executive summary advocating for alternative compliance and the table of contents of the 45-page CGNP packet submitted to the SWRCB on 03 February 2015. (There were technical difficulties with submission of large attachments to the CEC website that day.)

TN204275, Docketed 21 April 2015: The complete 45-page CGNP packet submitted to the SWRCB on 03 February 2015. The key finding was that forcing DCPP's owners to retrofit DCPP with salt-water-cooled cooling towers to comply with federal Clean Water Act( CWA) 316(B) legislation would cause unacceptable safety risks to DCPP and provide scant benefits regarding sea life impingement relative to the multi-billion dollar costs of the dangerous retrofit. In recognition of the emissions-free environmental benefits of generating extremely large amounts of electrical power, the CWA 316(B) legislation provides options to waiver nuclear power plants, particularly in light of the safety risks cited and the benefits being wholly out of proportion to the retrofit costs.

TN204278, Docketed 21 April 2015: 66 pages, including summary. The Energy Institute at Haas at the University of California at Berkeley studied the effects of the premature forced closure of San Onofre Nuclear Generation Station (SONGS) in February, 2012. They concluded that there were significant power line transmission constraints that prevented ratepayers in the area previously served by SONGS from receiving the most economical power available. As a result, regional gas-fired generators were utilized, increasing air pollution and emissions. Q~uoting from the abstract,...We find that in the months following the closure, almost all of the lost generation from SONGS was met by natural gas plants inside California at an average cost of

$66,000 per hour....The transmission constraints also made it potentially more profitable for certain plants to exercise market power, and we find evidence that one company, in particular, may have acted non-competitively (emphasis added) ....

and from the conclusion:

Co ncl usion: We find that the SONGS closure increased the private cost of electricity generation in California by about $369 million, (emphasis added) and the social cost of emissions from generation by about $331 million, during the first twelve months. Of this, $39 million reflects transmission constraints and other physical limitations of the grid that necessitated that a high fraction of lost generation be met by. plants located in the Southern part of the state. These

Page 2 of 5 CGNP 15-1EPR-12 Docket Log Summary as of 11 May 2015 by Gene A. Nelson, Ph.D.

constraints also increased the scope for market power, and we find evidence that one company, in particular, may have acted non-competitively ...

These data support the estimate that ratepayers will pay about $3.3 billion more for electric power over the projected life of SONGS had a license extension been granted, as noted in Docket submission TN 204275.

TN.204314, Docketed 23 April 2015. 5 pages, including summary. The article, "The Ten Biggest Power Plants In America -- Not What You Think" by James Conca, Ph.D. 20 April 2015, blog at Dr. Conca's Forbes.com website. This article highlighted the ten biggest power plants in the United States as measured by total electric power generated annually. In 2014, nuclear power plants occupied the top four positions and seven of the top ten. Measured by 2011 power production, DCPP would be just below number 13 in the rankings. DCPP's large generation capability implies that it is import~ant in maintaining grid stability (the match between supply and demand.) In a subsequent Docket Entries TN 204522 and TN 204530, additional detail is provided. These three docket entries establish that DCPP is the largest generator of electric power in California . Therefore the loss of DCPP would seriously harm California grid stability.

TN 204381, Docketed 27 April 2015, 10 pages. Some samples of the media coverage of the groundbreaking CGNP citizen advocacy for the continued safe operation of DCPP are included.

CGNP depends only on contributions of its members to defray necessary expenses. CGNP does not obtain intervenor funds from the California PUC, nor does it receive funding from any corporate body.

TN 204426, Docketed 29 April 2015, 4 pages, including summary. Media coverage of Governor Brown's Executive Order B-30-15 establishing aggressive new targets for emissions reductions on 29 April 2015. The only practical, cost-effective means to accomplish these important goals will be to remove the legal impediments to building additional California nuclear power generation capacity. This nuclear power generation could power millions of electric vehicles and provide much-needed energy for the construction of additional desalinatio~n facilities to supply water to drought-parched California.

TN 204427, Docketed 29 April 2015, 6 pages, including summary. A critique of wind generation of power with a focus on failures in California from the UK Daily Mail, 18 March 2012. A key question asked about the low capacity factor (CE) of wind generation is, "Why, they ask, should the debt-laden country be giving wind energy companies a 30 per cent tax credit, costing taxpayers nearly $3 billion a year, when wind accounts for only 2.3 per cent of America's electricity." While nuclear power and wind generation are both emissions-free, nuclear power is far more cost effective, reliable, and safe.

Page 3 of 5 CGNP 25-iEPR-12 Docket Log Summary as of 11 May 2015 by Gene A. Nelson, Ph.D.

TN 204429, Docketed 29 April 2015, 4 pages, including summary. Media account of the Nuclear Regulatory Commission (NRC) and a panel of independent seismologists reaffirming DCPP's seismic safety during a highly-technical four-hour-long teleconference from NRC headquarters.

This NRC reaffirmation of DCPP seismic safety stands in stark contrast to the alarmist claims being raised by PUC-funded intervenors such as the Alliance for Nuclear Responsibility, The Utility Reform Network, and the Friends of the Earth, among others.

TN 204430, Docketed 29 April 2015, 1 page. Color front cover of the 24 September 2014 issue of Science Magazine (Courtesy Alex Cannara, Ph.D.) showing the unprecedented declines in the California water table since 2002, as measured by NASA's GRACE mission. These declines are caused by the epic California drought, which has been exacerbated by global warming.

Nuclear power could run California desalination stations to compensate for this loss without adding emissions.

TN 204516 Docketed 06 May 2015, 237 pages. Transcript for the 27 April 2015 Nuclear Joint Lead Commissioner wOrkshop held in Sacramento, California. Dr. Gene Nelson's comments appear on pages 200-203, Mr. Bill Gloege's comments on pages 203-207, Joseph Ivora's on pages 206-207, and Dr. Alex Cannara, who supports CGNP, has comments on pages 213-218.

TN 204522 Docketed 07 May 2015, 7 pages, including summary. DCPP is important to California power grid stability - Rebuttal to the California ISO submission TN 204323 - Part 1 of

2. A 2004 Western Area Power Administration (WAPA) "Path 15" press release is annotated to show the power transmission lines connecting DCPP to PG&E's Helm Pumped Storage Unit.

DCPP is the largest California power generation facility and Helms is one of the top ten facilities. During the night hours, emissions-free power from DCPP may be employed to "charge up" Helms pumped storage. Then, during the day, Helms may generate the approximate emissions-free power of an additional DCPP reactor (typically accompanied by DCPP's twin reactors) to power the California grid. Emissions to generate California's electric power would be dramatically increased if DCPP were forced to shut down.

TN 204530, Docketed 07 May 2015, 5 pages, including summary. DCPP is important to California power grid stability - Rebuttal to the California ISO submission TN 204323 - Part 2 of

2. The table, "2013 Total System Power in Gigawatt Hours" from the California Energy Almanac (CEA) is re-organized to highlight power generation by emissions-free generation sources in contrast to the sources that emit emissions that exacerbate global warming and diminish air quality. Note the significant contribution to in-state emissions-free power generation from nuclear power. In 2013, 100% of the nuclear power generated in California came from DCPP.

On the other hand, the contributions of dirty out-of-state coal power generation was approximately equal to the annual power generation of SONGS in recent years. The out-of-state air pollution from burning coal drifts into California. This statistic rebuts the interruption of my

Page 4 of 5 CGNP 15-1EPR-12 Docket Log Summary as of 11 May 2015 by Gene A. Nelson, Ph.D.

CEC citizen testimony during the 27 April 2015 CEC hearing in Sacramento by apparent natural gas advocate and CEC Chair Robert B. Weisenmiller, Ph.D. The second spreadsheet highlights the "Top 10" California power generation facilities, extracted from a CEA tabulation. DCPP is number 1. Helms Pumped Storage is in the "Top 10." The third spreadsheet details the low.

capacity factor (CE) of natural-gas-powered Moss Landing in comparison with .DCPP. DCPP's CF is almost three times that of Moss Landing. These spreadsheets underscore the serious dimensions that a loss of DCPP power would cause.

TN 204551, Docketed 08 May 2015, 3 pages. A 20 April 2015 article from PG&E Currents that summarizes a recent meeting between executives at Japan's Chubu Electric Power Company and DCPP executives. This article underscores the dimensions of the positive DCPP nuclear safety culture which the executives of the third-largest power company in Japan wish to emulate.

TN 204560, Docketed 11 May 2015, 5 pages, including summary. Details, including the complete text of Governor Brown's Executive Order B-30-15. The political barriers to the expansion of the use of nuclear power will need to be taken down in order to comply with Governor Brown's 29 April 2015 executive order. As a consequence of their low capacity factors, solar and wind power are not cost-effective. Burning more natural gas or coal just increases global warming, contrary to the intent of this executive order.

TN 204561, Docketed 11 May 2015, 1 page by CGNP member Joe Ivora. Power-intensive desalination stations, such as the one under construction in Carlsbad, CA should be powered by emissions-free nuclear power plants.

TN 204562, Docketed 11 May 2015, 48 pages with summary. Relevant chapters of the California Central Coast Seismic Imaging Project (CCCSIP) are merged into a single document. This paragraph is a rebuttal to the overblown concern highlighted by Attorney John Geesman in his 08 May 2015 Docket entry TN 204546 at page 3 of 46: The CCCSIP information has been carefully reviewed by the NRC and their panel of seismologists. Dr. Hamilton's views are anomalous among most geologists that have studied the seismic potential of features underlying or near DCPP. It is likely that Dr. Hamilton receives 'things of value" from DCPP opponents, as do several other Ph.D.s recruited by the opposition. The CEC should also be reminded of the bias that Attorney John Geesman received intervenor compensation as high as

$545.00/hour, as noted in TN 204275. Per the PUC Intervenor Rate table updated 29 October 2014, Rochelle Becker received as much as $125.00 per hour

Page 5 of 5 CGNP 15-1EPR-12 Docket Log Summary as of 11 May 2015 by Gene A. Nelson, Ph.D.

At page 46 of 49:

CCCSIP studies have also addressed the testimony of Dr. Douglas Hamilton concerning a previously recognized fault mapped under the'DCPP turbine building and the Unit 1 containment (Diablo Cove fault), and a proposed fault named the San Luis Range/Inferred Offshore Fault (SLR/IOF). Through review of previously collected information about the Diablo Cove fault from the original siting and preconstruction activities supplemented with recently collected geologic map data and high-resolution 3D seismic -reflection data collected as part of the CCCSIP indicate that the Diablo Cove fault does not represent a seismic hazard (e.g.

vibratorY ground motion or surface faulting) to the DCPP. Analysis of high-resolution 2D and 3D seismic-reflection data, seismicity and potential field data does not support the SLR/IOF as proposed by Dr. Hamilton. ("Hamilton" appears 13 times in the docketed document.)

TN 204564 Docketed 11 May 2015,2 pages by CGNP member and founder William Gloege.

This docket entry summarizes the need for DCPP to meet pressing needs in California.

TN 204565 Docketed 11 May 2015,1 page by CGNP member Anthony Armini, Ph.D. California's likely economic harms caused-by a potential DCPP shutdown are highlighted by noting recent economic losses in the German economy as they turned from nuclear to solar, wind, and fossil fuel power.

TN 204566 Docketed 11 May 2015,2 pages with summary. The complementary role of PG&E's Helms Pumped Storage facility to DCPP is summarized in this one-page PG&E currents article.

Both DCPP and Helms (when powered by DCPP) are zero- emissions power generators.

TN 204570 Docketed 11 May 2015,1 page by CGNP member Anthony Armini, Ph.D Dr. Armini makes the case that it would be far less expensive to repair the steam generator problem at San Onofre Nuclear Generating Station (SONGS) instead of permanently decommissioning the plant.

TN 204581 Docketed 11 May 2015,5 pages with summary. Dr. James Conca provides additional documentation regarding the high reliability of nuclear power in an article published on his Forbes.com blog today.

TN 204583 Docketed 11 May 2015,6 pages with summary. In response to some extremely vocal critics of dry cask storage who are neither metallurgists nor nuclear engineers, a National Public Radio (NPR) article from 2012 is included as rebuttal with some included listener comments regarding nuclear waste politics.

Total page count: 231 pages.

5/11/2o15 5/11/2015 ~~~~~~~GAN 15-1EPR-12 Docket Log 05 11 15.xlsPae1o8GneANlsPh. Page I of 8 Gene A. Nelson, Ph.D.

Docket Log Docket: 15-1EPR-12 Project ittle: Nuclear Power Plants GeneratedOn. 5/8/2015 10:41:29 PM TNN Docketed Document Title Exhibit # To From Dat....e 203964 3/26/2015 Gene Nelson, Ph.D. Comments: The Californians CEO/Docket Gene Nelson, for Green Nuclear Power (CGNP) Advocates for Unit Ph.D.

AdoPtion of the SWRCB "Ap~pendix A" amendments for DCPP Air Quality, Efficiency, Compliance, Reliability, Transmission System Engineering, Greenhouse Gases 2 page(s) 204274 4/21/2015 Gene Nelson, Ph.D. Comments: Californians for CEC/ Docket Gene Nelson, Green Nuclear Power Board-Approved Submission Unit Ph.D.

Air Quality, Biological Resources, Efficiency, Executive Summary, Facility Design, Compliance, Geology/Paleontology, Reliability, Transmission Line Safety and Nuisance, Greenhouse Gases, _IEPR 2015-04-27 Workshop, _IEPR Presentation, IEPR Public Comments 2 page(s) 204275 4/21/2015 Californians for Green Nuclear Power (CGNP) CEC/Docket Gene Nelson, February 3. 2015 Board-Approved Packet Unit Ph.D.

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TN Docketed Document Title Exhibit # To From Date 45 page(s) 204278 4/21/2015 Energy Institute at Haas - The Value of CEC/Docket Gene Nelson, Transmission in Electricity Markets: Evidence from Unit Ph.D a Nuclear Power Plan Closure 66 page(s) 204314 4/23/2015 Gene Nelson. Ph.D. Comments: DCPP's High CEC/Docket Gene Nelson, Capacity Factor Makes the Plant a Critical Factor in Unit Ph.D.

Grid Stability Air Quality, Efficiency, Land Use, Reliability, Transmission System Engineering, Greenhouse Gases, _IEPR 201 5-04-27 Workshop , _IEPR Public Comments 5 page(s) 204381 4/27/2015 Gene Nelson. Ph.D. Comments: Sample of Media CEO/Docket Gene Nelson, Coverage Regarding Californians for Green Unit Ph.D.

Nuclear Power (CGNP)

Air Quality, Geology/Paleontology, Reliability, Transmission System Engineering, Greenhouse Gases, _IEPR 201 5-04-27 Workshop , IEPR Agenda _IEPR Public Comments 10 page(s) 204426 4/29/2015 Gene Nelson. Ph.D. Comments: California Gene Nelson, Governor Brown Announces Ambitious New Ph.D.

Emissions Targets

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TN Docketed Document Title Exhibit #* To From Date Biological Resources, Noise and Vibration, Visual Resources, Greenhouse Gases,

_IEPR 2015-04-27 Workshop, _IEPR Public Comments 4 page(s) 204427 4/29/2015 Gene Nelson, Ph.D. Comments: Wind Energ~y is not Gene Nelson, the path to Emissions-Free Power - Nuclear Is Ph.D Air Quality, Biological Resources, Land Use, Noise and Vibration, Visual Resources, Greenhouse Gases, _IEPR 2015-04-27 Workshop, _IEPR Public Comments 6 page(s) 204429 4/29/2015 Gene Nelson, Ph.D. Comments: The NRC Reaffirms CEO/Docket Gene Nelson, DCPP's Seismic Safety 28 April 2015 Unit Ph.D.

Air Quality, Biological Resources, Facility Design, Geology/Paleontology, Reliability, Transmission System Engineering, Greenhouse Gases, _IEPR 201 5-04-27 Workshop, IEPR Public Comments 4 page(s) 204430 4/29/201 5 Science the Droug~ht You Can't See CEC/ Raquel Gene A. Nelson, Kravitz Ph.D 1 page(s)

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TNN Docketed Document Title Exhibit # To From Date 204522 5/7/2015 Gene Nelson, Ph.D. Comments: DCPP is important CEC/Docket Gene Nelson, for Grid Stability Part 1 - Rebuttal to California ISO Unit Ph.D.

Facility Design, Reliability, Transmission System Engineering, _IEPR 2015-04-27 Workshop , IEPR Presentation 7 page(s) 204530 5/7/2015 Gene Nelson, Ph.D. Comments: DCPP is important CECI/Docket Gene Nelson, for Grid Stability Part 2 - Rebuttal to California ISO Unit Ph.D.

Air Quality, Efficiency, Facility Design, Reliability, Socioeconomics, Transmission Line Safety and Nuisance, Transmission System Engineering, Greenhouse Gases,

_IEPR 2015-04-27 Workshop, _IEPR Presentation, IEPR Public Comments 5 page(s) 204551 5/8/2015 Gene Nelson, Ph.D. Comments: Japan's Chubu CEC/Docket Gene Nelson, Electric Power Company - Unit Ph.D.

Looks to Diablo Canyon for Best Practices in Assessing Risk, Seismic Safety Air Quality, Efficiency, Facility Design, Geology/Paleontology, Reliability, Transmission System Engineering, Greenhouse Gases, _IEPR 2015-04-27 Workshop 3 page(s)

I I I J

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T..N Docketed Document Title Exhibit #* To From Date 204560 5/11/2015 Gene Nelson, Ph.D. Comments: Governor Brown CEO/Docket Gene Nelson, Establishes Most Ambitious Greenhouse Gas Unit Ph.D.

Reduction Target in North America Air Quality, Public Health, Reliability, Socioeconomics, Greenhouse Gases, _IEPR 2015-04-27 Workshop 5 page(s) 204561 5/11/2015 Joseph S. Ivora Comments: California future water CEO/Docket Joseph S. Ivora Unit 1 page(s) 204562 5/8/2015 Gene Nelson, Ph.D. Comments: DCPP's Seismic CEO/Docket Gene Nelson, Risk is bounded by the Predicted Energy Released Unit Ph.D.

by Hosgri Fault Facility Design, Geology/Paleontology, _IEPR 201 5-04-27 Workshop, _IEPR Public Comments 48 page(s) 204564 5/11/2015 William P. Gloege Comments: Need for Diablo CEO/Docket William P.

Canyon and Role of Nuclear Power in California Unit Gloege

_IEPR 2015-04-27 Workshop 2 page(s) 204565 5/10/2015 Anthony Armini Comments: Be careful not to CEO/Docket Anthony Armini wreck California's economy Unit

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TN Docketed Document Title Exhibit # To From Date

_IEPR 2015-04-27 Workshop 1 page(s) 204566 5/11/2015 Gene Nelson, Ph.D. Comments: Helms Pumped CEO/Docket Gene Nelson, Storage Operates in Conjunction with DCPP to Unit Ph.D.

Provide Emissions-Free Power Air Quality, Efficiency, Facility Design, Reliability, Transmission System Engineering, Greenhouse Gases, _IEPR 2015-04-27 Workshop , _IEPR Public Comments 2 page(s) 204570 5/11/2015 Anthony Armini PhD Comments: Fixing San Onofre CEO/Docket Anthony Armini is cheaper than closing it Unit PhD IEPR 2015-04-27 Workshop 1 page(s) 204581 5/11/2015 Gene Nelson, Ph.D. Comments: James Conca Ph.D. CEC/ Docket Gene Nelson, 11 May 2015 Article about Nuclear's High Cap~acitv Unit Ph.D.

Air Quality, Efficiency, Reliability, Transmission Facto System Engineering, Greenhouse Gases, _IEPR 2015-04-27 Workshop, IEPR Public Comments 5 page(s)

5/11/2015 GAN 15-1EPR-12 Docket Log 05 11 15.xls Page 7 of 8 Gene A. Nelson, Ph.D.

ITN Docketed Document Title Exhibit # Too From Date 204583 5/11/2015 Gene Nelson. Ph.D. Comments: NPR Reoorted on CEO/Docket Gene Nelson, the safety of dry cask storage 13 June 2012 Unit Ph.D.

Facility Design, Public Health, Reliability, Waste Management, _IEPR 201 5-04-27 Workshop , _IEPR Public Comments 6 page(s)

I

5/11/2015 ~~~~~~~GAN 5/11/2015 15-1EPR-12 Docket Log 05 11 15.xlsPae8o8GneANlsPhD Page 8 of 8 Gene A. Nelson, Ph.D.

TN Docketed Document Title Exhibit # To From Date TN Pages 203964 2 204274 2 204275 45 204278 66 204314 5 204381 10 204426 4 204427 _______ 6 204429 4 204430 1 204522 7 204530 5 204551 3 204560 5

________ F 204561 1i 204562 48 204564 2 204565 1 204566 2 204570 1 204581 5 204583 6 Total Pages 231