ML16040A084

FENOC, Beaver Valley Power Station, Unit Nos. 1 and 2; and Davis-Besse Nuclear Power Station, Unit No. 1 - Issuance of Amendments Revision to Technical Specification 5.3.1, Unit Staff Qualifications

ML16040A084
Person / Time
Site:	Beaver Valley, Davis Besse
Issue date:	06/07/2016
From:	Bhalchandra Vaidya Plant Licensing Branch III
To:	Belcher S FirstEnergy Nuclear Operating Co
Vaidya B, NRR/DORL/LPLIII-2
References
TAC MF7118, TAC MF7119, TAC MF7120
Download: ML16040A084 (19)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 7, 2016 Mr. Samuel L. Belcher Senior Vice President and Chief Nuclear Officer FirstEnergy Nuclear Operating Company 341 White Pine Drive Akron, OH 44320

SUBJECT:

BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2; AND DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 - ISSUANCE OF AMENDMENTS RE: REVISION TO TECHNICAL SPECIFICATION 5.3.1, "UNIT STAFF QUALIFICATIONS" (TAC NOS. MF7118, MF7119, AND MF7120)

Dear Mr. Belcher:

The U.S. Nuclear Regulatory Commission (NRG or Commission) has issued the enclosed Amendment No. 297 to Renewed Facility Operating License No. DPR-66 and Amendment No. 185 to Renewed Facility Operating License*No. NPF-73 for the Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2, respectively, and Amendment No. 292 to Renewed Facility Operating License No. NPF-3 for the Davis-Besse Nuclear Power Station (DBNPS), Unit No. 1. The amendments are in response to your application dated November 19, 2015, as supplemented by letter dated March 22, 2016.

The amendments changed the BVPS and DBNPS Technical Specifications (TSs). Specifically, the proposed license amendment would revise TS 5.3.1, "Unit Staff Qualifications," by incorporating an exception to American National Standards Institute (ANSI) Standard N18.1-1971, "Selection and Training of Nuclear Power Plant Personnel." This would require licensed operators to comply with the requirements of 10 CFR Part 55, "Operators' Licenses," in lieu of the ANSI standard.

S. L. Belcher A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, Bhalchandra Vaidya, Project Manager Plant Licensing Branch, 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334, 50-412, and 50-346

Enclosures:

1. Amendment No. 297 to DPR-66

2. Amendment No. 185 to NPF-73

3. Amendment No. 292 to NPF-3

4. Safety Evaluation cc w/encls:

Mr. Brian D. Boles Mr. Marty L. Richey, Site Vice President Site Vice President FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station, Unit No. 1 Beaver Valley Power Station, Units 1 and 2 FirstEnergy Nuclear Operating Company Mail Stop A-BV-SEB1 Mail Stop A-DB-3080 P.O. Box 4, Route 168 5501 North State, Route 2 Shippingport, PA 15077 Oak Harbor, OH 43449-9760 Additional Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FIRSTENERGY NUCLEAR OPERATING COMPANY DOCKET NO. 50-334 BEAVER VALLEY POWER STATION, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 297 Renewed Facility Operating License No. DPR-66

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

A. The application for amendment by FirstEnergy Nuclear Operating Company (the licensee) dated November 19, 2015, as supplemented by letter dated March 22, 2016, 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, 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-66 is hereby amended to read as follows:

Enclosure 1

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 297, are hereby incorporated into this license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of the date of issuance.

FOR THE NUCL~A/ REGULATORY COMMISSION (j.,/11/i'\

G. Edward Miller, Acting Chief Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: June 7 , 2O1 6

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FIRSTENERGY NUCLEAR OPERATING COMPANY DOCKET NO. 50-412 BEAVER VALLEY POWER STATION, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 185 Renewed Facility Operating No. NPF-73

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

A. The application for amendment by FirstEnergy Nuclear Operating Company (the licensee) dated November 19, 2015, as supplemented by letter dated March 22, 2016, 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 1; 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. NPF-73 is hereby amended to read as follows:

Enclosure 2

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 185, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of the date of issuance.

FOR;H(UCLEJR REGULATORY COMMISSION c;;Dbl/"1 G. Edward Miller, Acting Chief Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: June 7, 2O1 6

ATTACHMENT TO LICENSE AMENDMENT NOS. 297 AND 185 RENEWED FACILITY OPERATING LICENSE NOS. DPR-66 AND NPF-73 DOCKET NOS. 50-334 AND 50-412 Replace the following pages of the Renewed Facility Operating License and Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment numbers and contain marginal lines indicating the areas of change.

Remove Insert License DPR-66 License DPR-66 Page 3 Page 3 License NPF-73 License NPF-73 Page 4 Page 4 TSs TSs 5.3-1 5.3-1

(3) FENOC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, 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) FENOC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, 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 calibration or associated with radioactive apparatus or components; (5) FENOC, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

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, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and 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 FENOC is authorized to operate the facility at a steady state reactor core power level of 2900 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 297 , are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Auxiliary River Water System (Deleted by Amendment No. 8)

Amendment No. 297 Beaver Valley Unit 1 Renewed Operating License OPR-66

(b) Further, the licensees are also required to notify the NRC in writing prior to any change in: (i) the term or conditions of any lease agreements executed as part of these transactions; (ii) the BVPS Operating Agreement, (iii) the existing property insurance coverage for BVPS Unit 2, and (iv) any action by a lessor or others that may have adverse effect on the safe operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations set forth in 10 CFR Chapter 1 and 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 FENOC is authorized to operate the facility at a steady state reactor core power level of 2900 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No.1ss and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto are hereby incorporated in the license. FENOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Amendment No. 185 Beaver Valley Unit 2 Renewed Operating License NPF-73

Unit Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit and radiation protection staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the following:

• The operations manager as specified in Specification 5.2.2.e,

• The radiation protection manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975, and

• The technical advisory engineering representative who shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design and response analysis of the plant for transients and accidents.

• The licensed operators who shall comply only with the requirements of 10 CFR 55.

5.3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of Specification 5.3.1, perform the functions described in 10 CFR 50.54(m).

Beaver Valley Units 1 and 2 5.3 - 1 Amendment Nos. 297/185

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FIRSTENERGY NUCLEAR OPERATING COMPANY DOCKET NO. 50-346 DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 292 Renewed Facility Operating No. NPF-3

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

A. The application for amendment by FirstEnergy Nuclear Operating Company (the licensee) dated November 19, 2015, as supplemented by letter dated March 22, 2016, 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, 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. NPF-3 is hereby amended to read as follows:

Enclosure 3

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 292, are hereby incorporated into this license. FENOC shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of the date of issuance.

FOR~HrUCLEAR REGULATORY COMMISSION c;}~.J4*~

G. Edward Miller, Acting Chief Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: June 7, 2O1 6

ATTACHMENT TO LICENSE AMENDMENT NO. 292 RENEWED FACILITY OPERATING LICENSE NO. NPF-3 DOCKET NO. 50-346 Replace the following pages of the Renewed Facility Operating License and Appendix A, Technical Specifications, with the attached pages. The revised pages are identified by amendment numbers and contain marginal lines indicating the areas of change.

Remove License NPF-3 License NPF-3 Page L-5 Page L-5 TSs TSs 5.3-1 5.3-1

2.C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and 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 FENOC is authorized to operate the facility at steady state reactor core power levels not in excess of 2817 megawatts (thermal). Prior to attaining the power level, Toledo Edison Company shall comply with the conditions identified in Paragraph (3) (o) below and complete the preoperational tests, startup tests and other items identified in Attachment 2 to this license in the sequence specified. Attachment 2 is an integral part of this renewed license.

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 292* are hereby incorporated in the renewed license.

FENOC shall operate the facility in accordance with the Technical Specifications.

(3) Additional Conditions The matters specified in the following conditions shall be completed to the satisfaction of the Commission within the stated time periods following the issuance of the renewed license or within the operational restrictions indicated. The removal of these conditions shall be made by an amendment to the renewed license supported by a favorable evaluation by the Commission:

(a) FENOC shall not operate the reactor in operational Modes 1 and 2 with less than three reactor coolant pumps in operation.

(b) Deleted per Amendment 6 (c) Deleted per Amendment 5 L-5 Renewed License No. NPF-3 Amendment No. 292

Unit Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the radiation protection manager, the operations manager, and licensed operators. The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975. The operations manager shall be qualified as required by Specification 5.2.2.e. The licensed operators shall comply only with the requirements of 10 CFR 55.

5.3.2 For the purpose of 10 CFR 55.4, a licensed Senior Operator and a licensed Operator are those individuals who, in addition to meeting the requirements of Specification 5.3.1, perform the functions described in 10 CFR 50.54(m).

Davis-Besse 5.3-1 Amendment No. 292

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 297 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-66, AMENDMENT NO. 185 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-73.

AMENDMENT NO. 292 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-3.

FIRSTENERGY NUCLEAR OPERATING COMPANY BEAVER VALLEY POWER STATION. UNIT NOS. 1 AND 2 DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 DOCKET NOS. 50-334, 50-412, AND 50-346

1.0 INTRODUCTION

By letter to the U.S. Nuclear Regulatory Commission (NRC or Commission) dated November 19, 2015, (Agencywide Documents Access and Management System (ADAMS Accession No. ML15323A138), as supplemented by letter dated March 22, 2016 (ADAMS Accession No. ML16082A144), FirstEnergy Nuclear Operating Company (the licensee) requested changes to the technical specifications {TSs), and Renewed Facility Operating Licenses for the Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2, and Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS).

Specifically, the proposed changes would revise the BVPS and DBNPS TS 5.3.1, "Unit Staff Qualifications, by incorporating an exception to American National Standards Institute (ANSI}

Standard N18.1-1971, "Selection and Training of Nuclear Power Plant Personnel." This change would require licensed operators to comply with the requirements of Title 1O of the Code of Federal Regulations (1 O CFR) Part 55, "Operators' Licenses," in lieu of the ANSI standard.

The supplement dated March 22, 2016, 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 as published in the Federal Register on January 19, 2016 (81 FR 2918).

2.0 REGULATORY EVALUATION

In March 1985, the NRC issued the Commission Policy Statement (50 FR 111467) on training and qualification of nuclear power plant personnel which endorsed the training accreditation process and the National Academy for Nuclear Training (NANT} guidelines. In Generic Letter 87-07, Enclosure 4

"Information Transmittal of Final Rulemaking for Revisions to Operator Licensing - 10 CFR 55 and Conforming Amendments," dated March 19, 1987, and in NUREG-1262, "Answers to Questions at Public Meetings Regarding Implementation of Title 10, Code of Federal Regulations, Part 55 on Operators' Licenses," published November 1987, the NRC indicated that it would accept a facility's licensed operator training program if the facility certified in writing that the program was accredited and based on a systems approach to training (SAT). This certification would supersede the requirements of ANSI N 18.1-1971, "Selection and Training of Nuclear Power Plant Personnel," and ANSl/ANS-3.1-1978, "Selection and Training of Nuclear Power Plant Personnel." Facility licensees were advised to submit a request to the NRC for an administrative change to their licensing documents to conform to their accredited program status.

In January 1992, the NRC published its proposed rule 10 CFR 50.120, "Training and Qualification of Nuclear Power Plant Personnel." The proposed rule stated that, if adopted, the rule would supersede the Commission's Policy Statement on training and qualification of nuclear power plant personnel and would not result in any change to accredited programs. The Commission concluded that accredited programs, implemented consistently with industry objectives and criteria, would be in compliance with this regulation.

In April 1993, the NRC published its final rule on training and qualification of nuclear power plant personnel. The rule requires nuclear power plant licensees to establish, implement, and maintain SAT-based programs for nine non-licensed operator positions. Accreditation of these nine training programs is an acceptable means of meeting the requirements of 10 CFR 50.120.

In January 2001, the NRC published Regulatory Issue Summary (RIS) 2001-01, "Eligibility of Operator License Applicants," to familiarize licensees with the NRC's current guidelines for the qualification and training of reactor operator and senior operator license applicants.

RIS 2001-01 indicates that 10 CFR 55.31 (a)(4) allows the NRC to accept an application for an operator's license if the facility certifies that the applicant has successfully completed a Commission-approved training program that is based on an SAT. In addition, RIS 2001-01 stated that: (1) a training program would be considered approved by the NRC when it receives or renews accreditation from the National Nuclear Accrediting Board (NNAB); (2) accreditation of operator training programs suggests that facilities are implementing the education and experience guidelines endorsed by the NNAB; (3) NANT guidelines for education and experience outline acceptable methods for implementing the Commission's regulations; and (4) the staff encourages all facility licensees to review their requirements and commitments related to licensed operator and senior operator education and experience and to update their documentation (e.g., Final Safety Analysis Report (FSAR), TSs, and training program descriptions) to enhance consistency and minimize confusion.

In addition, 10 CFR 50.36{c)(5), "Administrative controls," states that administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure the operation the facility in a safe manner. Each licensee shall submit any report to the Commission pursuant to approved technical specifications as specified in 10 CFR 50.4.

3.0 TECHNICAL EVALUATION

The licensee has proposed to revise TS 5.3.1 "Unit Staff Qualifications," to add licensed operators to the list of staff excepted from the qualifications described in ANSI N18.1-1971.

In lieu of the ANSI standard for licensed operators, the operators will be exclusively required to comply with 10 CFR Part 55.

The licensee stated in ~s letter dated November 19, 2015, that the licensed operator training programs are based on a SAT and are accredited by the NANT. The letter also indicates that the respective FSARs have been updated accordingly. This change meets the 10 CFR 55.31 (a)(4) requirements because the licensee has certified that the applicant has successfully completed a Commission-approved training program that is based on SAT.

The NRC staff reviewed the licensee's request for compliance with the requirements in 10 CFR Part 55. The NRC staff may accept an application for an operator's license if the facility licensee certifies that the applicant has successfully completed a Commission-approved training program that is based on an SAT, in lieu of providing details of the applicant's education and experience as indicated in 10 CFR 55.31 (a)(4) and in accordance with RIS 2001-01, "Eligibility of Operator License Applicants." The licensee's revision is consistent with 10 CFR Part 55 and therefore, does not adversely affect nuclear safety or plant operations. Therefore, the staff concludes that the proposed changes to TS 5.3.1 are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Pennsylvania and Ohio State officials were notified of the proposed issuance of the amendment. The State officials had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments relate to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

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) 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 Contributor: B. Green, NRR/APHB Date of issuance: June 7, 2o1 6

ML16040A084

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NAME BVaidya SRohrer SWeerakkody SS loan AKlein DATE 6/6/16 6/6/16 1/13/16, 3/30/16 3/31/16 4/5/16 OFFICE OGG (NLO) DORULPL3-2/BC(A) DORULPL3-2/PM NAME MRing EMiller BVaidya DATE 4/8/16 6nl16 6/7/16