ML20141L718
| ML20141L718 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/14/2020 |
| From: | NRC/OCIO |
| To: | |
| Shared Package | |
| ML20141L707 | List: |
| References | |
| FOIA, NRC-2019-000279 | |
| Download: ML20141L718 (31) | |
Text
From: Pedersen, Renee To: Borchardt. BUI: Weber Michael: Johnson Michael: Satonus Mark* Mltcbell, Reggie Cc: Leeds. Erle: H!oweu. Art: z;mmeanan. Roy: Vble, Jeooiter: Bergman. Thomas; campbeu. Andy: Evans Michele:
OKeefe. Nen* Rutledge. steven: Trent Wertz CJreot Wertz@nrc gov}: Solorio Pave: Sewen. Margaret
Subject:
Notification of New DPO on Dlablo Canyon seismic Issues (DP0-2013-002)
Date: Wednesday. July 31, 2013 5:41:00 PM In accordance with section (D)(3)(c) of the MD 10.159, Handbook, I am notifying you that I have received, screened, and accepted a new DPO in coordination with the Director, OE, for review under the DPO process.
The DPO (DP0-2013-002) raises concerns about a 2011 Pacific Gas and Electric (PG&E) report to the NRC that included a reevaluation of the local geology surrounding the Diablo Canyon Power Plant. In particular, the DPO focuses on whether adequate action was taken to address the new seismic information Into the current licensing basis and whether appropriate actions were taken to address operability.
The DPO raises concerns similar to those addressed in NCP-2012-001 .
We will soon be forwarding this DPO to Eric Leeds, NRR, OD for appropriate disposition Ing.
Please feel free to contact me or Marge Sewell if you have any questions about this DPO or other DPO-related issues.
Renee Pedersen Senior Differing Views Program Manager (301) 415-2742 Renee.Pedersen@nrc.gov Marge Sewell Safety Culture Specialist (301) 415 -8045 Marge.Sewell@orc gov
From: Pedersen, Renee To: Peck Michael Cc: Sewen. Margaret Bex:: SoJorjo. Pave subJect Acceptance of DPO (DP0-2013-002)
Date: Wednesday, July 31, 2013 6:06:00 PM
- Michael, In accordance with the procedures included in MD 10.159. we have received, screened, and accepted your DPO in coordination with the Director, OE. for review under the DPO process.
Your DPO has been assigned the tracking number DP0-2013-002.
We will soon be forwarding this DPO to Eric Leeds, NRR, OD for appropriate dispositioning. We will contact you when the DPO Panel has been established.
Your differing view Is welcomed and valued and will be appropriately considered . An important aspect of our internal safety culture is respect. As such, all employees involved in the process are Instructed to exercise discretion and treat this matter sensitively.
Documents will be distributed on an as-need basis during the evaluation. In an effort to preserve your privacy and keep the focus on the issues, employees are instructed to slmply refer to you as the DPO submitter. It Is appropriate for you to discuss the details of the DPO with other NRC employees as part of the evaluation, however, as with other predecisional processes, you should not discuss details of the DPO outside the agency. A summary of the disposition of the DPO will be Included in the Commission's Weekly Information Report (posted on the public web site) when the process is complete and will include a link to the DPO Case File (with redactions, as warranted) if you request that the case file be public.
Finally, retaliation for engaging in the DPO process Is not tolerated. In the event you believe that you have been harassed. intimidated, or retaliated against for engaging in the DPO process, please contact me as soon as possible.
Thank you for pursuing your concern and engaging In the DPO process. A free and open discussion of differing views is essential to the development of sound regulatory policy and decisions.
Please feel free to contact me or Marge Sewell if you have any questions or concerns about your DPO or DPO-related Issues.
Renee Pedersen Senior Differing Views Program Manager (301) 415-2742 Renee.Pedersen@nrc gov Marge Sewell Safety Culture Specialist (301) 415-8045 Marge.Sewell@nrc.gov
Dan Dorman Approval - ACTION Need Approval for Public Release of DPO Case File.txt Fr,om: Dorman, Dan Sent: Tuesday, September 09, 2014 3:35 PM To: Pedersen, Renee Cc: Wertz, Trent; Uhle, Jennifer; Evans, Michele; Case, Michael; Markley, Michael; Holahan, Patricia; Solorio, Dave; Sewell, Margaret
Subject:
Re: ACTION: Need Approval for Public Release of DPO Case File
- Renee, I approve release of the DPO Case File as discussed below.
Thanks Dan From : Pedersen, Renee Sent: Tuesday, September 09, 2014 02:53 PM To: Dorman, Dan Cc: Wertz, Trent; Uhle, Jennifer; Evans, Michele; Case, Michael; Markley, Michael; Holahan, Patricia; Solorio, Dave; Sewell, Margaret
Subject:
ACTION: Need Approval for Public Release of DPO Case File
- Dan, The EDO has issued his decision and the employee has asked that the DPO Case File be made available to the public.
We have previously communicated with your staff and they indicated that they did not see the need for any redactions in the DPO Case File.
In accordance with the guidance in MD 10.159, you are responsible for ensuring that information is appropriately released to the public.
Therefore, please confirm that you support public release of the complete DPO Case File.
If you have any questions, please let us know.
We are hoping to get this declared as a public OAR ASAP so it will be available to the public by tomorrow.
Renee Page 1
On July XX, 2014, the Executive Director for Operations (EDO) issued a decision on an appeal to a May 29, 2014, Differing Professional Opinion (DPO) Decision made by the Director, Office of Nuclear Reactor regulation (NRR). The appeal was related to an NRC employee who submitted a DPO, dated July 19, 2013, concerning seismic issues at the Diablo Canyon Nuclear Power Plant (DCNPP). The original DPO contended that there is less than adequate corrective actions to Incorporate the new seismic information into the current licensing basis and that the licensee has failed to demonstrate that the plant technical specification required structures, systems, and components (SSCs) are operable On receipt of the DPO appeal, the EDO reviewed relevant documents, met with the DPO Panel, conferred with the Office of General Counsel, and met with the DPO submitter. The technical concerns addressed the NRC decision not to issue a violation based on the inaccurate statements In the FENOC submittal. After careful review and deliberation the EDO concluded that the actions taken by staff in response to the DPO are adequate. The EDO agreed with the DPO Panel decision that based on the staffs prior understanding of the factual backdrop which attended FENOC's submittal that no additional 10 CFR 50.9 violation occurred. Additionally, the EDO verified that the Panel's recommendation, to release the initial correspondence from FENOC's general counsel addressing FENOC's submittal publically, was carried out. As such, the EDO found there was no need to reopen the DPO on the "Davis Besse Reply to a Notice o Violation." The EDO also recognized the efforts of the submitter in raising the issues and concerns, and the contribution of the employee in ensuring the agency's safety goal~ are achieved.
DP0-2013-002: Diablo Canyon Seismic Issues DPO Case File -ADAMS ML14252A743 (Public)
DPO Appeal Decision On September 9, 2014, the Executive Director for Operations (EDO) issued a decision on the appeal of DPO 2013-002, concerning seismic issues at the Diablo Canyon Nuclear Power Plant (DCNPP). The EDO's decision on the appeal supported both the DPO panel's independent technical conclusions and subsequent Office of Nuclear Reactor Regulation (NRR) Director's decision that there was not a significant or immediate concern with seismic safety at DCPP, and that the licensee and staff had followed appropriate processes for technical specification operability of plant equipment and Title 10 Code of Federal Regulations 50.59 evaluations with a reasonable technical and safety rationale. The EDO noted that the DPO raised awareness of the complexity of the DCNPP seismic licensing basis, but also illustrated the need for the agency to ensure there are clear guidelines for staff and licensees regarding how changes in natural hazards should be evaluated for all licensees. The public records for this DPO are available in the DPO case file package in ADAMS ML14252A743.
Questions, comments?
Telephone (301) 415-2741 E-mail: DPOPM.Resource@ nrc.gov
The purpose of this memorandum is to inform you of my considerations and conclusions regarding the appeal you submitted on June 23, 2014, on the subject Differing Professional Opinion (DPO).
BACKGROUND Your DPO is rooted in the Dlablo Canyon Power Plant (DCPP) seismic licensing history and how the licensing basis is applied to the plant today. The-In 1968, when the DCPP Unit 1 Construction Permit was issued, the seismic evaluation had been completed under the Atomic Energy Commission's requirements. Based on the Information available at the time, the design earthquake (DE) was defined as having a peak ground acceleration of 0.2 g, and the double design earthquake (DOE) was a doubling of the DE earthquake to ensure safety-related structures, systems, and components would function as expected after the earthquake, 0.4 g.
In 1973, the DCPP iicensee, Pacific Gas and Electric (PG&E), became aware of the Hosgri eon-11111 [PR1]: Shol.Cd 1h11 be 'applk;alt' beceuae they fault. PG&E evaluated the Hosgri fault using Regulatory Guide 1.61 , ' Damping Values for dktl't ljlll lhe ~ UOUI 1984?
Seismic Design of Nuclear Power Plants* October 1973. Though not included in the construction application, NRC reviewed the liGeflsee'.sapplicant's evaluation the Hosgri fault and required PG&E to make plant modifications to be able to withstand the 0.75 g peak ground acceleration associated with the Hosgri fault. The operating license for Unit 1, issued In 1984, was based on review of the Updated Final Safety Analysis Report which included two different seismic methodologies, the ODE and the Hosgri evaluation. Given expected advances in the science of seismic evaluation, the license was also conditioned to require a confirmatory seismic study over the first 1O years of operation, referred to as the Long Term Seismic Program. C - -
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In November 2008, PG&E reported identification of a new offshore fault, subsequently identified as the Shoreline fault zone. The initial evaluation in Event Report No. 44675 indicated that the ' C - - - . . [M3]1 For tom* prior OPO's the rnponH letter has also Included
- b<1ef d11CU&soon of relMed non-newly identified fault was *smaller than the Hosgri fault, which is the current bounding seismic concuirences from the filer I have not tnduded tile related Howe-. n feature for DCPP.' In January 2011 , PG&E submitted the ' Report on the Analysis of the non-11111 were flied on 111i. 111ue you would lll<e ,t added for completentll, I can prepare ,
Shoreline Fault Zone, Central Coast California" (Agencywide Documents Access and addtbonal paragraphs 10 d,SQM the 2011 and lhen 2012 non*
Management System (ADAMS) Accession Number MU 10140431) which documented their 1 investigation of the Shoreline fault zone and its relations hip to other seismic sources in proximity to the DCPP. In September 2012, the NRC issued Research Information Letter 12-01, "Confirmatory Analysis of Seismic Hazard at the Oiablo Canyon Power Plant from the Shoreline Fault Zone" (ADAMS Accession No. ML121230035). The conclusion of the review from the executive summary is excerpted below:
"In this review of the hazard from the Shoreline fault, the NRC compared the resulting deterministic seismic ground motions to loading levels for which the plant has been previously reviewed, specifically the Hosgri Earthquake (HE) ground motion response spectrum as described In NUREG-0675, *safety Evaluation Report Related to the Operation of Diablo Canyon Power Plant, Units 1 and 2,"Supplement No. 7 (NRC, 1978),
and the LTSP ground motion response spectrum as detailed in NUREG-0675, Supplement No. 34 (NRC, 1991 ). The results indicate that deterministic seismic-loading levels predicted for all the Shoreline fault earthquake scenarios developed and analyzed by the NRC are at, or below, those levels for the HE ground motion and the LTSP ground motion. The HE ground motion and the LTSP ground motion are those for which the plant was evaluated previously and demonstrated to have reasonable assurance of safety.'
Beginning in 2010, as thEl__se_oior resident inspector for DiablQ...Canyon -you raisedl concerns with your Region IV management regardirlg the adequacy of PG&E's evaluation of the c-tlld [PR4): Ct1lci< '0/1111 Region IV tor acwracy He mey have _._ VO!CinQ c:oncem, Mr11*
I
Shoreline fault zone. In July 12..201.3, you submitted this DPO documenting your concerns. ; C - - ' [PRS): Th,, 11 wt.. you may w<<1I to IOCIUCltJ The statement of concerns from your DPO is summarized as follows: lhr:rt dtaQMion of put. NCPs IO help 11111 the floly thllt Im employee has been ,.....ng , _ and we hew been
- 1. The NRC did not enforce the Diablo Canyon Technical Specifications with respect to this follawlng our pn:,oeutt IO lldd<Ha his laauea. Be <*ef\JI on seismic issue, because the new seismic information showed that required structures, J chllnlcleN:allon - lhe prevklus NCPs mtrf be Nlla1ed, systems and components could be exposed to greater vibratory motion than previously l bolnotexact,- 1nD!(> _ .__ _ _ _ - -*
considered for the safe shutdown earthquake.
- 2. PG&E's operability evaluation following the development of the new seismic information was inadequate, because the new seismic information was not compared correctly to the plant's licensing basis.
- 3. The NRC failed to enforce 10 CFR 50.59 requirements that PG&E obtain an amendment to their license, because the new seismic information showed that more than a minimal increase would occur in the likelihood of malfunction of structures, systems and components Important to safety.
- 4. The NRC failed to adequately address the Los Osos and San Luis Bay faults, which could produce ground motions in excess of the safe shutdown earthquake ground motion.
The DPO Ad Hoc Review Panel was established on September 3, 2013. The Ad Hoc Review Panel met with you on October 23, 2013, and then periodically throughout their review to further discuss your concerns. The Ad Hoc Review Panel focused their review on the agreed to statement of concerns, as summarized above. The panels' conclusions are summarized for each concern:
- 1. The panel noted that your DPO was instrumental in identifying the complexity of the range of conditions considered in the DCPP Updated Final Safety Analysis Report seismic evaluation. However, the panel concluded that given appropriate comparisons, the potential ground motions from the Shoreline fault zone do not exceed the levels of acceleration considered in the design and licensing of DCPP for required structures, systems and components.
- 2. The panel noted that this concern Is based upon your conclusion that there is only one appropriate evaluation method for new seismic information, specifically to substitute the new seismic information into the oniginal DOE method. The panel concluded that the licensee's evaluation method was acceptable given that the Updated Final Safety Analysis Report identifies both the DOE and the Hosgri evaluation.
- 3. The panel concluded that an amendment to the license was not required because the Shoreline fault zone ground motions do not exceed the levels evaluated in the DCPP design and licensing. Therefore, there is no potential violation of the 10 CFR 50.59 requirements.
- 4. The panel agreed with you that the NRC staff did not clearly and explicitly consider the potential ground motions from the Los Osos and San Luis Bay fault. However, the panel noted that both the Los Osos and San Luis Bay faults had previously been evaluated in the Long Term Seismic Program. Additionally, these faults were evaluated* from a risk perspective by NRG staff in Research Information Letter 12-01. The panel concluded that the Los Osos, San Luis Bay, and the Shoreline faults do not exceed the level of ground motion already considered in the design and licensing of DCPP.
On May 29, 2014, the Director, Office of Nuclear Reactor Regulation, provided ~ with his decision on yourtl.&-DPO-eeeisi&n. The Office Director agreed with the Ad Hoc Review Panel's report with respect to your specific technical concerns. However, he noted that your DPO highlighted the need for the agency to further consider how new information on natural hazards should be considered In the regulatory process and his expectation that the work currently
underway on the Fukushima Near Term Task Force Recommendations 2.1 and 2.2, would address this issue.
On June 23, 2014, you filed a DPO appeal. In the appeal, you noted your agreement with the Panel's conclusion that issues raised In the DPO do not result In a significant or immediate
.(c - - 1 [PR6]: OK. dmeforcandd!Mdbaek lf1twas IM, I'd be 1N1lraled that you n 191 llng 1M whit I agreed wllh l
sa.fety concern. You also state agreement that the potential ground motions from the Shoreline n1ther than captUnt10 the 2 111U81 I dearly idaOll1leCI II lhe I fault zone do not exceed the levels considered during licensing of the plant. However, you have l'Nton for Ille appeal that auppolt my * - 1h11 Iha panel l9POl1 hid ,neumaenc dellll to MJPPOrt kl c:onclu11011. I'm not auggesling lhet you don't lndude the "it'e NIie" measege, JUSt I
very narrowly defined the licensing basis and approved methodology for seismic evaluation as be mlr'd\JI or tdenbfy,ng Illa ,uues This ha1 been* repealed 1 being limited to the methodology associated with the DOE from the original license application. fruttrallOn by the employee lnclOde Ille eVllutitlon or his I Based on your exclusion of the Hosgri evaluation from the licensing basis, your appeal reiterates your belief that a license amendment is required to revise the DOE evaluation to the
- Issues In the next section higher ground motions associated with the new seismic information. Additionally, you recommend the agency initiate enforcement ~ f o r the failure to take appropriate actions to address the new seismic information associated with the Shoreline fault zone.
EXECUTIVE DIRECTOR FOR OPERATIONS REVIEW AND DECISION When I received your appeal, I initiated an extensive review of the available information related ~ [N7]: Ttl<S p.-. ls faotly ltenderd bolterpate to DPO 2013-002. I reviewed many documents including, but not limited to, the DPO you f1'om pno( appeal re,pon&el. I originally submitted, the Ad Hoc Review Panel's report dated April 3, 2014, the Office Director's ..?OIIIIIWlllld [PU]: Editoolll oomment-11 you lnchJde one ]
decision regarding your DPO, ane-your appeal of the Office Director's decision,.jlnd the Office I dale, include.~ Ill _
Director's statement of views on the contended issues in your DPO appeal . To understand the issues fully, I met with members of the Ad Hoc Review Panel on July 28, 2014, a111d I met with you on July 30, 2014. My review was focused on th_e agreed ..\!QQ_QJssues thaJ_y_o~u_r:aised in
,:our DPO submittal.limileQ..to-th~~- c : - - . t [Pill]: The Clffllllt worcllng may Nied ott.. lO
- beloew that t h e ~ raieec:I other IHues to the EOO, lI
, euch ** the posslblli1y of retalolltlon 1would like to commend you on a package that was well.researched, and insightful. Based on my review. discussion with the Ad Hoc Review Panel, and our interview, I agree that there is no significant or immediate safety concern associated with the issue you have raised. However, c - . . . 1 (PIUO]: Once again, lt'I OK to ~ t the ]
you have highlighted the complexity of the Diabio Canyon licensing basis as documented in the 'N's sata* mell8ge, but dealiy a111culatle lhe ratoonlle for the !
OUICOme of hi* , -. The muts of OU( targeted IUl\l6V Updated Final Safety Analysis Report, which is a direct result of how the licensing basis was ondi<:Med thlt 33~ Of tut>mittn cldn't thW'ok the rabOlllla for I augmented during the original licensing process, between issuance of the construction permit in _OPO deoloona °"re d68lly ltated, _.1 1968 and issuance of the operating licensing In 1984. While I appreciate your concern with the clarity of the Updated Final Safety Analysis Report, I am unable to arrive at the same conclusion whereby you exclude the Hosgri evaluation from the licensing basis.
Nevertheless, your questioning attitude and perseverance were key to ensuring the licensee and staff fully evaluated the Implications of the Shoreline fault zone. In addition to raising awareness of the complexity of the DCPP seismic licensing basis, you have illustrated the need for the agency to ensure there are clear guidelines for staff and licensees regarding how changes in natural hazards should be evaluated. This awareness is particularly timely and important as we move forward with the Fukushima Near Term Task Force Recommendations. r c - - . i [NU]: Are Ihm Broy potentllt addltloNil actlone that need to be c:ooslde<ed for NRR'* foll<t*H"'?
I want to thank you for bringing your concerns to my attention. Your DPO was well thought out ' c:--s (M12J: This pam,. fllr1y 1tandlld bode1prete and researched. As you know, our agency relies on its staff members to raise concerns from pnor appeal f"'P"f'IMI.
regarding decisions so that they can be properly considered. Your perseverance in raising these concerns demonstrates your dedication to safety that is the foundation of the agency's excellent staff, and I applaud your efforts in this regard. I take concerns such as the ones you raised very seriously, and hope that my interactions with you have shown my complete and thorough review of your concerns in making my decision.
Extension Approval 5-30 STARS OEDO ACS ~otification (OED0-14-00211-NRR).txt From: ADAMS p8_icm_service Sent: Friday, May 09, 2014 2:11 PM To: ICM-STARS-OEDO-ACS@nrc.gov; Pedersen, Renee; Sewell, Margaret; Foster, Jack
Subject:
STARS OEDO ACS Notification (OED0-14-00211-NRR)
A new OEDO Ticket has been assigned to you by Brock, Kathryn (kmb3) _on 05/09/2014.
Last User Comment has been added to a Ticket by Brock, Kathryn (kmb3) on 05/09/2014.
The comment was -
Extension approved per request. To Whom It May Concern, In accordance with Management Directive 10.159, Handbook (D)(5)(b), OPOs are expected to be completed within 120 days and the 120-day time frame may only be extended with the approval of the EDO through the OPOPM *f or offices that report to the EDO. The purpose of this email is to request an extension for DP0-2013 -002. In particular, please revise the current due date from April 30, 2014 to May 30, 2014. The schedule has been impacted by the complex nature of the issue, the need to gather information from the licensee, and competing schedule commitments. The DPO process affords employees an opportunity to have their views expressed to and considered by high level managers. Ensuring that managers have sufficient time to fully consider the issues is critical to the success of the process. We have reviewed the extension request and think that it is reasonable and consistent with the goals of the DPO Program. Thank you for your consideration of this request. Eric J . Leeds Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 301-415-1270 The Ticket information is below.
Ticket Info Activity Information Case Number OED0- 14-00211-NRR Page 1
Extension Approval 5-30 STARS OEDO ACS Notification (OED0-14-00211-NRR).txt Status Approved by DAO Activity Type Task EDO Due Date 04/30/2014 SECY Due Date Requested Due Date Assigned Offices NRR Routing Copies to OE EDO Point of Contact Pedersen, Renee (rmp) I Sewell, Margaret (mhsl) I Foster, Jack (jwf)
Other Parties Incoming ADAMS Accession ML13213A248 Date of Incoming 08/02/2013 Incoming ADAMS Package ML14087A354 Frequency Incoming Page 2
Extension Approval 5-30 STARS OEDO ACS Notification (OED0-14-00211-NRR).txt Inf ormation Originator Michael Peck Ori gi nator Organization Other NRC Offices - OCHCO Task DPO Addressee Name Peck MS Addressee Affiliation NRC/OCHCO Incoming Received Date 08/09/2013 Subject Differing Professional Opinion (DPO) Involving Diablo Canyon Seismic Issues (DP0-2013-002)
Description Process Information Special Instructions Type Special Instructions Please process DPO and associated actions in accordance with guidance included in ML13213A248. (1) Decision for DP0-2013-002 is due April 30, 2014 .and (2) Follow-up action memorandum and Weekly Information Report Summary is due two weeks after DPO decision.
Page 3
Extension Approval 5-30 STARS OEDO ACS Notification (OED0-14-00211- NRR).txt Near Term Comment Requested Action Type Memo Cross Reference Numbers DP0-2013-002 Signature Level Direct Reply - NRR OIG Recommend OEDO Concurrence OCM Concurrence OCA Concurrence Page 4
EDO Approval 30 STARS OEDO Office Notification OED0-14-00211-NRR.txt From: ADAMS p8_icm_service Sent: Friday, May 09, 2014 2:20 PM To: ICM_STARS_NRR; Pedersen, Renee; Sewell, Margaret; Foster, Jack
Subject:
STARS OEDO Office Notification (OED0-14-00211- NRR)
A new OEDO Ticket has been assigned to you by Jones(NRR), Latoya (ldj) on 05/09/2014.
Last User Comment has been added to a Ticket by Jones(NRR), Latoya (ldj) on 05/09/2014. The comment was -
OEDO approved an extension request to 05/30/14.
The Ticket information is below.
Ticket Info Activity Information Case Number OED0-14-00211-NRR Status Due Date Extended Activity Type Task EDO Due Date 05/30/2014 SECY Due Date Requested Due Date Assigned Offices NRR Routing Copies to OE EDO Point of Page 1
EDO Approval 30 STARS OEDO Office Notification OED0-14-00211-NRR.txt Contact Pedersen, Renee (rmp) I Sewell, Margaret {mhsl) I Foster, Jack (jwf)
Other Parties Incoming ADAMS Accession ML13213A248 Date of Incoming 08/02/2013 Incoming ADAMS Package ML14087A354 Frequency Incoming Information Originator Michael Peck Originator Organization Other NRC Offices - OCHCO Task DPO Addressee Name Peck MS Addressee Affiliation NRC/OCHCO Incoming Received Date 08/09/2013 Page 2
EDD Approval 30 STARS DEDO Office Notification OED0-14-00211-NRR.txt Subject Differing. Professional Opinion (DPO) Involving Diablo Canyon Seismic Issues (DP0-2013-002)
Description Process Information Special Instructions Type Special Jnstructions Please process DPO and associated actions in accordance with guidance included in ML13213A248 . (1) Decision for DP0-2013-002 is due April 30, 2014 and (2) Follow-up action memorandum and Weekly Information Report Summary is due two weeks after DPO decision.
Near Term Comment Requested Action Type Memo Cross Reference Numbers DP0- 2013-002 Signature Level Direct Reply - NRR DIG Recommend DEDO Concurrence Page 3
EDO Approval 30 STARS OEDO Office Notification OED0-14-00211-NRR.txt OCM Concurrence OCA Concurrence Page 4
RE QUESTION DP0-2013-00 ~ Extension Requested for Appeal Opportunity.txt From: DPOPM Resource Sent: Monday, June 02, 2014 11 : 25 AM To: Peck, Michael Cc: Pedersen, Renee; Solorio, Dave; Hilton, Nick; Sewell, Margaret
Subject:
RE: QUESTION: DP0-2013 Extension Requested for Appeal Opportunity
- Michael, Your request for an appeal extension has been granted and the deadline is now June 30, 2014.
If you have any additional questions, please feel free to contact us.
Thanks you.
From: Peck, Michael Sent: Friday, May 30, 2014 8:50 AM To: DPOPM Resource Cc: Pedersen, Renee; Solorio, Dave; Hilton, Nick; Sewell, Margaret
Subject:
QUESTION: DP0-2013 Extension Requested for Appeal Opportunity Ms. Pedersen, I received Mr. Leeds' DPO 2013-002 decision memo this morning. I understand that MD 10.159 provides 21 calendar days for me to appeal the decision May I have an extension to the appeal deadline until June 30, 2014?
I request the additional time to comprehensively address the highly complex issues involved in the OPO Panel Report and to compensate for my unavailability during the first two weeks in June due to official travel.
Thank you, Michael From: OPOPM Resource Sent: Thursday, May 29, 2014 5:56 PM To: Peck, Michael Cc: Pedersen, Renee; Solorio, Dave; Hilton, Nick; Sewell, Margaret
Subject:
DP0-2013 -002 - Diablo Canyon Seismic Issues - Opportunity to Appeal
- Michael, Page 1
RE QUESTION DP0-2013 Extension Requested for Appeal Opportunity.txt By now you should have received the DPO Decision dated May 29, 2014. In accordance with the guidance in MD 10.159, "The NRC Differing Professional Opinions Program," you have 21 calendar days from the date you received the DPO Decision to submit an appeal if you choose.
If you have questions about the appeal process or any other DPO-related questions or concerns, please feel free to contact us.
If you do not send an appeal by June 30 19, 2014, we will assume that you do not warnt to submit an appeal. At this point, the DPO process will be considered complete. When the DPO process is complete, we will contact you about whether you would like to request that. the DPO Case File be made public or remain non-public. The DPO Case File serves as a valuable KM tool. The DPO Case File will be posted on the internal Web site and the ADAMS accession number (if public) will be included in the summary of the case that is included in the Commission's Weekly Information Report (e.g.,
http://www.internal.nrc;gov/OE/dpo/dpo-2012-003.html).
As a reminder, we are still in a predecisional process and you should not release or discuss documents until the process is complete and records are reviewed in accordance with procedures for discretionary release.
Thank you for exercising your responsibility as an NRC employee and ensuring that agency decision-makers have all the information they need to make well-informed decisions that help us fulfill our regulatory mission. We understand that the DPO process can be an emotional journey and we appreciate your professionalism during the process.
Please feel free to call Renee Pedersen or Marge Sewell if you have any questions.
Renee Pedersen OE/CRB Senior Differing Views Program Manager 301-415-2742 Page 2
RE QUESTION DP0-2013 Extension Requested for Appeal Opportunity.txt Marge Sewell OE/CRB Safety Culture Specialist 301-415-8045 Page 3
Summary of Appeal of DPO 2013-002 Diablo Canyon Seismic Issues.txt From: Peck, Michael Sent: Monday, July 07, 2014 1:51 PM To: Pedersen, Renee
Subject:
Summary of Appeal of DPO 2013-002, Diablo Canyon Seismic Issues Summary of Appeal of DPO 2013-002, Diablo Canyon Seismic Issues Mr. Leeds endorsed (ref. 1) the following conclusions from the DPO Panel Report:
- The DPO issues did not represent a significant or immediate safety concern,
- The Diablo Canyon licensing seismic history is complex, and
- The potential ground motions from nearby faults would not exceed the levels of ground motion already considered during the design and licensing of the pant.
I am in full agreement with Mr. Leeds and the DPO Panel on all of these conclusions.
However, none of these points were raised as concerns in the DPO.
In contrasted, the DPO did address the following issues:
- The licensee failed to obtain an amendment to the operating license prior to adding the new seismic information to the FSAR. The new seismic information (ground motions) were beyond the boundary of the existing GDC 2 design bases and safety analysis.
The failure of the licensee to correct the non-conforming safety analysis was a violation of 10 CFR 50, Appendix B, and failure to obtain NRC approval prior to the FSAR update was a
violation of 10 CFR 50.59.
- The NRR PM provided direction to the licensee to directly place the new seismic information into the FSAR after the agency rejected the license amendment request.
As a result, the notice and hearing opportunity requirements per 10 CFR 50.91 were bypassed for this controversial change to the facility as described in the FSAR.
- The licensee omitted information from two of the three reanalyzed (and more limiting) earthquake faults.
- The licensee failed to adequately demonstrate operability for technical specification required structure, system and components for the new higher ground motions. Region Page 1
Summary of Appeal of DPO 2013-002 Diablo Canyon Seismic Issues.txt IV failed to initiate enforcement action following the licensing failure to meet technical specification requirements.
The DPO Panel Report redefined the Diablo Canyon design and licensing bases. This redefined design and licensing bases was different than described in the DPO and the facility FSAR. This redefined design and licensing bases was necessary to support the Panel's conclusions on the DPO issues. Prior to the DPO Panel Report, the facility seismic design and
- licensing based had not been in dispute. Both the DPO and DPO Appeal included actual pages from the FSAR to ensure a consistent understanding of the facility design and licensing bases. The Panel Report did not include the rationale or justification for using the redefined design and licensing based.
Consequence of the issued raised in the DPO:
- Bypassing the license amendment process subverted the required notice and herring opportunity for a controversial action.
- Several violations of NRC requirements continued to be uncorrected. Some of these violations are potential escalated traditional enforcement and potential greater than Green findings.
- The failure to correct noncompliance with NRC regulations undermines both agency credibility and public confidence that safety is maintained.
(Ref 1: Memorandum to MS Peck, Frpm EJ Leeds, DPO Involving Seismic Issues at the Diablo Canon, May 29, 2014)
Michael Peck, Ph.D.
Senior Reactor Technology Instructor TTC, 432-855-6515 Page 2
FW WIR input - EDO Decision on Diablo Canyon DPO Appeal.txt From: Pedersen, Renee Sent: Thursday, September 11, 2014 2:09 PM To: Sewell, Margaret Cc : Solorio, Dave
Subject:
FW: WIR input - EDO Decision on Diablo Canyon DPO Appeal
- Marge, Please use this summary and have the case placed on the DPO web site. You can also include the summary in the assessment appendix.
Thanks!
Renee From: Segala, John Sent: Thursday, September 11, 2014 1:46 PM To: Cianci, Sandra; Schumann, Stacy Cc: Pedersen, Renee; Sampson, Michele; Galloway, Melanie; Bowers, Anthony
Subject:
WIR input - EDO Decision on Diablo Canyon DPO Appeal Sandy/Stacy, Melanie has approved the following WIR input.
Per our discussion yesterday, please add it to the September 12th WIR.
Please let me know if you have any questions .
Thanks, John Office of the Executive Director for Operations (EDO)
Items of Interest EDO Decision on Differing Professional Opinion (DPO) 2013-002 Appeal: Diablo Canyon Seismic Issues (DPO 2013-002)
On September 9, 2014, the Executive Director for Operations (EDO) issued a decision on the appeal of DPO 2013-002, concerning seismic issues at the Diablo Canyon Nuclear Power Plant (DCNPP). The EDO's decision on the appeal supported both the DPO panel's independent technical conclusions and subsequent Office of Nuclear Reactor Regulation (NRR)
Director's decision that there was not a significant or immediate concern with seismic safety at DCPP, and Page 1
FW WIR input - EDO Decision on Diablo Canyon DPO Appeal.txt that the licensee and staff had followed appropriate processes for technical specification operability of plant equipment and Title 10 Code of Federal Regulations 50.59 evaluations with a reasonable technical and safety rationale. The EDO noted that the DPO raised awareness of the complexity of the DCNPP seismic licensing basis, but also illustrated the need for the agency to ensure there are clear guidelines for staff and licensees regarding how changes in natural hazards should be evaluated for all licensees. The public records for this DPO are available in the DPO case file package in ADAMS (ML14252A743).
Page 2
FW RES Follow Up From Diablo Canyon Seismic DPO Discussion.txt From: Pedersen, Renee Sent: Thursday, October 30, 2014 10:17 AM To : Holahan, Patricia Cc: Sosa, Belkys; Solorio, Dave; Sewell, Margaret
Subject:
FW: RES: Follow Up From Diablo Canyon Seismic DPO Discussion FYI...
From: Peck, Michael Sent: Thursday, October 30, 2014 9:37 AM To: Satorius, Mark Cc: Pedersen, Renee
Subject:
RES: Follow Up From Diablo canyon Seismic DPO Discussion Mr. Satorius, Thank you for rec~gnizing my contribution to the agency's Differing Professional Opinions (DPO) Program. I also appreciated the consolatory language used in your reply to my appeal and the opportunity to discuss the Diablo Canyon DPO issues with you in person .
During our meeting this past Friday and in late July, I understood you to say that the agency will focus forward rather than expending resources on past issues that have been corrected. After considering your feedback, I wanted to ensure that you understood that I view the issues identified in the DPO and Appeal as ongoing violations of NRC Rules and Diablo Canyon license requirements. I believe these uncorrected violations do have an impact on plant safety.
During 2013, Pacific Gas and Electric (PG&E) made changes to the Diablo Canyon FSARU. These changes were sufficient to lead the DPO Panel to conclude that the Hosgri Event was the/a facility safe s hutdown earthquake for the facility. Sin,ce these changes would require an amendment to the Operating License, and no amendment was approved by the ag,ency, PG&E's action represents an ongoing violation of 10 CFR 50.59 and should be promptly addressed in accordance with the NRC Enforcement Policy.
I realize enforcing the Diablo Canyon seismic design basis would result agency challenges. The moit obvious corrective action would include agency approval of the Hosgri as the facility safe shutdown earthquake. However, this proposed action was previously considered and rejected by agency technical staff. Without a safe s hutdown Page 1
FW RES Follow Up From Diablo Canyon Seismic DPO Discussion.txt earthquake methodology that is both acceptable to the staff and can accommodate the new higher seismic loading results in ongoing violation of NRC 10 CFR 50, Appendix B, quality assurance requirements and should be promptly addressed in accordance with the NRC Enforcement Policy.
PG&E's failure to adequately demonstrate operability of important to safety SSCs also remains as an ongoing issue. ASME,Section III, Code acceptance limits are exceeded when the new seismic loads are summed with the required load combinations using the NRC approved safe shutdown earthquake methodology (considering the new maximum capable ground motion). The NRC requires that licensee satisfy Code acceptance limits for operability of reactor coolant pressure boundary components. PG&E's failure to demonstrate that Code requirements were met was not addressed in either the DPO Panel Report or your DPO Appeal response letter. The failure to meet Code acceptance limits repres~nts an ongoing violation of 10 CFR 50.55a and the facility Technical Specifications and should be promptly addressed in accordance with the NRC Enforcement Policy.
I appreciated -the sunvnary of the Diablo Canyon seismic licensing bases included in your September 9, 2014 memorandum. This summary acknowledged the original design bases as presented in the Preliminary Safety Analysis Report, NRC review of the Hosgri Evaluation provided in Supplemental Safety Evaluation Report 7, a description of the NRC review of Long Term Seismic Program provided in Supplemental Safety Evaluation Report 34, and requested actions associated with Recommendation 2.1 from the Near-Term Task Force Review of the Fukushima Accident. While this information provides insight into the Diablo Canyon seismic licensing bases and may be used to support future NRC licensing actions, none of this information may be used by the licensee as a bases to change the facility safe shutdown earthquake methodology without prior NRC approval. 10 CFR 50.59 and agency endorsed guidance established the threshold for facility changes that require an amendment to Page 2
FW RES Follow Up From Diablo Canyon Seismic DPO Discussion.txt the Operating License. This threshold was based on the methodology described in the FSAR for meeting regulatory driven design bases requirements, such as General Design Criteria (GDC) 2 for protection against earthquakes. Prior to the 2013 changes, the Diablo Canyon FSARU clearly stated that the GDC 2 facility safe shutdown earthquake requirement was meet by the Double Design Earthquake safety analysis. The FSARU when on to explicitly state that the Hosgri Evaluation methodology did not satisfy NRC GDC 2 design bases requirements for the facility safe shutdown earthquake.
I would like to thank you again for your time and attention to the Diablo Canyon issues raised in DPO 2013-02. Please feel free to contact me if I can provide any additional information regarding ongoing compliance issues at Diablo Canyon.
Thank you, Michael Peck, Ph.D.
Senior Reactor Technology Instructor TTC, 423-855-6515 Page 3
e~ T 8 FFl81M: ~BE 8fl11Y SENSI I IVE IN I ER'4AL INFORMAi ION - NU I FOR PUBLIC RELEASE Non-concurrence and DPO Questions
[NOTE - this information is generally NON-PUBLIC, but is provided as background only)
NOTE: General FAQs on the DPO Program are included on the DPO Web site Clook under Employee Resources-Employee Concerns.
No. Michael Peck was not reassigned. He applied for an instructor position in his area of expertise at the NRC's technical training center In Chattanooga, TN, at about the time he submitted~ his non-coocurTence in accordance with the Non-Concurrence Process described in MD 10.158.1'>,JeR C0R81.1Ff8Rse Paper (NCP). He was competitively selected for this sought-after position, and reported to his new assignment in September 2012. Resident Inspector assignments are limited to 7 years to ensure objectivity. It Is common for resident inspectors to apply for their next job when a desirable position comes open.
- 2. When were the non-concurrences filed?
Two non-<:oncurrences were filed by the OCPP SRI.
1117/11. The DCPP SRI submitted NCP 2011-103, on inspection report 05000275; 323/201104.
1/26/12. The DCPP SRI submitted NCP 2012-01 , on Inspection report 05000275; 323/201105. -
- 3. What were the non-concurrences?
Both non-concurrences involve the same subject; regulatory actions in response to the discovery of the Shoreline Fault.
NCP 2011-103 was flied by the DCPP SRI on the basis that no violation was issued (as he had submitted in the draft report) related to operability evaluation of the Shoreline fault in Report 2011-04. NCP 2011-103 was disposltioned finalizing the violation In JR 2011-05 issued on 2/14/12. {The employee requested that the NCP be non-public.)
NCP 2012-01 was filed by the DCPP SRI because the SRI believed the violation in NRC IR 2011-05 should be for an Inadequate operablllty evaluation of the Shoreline Fault rather than not doing an operability evaluation until June 2012. The SRI believed the facility should be shutdown or the license amended to reflect the Shoreline fault. NCP 2012-01was discussed with NRC stakeholders representing NRR/DE, NRR/DORL, RIV, and RES. NCP 2012-01 was disposltloned as a multi-office staff position which concluded that a violation for having no operability evaluation from January 2011 to June 2011 existed because the licensee completed the RIS 2005-020 immediate (Interim) operability evaluation In June 2011. Additionally, the offices Involved In NCP 2012-01 acknowledged that a final operability evaluation could not be completed by the licensee until the NRC decided what requirements and methods should be applied to new seismic information. At the time of Inspection Report 2011-05 issuance It was expected that the requirements and methods would be addressed in a Llcens.e Amendment-Request that Page 44 BRlcF'f 8FFIQIAa I liliOMI Y 31!1.SIThl! llfTl!ltlflcL llfl"9 ..Mili"81f lf8T P'8" llttBLIB REl::EA8E
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- Wli&i Qtll.¥
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was under consideration. However, by 3Q/2012, enough progress had been made on RIL 2012-01 for NRR and RES to conclude that the LTSP method of analysis used in the immediate operability assessment was sufficient to evaluate the Shoreline fault and that the Shoreline Fault should be considered a lesser Included case of the Hosgri event.
{Il)~ employee supported public rfile_ase of the NCP ADAM§. ML121f.173.l
- 4. When was the DPO flied?
July 18, 2013. The former DCPP SRI filed Differing Professional Opinion (DPO) 2013-02 associated with the regulatory response following the discovery of the Shoreline Fault.
NRC employees are encouraged to file a DPO if they believe an agency decision is in error. The DPO process is In keeping with the agency's open and collaborative working environment.
- 5. What is the OPO?
DPO 2013-02 restated the issues presented in NCP 2012-01 and added a concern that a license amendment was needed incorporate the shoreline fault into Diablo Canyon's FSAR as described in the RIL 12-01 cover letter. The added concern was that the NRC did not review or take action on the Los Osos and San Luis Bay faults.
- 6. What is the status of the DPO?
The DPO is still being reviewed consistent with the NRC's process included in MD 10.159. In particular, a decision was issued by the Office Director for NRR on May 29, 2014. The employee appealed the decision to the EDO on June 23. 2014, and the _i§.S_l!.8 Is currently being evaluated by the EDO.OR A1,1g1,1&t 2, 2013, DPO 2013 g ~
assigRea ta ~IRR for re~ew. The DPO F'BRel was estalllishea eR SeJ;Jteml!er 3, 2013.
As part of the agency"s open and collaborative work environment. the NRC has established the DPO program as a means for employees to have their concerns reviewed by high level managers. The DPO Program is a formal process that allows all employees and contractors to have their differing views on established, mission-related issues considered by the highest level managers in their organizations, I.e., Office Directors and Regional Administrators. The process also provides managers with an independent, three-person review of the issue (one person chosen by the employee).
After a decision is issued to an employee, he or she may appeal the decision to the Executive Director for Operations (or the Chairman for those offices reporting to the Commission).
- 7. WIii the decision regarding the DPO be made public?
The _NRC supports openness and will include a summary of the disposition of the DPO In the Commission's Weekly Information Report included on the NRC Web site (see Commission Documents under the Document Collections in the NRC Ubrabyl. If the submitter supports public release. the DPO Case File (with appropriate redactions) will be included .. Maylle, The DPO J;Jreeess is dl66bl&sed iR MaRagemeRt Direstlve 10.159 (a 1nilllisally availallle llee1,1meAt). Meweo;er, the DPO presess fer a Page 45 e"M' err1e1J11t 1:1sl! e1*t, Slifl&ITIVE IIITERPfAl llfl'8ftMAJl811 ue, rel\ l'tl!t::le "l!Ll!MIE
BRKT 8FFl81AL l:IBE 8ULV 91!!1.91Th I! IP4'1!!ftltit.t U.1'911lMAl18H N8l F8R PYBlali Aii._iial::Hi epeellle review i& BR IRterRal, R8A p11elle l')Fooes&,- The QPO ,:,elltieAer~~
iAslYEliA9 IRe Fight le flFi\*asy e\*er aAy i&&Yes raised IA !Re flRleess. The QPO iietitieRer has a key rele iA Elet1m1iRiRg whether er Rel the QPO aAEI Qireeter's Elesi&ieR beseme aYailaele p11elisly.
No. Tl=le SRl's wereiRg iA ll=le QPO se11IEI ee *,iewed by same lo mean l=le was reassigneEI fellewiRg tl=le filing ef the A8R eene11R"eAsee agaiAsl l=lis will. As noted in Q&A
- 1 above, the SRI applied for and was selected to a highly sought Instructor poslUon at the NRC's Technical Training Center. The NRG does not tolerate retaliation for
- engaging In the NCP or the DPO Program and both MDs reiterate this policy and direct employees to resources in the event they believe that they have been retaliated against.
Page 46 PROFI Olilil~I'* W&ii 8tlllf Sl!!NSI IIOI!! lln71!!ftl.Jld... ll.1'911lMATl91. ,.e, 1'9fil. l't::119tle ftl!LEit.91!
SEt.81ll'JE lt.lERt*M. IHP'eptMit.fl81f lf8T P'8Pl ,~l!!ltre PlELE.tll91!
- 9. Tlmellne of Events associated with the NCPs and OPO:
11/7/11 [NON-PUBLIC) DCPP SRI submits Non-Concurrence NCP 2011-103.
The SRI non-concurs on Inspection Report 05000275; 323/2011004 because the proposed violation involving the Shoreline Fault operability evaluation was not issued.
11/9/11 [NON-PUBLIC] NCP 2011-103 is dispositioned by Region IV. The operability evaluation issue was documented as an Unresolved Item in Inspection Report 05000275; 323/2011002 and dlsposltloned as a violation in Inspection Report 05000275; 323/2011005.
40/2011 [NON-PUBLIC] The DCPP SRI continues to question the enforcement action associated with the Shoreline Fault operabUlty evaluaUon. Several meetings between multiple NRC offices are conducted to discuss the Shoreline Fault.
1/26/12 [NQN..PUBLIC ML121A17l] Q9~P. Sf.U ~~brT)lts. !'!,GP 2012-01, non- Com-ted [A2): Tho , ubm4ttal and 2/13/20012 ro,ponse are
[ included i'1 tho complete<! NCP Form for NCP-2012.001.
J concurring on Inspection report 05000275; 323/201105. The SRI believed the violation in NRC Report 2011-05 should be for an inadequate operability evaluaUon of the Shoreline Fault rather than not doing an operability evaluation until June 2012. The SRI believed the facility should be shutdown or the license amended to reflect the Shoreline fault.
Feb 2012 [NON-PUBLIC] DCPP SRI applies for Instructor position vacancy at the Technical Training Center (TTC).
02/12-07/13 [NON-PUBLIC] RIV management frequently encourages the DCPP SRI to submit a Differing Professional Opinion (DPO) during several discussions involving seismic issues.
May 2012 [NON-PUBLIC] DCPP SRI is selected for instructor position at the Technical Training Center (TIC).
Sept 2012 [NON-PUBLIC] The (now former) DCPP SRI reports to the TIC as a training instructor.
~~ 2012 [~ PUBLIC ML121A173)1 Response to NCP 2012-01 Issued.
NCP 2012-01 was discussed with NRG stakeholders representing NRR/DE, NRR/DORL, RIV, and RES. NCP 2012-01 was dlspositloned as a multi-office staff position which concluded that a violation for having no operability evaluation from January 2011 to June 2011 existed because the licensee completed the RIS 2005-020 immediate (Interim) operability evaluation in June 2011 . Additionally, the offices Involved In NCP 2012-01 acknowledged that a final operability evaluation could not be completed by the licensee until the NRC decided what requirements and methods should be applied to new seismic Information. At the time of Report 2011-05 Issuance it was expected that the requirements and methods would be addressed In a License Amendment Request that was under consideration. However, by 30/2012, enough progress had been made on RIL 2012-01 for NRR and RES to conclude that the LTSP Page 47 DRAF I a OFP'ISIM.. Y&i OHi.¥ 3 1!1491?1tl! 114Tl!PI.Ni111...114P'OfllllJIIJltTl014 lf8f f8Pl P'~l!!ILIS PlELE.IISE
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Sl!l'SITIVI! 114Tl!ftf4AL 114f8ftMATl814 tl8f F8R Pl:lilal; Mlilali:Mlli method of analysis used in the immediate operability assessment was sufficient to evaluate the Shoreline fault and that the Shoreline Fault should be considered a lesser included case of the Hosgri event.
7/18/13 [NON-PUBLIC) Former SRI submits a DPO regarding the agency's regu latory actions associated with the Shoreline Fault.
8/2/13 [NON-PUBLIC) DPO 2013-002 was assigned to NRR for an Independent review.
9/3/13 [NON-PUBLIC] Director, NRR establishes a DPO Ad Hoc Review Panel (DPO Panel} for DPO 2013-002 with three NRC staff members who have been independent of the initial concerns raised by the former DCPP SRI.
4/3/14 [NON-PUBLIC] DPO Panel completes its review of DPO 2013-002 and submits Its report to the Director, NRR.
5/29/14 [NON-PUBLIC] Director, NRR Issues his decision on DPO 2013-002 by memo to the former DCPP SRI.
2'23/~14.. Employee submi_ts ~PQ appea~
6127/2014 Director NRR provided ~ement of Views on contested Issues in fililllli 717/2014 DPO appeal package provided to EDO for disposition and decision.
8/25/14 Associated Press article released discussing the DPO.
Page 48 CfilOFT 8FFlelJll:I... USE ONLY 91!1491Tlil! 114Tl!ftl4M.. llff8ftMATl8H U8f F8R Pl:IBl:18 R61alii:t.ilii