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| {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Christopher Costanzo Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093 October 9, 2013 | | {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 9, 2013 Mr. Christopher Costanzo Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093 |
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| ==SUBJECT:== | | ==SUBJECT:== |
| NINE MILE POINT NUCLEAR STATION, UNIT NO. 1 -SECOND ROUND OF REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR ADOPTION OF NFPA 805 (TAC NO. ME8899) | | NINE MILE POINT NUCLEAR STATION, UNIT NO. 1 -SECOND ROUND OF REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR ADOPTION OF NFPA 805 (TAC NO. ME8899) |
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| ==Dear Mr. Costanzo:== | | ==Dear Mr. Costanzo:== |
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| By letter dated June 11, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12170A868), Nine Mile Point Nuclear Station, Unit 1 (NMP1) submitted a license amendment request (LAR) for adoption of a new risk-informed performance-based (RI-PB) fire protection licensing basis which complies with the requirements in Title 10 of the Code of Federal Regulations (1 0 CFR) 50.48(a) and 10 CFR 50.48(c); | | By letter dated June 11, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12170A868), Nine Mile Point Nuclear Station, Unit 1 (NMP1) submitted a license amendment request (LAR) for adoption of a new risk-informed performance-based (RI-PB) fire protection licensing basis which complies with the requirements in Title 10 of the Code of Federal Regulations (1 0 CFR) 50.48(a) and 10 CFR 50.48(c); the guidance in Regulatory Guide (RG) 1.205, "Risk-Informed Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants," Revision 1, and National Fire Protection Association 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition. This LAR also follows the guidance in Nuclear Energy Institute (NEI) 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)," Revision 2. |
| the guidance in Regulatory Guide (RG) 1.205, "Risk-Informed Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants," Revision 1, and National Fire Protection Association 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition. This LAR also follows the guidance in Nuclear Energy Institute (NEI) 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)," Revision 2. By letters dated February 27, 2013, March 27, 2013, and April 30, 2013 (ADAMS Accession Nos. ML13064A466, ML13092A139, and ML131270405, respectively), the licensee submitted its responses to the U.S. Nuclear Regulatory Commission's (NRC) RAis dated January 3, 2013 (ADAMS Accession No. ML12361A050). | | By letters dated February 27, 2013, March 27, 2013, and April 30, 2013 (ADAMS Accession Nos. ML13064A466, ML13092A139, and ML131270405, respectively), the licensee submitted its responses to the U.S. Nuclear Regulatory Commission's (NRC) RAis dated January 3, 2013 (ADAMS Accession No. ML12361A050). |
| The NRC staff has reviewed the information provided by NMP1 in the above mentioned letters and has determined that additional information is needed to complete its review. Enclosed is the NRC staff's second round of request for additional information (RAI). Clarification conference calls were held between the NRC staff and the licensee on October 7, 8, and 9, 2013, and it was agreed that the response times for the RAis would be as follows: (a) ForRAI, Fire Protection Engineering RAI-11: December9, 2013 (b) For RAI, Safe Shutdown (SSD) RAI 08.01, January 22, 2014, Please note that review efforts on this task are being continued and additional RAis may be forthcoming. | | The NRC staff has reviewed the information provided by NMP1 in the above mentioned letters and has determined that additional information is needed to complete its review. |
| C. Costanzo Please contact me at (301) 415-3308, if you have any questions. | | Enclosed is the NRC staff's second round of request for additional information (RAI). |
| Docket No. 50-220 | | Clarification conference calls were held between the NRC staff and the licensee on October 7, 8, and 9, 2013, and it was agreed that the response times for the RAis would be as follows: |
| | (a) ForRAI, Fire Protection Engineering RAI-11: December9, 2013 (b) For RAI, Safe Shutdown (SSD) RAI 08.01, January 22, 2014, Please note that review efforts on this task are being continued and additional RAis may be forthcoming. |
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| | C. Costanzo Please contact me at (301) 415-3308, if you have any questions. |
| | Sincerely, |
| | ~--~- g J "- |
| | ............-;. ,. |
| | Bhalchandra Vaidya, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-220 |
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| ==Enclosure:== | | ==Enclosure:== |
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| As stated cc w/encl: Distribution via Listserv Sincerely, J g ............-;. | | As stated cc w/encl: Distribution via Listserv |
| ,. Bhalchandra Vaidya, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS NINE MILE POINT NUCLEAR STATION. UNIT 1 DOCKET NUMBER 50-220 (TAC NO. ME8889) Fire Protection Engineering RAI 11 The compliance statement for License Amendment Request (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12170A869)
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| Table B-1, Element 3.4.1(c), "On-Site Fire-Fighting Capability" is "Complies". | | REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS NINE MILE POINT NUCLEAR STATION. UNIT 1 DOCKET NUMBER 50-220 (TAC NO. ME8889) |
| The associated compliance bases states "This training program also ensures that the Brigade leader and at least two members have sufficient training and knowledge of plant safety-related systems to understand the effects of fire and fire suppression on safe shutdown capability." Describe how the requirements of National Fire Protection Association Standard 805 (NFPA 805), "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants", 2001 Edition, Section 3.4.1 (c), are met, namely "the brigade leader and at least two brigade members shall have sufficient training and knowledge of nuclear safety systems to understand the effects of fire and fire suppressants on nuclear safety performance criteria". | | Fire Protection Engineering RAI 11 The compliance statement for License Amendment Request (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12170A869) Table B-1, Element 3.4.1(c), |
| An approach acceptable to the staff for meeting this training and knowledge requirement is provided in Regulatory Guide 1.189, "Fire Protection for Operating Nuclear Power Plants," Revision 2, (ADAMS Accession No. ML092580550) | | "On-Site Fire-Fighting Capability" is "Complies". The associated compliance bases states "This training program also ensures that the Brigade leader and at least two members have sufficient training and knowledge of plant safety-related systems to understand the effects of fire and fire suppression on safe shutdown capability." |
| Section 1.6.4.1, Qualifications: "The brigade leader and at least two brigade members should have sufficient training in or knowledge of plant systems to understand the effects of fire and fire suppressants on safe-shutdown capability. | | Describe how the requirements of National Fire Protection Association Standard 805 (NFPA 805), "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants", 2001 Edition, Section 3.4.1 (c), are met, namely "the brigade leader and at least two brigade members shall have sufficient training and knowledge of nuclear safety systems to understand the effects of fire and fire suppressants on nuclear safety performance criteria". |
| The brigade leader should be competent to assess the potential safety consequences of a fire and advise control room personnel. | | An approach acceptable to the staff for meeting this training and knowledge requirement is provided in Regulatory Guide 1.189, "Fire Protection for Operating Nuclear Power Plants," |
| Such competence by the brigade leader may be evidenced by possession of an operator's license or equivalent knowledge of plant systems." Enclosure Safe Shutdown (SSD) RAI 08.01 In a letter dated February 27, 2013 (ADAMS Accession No. ML13064A466), the licensee responded to SSD RAI 08 and stated that the risk of loss of power of safe shutdown loads as a result of a lack of electrical coordination was low. NFPA 805 Section 2.4.2.2.2, Other Required Circuits, Subpart (a) Common Power Supply requires that: "Those circuits whose fire-induced failure could cause the loss of a power supply required to achieve the nuclear safety performance criteria shall be identified. | | Revision 2, (ADAMS Accession No. ML092580550) Section 1.6.4.1, Qualifications: |
| This situation could occur if the upstream protection device (i.e., breaker or fuse) is not properly coordinated with the downstream protection device." Based on the licensee's response to SSD RAI 8 the staff noted that there may be situations where load circuit breakers (motor control center (MCC) 161A feeder breaker, MCC 176 feeder breaker, MCC 167 feeder breaker, MCC 171A feeder breaker, and MCC 1671 feeder breaker) are not electrically coordinated with the associated cross tie circuit breakers (R1 042 or R1 052). Two case studies were performed. | | "The brigade leader and at least two brigade members should have sufficient training in or knowledge of plant systems to understand the effects of fire and fire suppressants on safe-shutdown capability. The brigade leader should be competent to assess the potential safety consequences of a fire and advise control room personnel. Such competence by the brigade leader may be evidenced by possession of an operator's license or equivalent knowledge of plant systems." |
| The licensee stated that the first case study "SA" used a conservative approach and all uncoordinated breaker impacts from the Breaker Coordination Study were used in the Fire PRA model. In the second case study "8B", the tie breakers were modeled as coordinated and the remaining uncoordinated breakers were left uncoordinated. | | Enclosure |
| The case studies were used to determine the increase in risk due to the lack of electrical coordination between the load breakers and the tie breakers. | | |
| The licensee stated that, the results of the sensitivity analysis show that the remaining uncoordinated breakers are low risk. The failure to provide electrical coordination between the emergency supply circuit breaker and the cross tie circuit breaker does not meet the requirements for common power supply, requiring this condition to be considered a Variance from Deterministic Requirement. | | Safe Shutdown (SSD) RAI 08.01 In a letter dated February 27, 2013 (ADAMS Accession No. ML13064A466), the licensee responded to SSD RAI 08 and stated that the risk of loss of power of safe shutdown loads as a result of a lack of electrical coordination was low. NFPA 805 Section 2.4.2.2.2, Other Required Circuits, Subpart (a) Common Power Supply requires that: |
| Provide the risk increase as a result of failure to coordinate these circuit breakers and report the revised value of the delta risk for each fire area (and to the total fire delta risk) where fire-induced damage could cause the loss of the common power supply. | | "Those circuits whose fire-induced failure could cause the loss of a power supply required to achieve the nuclear safety performance criteria shall be identified. This situation could occur if the upstream protection device (i.e., breaker or fuse) is not properly coordinated with the downstream protection device." |
| C. Costanzo Please contact me at (301) 415-3308, if you have any questions. | | Based on the licensee's response to SSD RAI 8 the staff noted that there may be situations where load circuit breakers (motor control center (MCC) 161A feeder breaker, MCC 176 feeder breaker, MCC 167 feeder breaker, MCC 171A feeder breaker, and MCC 1671 feeder breaker) are not electrically coordinated with the associated cross tie circuit breakers (R1 042 or R1 052). |
| Docket No. 50-220 | | Two case studies were performed. The licensee stated that the first case study "SA" used a conservative approach and all uncoordinated breaker impacts from the Breaker Coordination Study were used in the Fire PRA model. In the second case study "8B", the tie breakers were modeled as coordinated and the remaining uncoordinated breakers were left uncoordinated. |
| | The case studies were used to determine the increase in risk due to the lack of electrical coordination between the load breakers and the tie breakers. The licensee stated that, the results of the sensitivity analysis show that the remaining uncoordinated breakers are low risk. |
| | The failure to provide electrical coordination between the emergency supply circuit breaker and the cross tie circuit breaker does not meet the requirements for common power supply, requiring this condition to be considered a Variance from Deterministic Requirement. Provide the risk increase as a result of failure to coordinate these circuit breakers and report the revised value of the delta risk for each fire area (and to the total fire delta risk) where fire-induced damage could cause the loss of the common power supply. |
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| | C. Costanzo Please contact me at (301) 415-3308, if you have any questions. |
| | Sincerely, Ira/ |
| | Bhalchandra Vaidya, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-220 |
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| ==Enclosure:== | | ==Enclosure:== |
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| RAI Sincerely, Ira/ Bhalchandra Vaidya, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation cc w/encl: Distribution via Listserv DISTRIBUTION: | | RAI cc w/encl: Distribution via Listserv DISTRIBUTION: |
| PUBLIC RidsNRRLAKGoldstein | | PUBLIC LPL 1-1 RIF RidsNRRPMNineMilePoint RidsNRRLAKGoldstein RidsNrrDoriDpr RidsRgn1 MaiiCenter RidsNrrDirsltsb RidsAcrsAcnw_MaiiCTR DSchroeder, Rl RidsNrrDraApla RidsN rrDraAfpb RidsNrrDssStsb RidsNrrDraAhpb L. Fields, NRR/AFPB J. Hyslop, NRR/APLA C. Candace, NRR/AHPB J. Robinson, NRR/AFPB H. Khadijah, NRR/STSB S. Wall, NRR/DORL/LPL3-1 RidsDoriLpl1-1 ADAMS Accession Number.: ML13281A010 *For AFPB NRR!DRA/AFPB/BC OFFICE LPL 1-1/PM LPL 1-1/LA 'Lead Reviewer)(2 LPLI-1/BC LPLI-1/PM NAME BVaidya KGoldstein AKiein/JRobinson RBeall BVaidya DATE 10/09/13 10/08/13 10/09/13 10/09/13 10/09/13 OFFICIAL RECORD COPY}} |
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| RidsNrrDirsltsb Rl RidsNrrDraApla RidsNrrDraAhpb C. Candace, NRR/AHPB S. Wall, NRR/DORL/LPL3-1 LPL 1-1 RIF RidsNrrDoriDpr RidsAcrsAcnw_MaiiCTR RidsN rrDraAfpb L. Fields, NRR/AFPB J. Robinson, NRR/AFPB RidsDoriLpl1-1 RidsNRRPMNineMilePoint RidsRgn1 MaiiCenter DSchroeder, RidsNrrDssStsb J. Hyslop, NRR/APLA H. Khadijah, NRR/STSB ADAMS Accession Number.: ML13281A010
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| *For AFPB NRR!DRA/AFPB/BC OFFICE LPL 1-1/PM LPL 1-1/LA 'Lead Reviewer)(2 LPLI-1/BC LPLI-1/PM NAME BVaidya KGoldstein AKiein/JRobinson RBeall BVaidya DATE 10/09/13 10/08/13 10/09/13 10/09/13 10/09/13 OFFICIAL RECORD COPY}} | |
Letter Sequence RAI |
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MONTHYEARML12170A8692012-06-30030 June 2012
Transition to 10 CFR 50.48(c) - NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition
Project stage: Request
ML12221A0152012-08-0808 August 2012
Issuance of Amendments License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants.
Project stage: Approval
ML12222A0292012-08-0909 August 2012
Correction to Acceptance Letter - Nine Mile Point Nuclear Station, Unit No. 1 - License Amendment Request Pursuant to 10CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generat
Project stage: Acceptance Review
ML12319A2632012-11-13013 November 2012
ME8899 Draft RAIs License Amendment Request to Adopt NFPA-805
Project stage: Draft RAI
ML13064A4662013-02-27027 February 2013
License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) - Response to NRC RAI
Project stage: Response to RAI
ML13092A1392013-03-27027 March 2013
Response to NRC Request for Additional Information on License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants
Project stage: Response to RAI
ML13127A3952013-04-30030 April 2013
License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) - Response to NRC Rai. Part 1 of 3
Project stage: Response to RAI
ML13127A3972013-04-30030 April 2013
License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) - Response to NRC Rai. Part 2 of 3
Project stage: Response to RAI
ML13127A3982013-04-30030 April 2013
License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) - Response to NRC Rai. Part 3 of 3
Project stage: Response to RAI
ML13282A6292013-10-0909 October 2013
ME8899, Second Round of Request for Additional Information (Rais) License Amendment Request (LAR) to Adopt NFPA-805
Project stage: RAI
ML13281A0102013-10-0909 October 2013
Second Round of Request for Additional Information Regarding License Amendment Request for Adoption of NFPA 805
Project stage: RAI
ML13347B1872013-12-0909 December 2013
License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) - Response to Nrc......
Project stage: Request
ML14024A4162014-01-22022 January 2014
License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Ed.) - Response to NRC Request for Additional..
Project stage: Request
ML14030A3772014-02-12012 February 2014
Third Round of Request for Additional Information Regarding License Amendment Request for Adoption of NFPA 805
Project stage: RAI
ML14085A1612014-03-14014 March 2014
License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) - Response to NRC Request For..
Project stage: Request
ML14087A2742014-03-28028 March 2014
ISFSI, Nine Mile Point Units 1 & 2 and R. E. Ginna - Pending NRC Actions Requested by Constellation Energy Nuclear Group, LLC
Project stage: Request
ML14113A1752014-04-15015 April 2014
License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) - Response to NRC RAI
Project stage: Response to RAI
ML14132A1992014-05-0909 May 2014
License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) - Response to Nrc.
Project stage: Request
ML14149A3562014-05-23023 May 2014
License Amendment Request, Per 10CFR50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)-Supplemental Information Regarding Fire PRA Mode
Project stage: Supplement
ML14181B0862014-06-30030 June 2014
(NMP1), ME8899, Email from Licensee to Confirm the Change from Nine Mile Point Nuclear Station LLC, to Exelon Generation LAR to Adopt NFPA 805
Project stage: Other
ML14126A0032014-06-30030 June 2014
Issuance of Amendment Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance with 10 CFR 50.48(c)
Project stage: Approval
2013-04-30
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Category:Letter
MONTHYEARNMP1L3570, Supplemental Information Letter - Revision to the Technical Specifications Design Features Sections to Remove the Nine Mile 3 Nuclear Project, LLC, Designation2024-02-0101 February 2024
Supplemental Information Letter - Revision to the Technical Specifications Design Features Sections to Remove the Nine Mile 3 Nuclear Project, LLC, Designation
IR 05000220/20230042024-02-0101 February 2024
Integrated Inspection Report 05000220/2023004 and 05000410/2023004
NMP1L3569, CFR 50.46 Annual Report2024-01-26026 January 2024
CFR 50.46 Annual Report
ML24004A2122024-01-0808 January 2024
Senior Reactor and Reactor Operator Initial License Examinations
ML23354A0012024-01-0404 January 2024
Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0059 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting))
ML23278A1292023-12-14014 December 2023
Units 1 & 2; Limerick, Units 1 & 2; Nine Mile Point, Units 1 & 2; and Peach Bottom, Units 2 & 3 -Revision to Approved Alternatives to Use Boiling Water Reactor Vessel and Internals Project Guidelines
NMP1L3566, Radiological Emergency Plan Document Revision. Includes EP-AA-1013, Revision 10, Radiological Emergency Plan Annex for Nine Mile Point Station2023-12-14014 December 2023
Radiological Emergency Plan Document Revision. Includes EP-AA-1013, Revision 10, Radiological Emergency Plan Annex for Nine Mile Point Station
IR 05000410/20243012023-12-14014 December 2023
Initial Operator Licensing Examination Report 05000410/2024301
ML23305A1402023-12-13013 December 2023
Units 1 & 2; Nine Mile Point, Unit 2; Peach Bottom, Units 2 & 3; and Quad Cities, Units 1 and 2 - Issuance of Amendments to Adopt Traveler TSTF-580
NMP1L3564, Supplemental Response to Part 73 Exemption Request - Withdrawal of Request for Exemption from 10 CFR 73, Subpart B, Preemption Authority Requirements2023-12-0707 December 2023
Supplemental Response to Part 73 Exemption Request - Withdrawal of Request for Exemption from 10 CFR 73, Subpart B, Preemption Authority Requirements
ML23291A4642023-12-0707 December 2023
Issuance of Amendment No. 251 Regarding the Adoption of Title 10 the Code of Federal Regulations Section 50.69, Risk-Informed Categorization and Treatment of SSC for Nuclear Power Plants
ML23289A0122023-12-0606 December 2023
Issuance of Amendment No. 250 Regarding the Revision to Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b
NMP1L3563, Submittal of Relief Request I5R-12, Revision 0, Concerning the Installation of a Full Structural Weld Overlay on Reactor Pressure Vessel Recirculation Inlet Nozzle N2E Safe End-to-Nozzle Dissimilar Metal Weld (32-WD-208)2023-12-0404 December 2023
Submittal of Relief Request I5R-12, Revision 0, Concerning the Installation of a Full Structural Weld Overlay on Reactor Pressure Vessel Recirculation Inlet Nozzle N2E Safe End-to-Nozzle Dissimilar Metal Weld (32-WD-208)
IR 05000220/20234022023-11-28028 November 2023
Security Baseline Inspection Report 05000220/2023402 and 05000410/2023402
NMP1L3557, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-22022 November 2023
Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation
ML23317A1192023-11-10010 November 2023
Constellation Energy Generation, LLC - 2023 Annual Report - Guarantees of Payment of Deferred Premiums
IR 05000220/20234202023-11-0101 November 2023
Security Baseline Inspection Report 05000220/2023420 and 05000410/2023420
ML23305A0052023-11-0101 November 2023
Operator Licensing Examination Approval
IR 05000220/20230032023-10-25025 October 2023
Integrated Inspection Report 05000220/2023003 and 05000410/2023003
IR 05000220/20235012023-10-17017 October 2023
Emergency Preparedness Biennial Exercise Inspection Report 05000220/2023501 and 05000410/2023501
IR 05000220/20230112023-10-16016 October 2023
Comprehensive Engineering Team Inspection Report 05000220/2023011 and 05000410/2023011
RS-23-097, Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans2023-10-12012 October 2023
Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans
NMP1L3554, Submittal of Revision 28 to the Final Safety Analysis Report (Updated), Fire Protection Design Criteria Document, 10CFR50.59 Evaluation Summary Report, 10CFR54.37(b) Aging Management Review, and Technical Specifications with Revised Bases2023-10-0606 October 2023
Submittal of Revision 28 to the Final Safety Analysis Report (Updated), Fire Protection Design Criteria Document, 10CFR50.59 Evaluation Summary Report, 10CFR54.37(b) Aging Management Review, and Technical Specifications with Revised Bases C
IR 05000220/20233032023-09-20020 September 2023
Retake Operator Licensing Examination Report 05000220/2023303
ML23250A0822023-09-19019 September 2023
Regulatory Audit Summary Regarding LARs to Adopt TSTF-505, Rev. 2, and 10 CFR 50.69
ML23257A1732023-09-14014 September 2023
Requalification Program Inspection
IR 05000220/20230052023-08-31031 August 2023
Updated Inspection Plan for Nine Mile Point Nuclear Station, Units 1 and 2 (Report 05000220/2023005 and 05000410/2023005)
RS-23-080, Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs2023-08-30030 August 2023
Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs
NMP2L2851, Relief Request Associated with Successive Inspections for Generic Letter 88-01 / BWRVIP-75-A Augmented Examinations2023-08-25025 August 2023
Relief Request Associated with Successive Inspections for Generic Letter 88-01 / BWRVIP-75-A Augmented Examinations
ML23151A3472023-08-21021 August 2023
Issuance of Amendments to Adopt TSTF-295-A, Modify Note 2 to Actions of PAM Table to Allow Separate Condition Entry for Each Penetration
NMP1L3534, License Amendment Request - Revision to the Technical Specifications Design Features Sections to Remove the Nine Mile 3 Nuclear Project, LLC, Designation2023-08-18018 August 2023
License Amendment Request - Revision to the Technical Specifications Design Features Sections to Remove the Nine Mile 3 Nuclear Project, LLC, Designation
ML23220A0262023-08-0808 August 2023
Licensed Operator Positive Fitness-for-Duty Test
IR 05000220/20234012023-08-0808 August 2023
Cyber Security Inspection Report 05000220/2023401 and 05000410/2023401 (Cover Letter Only)
NMP1L3545, Supplemental Information Letter to Adopt TSTF-505, Provide Risk- Informed Extended Completion Times - RITSTF Initiative 4b, Revision 2 and 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems .2023-08-0404 August 2023
Supplemental Information Letter to Adopt TSTF-505, Provide Risk- Informed Extended Completion Times - RITSTF Initiative 4b, Revision 2 and 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems .
RS-23-087, Revision to Approved Alternatives Associated with the Use of the BWRVIP Guidelines in Lieu of Specific ASME Code Requirements on Reactor2023-08-0404 August 2023
Revision to Approved Alternatives Associated with the Use of the BWRVIP Guidelines in Lieu of Specific ASME Code Requirements on Reactor
IR 05000220/20230022023-08-0101 August 2023
Integrated Inspection Report 05000220/2023002 and 05000410/2023002
ML23207A0762023-07-14014 July 2023
EN 56557 - Update to Part 21 Report Re Potential Defect with Trane External Auto/Stop Emergency Stop Relay Card Pn: XI2650728-06
NMP1L3544, Fifth Inservice Inspection Interval, First Inservice Inspection Period 2023 Owner'S Activity Report for RFO-27 Inservice Examinations2023-07-14014 July 2023
Fifth Inservice Inspection Interval, First Inservice Inspection Period 2023 Owner'S Activity Report for RFO-27 Inservice Examinations
ML23186A1642023-07-0606 July 2023
Operator Licensing Retake Examination Approval
NMP2L2846, Nine Mire Point Nuclear Station, Units 1 and 2, General License 30-day Cask Registration Notifications2023-07-0505 July 2023
Nine Mire Point Nuclear Station, Units 1 and 2, General License 30-day Cask Registration Notifications
ML23192A0622023-06-30030 June 2023
Engine Systems, Inc., 10CFR21 Reporting of Defects and Non-Compliance, Report No. 10CFR21-0136, Rev. 0
IR 05000220/20230102023-06-29029 June 2023
Biennial Problem Identification and Resolution Inspection Report 05000220/2023010 and 05000410/2023010
ML23131A4242023-06-23023 June 2023
Issuance of Amendment No. 249 Regarding the Revision to Technical Specification 3.3.1 to Adopt Technical Specifications Task Force Traveler TSTF-568
RS-23-077, Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-06-16016 June 2023
Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations
NMP1L3539, Day Commitment Response - Relief Request I5R-11 Concerning the Installation of a Weld Overlay on Reactor Pressure Vessel Recirculation Inlet Nozzle N2E Safe End-to-Nozzle Dissimilar Metal Weld (32-WD-208)2023-06-0909 June 2023
Day Commitment Response - Relief Request I5R-11 Concerning the Installation of a Weld Overlay on Reactor Pressure Vessel Recirculation Inlet Nozzle N2E Safe End-to-Nozzle Dissimilar Metal Weld (32-WD-208)
ML23159A0052023-06-0505 June 2023
56557-EN 56557 - Paragon - Redlined
RS-23-042, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-05-25025 May 2023
Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling
IR 05000410/20233022023-05-15015 May 2023
Initial Operator Licensing Examination Report 05000410/2023302
2024-02-01
[Table view]
Category:Request for Additional Information (RAI)
MONTHYEARML23264A7992023-09-21021 September 2023
NRR E-mail Capture - Final RAI - Constellation Energy Generation, LLC Fleet Request License Amendment Request to Adopt TSTF-580, Revision 1
ML23205A2432023-07-19019 July 2023
NRC Staff Follow-up Question on Audit Question 18 TSTF-505 and 50.69 Regulatory Audit (E-mail Dated 7/19/2023) (EPIDs L-2022-LLA-0185 and L-2022-LLA-0186)
ML23087A2912023-03-28028 March 2023
Request for Additional Information (3/28/2023 E-mail) - Proposed Emergent I5R-11 Alternative Associated with a Weld Overlay on RPV Recirculation Nozzle N2E DM Weld
ML23061A0522023-03-0202 March 2023
Request for Additional Information (3/2/2023 E-mail) - Proposed Alternative Associated with a Weld Overlay Repair to the Torus
ML23012A2002023-01-13013 January 2023
Information Request for the Cyber Security Baseline Inspection, Notification to Perform Inspection 05000220/2023401 and 05000410/2023401
ML22207A2162022-07-26026 July 2022
Information Request to Support Triennial Baseline Design-Basis Capability of Power-Operated Valves Inspection; Inspection Report 05000220/2022010 and 05000410/2022010
ML22194A9412022-07-13013 July 2022
Request for Additional Information Relief Request CS-PR-02 (7/13/2022 e-mail)
ML22041B5362022-02-10010 February 2022
NRR E-mail Capture - Constellation Energy Generation, LLC - Request for Additional Information Regarding Fleet License Amendment Request to Adopt TSTF-541
ML22020A0642022-01-13013 January 2022
NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Proposed Fleet Alternative for Repair of Water Level Instrumentation Partial Penetration Nozzles
ML21320A3472021-11-16016 November 2021
Request for Additional Information LAR to Revise TSs to Adopt TSTF-582, Revision 0
ML21306A3312021-11-0202 November 2021
Request for Additional Information Alternative Request GV-RR-10 (11/2/2021 e-mail)
ML21256A1902021-09-10010 September 2021
NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application
ML21144A2132021-05-24024 May 2021
NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application
ML21117A0342021-05-0505 May 2021
Request for Additional Information Regarding Proposed Alternative to Use ASME Code Case N-893
ML21125A1282021-05-0404 May 2021
OPC Document Request - Feb 2021
ML21110A5112021-04-20020 April 2021
Request for Additional Information Review of License Amendment Request to Revise Technical Specifications to Adopt TSTF-582
ML21088A2682021-03-30030 March 2021
Notification of Conduct of a Fire Protection Team Inspection
ML21062A0652021-03-0101 March 2021
NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Proposed Fleet Alternative to Documentation Requirements for Pressure Retaining Bolting
ML21049A2572021-02-18018 February 2021
Request for Additional Information Byron/Dresden Proposed Changes to Site Emergency Plans to Support Post-Shutdown and Permanently Defueled Conditions (EPID-2020-LLA-0240 & EPID-2020-LLA-0237)
ML20365A0092020-12-30030 December 2020
Request for Additional Information Concerning Review of License Amendment Request and Relief Request to Change Excess Flow Check Valve Testing Frequency (EPIDs L-2020-LLA-0188 and L-2020-LLR-0114)
ML20358A2602020-12-28028 December 2020
Changes to Draft Request for Additional Information Regarding License Amendment Request and Relief Request to Change Excess Flow Check Valve Testing Frequency
ML20272A2802020-09-28028 September 2020
Withdrawal and Replacement of Request for Additional Information to Support Review of License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times
ML20248H5192020-09-28028 September 2020
Changes to Draft Request for Additional Information Regarding Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times
ML20246G6362020-09-0202 September 2020
Request for Additonal Information to Support Review of License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times
NMP2L2739, Request for Additional Information for Nine Mile Point Nuclear Station, Unit 2, to Adopt TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, Revision 22020-08-28028 August 2020
Request for Additional Information for Nine Mile Point Nuclear Station, Unit 2, to Adopt TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, Revision 2
ML20239A7982020-08-25025 August 2020
NRR E-mail Capture - Exelon Generation Company, LLC - Fleet License Amendment Request to Adopt TSTF-568, Revision 2
ML20212L8702020-07-30030 July 2020
Request for Additonal Information Review of License Amendment Requests Regarding Riskinformed Categorization and Treatment of Structures, Systems and Components (L-2019-LLA-0290)
ML20213A9352020-07-30030 July 2020
Request for Additional Information Review of License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times
ML20153A7042020-06-0101 June 2020
NRR E-mail Capture - Preliminary RAI for Fleet Request to Use Alternative OMN-26
ML20135H1972020-05-14014 May 2020
NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Request to Extend Safety Relief Valve Test Interval
ML20045E3582020-02-14014 February 2020
Draft Request for Additional Information Regarding License Amendment Request to Increase Allowable MSIV Leakage Rates
ML19296A1862019-10-23023 October 2019
Request for Additional Information Regarding License Amendment Request to Increase Allowable MSIV Leakage Rates (L-2019-LLA-0115)
ML19275H1362019-10-0202 October 2019
NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Request to Use ASME Code Case N-879
ML19179A0612019-07-19019 July 2019
Three Mile Point 1 - Supplemental Information Needed to Proposed Alternative to Use ASME Code Case N-879
ML19151A8132019-05-31031 May 2019
Licensed Operator Positive Fitness-For-Duty Test
ML19025A1572019-01-25025 January 2019
Request for Additional Information Regarding Primary Containment Oxygen Concentration License Amendment Request
ML19025A1202019-01-24024 January 2019
NRR E-mail Capture - Calvert Cliffs, Fitzpatrick, and Nine Mile Point - Request for Additional Information Regarding License Amendment Request to Revise Emergency Response Organization Staffing
ML18341A2212018-12-0707 December 2018
Request for Additional Information Regarding Emergency Tech Spec Change Re HPCS Completion Time (EPID -L-2018-LLA-0491)
ML18228A6932018-08-15015 August 2018
Request for Additional Information Regarding Reactor Pressure Vessel Water Inventory Control License Amendment Request (L-2017-LLA-0426)
ML18205A3922018-07-24024 July 2018
Request for Additional Information Regarding Reactor Pressure Vessel Water Inventory Control License Amendment Request (L-2017-LLA-0426)
ML18184A2882018-07-0303 July 2018
Request for Additional Information Regarding Removal of Boraflex Credit from Spent Fuel Pool License Amendment Request(L-2018-LLA-0039)
ML18102A2372018-04-12012 April 2018
NRR E-mail Capture - Calvert Cliffs, Ginna, and Nine Mile Point - Request for Additional Information Regarding License Amendment Request to Revise Emergency Action Level Schemes (EPID-L-2017-LLA-0237)
ML17331B1342017-12-12012 December 2017
2, and R.E. Ginna Nuclear Power Plant - Request for Additional Information - Regarding
ML17285B1962017-10-27027 October 2017
Request for Additional Information Regarding Generic Letter 2016-01, Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools.
ML17272A0112017-10-10010 October 2017
Request for Additional Information Regarding License Amendment Concerning Reactor Pressure Vessel Water Inventory Control
ML17234A3592017-08-30030 August 2017
Request for Additional Information Regarding Relief Request NMP-RR-001 to Utilize Code Case N-702
ML17241A2752017-08-29029 August 2017
Request for Additional Information Response MSA (MF7946,7) and FE (MG0087,8) E-mail Attachment
ML17240A3102017-08-15015 August 2017
NRR E-mail Capture - Nine Mile Point MSA and FE RAI
ML17172A0842017-06-27027 June 2017
Request for Additional Information Regarding Relief Request to Utilize ASME Code Case N-702
ML17065A1622017-03-14014 March 2017
Request for Additional Information Regarding Proposed Alternative to Perform Pressure Isolation Valve Leakage Testing at Frequencies Consistent with 10 CFR Part 50, Appendix J
2023-09-21
[Table view] |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 9, 2013 Mr. Christopher Costanzo Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093
SUBJECT:
NINE MILE POINT NUCLEAR STATION, UNIT NO. 1 -SECOND ROUND OF REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR ADOPTION OF NFPA 805 (TAC NO. ME8899)
Dear Mr. Costanzo:
By letter dated June 11, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12170A868), Nine Mile Point Nuclear Station, Unit 1 (NMP1) submitted a license amendment request (LAR) for adoption of a new risk-informed performance-based (RI-PB) fire protection licensing basis which complies with the requirements in Title 10 of the Code of Federal Regulations (1 0 CFR) 50.48(a) and 10 CFR 50.48(c); the guidance in Regulatory Guide (RG) 1.205, "Risk-Informed Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants," Revision 1, and National Fire Protection Association 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition. This LAR also follows the guidance in Nuclear Energy Institute (NEI) 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)," Revision 2.
By letters dated February 27, 2013, March 27, 2013, and April 30, 2013 (ADAMS Accession Nos. ML13064A466, ML13092A139, and ML131270405, respectively), the licensee submitted its responses to the U.S. Nuclear Regulatory Commission's (NRC) RAis dated January 3, 2013 (ADAMS Accession No. ML12361A050).
The NRC staff has reviewed the information provided by NMP1 in the above mentioned letters and has determined that additional information is needed to complete its review.
Enclosed is the NRC staff's second round of request for additional information (RAI).
Clarification conference calls were held between the NRC staff and the licensee on October 7, 8, and 9, 2013, and it was agreed that the response times for the RAis would be as follows:
(a) ForRAI, Fire Protection Engineering RAI-11: December9, 2013 (b) For RAI, Safe Shutdown (SSD) RAI 08.01, January 22, 2014, Please note that review efforts on this task are being continued and additional RAis may be forthcoming.
C. Costanzo Please contact me at (301) 415-3308, if you have any questions.
Sincerely,
~--~- g J "-
............-;. ,.
Bhalchandra Vaidya, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-220
Enclosure:
As stated cc w/encl: Distribution via Listserv
REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS NINE MILE POINT NUCLEAR STATION. UNIT 1 DOCKET NUMBER 50-220 (TAC NO. ME8889)
Fire Protection Engineering RAI 11 The compliance statement for License Amendment Request (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12170A869) Table B-1, Element 3.4.1(c),
"On-Site Fire-Fighting Capability" is "Complies". The associated compliance bases states "This training program also ensures that the Brigade leader and at least two members have sufficient training and knowledge of plant safety-related systems to understand the effects of fire and fire suppression on safe shutdown capability."
Describe how the requirements of National Fire Protection Association Standard 805 (NFPA 805), "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants", 2001 Edition, Section 3.4.1 (c), are met, namely "the brigade leader and at least two brigade members shall have sufficient training and knowledge of nuclear safety systems to understand the effects of fire and fire suppressants on nuclear safety performance criteria".
An approach acceptable to the staff for meeting this training and knowledge requirement is provided in Regulatory Guide 1.189, "Fire Protection for Operating Nuclear Power Plants,"
Revision 2, (ADAMS Accession No. ML092580550) Section 1.6.4.1, Qualifications:
"The brigade leader and at least two brigade members should have sufficient training in or knowledge of plant systems to understand the effects of fire and fire suppressants on safe-shutdown capability. The brigade leader should be competent to assess the potential safety consequences of a fire and advise control room personnel. Such competence by the brigade leader may be evidenced by possession of an operator's license or equivalent knowledge of plant systems."
Enclosure
Safe Shutdown (SSD) RAI 08.01 In a letter dated February 27, 2013 (ADAMS Accession No. ML13064A466), the licensee responded to SSD RAI 08 and stated that the risk of loss of power of safe shutdown loads as a result of a lack of electrical coordination was low. NFPA 805 Section 2.4.2.2.2, Other Required Circuits, Subpart (a) Common Power Supply requires that:
"Those circuits whose fire-induced failure could cause the loss of a power supply required to achieve the nuclear safety performance criteria shall be identified. This situation could occur if the upstream protection device (i.e., breaker or fuse) is not properly coordinated with the downstream protection device."
Based on the licensee's response to SSD RAI 8 the staff noted that there may be situations where load circuit breakers (motor control center (MCC) 161A feeder breaker, MCC 176 feeder breaker, MCC 167 feeder breaker, MCC 171A feeder breaker, and MCC 1671 feeder breaker) are not electrically coordinated with the associated cross tie circuit breakers (R1 042 or R1 052).
Two case studies were performed. The licensee stated that the first case study "SA" used a conservative approach and all uncoordinated breaker impacts from the Breaker Coordination Study were used in the Fire PRA model. In the second case study "8B", the tie breakers were modeled as coordinated and the remaining uncoordinated breakers were left uncoordinated.
The case studies were used to determine the increase in risk due to the lack of electrical coordination between the load breakers and the tie breakers. The licensee stated that, the results of the sensitivity analysis show that the remaining uncoordinated breakers are low risk.
The failure to provide electrical coordination between the emergency supply circuit breaker and the cross tie circuit breaker does not meet the requirements for common power supply, requiring this condition to be considered a Variance from Deterministic Requirement. Provide the risk increase as a result of failure to coordinate these circuit breakers and report the revised value of the delta risk for each fire area (and to the total fire delta risk) where fire-induced damage could cause the loss of the common power supply.
C. Costanzo Please contact me at (301) 415-3308, if you have any questions.
Sincerely, Ira/
Bhalchandra Vaidya, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-220
Enclosure:
RAI cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC LPL 1-1 RIF RidsNRRPMNineMilePoint RidsNRRLAKGoldstein RidsNrrDoriDpr RidsRgn1 MaiiCenter RidsNrrDirsltsb RidsAcrsAcnw_MaiiCTR DSchroeder, Rl RidsNrrDraApla RidsN rrDraAfpb RidsNrrDssStsb RidsNrrDraAhpb L. Fields, NRR/AFPB J. Hyslop, NRR/APLA C. Candace, NRR/AHPB J. Robinson, NRR/AFPB H. Khadijah, NRR/STSB S. Wall, NRR/DORL/LPL3-1 RidsDoriLpl1-1 ADAMS Accession Number.: ML13281A010 *For AFPB NRR!DRA/AFPB/BC OFFICE LPL 1-1/PM LPL 1-1/LA 'Lead Reviewer)(2 LPLI-1/BC LPLI-1/PM NAME BVaidya KGoldstein AKiein/JRobinson RBeall BVaidya DATE 10/09/13 10/08/13 10/09/13 10/09/13 10/09/13 OFFICIAL RECORD COPY
