ML13015A138: Difference between revisions

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=Text=
=Text=
{{#Wiki_filter:UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 February 25, 2013 LICENSEE:
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 25, 2013 LICENSEE:               Entergy Nuclear Operations, Inc.
Entergy Nuclear Operations, Inc. FACILITY:
FACILITY:               Indian Point Nuclear Generating Station. Units 2 and 3
Indian Point Nuclear Generating Station. Units 2 and 3  


==SUBJECT:==
==SUBJECT:==


==SUMMARY==
==SUMMARY==
OF CONFERENCE CALL HELD ON JANUARY 7.2013. BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS.
OF CONFERENCE CALL HELD ON JANUARY 7.2013.
INC .* CONCERNING THE REACTOR VESSEL INTERNALS PROGRAM AT INDIAN POINT NUCLEAR GENERATING STATION, UNITS 2 AND 3 -RAI15A Representatives of the U.S. Nuclear Regulatory Commission (NRC or the staff), and representatives of Entergy Nuclear Operations, Inc., (Entergy or the applicant), held a conference call on January 7, 2013. to provide clarification on a request for additional information (RAI) 15a. related to the Indian Point (IP) Nuclear Generating Station. Units 2 and 3. license renewal application.
BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS. INC .* CONCERNING THE REACTOR VESSEL INTERNALS PROGRAM AT INDIAN POINT NUCLEAR GENERATING STATION, UNITS 2 AND 3 - RAI15A Representatives of the U.S. Nuclear Regulatory Commission (NRC or the staff), and representatives of Entergy Nuclear Operations, Inc., (Entergy or the applicant), held a conference call on January 7, 2013. to provide clarification on a request for additional information (RAI) 15a. related to the Indian Point (IP) Nuclear Generating Station. Units 2 and 3.
The telephone conference call was useful in clarifying the response to the RAI. Enclosure 1 provides a listing of the participants and Enclosure 2 contains a summary of the discussion.
license renewal application. The telephone conference call was useful in clarifying the response to the RAI. provides a listing of the participants and Enclosure 2 contains a summary of the discussion.
The applicant had an opportunity to comment on this summary. Sincerely.
The applicant had an opportunity to comment on this summary.
John Daily, Senior Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286  
Sincerely.
John Daily, Senior Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286


==Enclosure:==
==Enclosure:==
: 1. List of Participants
: 1. List of Participants
: 2. Summary of the Discussion cc w/encl: Listserv
: 2. Summary of the Discussion cc w/encl: Listserv


February 25, 2013 LICENSEE:
February 25, 2013 LICENSEE:               Entergy Nuclear Operations, Inc.
Entergy Nuclear Operations, Inc. FACILITY:
FACILITY:               Indian Point Nuclear Generating Station, Units 2 and 3
Indian Point Nuclear Generating Station, Units 2 and 3  


==SUBJECT:==
==SUBJECT:==


==SUMMARY==
==SUMMARY==
OF CONFERENCE CALL HELD ON JANUARY 7,2013, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC., CONCERNING THE REACTOR VESSEL INTERNALS PROGRAM AT INDIAN POINT NUCLEAR GENERATING STATION, UNITS 2 AND 3 -RAI15A Representatives of the U.S. Nuclear Regulatory Commission (NRC or the staff), and representatives of Entergy Nuclear Operations, Inc., (Entergy or the applicant), held a conference call on January 7,2013, to provide clarification on a request for additional information (RAI) 15a, related to the Indian Point (IP) Nuclear Generating Station, Units 2 and 3, license renewal application.
OF CONFERENCE CALL HELD ON JANUARY 7,2013, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC., CONCERNING THE REACTOR VESSEL INTERNALS PROGRAM AT INDIAN POINT NUCLEAR GENERATING STATION, UNITS 2 AND 3 - RAI15A Representatives of the U.S. Nuclear Regulatory Commission (NRC or the staff), and representatives of Entergy Nuclear Operations, Inc., (Entergy or the applicant), held a conference call on January 7,2013, to provide clarification on a request for additional information (RAI) 15a, related to the Indian Point (IP) Nuclear Generating Station, Units 2 and 3, license renewal application. The telephone conference call was useful in clarifying the response to the RAI.
The telephone conference call was useful in clarifying the response to the RAI. Enclosure 1 provides a listing of the participants and Enclosure 2 contains a summary of the discussion.
Enclosure 1 provides a listing of the participants and Enclosure 2 contains a summary of the discussion.
The applicant had an opportunity to comment on this summary. Sincerely, /raJ John Daily, Senior Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286  
The applicant had an opportunity to comment on this summary.
Sincerely,
                                                  /raJ John Daily, Senior Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286


==Enclosure:==
==Enclosure:==
: 1. List of Participants
: 1. List of Participants
: 2. Summary of the Discussion cc wlencl: Listserv ADAMS Accession No.: ML13015A138  
: 2. Summary of the Discussion cc wlencl: Listserv ADAMS Accession No.: ML13015A138                       *concurrence via e-mail II   OFFICE         LA: DLRlRPB 1*   PM:DLRlRPB1         BC:DLR/RPB1     PM:DLR/RPB1 i
*concurrence via e-mail II OFFICE LA: DLRlRPB 1
I NAME             YEdmonds           JDaily             DMorey           JDaily
* PM:DLRlRPB1 BC:DLR/RPB1 PM:DLR/RPB1 I NAME YEdmonds JDaily DMorey JDaily ;1 DATE 2/5/2013 2/21/2013 2/22/2013 2/25/2013 i OFFICIAL RECORD
;1   DATE           2/5/2013           2/21/2013           2/22/2013       2/25/2013 OFFICIAL RECORD COP


REQUEST FOR ADDITIONAL INFORMATION CONFERENCE INDIAN POINT ENTERGY CENTER, UNITS 2 AND LICENSE RENEWAL REACTOR VESSEL INTERNALS PROGRAM AND LIST OF January 7,
REQUEST FOR ADDITIONAL INFORMATION CONFERENCE CALL INDIAN POINT ENTERGY CENTER, UNITS 2 AND 3 LICENSE RENEWAL APPLICATION REACTOR VESSEL INTERNALS PROGRAM AND MRP-227-A RAI15A LIST OF PARTICIPANTS January 7, 2013 PARTICIPANT                                AFFILIATION
* John Daily PARTICIPANT Nuclear Regulatory Commission (NRC) Jeff Poehler NRC I Ching'Ng NRC Ion Vee i NRC Roger Waters Entergy Nuclear Operations, Inc. (§ntergy)
* John Daily                                   Nuclear Regulatory Commission (NRC)           i Jeff Poehler                                 NRC I Ching'Ng                                     NRC Ion Vee                                   i   NRC Roger Waters                                 Entergy Nuclear Operations, Inc. (§ntergy)   I I
I I i Nelson Azevedo Entergy I Ted Ivy . Entergy ! Alan Cox Entergy ....
i Nelson Azevedo                               Entergy                                       I
* Charlie Caputo Entergy John Curry Entergy I Bob Dolansky i Entergy I Randy Lott Westinghouse
                                                                                            !
!
Ted Ivy                                 . Entergy Alan Cox                                     Entergy
* David Roarty I Westinghouse I Sallie_C_a_rr_er_a
                                                                          ..   ..
___________
* Charlie Caputo                               Entergy I
L-1 W_e_st_in_g_ho_u_s_e
John Curry                                   Entergy Bob Dolansky Randy Lott i Entergy Westinghouse
__________
                                                                                        ~    I
_ ENCLOSURE
                                                                                            !
* David Roarty                             I Westinghouse I Sallie_C_a_rr_er_a_ _ _ _ _ _ _ _ _ _ _ W_e_st_in_g_ho_u_s_e_ _ _ _ _ _ _ _ _ __
L-1 ENCLOSURE 1


REQUEST FOR ADDITIONAL INFORMATION CONFERENCE ENTERGY INDIAN POINT, UNITS 2 AND LICENSE RENEWAL REACTOR VESSEL INTERNALS PROGRAM AND January 7,2013 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Entergy Nuclear Operations, Inc. (Entergy or the applicant) held a telephone conference call on January 7,2013, to discuss staff aging management questions related to the applicant's Reactor Vessel Internals Aging Management Program, in the Indian Point Energy Center (IPEC), Units 2 and 3, license renewal application (LRA). The telephone conference call was IJseful in clarifying the requests for additional information (RAls) on the issue. RAI-15a, Reactor Vessel Internals Program and MRP-227-A Fatigue-induced Cracking for RVI Components-Followup The staff noted that the applicant's revised response to RAI 12 indicates that Entergy intends to use the Reactor Vessel Internals (RVI) Program to manage the cracking-fatigue aging effect for RVI components that have a time-limited aging analysis (TLAA) which determines a cumulative usage factor (CUF). The staff had questions regarding the following: Most of the applicant's RVI components that have an associated fatigue TLAA are not "Primary" inspection category components under the RVI Program, thus they may be subject to no inspection other than a VT-3 visual examination under the ASME Section XI, Inservice Inspection Program, since "Expansion" category component inspections are only triggered in the event of degradation of the linked "Primary" inspection category component(s). The applicant did not justify the adequacy of the periodicity of RVI Program inspections performed on RVI components that have a fatigue TLAA. Components that are not in the "Primary," "Expansion," or "Existing Programs" categories of MRP-227-A fall into the "No Additional Measures" category, for which all aging mechanisms are below the screening criteria, therefore no examination techniques, periodicity, coverage, or acceptance criteria are specified for these components in MRP-227-A.
REQUEST FOR ADDITIONAL INFORMATION CONFERENCE CALL ENTERGY INDIAN POINT, UNITS 2 AND 3 LICENSE RENEWAL APPLICATION REACTOR VESSEL INTERNALS PROGRAM AND MRP-227-A RAI15A January 7,2013 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Entergy Nuclear Operations, Inc. (Entergy or the applicant) held a telephone conference call on January 7,2013, to discuss staff aging management questions related to the applicant's Reactor Vessel Internals Aging Management Program, in the Indian Point Energy Center (IPEC), Units 2 and 3, license renewal application (LRA). The telephone conference call was IJseful in clarifying the requests for additional information (RAls) on the issue.
The staff and Entergy discussed these issues and agreed to clarify the RAI in that it is not intended to re-visit components having a TLAA for CUF and that are classified as Primary, Expansion, or Existing components; for those components, the staff agreed that the inspection techniques as recommended in MRP-227-A are sufficient.
RAI-15a, Reactor Vessel Internals Program and MRP-227-A Fatigue-induced Cracking for RVI Components-Followup The staff noted that the applicant's revised response to RAI 12 indicates that Entergy intends to use the Reactor Vessel Internals (RVI) Program to manage the cracking-fatigue aging effect for RVI components that have a time-limited aging analysis (TLAA) which determines a cumulative usage factor (CUF).
The applicant would still, however, need to justify the inspection periodicity for the components, since a default 10-year reinspection frequency may not be adequate for a CUF (inclusive of environmental effects) that is greater than 1.0 at some point in the period of extended operation.
The staff had questions regarding the following:
* Most of the applicant's RVI components that have an associated fatigue TLAA are not "Primary" inspection category components under the RVI Program, thus they may be subject to no inspection other than a VT-3 visual examination under the ASME Section XI, Inservice Inspection Program, since "Expansion" category component inspections are only triggered in the event of degradation of the linked "Primary" inspection category component(s).
* The applicant did not justify the adequacy of the periodicity of RVI Program inspections performed on RVI components that have a fatigue TLAA.
* Components that are not in the "Primary," "Expansion," or "Existing Programs" categories of MRP-227-A fall into the "No Additional Measures" category, for which all aging mechanisms are below the screening criteria, therefore no examination techniques, periodicity, coverage, or acceptance criteria are specified for these components in MRP-227-A.
The staff and Entergy discussed these issues and agreed to clarify the RAI in that it is not intended to re-visit components having a TLAA for CUF and that are classified as Primary, Expansion, or Existing components; for those components, the staff agreed that the inspection techniques as recommended in MRP-227-A are sufficient. The applicant would still, however, need to justify the inspection periodicity for the components, since a default 10-year reinspection frequency may not be adequate for a CUF (inclusive of environmental effects) that is greater than 1.0 at some point in the period of extended operation.


-In addition, the staff and Entergy agreed that the reply window for this RAI would be 90 days from date of issue. The staff indicated its intent to issue this RAI in conjunction with RAI 11 a. The applicant agreed that it would take the staffs questions into account as it prepares its response to RAI 15a. Both the staff and the applicant agreed that the discussion was useful in clarifying the RAI.
                                                - 2 In addition, the staff and Entergy agreed that the reply window for this RAI would be 90 days from date of issue. The staff indicated its intent to issue this RAI in conjunction with RAI 11 a.
The applicant agreed that it would take the staffs questions into account as it prepares its response to RAI 15a. Both the staff and the applicant agreed that the discussion was useful in clarifying the RAI.
 
==SUBJECT:==


==SUMMARY==
==SUMMARY==
OF CONFERENCE CALL HELD ON JANUARY 7,2012, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC., CONCERNING THE REACTOR VESSEL INTERNALS PROGRAM AND MRP-227-AAT INDIAN POINT NUCLEAR GENERATING STATION, UNITS 2 AND 3 -RAI15A DISTRIBUTION:
OF CONFERENCE CALL HELD ON JANUARY 7,2012, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC., CONCERNING THE REACTOR VESSEL INTERNALS PROGRAM AND MRP-227-AAT INDIAN POINT NUCLEAR GENERATING STATION, UNITS 2 AND 3 - RAI15A DISTRIBUTION:
HARDCOPY:
HARDCOPY:
DLR RF E-MAIL: PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDeEvib Resource RidsOgcMailCenter Resource DWrona GMeyer, RI KGreen RConte, RI JPoehler JBoska PCataldo, RI DScrenci, RI OPA NMcNamara, RI NSheehan, RI OPA DJackson, RI BWelling, RI BMizuno, OGC OAvegbusi, RI STurk,OGC MCatts, RI SBurnell, OPA MHalter, RI DMclntyre, OPA EDacus,OCA}}
DLR RF E-MAIL:
PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDeEvib Resource RidsOgcMailCenter Resource DWrona               GMeyer, RI KGreen               RConte, RI JPoehler             JBoska PCataldo, RI         DScrenci, RI OPA NMcNamara, RI         NSheehan, RI OPA DJackson, RI         BWelling, RI BMizuno, OGC         OAvegbusi, RI STurk,OGC             MCatts, RI SBurnell, OPA         MHalter, RI DMclntyre, OPA EDacus,OCA}}

Revision as of 17:31, 11 November 2019

RAI Telecon Summary of Jan 7, 2013 with Entergy Indian Point, RAI 15A
ML13015A138
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 02/25/2013
From: Daily J
License Renewal Projects Branch 1
To:
Entergy Nuclear Operations
Daily, J, 415-3873
References
Download: ML13015A138 (12)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 25, 2013 LICENSEE: Entergy Nuclear Operations, Inc.

FACILITY: Indian Point Nuclear Generating Station. Units 2 and 3

SUBJECT:

SUMMARY

OF CONFERENCE CALL HELD ON JANUARY 7.2013.

BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS. INC .* CONCERNING THE REACTOR VESSEL INTERNALS PROGRAM AT INDIAN POINT NUCLEAR GENERATING STATION, UNITS 2 AND 3 - RAI15A Representatives of the U.S. Nuclear Regulatory Commission (NRC or the staff), and representatives of Entergy Nuclear Operations, Inc., (Entergy or the applicant), held a conference call on January 7, 2013. to provide clarification on a request for additional information (RAI) 15a. related to the Indian Point (IP) Nuclear Generating Station. Units 2 and 3.

license renewal application. The telephone conference call was useful in clarifying the response to the RAI. provides a listing of the participants and Enclosure 2 contains a summary of the discussion.

The applicant had an opportunity to comment on this summary.

Sincerely.

John Daily, Senior Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286

Enclosure:

1. List of Participants
2. Summary of the Discussion cc w/encl: Listserv

February 25, 2013 LICENSEE: Entergy Nuclear Operations, Inc.

FACILITY: Indian Point Nuclear Generating Station, Units 2 and 3

SUBJECT:

SUMMARY

OF CONFERENCE CALL HELD ON JANUARY 7,2013, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC., CONCERNING THE REACTOR VESSEL INTERNALS PROGRAM AT INDIAN POINT NUCLEAR GENERATING STATION, UNITS 2 AND 3 - RAI15A Representatives of the U.S. Nuclear Regulatory Commission (NRC or the staff), and representatives of Entergy Nuclear Operations, Inc., (Entergy or the applicant), held a conference call on January 7,2013, to provide clarification on a request for additional information (RAI) 15a, related to the Indian Point (IP) Nuclear Generating Station, Units 2 and 3, license renewal application. The telephone conference call was useful in clarifying the response to the RAI.

Enclosure 1 provides a listing of the participants and Enclosure 2 contains a summary of the discussion.

The applicant had an opportunity to comment on this summary.

Sincerely,

/raJ John Daily, Senior Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286

Enclosure:

1. List of Participants
2. Summary of the Discussion cc wlencl: Listserv ADAMS Accession No.: ML13015A138 *concurrence via e-mail II OFFICE LA: DLRlRPB 1* PM:DLRlRPB1 BC:DLR/RPB1 PM:DLR/RPB1 i

I NAME YEdmonds JDaily DMorey JDaily

1 DATE 2/5/2013 2/21/2013 2/22/2013 2/25/2013 OFFICIAL RECORD COP

REQUEST FOR ADDITIONAL INFORMATION CONFERENCE CALL INDIAN POINT ENTERGY CENTER, UNITS 2 AND 3 LICENSE RENEWAL APPLICATION REACTOR VESSEL INTERNALS PROGRAM AND MRP-227-A RAI15A LIST OF PARTICIPANTS January 7, 2013 PARTICIPANT AFFILIATION

  • John Daily Nuclear Regulatory Commission (NRC) i Jeff Poehler NRC I Ching'Ng NRC Ion Vee i NRC Roger Waters Entergy Nuclear Operations, Inc. (§ntergy) I I

i Nelson Azevedo Entergy I

!

Ted Ivy . Entergy Alan Cox Entergy

.. ..

  • Charlie Caputo Entergy I

John Curry Entergy Bob Dolansky Randy Lott i Entergy Westinghouse

~ I

!

  • David Roarty I Westinghouse I Sallie_C_a_rr_er_a_ _ _ _ _ _ _ _ _ _ _ W_e_st_in_g_ho_u_s_e_ _ _ _ _ _ _ _ _ __

L-1 ENCLOSURE 1

REQUEST FOR ADDITIONAL INFORMATION CONFERENCE CALL ENTERGY INDIAN POINT, UNITS 2 AND 3 LICENSE RENEWAL APPLICATION REACTOR VESSEL INTERNALS PROGRAM AND MRP-227-A RAI15A January 7,2013 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Entergy Nuclear Operations, Inc. (Entergy or the applicant) held a telephone conference call on January 7,2013, to discuss staff aging management questions related to the applicant's Reactor Vessel Internals Aging Management Program, in the Indian Point Energy Center (IPEC), Units 2 and 3, license renewal application (LRA). The telephone conference call was IJseful in clarifying the requests for additional information (RAls) on the issue.

RAI-15a, Reactor Vessel Internals Program and MRP-227-A Fatigue-induced Cracking for RVI Components-Followup The staff noted that the applicant's revised response to RAI 12 indicates that Entergy intends to use the Reactor Vessel Internals (RVI) Program to manage the cracking-fatigue aging effect for RVI components that have a time-limited aging analysis (TLAA) which determines a cumulative usage factor (CUF).

The staff had questions regarding the following:

  • Most of the applicant's RVI components that have an associated fatigue TLAA are not "Primary" inspection category components under the RVI Program, thus they may be subject to no inspection other than a VT-3 visual examination under the ASME Section XI, Inservice Inspection Program, since "Expansion" category component inspections are only triggered in the event of degradation of the linked "Primary" inspection category component(s).
  • The applicant did not justify the adequacy of the periodicity of RVI Program inspections performed on RVI components that have a fatigue TLAA.
  • Components that are not in the "Primary," "Expansion," or "Existing Programs" categories of MRP-227-A fall into the "No Additional Measures" category, for which all aging mechanisms are below the screening criteria, therefore no examination techniques, periodicity, coverage, or acceptance criteria are specified for these components in MRP-227-A.

The staff and Entergy discussed these issues and agreed to clarify the RAI in that it is not intended to re-visit components having a TLAA for CUF and that are classified as Primary, Expansion, or Existing components; for those components, the staff agreed that the inspection techniques as recommended in MRP-227-A are sufficient. The applicant would still, however, need to justify the inspection periodicity for the components, since a default 10-year reinspection frequency may not be adequate for a CUF (inclusive of environmental effects) that is greater than 1.0 at some point in the period of extended operation.

- 2 In addition, the staff and Entergy agreed that the reply window for this RAI would be 90 days from date of issue. The staff indicated its intent to issue this RAI in conjunction with RAI 11 a.

The applicant agreed that it would take the staffs questions into account as it prepares its response to RAI 15a. Both the staff and the applicant agreed that the discussion was useful in clarifying the RAI.

SUBJECT:

SUMMARY

OF CONFERENCE CALL HELD ON JANUARY 7,2012, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC., CONCERNING THE REACTOR VESSEL INTERNALS PROGRAM AND MRP-227-AAT INDIAN POINT NUCLEAR GENERATING STATION, UNITS 2 AND 3 - RAI15A DISTRIBUTION:

HARDCOPY:

DLR RF E-MAIL:

PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDeEvib Resource RidsOgcMailCenter Resource DWrona GMeyer, RI KGreen RConte, RI JPoehler JBoska PCataldo, RI DScrenci, RI OPA NMcNamara, RI NSheehan, RI OPA DJackson, RI BWelling, RI BMizuno, OGC OAvegbusi, RI STurk,OGC MCatts, RI SBurnell, OPA MHalter, RI DMclntyre, OPA EDacus,OCA