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| number = ML070870715 | | number = ML070870715 | ||
| issue date = 03/22/2007 | | issue date = 03/22/2007 | ||
| title = | | title = Response to Request for Additional Information Regarding the Third Ten-Year Interval Inservice Testing Program | ||
| author name = Oxenford W | | author name = Oxenford W | ||
| author affiliation = Energy Northwest | | author affiliation = Energy Northwest | ||
| addressee name = | | addressee name = | ||
| Line 13: | Line 13: | ||
| document type = Inservice/Preservice Inspection and Test Report, Letter | | document type = Inservice/Preservice Inspection and Test Report, Letter | ||
| page count = 6 | | page count = 6 | ||
| project = | |||
| stage = Response to RAI | |||
}} | }} | ||
=Text= | =Text= | ||
{{#Wiki_filter:ENERGY R NORTHWEST I~'eopne *V/~sin | {{#Wiki_filter:ENERGY R NORTHWEST I~'eopne *V/~sin | ||
* P.O. Box 968 -Richland, WA | * o~u*;ions P.O. Box 968 - Richland, WA | ||
* 99352-0968 March 22, 2007 G02-07-052 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 | * 99352-0968 March 22, 2007 G02-07-052 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 | ||
==Subject:== | ==Subject:== | ||
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE THIRD TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM AT COLUMBIA GENERATING STATION | COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE THIRD TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM AT COLUMBIA GENERATING STATION | ||
==References:== | ==References:== | ||
: 1) Letter dated, October 10, 2005, G02-05-166, WS Oxenford (Energy Northwest) to NRC, "Submittal of the Third Ten-Year Interval Pump and Valve Inservice Testing (IST) Program Plan" 2) Letter dated, February 22, 2007, G02-07-035, WS Oxenford (Energy Northwest) to NRC, "Response to Request for Additional Information Regarding the Third Ten-Year Interval Pump and Valve Inservice Testing (IST) Program Plan" | : 1) Letter dated, October 10, 2005, G02-05-166, WS Oxenford (Energy Northwest) to NRC, "Submittal of the Third Ten-Year Interval Pump and Valve Inservice Testing (IST) Program Plan" | ||
: 2) Letter dated, February 22, 2007, G02-07-035, WS Oxenford (Energy Northwest) to NRC, "Response to Request for Additional Information Regarding the Third Ten-Year Interval Pump and Valve Inservice Testing (IST) Program Plan" | |||
==Dear Sir or Madam:== | ==Dear Sir or Madam:== | ||
Transmitted herewith in Attachment 1 is the Energy Northwest response to a Request for Additional Information. | |||
This response provides the additional information as discussed with the Staff in a teleconference on March 7, 2007. As noted in Attachment 1, Energy Northwest hereby withdraws requests RP-02 and RP-08. There are no new commitments contained in this response.If you have any questions or require additional information, please contact GV Cullen at (509) 377-6105., I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.Respectfull WS Oxe~nford/(Mailýrop PE04)Vice Preside t,rXchnical Services Attachments: | Transmitted herewith in Attachment 1 is the Energy Northwest response to a Request for Additional Information. This response provides the additional information as discussed with the Staff in a teleconference on March 7, 2007. As noted in Attachment 1, Energy Northwest hereby withdraws requests RP-02 and RP-08. There are no new commitments contained in this response. | ||
If you have any questions or require additional information, please contact GV Cullen at (509) 377-6105., | |||
: 2) Revised-Request RV-01 cc: BS Mallett -NRC RIV | I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter. | ||
Strawn RN Sherman -BPA/1 399ý 0(47ý | Respectfull WS Oxe~nford/(Mailýrop PE04) | ||
Please explain the reason for the change.The technical specification addresses system operability while inservice testing deals with component operability and sometimes system operability as well. The technical requirements may satisfy system operability but not necessarily component operability. | Vice Preside t,rXchnical Services Attachments: 1) " Response to Request for Additional Information | ||
Response The components identified in Relief Request RV-01 consist of two independent testable check valves in series and cannot be tested individually as described in Subsection ISTC-3630. | : 2) Revised-Request RV-01 cc: BS Mallett - NRC RIV WA Horin-- Winston!& Strawn CF Lyon - NRC NRR RN Sherman - BPA/1 399 ý 0(47ý NRC Senior Resident Inspector/988C | ||
Therefore, leak testing in accordance with the Code is impractical. | |||
Relief Request RV-01 has been revised to state the basis for the relief is impracticality as indicated in Attachment 2.Request RV-01 has also been revised to request leak test substitutions approved by the Staff in an SER dated February 9, 2007 (referenced in attached revised relief request), to also apply to the testing specified in Paragraph ISTC-3630. | RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE THIRD TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM AT COLUMBIA GENERATING STATION Page 1 of 2 Response to Request for Additional Information Item 1 In Revision 1 of Relief Request RV01, the licensee changed the basis for the relief to "the alternative provides an acceptable level of quality and safety," while in the original relief request, the basis was impracticality. Please explain the reason for the change. | ||
Item 2 For RP-02, you want to use Section 5.5.2 of NUREG-1482, which is applicable to positive displacement pumps. The pumps are vertical centrifugal pumps. The RAI response says that the methodology in the NUREG is germane to both types of pumps.Provide a different justification as to why the alternative testing is acceptable. | The technical specification addresses system operability while inservice testing deals with component operability and sometimes system operability as well. The technical requirements may satisfy system operability but not necessarily component operability. | ||
Response The ASME Code components identified in Relief Request RP-02 (DO-P-1A, DO-P-1 B, and DO-P-2) qualify for classification as "skid mounted pumps" as defined in ISTA-2000 and therefore exclusion from subsection ISTB pursuant to ISTB-1200. | |||
As such, Energy Northwest hereby withdraws Relief Request RP-02 from its third ten-year interval IST program. | ===Response=== | ||
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE THIRD TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM AT COLUMBIA GENERATING STATION | The components identified in Relief Request RV-01 consist of two independent testable check valves in series and cannot be tested individually as described in Subsection ISTC-3630. Therefore, leak testing in accordance with the Code is impractical. Relief Request RV-01 has been revised to state the basis for the relief is impracticality as indicated in Attachment 2. | ||
As such, Energy Northwest hereby withdraws Relief Request RP-08 from its third ten-year interval IST program. | Request RV-01 has also been revised to request leak test substitutions approved by the Staff in an SER dated February 9, 2007 (referenced in attached revised relief request), | ||
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE THIRD TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM AT COLUMBIA GENERATING STATION | to also apply to the testing specified in Paragraph ISTC-3630. | ||
-- Inservice Testing Impracticality | Item 2 For RP-02, you want to use Section 5.5.2 of NUREG-1482, which is applicable to positive displacement pumps. The pumps are vertical centrifugal pumps. The RAI response says that the methodology in the NUREG is germane to both types of pumps. | ||
--ASME Code Components Affected Affected Class Cat. Function System(s)Valves CVB-V-1AB, 2 AC To break vacuum on the drywell to Primary CD, EF, GH, suppression chamber downcomers Containment JK, LM, NP, and to limit steam leakage from the Cooling and Purge QR, ST downcomer to the wetwell gas space.Applicable Code Edition and Addenda The 2001 Edition and the 2002 and 2003 Addenda of the ASME OM Code.Applicable Code Requirement OM Subsection ISTC-3630, Leakage Rate for Other Than Containment Isolation Valves.Impracticality of Compliance These check valves cannot be tested individually therefore, assigning a limiting leakage rate for each valve or valve combination is not practical. | Provide a different justification as to why the alternative testing is acceptable. | ||
Burden Caused by Compliance Subsection ISTC-3630 requires Category A valves, other than containment isolation valves, to be individually leak tested. Each vacuum relief valve assembly consists of two independent testable check valves in series with no instrument located between them to allow testing of each of the two check valves. Therefore, leak testing in accordance with the Code is impractical. | |||
Modifications to allow individual testing of these valves would require a major system redesign and be burdensome. | ===Response=== | ||
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE THIRD TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM AT COLUMBIA GENERATING STATION | The ASME Code components identified in Relief Request RP-02 (DO-P-1A, DO-P-1 B, and DO-P-2) qualify for classification as "skid mounted pumps" as defined in ISTA-2000 and therefore exclusion from subsection ISTB pursuant to ISTB-1200. As such, Energy Northwest hereby withdraws Relief Request RP-02 from its third ten-year interval IST program. | ||
The, tes~t frequencyis7 120 months and 48 months following one test failure~ and 24 months 'if | |||
Thus, tadetermination of suppraesion chaemaeril qouywll van leaka i aveaeak test frequency of 24 monhs by eithe 3 .6.. | RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE THIRD TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM AT COLUMBIA GENERATING STATION Page 2 of 2 Item 3 In RP-08, you want to increase the upper limit of the acceptable range from 1.03 to 1.10. | ||
These valves are also verified-closed by position indicators, exercised., and tested in the open direction using a torque wrench per Technical Specification SR 3.6.1.7.1, SR 3.6.1.7.2, and SR 3.6.1.7.3. | |||
In accordance with a se~parate commitment, the | ===Response=== | ||
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE THIRD TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM AT COLUMBIA GENERATING STATION | The ASME Code components identified in Relief Request RP-08 (DO-P-1A, DO-P-1 B, and DO-P-2) qualify for classification as "skid mounted pumps" as defined in ISTA-2000 and therefore exclusion from subsection ISTB pursuant to ISTB-1200. As such, Energy Northwest hereby withdraws Relief Request RP-08 from its third ten-year interval IST program. | ||
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE THIRD TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM AT COLUMBIA GENERATING STATION Page 1 of 3 Revised Request RV-01 Relief Request -- RV01 aRev~ision 1, Relief Request in Accordance with 10CFR 50.55a(f)(5)(iii) | |||
-- Inservice Testing Impracticality -- | |||
ASME Code Components Affected Affected Class Cat. Function System(s) | |||
Valves CVB-V-1AB, 2 AC To break vacuum on the drywell to Primary CD, EF, GH, suppression chamber downcomers Containment JK, LM, NP, and to limit steam leakage from the Cooling and Purge QR, ST downcomer to the wetwell gas space. | |||
===Applicable Code Edition and Addenda=== | |||
The 2001 Edition and the 2002 and 2003 Addenda of the ASME OM Code. | |||
===Applicable Code Requirement=== | |||
OM Subsection ISTC-3630, Leakage Rate for Other Than Containment Isolation Valves. | |||
Impracticality of Compliance These check valves cannot be tested individually therefore, assigning a limiting leakage rate for each valve or valve combination is not practical. | |||
Burden Caused by Compliance Subsection ISTC-3630 requires Category A valves, other than containment isolation valves, to be individually leak tested. Each vacuum relief valve assembly consists of two independent testable check valves in series with no instrument located between them to allow testing of each of the two check valves. Therefore, leak testing in accordance with the Code is impractical. Modifications to allow individual testing of these valves would require a major system redesign and be burdensome. | |||
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE THIRD TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM AT COLUMBIA GENERATING STATION Page 2 of 3 Relief Request -- RVOI (Contd.) | |||
Proposed Alternative and Basis for Use These valves will be leak tested in accordance with Columbia Generating Station Technical Specifications SR 3.6.1.1.2, SR 3.6.1.1.3, and SR 3.6..1.4 during refueling outages. | |||
TechnicalSpecifications SR Spefession chamber bypass leg tesl itors theyombined leakagcofi t of pathtways- (1)th f Towlcomears,c(2 piping ecorrealy aconnectd to oti ithe drywell and suppressian chamber air space, and (3)the7 suppression chamber-to-drwe~llxacuum; breakers. The, tes~t frequencyis7 120 months and 48 months following one test failure~and 24 months 'if 6wconsecutive tests fail until tw !conse~cutive tests are less than~or e&aI to the Technical Specifications SR 3.6.1.1.2 estbli** es a IeAk rate test frquency of 24 monhseon ahsupeso chme-odryell vacuum breaker pathway, xcept whnthe leakage test of SR3.6.1..2 has b~een performed (Note tc SR 3.6.1.3) | |||
Thu, ech uppesson haberto-rywll acum beaer pathway willhav aIlak, Technical Specifications v S 3.6.1 .14 establishes outage tes freque of 24 onths toedetermine the suppr ssion chainber-to-drywell vacuumebrea totalsonpool lIeakage, excep whe te bypass leakagetest of SIR 3.6.'1.1.2 has been perfo rmed (Note to SR 3.6.1.1.4). Thus,tadetermination of suppraesion chaemaeril qouywll van leaka i aveaeak test frequency of 24 monhs by eithe 3 .6..12or SIR 3.6.1.1.4. | |||
These valves are also verified-closed by position indicators, exercised., and tested in the open direction using a torque wrench per Technical Specification SR 3.6.1.7.1, SR 3.6.1.7.2, and SR 3.6.1.7.3. In accordance with a se~parate commitment, the valves3/4a visually inspected e~ach refueling ou e., | |||
Quality/Safety Impact The leakage criteria and corrective actions specified in the Columbia Generating Station Technical Specifications SR 3.6.1.1.2, SR36. 1.1.31 'nd SIR 3.6.1.1.4 , combined with visual examination of valve seats every refuel outage provides adequate assurance of the relief valve assembly's ability to remain leak tight and to prevent a suppression pool bypass. Thus, proposed alternative provides adequate assurance of material quality and public safety. | |||
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE THIRD TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM AT COLUMBIA GENERATING STATION Page 3 of 3 Duration of Proposed Alternative Third 10 year interval. | |||
Precedents This relief request was granted for the previous 10 year interval. | |||
SER letter dated November 27, 1995 (TAC No. M91159); Relief Request No. RV01. | |||
References}} | |||
Latest revision as of 07:55, 23 November 2019
| ML070870715 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 03/22/2007 |
| From: | Oxenford W Energy Northwest |
| To: | Document Control Desk, NRC/NRR/ADRO |
| References | |
| G02-07-052 | |
| Download: ML070870715 (6) | |
Text
ENERGY R NORTHWEST I~'eopne *V/~sin
- o~u*;ions P.O. Box 968 - Richland, WA
- 99352-0968 March 22, 2007 G02-07-052 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE THIRD TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM AT COLUMBIA GENERATING STATION
References:
- 1) Letter dated, October 10, 2005, G02-05-166, WS Oxenford (Energy Northwest) to NRC, "Submittal of the Third Ten-Year Interval Pump and Valve Inservice Testing (IST) Program Plan"
- 2) Letter dated, February 22, 2007, G02-07-035, WS Oxenford (Energy Northwest) to NRC, "Response to Request for Additional Information Regarding the Third Ten-Year Interval Pump and Valve Inservice Testing (IST) Program Plan"
Dear Sir or Madam:
Transmitted herewith in Attachment 1 is the Energy Northwest response to a Request for Additional Information. This response provides the additional information as discussed with the Staff in a teleconference on March 7, 2007. As noted in Attachment 1, Energy Northwest hereby withdraws requests RP-02 and RP-08. There are no new commitments contained in this response.
If you have any questions or require additional information, please contact GV Cullen at (509) 377-6105.,
I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.
Respectfull WS Oxe~nford/(Mailýrop PE04)
Vice Preside t,rXchnical Services Attachments: 1) " Response to Request for Additional Information
- 2) Revised-Request RV-01 cc: BS Mallett - NRC RIV WA Horin-- Winston!& Strawn CF Lyon - NRC NRR RN Sherman - BPA/1 399 ý 0(47ý NRC Senior Resident Inspector/988C
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE THIRD TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM AT COLUMBIA GENERATING STATION Page 1 of 2 Response to Request for Additional Information Item 1 In Revision 1 of Relief Request RV01, the licensee changed the basis for the relief to "the alternative provides an acceptable level of quality and safety," while in the original relief request, the basis was impracticality. Please explain the reason for the change.
The technical specification addresses system operability while inservice testing deals with component operability and sometimes system operability as well. The technical requirements may satisfy system operability but not necessarily component operability.
Response
The components identified in Relief Request RV-01 consist of two independent testable check valves in series and cannot be tested individually as described in Subsection ISTC-3630. Therefore, leak testing in accordance with the Code is impractical. Relief Request RV-01 has been revised to state the basis for the relief is impracticality as indicated in Attachment 2.
Request RV-01 has also been revised to request leak test substitutions approved by the Staff in an SER dated February 9, 2007 (referenced in attached revised relief request),
to also apply to the testing specified in Paragraph ISTC-3630.
Item 2 For RP-02, you want to use Section 5.5.2 of NUREG-1482, which is applicable to positive displacement pumps. The pumps are vertical centrifugal pumps. The RAI response says that the methodology in the NUREG is germane to both types of pumps.
Provide a different justification as to why the alternative testing is acceptable.
Response
The ASME Code components identified in Relief Request RP-02 (DO-P-1A, DO-P-1 B, and DO-P-2) qualify for classification as "skid mounted pumps" as defined in ISTA-2000 and therefore exclusion from subsection ISTB pursuant to ISTB-1200. As such, Energy Northwest hereby withdraws Relief Request RP-02 from its third ten-year interval IST program.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE THIRD TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM AT COLUMBIA GENERATING STATION Page 2 of 2 Item 3 In RP-08, you want to increase the upper limit of the acceptable range from 1.03 to 1.10.
Response
The ASME Code components identified in Relief Request RP-08 (DO-P-1A, DO-P-1 B, and DO-P-2) qualify for classification as "skid mounted pumps" as defined in ISTA-2000 and therefore exclusion from subsection ISTB pursuant to ISTB-1200. As such, Energy Northwest hereby withdraws Relief Request RP-08 from its third ten-year interval IST program.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE THIRD TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM AT COLUMBIA GENERATING STATION Page 1 of 3 Revised Request RV-01 Relief Request -- RV01 aRev~ision 1, Relief Request in Accordance with 10CFR 50.55a(f)(5)(iii)
-- Inservice Testing Impracticality --
ASME Code Components Affected Affected Class Cat. Function System(s)
Valves CVB-V-1AB, 2 AC To break vacuum on the drywell to Primary CD, EF, GH, suppression chamber downcomers Containment JK, LM, NP, and to limit steam leakage from the Cooling and Purge QR, ST downcomer to the wetwell gas space.
Applicable Code Edition and Addenda
The 2001 Edition and the 2002 and 2003 Addenda of the ASME OM Code.
Applicable Code Requirement
OM Subsection ISTC-3630, Leakage Rate for Other Than Containment Isolation Valves.
Impracticality of Compliance These check valves cannot be tested individually therefore, assigning a limiting leakage rate for each valve or valve combination is not practical.
Burden Caused by Compliance Subsection ISTC-3630 requires Category A valves, other than containment isolation valves, to be individually leak tested. Each vacuum relief valve assembly consists of two independent testable check valves in series with no instrument located between them to allow testing of each of the two check valves. Therefore, leak testing in accordance with the Code is impractical. Modifications to allow individual testing of these valves would require a major system redesign and be burdensome.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE THIRD TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM AT COLUMBIA GENERATING STATION Page 2 of 3 Relief Request -- RVOI (Contd.)
Proposed Alternative and Basis for Use These valves will be leak tested in accordance with Columbia Generating Station Technical Specifications SR 3.6.1.1.2, SR 3.6.1.1.3, and SR 3.6..1.4 during refueling outages.
TechnicalSpecifications SR Spefession chamber bypass leg tesl itors theyombined leakagcofi t of pathtways- (1)th f Towlcomears,c(2 piping ecorrealy aconnectd to oti ithe drywell and suppressian chamber air space, and (3)the7 suppression chamber-to-drwe~llxacuum; breakers. The, tes~t frequencyis7 120 months and 48 months following one test failure~and 24 months 'if 6wconsecutive tests fail until tw !conse~cutive tests are less than~or e&aI to the Technical Specifications SR 3.6.1.1.2 estbli** es a IeAk rate test frquency of 24 monhseon ahsupeso chme-odryell vacuum breaker pathway, xcept whnthe leakage test of SR3.6.1..2 has b~een performed (Note tc SR 3.6.1.3)
Thu, ech uppesson haberto-rywll acum beaer pathway willhav aIlak, Technical Specifications v S 3.6.1 .14 establishes outage tes freque of 24 onths toedetermine the suppr ssion chainber-to-drywell vacuumebrea totalsonpool lIeakage, excep whe te bypass leakagetest of SIR 3.6.'1.1.2 has been perfo rmed (Note to SR 3.6.1.1.4). Thus,tadetermination of suppraesion chaemaeril qouywll van leaka i aveaeak test frequency of 24 monhs by eithe 3 .6..12or SIR 3.6.1.1.4.
These valves are also verified-closed by position indicators, exercised., and tested in the open direction using a torque wrench per Technical Specification SR 3.6.1.7.1, SR 3.6.1.7.2, and SR 3.6.1.7.3. In accordance with a se~parate commitment, the valves3/4a visually inspected e~ach refueling ou e.,
Quality/Safety Impact The leakage criteria and corrective actions specified in the Columbia Generating Station Technical Specifications SR 3.6.1.1.2, SR36. 1.1.31 'nd SIR 3.6.1.1.4 , combined with visual examination of valve seats every refuel outage provides adequate assurance of the relief valve assembly's ability to remain leak tight and to prevent a suppression pool bypass. Thus, proposed alternative provides adequate assurance of material quality and public safety.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE THIRD TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM AT COLUMBIA GENERATING STATION Page 3 of 3 Duration of Proposed Alternative Third 10 year interval.
Precedents This relief request was granted for the previous 10 year interval.
SER letter dated November 27, 1995 (TAC No. M91159); Relief Request No. RV01.
References