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| number = ML110400037
| number = ML110400037
| issue date = 02/09/2011
| issue date = 02/09/2011
| title = Nine Mile Point Unit No. 2 - Request for Additional Information Extended Power Uprate - Safety Systems and Component Integrity Review (TAC No. ME1476)
| title = Request for Additional Information Extended Power Uprate - Safety Systems and Component Integrity Review
| author name = Guzman R V
| author name = Guzman R
| author affiliation = NRC/NRR/DORL
| author affiliation = NRC/NRR/DORL
| addressee name = Belcher S L
| addressee name = Belcher S
| addressee affiliation = Nine Mile Point Nuclear Station, LLC
| addressee affiliation = Nine Mile Point Nuclear Station, LLC
| docket = 05000410
| docket = 05000410
| license number = NPF-069
| license number = NPF-069
| contact person = Guzman R V, NRR/DORL, 415-1030
| contact person = Guzman R, NRR/DORL, 415-1030
| case reference number = TAC ME1476
| case reference number = TAC ME1476
| document type = Letter, Request for Additional Information (RAI)
| document type = Letter, Request for Additional Information (RAI)
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 February 9, 2011 Mr. Samuel L. Belcher Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093 REQUEST FOR ADDITIONAL INFORMATION REGARDING NINE MILE POINT NUCLEAR STATION, UNIT NO.2 -RE: THE LICENSE AMENDMENT REQUEST FOR EXTENDED POWER UPRATE OPERATION (TAC NO. ME1476)  
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 9, 2011 Mr. Samuel L. Belcher Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093
 
==SUBJECT:==
REQUEST FOR ADDITIONAL INFORMATION REGARDING NINE MILE POINT NUCLEAR STATION, UNIT NO.2 - RE: THE LICENSE AMENDMENT REQUEST FOR EXTENDED POWER UPRATE OPERATION (TAC NO. ME1476)


==Dear Mr. Belcher:==
==Dear Mr. Belcher:==
By letter dated May 27, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML091610103), Nine Mile Point Nuclear Station, LLC (NMPNS or the licensee) submitted a license amendment request (LAR) for Nine Mile Point, Unit No.2 (NMP2). The proposed amendment requests an increase in the maximum steady-state power level at NMP2 from 3467 megawatts thermal (MWt) to 3988 MWt. This represents a 15-percent increase over the current licensed thermal power. Based on its review of the LAR and the supplemental information provided by the NMPNS in letter December 13, 2010 (ADAMS Accession No. ML 103500364), the Nuclear Regulatory Commission (NRC) staff has determined that additional information is needed to support its review. Enclosed is the NRC staff's request for additional information (RAI). The RAI was discussed with your staff on January 27 and February 8, 2011, and it was agreed that your response would be provided within 60 days from the date of this letter. Sincerely, Richard V. Guzman, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-410  
 
By letter dated May 27, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML091610103), Nine Mile Point Nuclear Station, LLC (NMPNS or the licensee) submitted a license amendment request (LAR) for Nine Mile Point, Unit No.2 (NMP2).
The proposed amendment requests an increase in the maximum steady-state power level at NMP2 from 3467 megawatts thermal (MWt) to 3988 MWt. This represents a 15-percent increase over the current licensed thermal power.
Based on its review of the LAR and the supplemental information provided by the NMPNS in letter December 13, 2010 (ADAMS Accession No. ML103500364), the Nuclear Regulatory Commission (NRC) staff has determined that additional information is needed to support its review. Enclosed is the NRC staff's request for additional information (RAI). The RAI was discussed with your staff on January 27 and February 8, 2011, and it was agreed that your response would be provided within 60 days from the date of this letter.
Sincerely, Richard V. Guzman, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-410


==Enclosure:==
==Enclosure:==


As stated cc w/encl: Distribution via Listserv REQUEST FOR ADDITIONAL INFORMATION (RAn FOR LICENSE AMENDMENT REQUEST RE: EXTENDED POWER UPRATE (EPU) NINE MILE POINT NUCLEAR STATION, LLC NINE MILE POINT NUCLEAR STATION, UNIT NO.2 DOCKET NO.
As stated cc w/encl: Distribution via Listserv
By letter dated May 27, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML091610103), Nine Mile Point Nuclear Station, LLC (NMPNS or the licensee) submitted a license amendment request (LAR) for Nine Mile Point. Unit No.2 (NMP2). The proposed amendment requests an increase in the maximum power level at NMP2 from 3467 megawatts thermal (MWt) to 3966 MWt. This represents a 15-percent increase over the current licensed thermal power. Based on its review of the license amendment request and the supplemental information provided by the NMPNS in letter dated December 13. 2010 (ADAMS Accession No. ML 103500364), the Nuclear Regulatory Commission staff has determined that additional information requested below will be needed to support its review. 1. In letter dated December 13,2010, the licensee stated that: All fuel assembly types were analyzed using CASM04 at 4.95% enrichment (including the manufacturing tolerance of +/- 0.05% enrichment which is equivalent to the 5.0% enrichment discussed in NMP2 Updated Safety Analysis Report Section 9.1.2.2).
The above statement appears inadequate to support an enrichment of 5.0%. Analysis at 4.95% with a +/- 0.05% tolerance would justify an enrichment of 4.95%. By the same reason, the updated safety analysis report also appears inadequate.
Clarify this statement.
The various submittals lack clarity of the licensed enrichment limit. The NMP2 power uprate safety analysis report (PUSAR) Table specifies 5.0%. PUSAR Table specifies 4.9%. The letter dated December 13. 2010, specifies 4.95%. What is the enrichment limit justified by analysiS?
Specify this limit in the Technical Specifications (TSs) in accordance with Title 10 of the Code of Federal Regulations, (10 CFR) Section 50.36. 2. In letter dated December 13, 2010, the licensee stated that: The current GE14 fuel lattice design satisfies the NMP2 new fuel vault storage criteria outlined in Technical Specification (TS) Section 4.3 provided that the peak, eigenvalue of any constituent fuel lattice, as computed by either the GNF lattice physics codes TGBLA04A or TGBLA06A, does not exceed 1.29. However. the PUSAR lists a peak in-core eigenvalue limit of 1.3392. Clarify this discrepancy and specify this limit in the TSs in accordance with 10 CFR 50.36. In addition, provide the in-Enclosure 
-2 rack maximum k-effective for new fuel storage determined by analysis and the supporting analysis. On page 3 of Attachment 1 of its response dated December 13, 2010, the licensee states that NMP2 added 10 new Holtec Boral spent fuel storage racks in the NMP2 spent fuel pool as part of the Phase I re-rack via a 10 CFR 50.59 evaluation.
Afterward, NMP2 performed the Phase II re-rack, similarly using a 10 CFR 50.59 evaluation in support of the modification, which replaced 16 original Boraflex spent fuel storage racks with Holtec Boral racks. The licensee further stated that the new Boral spent fuel storage racks are incorporated into the criticality analysis that has been submitted in support of NMPZs EPU LAR. It is not clear to the NRC staff how the licensee can ensure that the Boral material will continue to perform its intended function in the future. As such, please discuss how the neutron absorber will be monitored and maintained (e.g. use of surveillance program).
If a program is utilized, discuss in detail the approach that will be used in the monitoring program, specifically the methods and techniques utilized (e.g., visual, weight, volumetric, surface inspection, neutron attenuation testing), frequency of inspection, sample size, data collection and acceptance criteria.
: a. Please indicate the installation date for new and replacement Boral storage racks. b. Please discuss whether NMP2 utilizes a Boral coupon program for the new and replacement Boral storage racks. If a coupon program is being used, please describe the program. Specifically: (i) Identify the quantity and location of coupons relative to the spent fuel racks. (ii) Describe how the coupons are mounted and whether they are fully exposed to the spent fuel pool water. (iii) Discuss whether any coupons that are removed and inspected using non destructive techniques will be re-inserted in the spent fuel pool for future evaluation. (iv) Indicate whether the Boral racks in the spent fuel pool are vented or not. Please describe how the areal density of the Boral material will be measured (e.g., neutron attenuation) and maintained to prevent an inadvertent criticality.
Please include a description of the testing, parameters measured, calculations, and acceptance criteria.
February 9, 2011 Mr. Samuel L. Belcher Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093 REQUEST FOR ADDITIONAL INFORMATION REGARDING NINE MILE POINT NUCLEAR STATION, UNIT NO.2 -RE: THE LICENSE AMENDMENT REQUEST FOR EXTENDED POWER UPRATE OPERATION (TAC NO. ME1476)


==Dear Mr. Belcher:==
REQUEST FOR ADDITIONAL INFORMATION (RAn FOR LICENSE AMENDMENT REQUEST RE: EXTENDED POWER UPRATE (EPU)
By letter dated May 27, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML09161 01 03), Nine Mile Point Nuclear Station, LLC (NMPNS or the licensee) submitted a license amendment request (LAR) for Nine Mile Point, Unit No.2 (NMP2). The proposed amendment requests an increase in the maximum steady-state power level at NMP2 from 3467 megawatts thermal (MWt) to 3988 MWt. This represents a 15-percent increase over the current licensed thermal power. Based on its review of the LAR and the supplemental information provided by the NMPNS in letter December 13,2010 (ADAMS Accession No. ML 103500364), the Nuclear Regulatory Commission (NRC) staff has determined that additional information is needed to support its review. Enclosed is the NRC staff's request for additional information (RAI). The RAI was discussed with your staff on January 27 and February 8, 2011, and it was agreed that your response would be provided within 60 days from the date of this letter. Sincerely, Ira! Richard V. Guzman, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-410  
NINE MILE POINT NUCLEAR STATION, LLC NINE MILE POINT NUCLEAR STATION, UNIT NO.2 DOCKET NO. 50~410 By letter dated May 27, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML091610103), Nine Mile Point Nuclear Station, LLC (NMPNS or the licensee) submitted a license amendment request (LAR) for Nine Mile Point. Unit No.2 (NMP2).
The proposed amendment requests an increase in the maximum steady~state power level at NMP2 from 3467 megawatts thermal (MWt) to 3966 MWt. This represents a 15-percent increase over the current licensed thermal power.
Based on its review of the license amendment request and the supplemental information provided by the NMPNS in letter dated December 13. 2010 (ADAMS Accession No. ML103500364), the Nuclear Regulatory Commission staff has determined that additional information requested below will be needed to support its review.
: 1. In letter dated December 13,2010, the licensee stated that:
All fuel assembly types were analyzed using CASM04 at 4.95% enrichment (including the manufacturing tolerance of +/- 0.05% enrichment which is equivalent to the 5.0% enrichment discussed in NMP2 Updated Safety Analysis Report Section 9.1.2.2).
The above statement appears inadequate to support an enrichment of 5.0%. Analysis at 4.95%
with a +/- 0.05% tolerance would justify an enrichment of 4.95%. By the same reason, the updated safety analysis report also appears inadequate. Clarify this statement.
The various submittals lack clarity of the licensed enrichment limit. The NMP2 power uprate safety analysis report (PUSAR) Table 2.6~10 specifies 5.0%. PUSAR Table 2.6~10 specifies 4.9%. The letter dated December 13. 2010, specifies 4.95%. What is the enrichment limit justified by analysiS? Specify this limit in the Technical Specifications (TSs) in accordance with Title 10 of the Code of Federal Regulations, (10 CFR) Section 50.36.
: 2. In letter dated December 13, 2010, the licensee stated that:
The current GE14 fuel lattice design satisfies the NMP2 new fuel vault storage criteria outlined in Technical Specification (TS) Section 4.3 provided that the peak, in~core eigenvalue of any constituent fuel lattice, as computed by either the GNF lattice physics codes TGBLA04A or TGBLA06A, does not exceed 1.29.
However. the PUSAR lists a peak in-core eigenvalue limit of 1.3392. Clarify this discrepancy and specify this limit in the TSs in accordance with 10 CFR 50.36. In addition, provide the in-Enclosure
 
                                                  -2 rack maximum k-effective for new fuel storage determined by analysis and the supporting analysis.
: 3. On page 3 of Attachment 1 of its response dated December 13, 2010, the licensee states that NMP2 added 10 new Holtec Boral spent fuel storage racks in the NMP2 spent fuel pool as part of the Phase I re-rack via a 10 CFR 50.59 evaluation. Afterward, NMP2 performed the Phase II re-rack, similarly using a 10 CFR 50.59 evaluation in support of the modification, which replaced 16 original Boraflex spent fuel storage racks with Holtec Boral racks. The licensee further stated that the new Boral spent fuel storage racks are incorporated into the criticality analysis that has been submitted in support of NMPZs EPU LAR. It is not clear to the NRC staff how the licensee can ensure that the Boral material will continue to perform its intended function in the future. As such, please discuss how the neutron absorber will be monitored and maintained (e.g. use of surveillance program). If a program is utilized, discuss in detail the approach that will be used in the monitoring program, specifically the methods and techniques utilized (e.g., visual, weight, volumetric, surface inspection, neutron attenuation testing), frequency of inspection, sample size, data collection and acceptance criteria.
: a. Please indicate the installation date for new and replacement Boral storage racks.
: b. Please discuss whether NMP2 utilizes a Boral coupon program for the new and replacement Boral storage racks. If a coupon program is being used, please describe the program. Specifically:
(i)    Identify the quantity and location of coupons relative to the spent fuel racks.
(ii)    Describe how the coupons are mounted and whether they are fully exposed to the spent fuel pool water.
(iii)  Discuss whether any coupons that are removed and inspected using non destructive techniques will be re-inserted in the spent fuel pool for future evaluation.
(iv)    Indicate whether the Boral racks in the spent fuel pool are vented or not.
: 4. Please describe how the areal density of the Boral material will be measured (e.g., neutron attenuation) and maintained to prevent an inadvertent criticality. Please include a description of the testing, parameters measured, calculations, and acceptance criteria.
 
ML103500364), the Nuclear Regulatory Commission (NRC) staff has determined that additional information is needed to support its review. Enclosed is the NRC staff's request for additional information (RAI). The RAI was discussed with your staff on January 27 and February 8, 2011, and it was agreed that your response would be provided within 60 days from the date of this letter.
Sincerely, Ira!
Richard V. Guzman, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-410


==Enclosure:==
==Enclosure:==


As stated cc w/encl: Distribution via Listserv DISTRIBUTION:
As stated cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC RidsNrrPMNineMilePoint RidsNrrLASLiUle RidsNrrDorlLpl1-1 LPLI-1 RlF RidsOGCRp RidsRgn 1 MailCenter RidsNrrDssSrxb TNakanishi, NRR EWong, NRR AObodoako, NRR RidsNrrDeCsgb RidsNrrAcrsAcnw&mMailCenter ADAMS A . 0.: ML110400037  
PUBLIC                 RidsNrrPMNineMilePoint             RidsNrrLASLiUle         RidsNrrDorlLpl1-1 LPLI-1 RlF             RidsOGCRp                           RidsRgn 1MailCenter      RidsNrrDssSrxb TNakanishi, NRR         EWong, NRR                         AObodoako, NRR           RidsNrrDeCsgb RidsNrrAcrsAcnw&mMailCenter ADAMS Accesslon . N0.: ML110400037 *RAI provi'd edb>y memo. No su b    t flal h San      c anges made.
*RAI provi >y memo. o su btflh c anges ma e. ccesslon 'd e db N S an la d NRR 088 [OFFICE LPL1-1/PM LPL1-1/LA CSGB/BC SRXB/BC LPL 1-1/BC NAME RGuzman SUttle RTaylor' AUlses' NSalgado DATE 2/9/11 2/9/11 1/20/11 Memo DTD 1/12/11 Memo DTD 219/11 OFFICIAL RECORD COPY}}
NRR 088
[OFFICE     LPL1-1/PM         LPL1-1/LA         CSGB/BC             SRXB/BC             LPL 1-1/BC NAME       RGuzman           SUttle             RTaylor'           AUlses'             NSalgado DATE       2/9/11           2/9/11             1/20/11 Memo DTD   1/12/11 Memo DTD   219/11}}

Latest revision as of 07:05, 11 March 2020

Request for Additional Information Extended Power Uprate - Safety Systems and Component Integrity Review
ML110400037
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 02/09/2011
From: Richard Guzman
Division of Operating Reactor Licensing
To: Belcher S
Nine Mile Point
Guzman R, NRR/DORL, 415-1030
References
TAC ME1476
Download: ML110400037 (4)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 9, 2011 Mr. Samuel L. Belcher Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING NINE MILE POINT NUCLEAR STATION, UNIT NO.2 - RE: THE LICENSE AMENDMENT REQUEST FOR EXTENDED POWER UPRATE OPERATION (TAC NO. ME1476)

Dear Mr. Belcher:

By letter dated May 27, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML091610103), Nine Mile Point Nuclear Station, LLC (NMPNS or the licensee) submitted a license amendment request (LAR) for Nine Mile Point, Unit No.2 (NMP2).

The proposed amendment requests an increase in the maximum steady-state power level at NMP2 from 3467 megawatts thermal (MWt) to 3988 MWt. This represents a 15-percent increase over the current licensed thermal power.

Based on its review of the LAR and the supplemental information provided by the NMPNS in letter December 13, 2010 (ADAMS Accession No. ML103500364), the Nuclear Regulatory Commission (NRC) staff has determined that additional information is needed to support its review. Enclosed is the NRC staff's request for additional information (RAI). The RAI was discussed with your staff on January 27 and February 8, 2011, and it was agreed that your response would be provided within 60 days from the date of this letter.

Sincerely, Richard V. Guzman, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-410

Enclosure:

As stated cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION (RAn FOR LICENSE AMENDMENT REQUEST RE: EXTENDED POWER UPRATE (EPU)

NINE MILE POINT NUCLEAR STATION, LLC NINE MILE POINT NUCLEAR STATION, UNIT NO.2 DOCKET NO. 50~410 By letter dated May 27, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML091610103), Nine Mile Point Nuclear Station, LLC (NMPNS or the licensee) submitted a license amendment request (LAR) for Nine Mile Point. Unit No.2 (NMP2).

The proposed amendment requests an increase in the maximum steady~state power level at NMP2 from 3467 megawatts thermal (MWt) to 3966 MWt. This represents a 15-percent increase over the current licensed thermal power.

Based on its review of the license amendment request and the supplemental information provided by the NMPNS in letter dated December 13. 2010 (ADAMS Accession No. ML103500364), the Nuclear Regulatory Commission staff has determined that additional information requested below will be needed to support its review.

1. In letter dated December 13,2010, the licensee stated that:

All fuel assembly types were analyzed using CASM04 at 4.95% enrichment (including the manufacturing tolerance of +/- 0.05% enrichment which is equivalent to the 5.0% enrichment discussed in NMP2 Updated Safety Analysis Report Section 9.1.2.2).

The above statement appears inadequate to support an enrichment of 5.0%. Analysis at 4.95%

with a +/- 0.05% tolerance would justify an enrichment of 4.95%. By the same reason, the updated safety analysis report also appears inadequate. Clarify this statement.

The various submittals lack clarity of the licensed enrichment limit. The NMP2 power uprate safety analysis report (PUSAR) Table 2.6~10 specifies 5.0%. PUSAR Table 2.6~10 specifies 4.9%. The letter dated December 13. 2010, specifies 4.95%. What is the enrichment limit justified by analysiS? Specify this limit in the Technical Specifications (TSs) in accordance with Title 10 of the Code of Federal Regulations, (10 CFR) Section 50.36.

2. In letter dated December 13, 2010, the licensee stated that:

The current GE14 fuel lattice design satisfies the NMP2 new fuel vault storage criteria outlined in Technical Specification (TS) Section 4.3 provided that the peak, in~core eigenvalue of any constituent fuel lattice, as computed by either the GNF lattice physics codes TGBLA04A or TGBLA06A, does not exceed 1.29.

However. the PUSAR lists a peak in-core eigenvalue limit of 1.3392. Clarify this discrepancy and specify this limit in the TSs in accordance with 10 CFR 50.36. In addition, provide the in-Enclosure

-2 rack maximum k-effective for new fuel storage determined by analysis and the supporting analysis.

3. On page 3 of Attachment 1 of its response dated December 13, 2010, the licensee states that NMP2 added 10 new Holtec Boral spent fuel storage racks in the NMP2 spent fuel pool as part of the Phase I re-rack via a 10 CFR 50.59 evaluation. Afterward, NMP2 performed the Phase II re-rack, similarly using a 10 CFR 50.59 evaluation in support of the modification, which replaced 16 original Boraflex spent fuel storage racks with Holtec Boral racks. The licensee further stated that the new Boral spent fuel storage racks are incorporated into the criticality analysis that has been submitted in support of NMPZs EPU LAR. It is not clear to the NRC staff how the licensee can ensure that the Boral material will continue to perform its intended function in the future. As such, please discuss how the neutron absorber will be monitored and maintained (e.g. use of surveillance program). If a program is utilized, discuss in detail the approach that will be used in the monitoring program, specifically the methods and techniques utilized (e.g., visual, weight, volumetric, surface inspection, neutron attenuation testing), frequency of inspection, sample size, data collection and acceptance criteria.
a. Please indicate the installation date for new and replacement Boral storage racks.
b. Please discuss whether NMP2 utilizes a Boral coupon program for the new and replacement Boral storage racks. If a coupon program is being used, please describe the program. Specifically:

(i) Identify the quantity and location of coupons relative to the spent fuel racks.

(ii) Describe how the coupons are mounted and whether they are fully exposed to the spent fuel pool water.

(iii) Discuss whether any coupons that are removed and inspected using non destructive techniques will be re-inserted in the spent fuel pool for future evaluation.

(iv) Indicate whether the Boral racks in the spent fuel pool are vented or not.

4. Please describe how the areal density of the Boral material will be measured (e.g., neutron attenuation) and maintained to prevent an inadvertent criticality. Please include a description of the testing, parameters measured, calculations, and acceptance criteria.

ML103500364), the Nuclear Regulatory Commission (NRC) staff has determined that additional information is needed to support its review. Enclosed is the NRC staff's request for additional information (RAI). The RAI was discussed with your staff on January 27 and February 8, 2011, and it was agreed that your response would be provided within 60 days from the date of this letter.

Sincerely, Ira!

Richard V. Guzman, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-410

Enclosure:

As stated cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsNrrPMNineMilePoint RidsNrrLASLiUle RidsNrrDorlLpl1-1 LPLI-1 RlF RidsOGCRp RidsRgn 1MailCenter RidsNrrDssSrxb TNakanishi, NRR EWong, NRR AObodoako, NRR RidsNrrDeCsgb RidsNrrAcrsAcnw&mMailCenter ADAMS Accesslon . N0.: ML110400037 *RAI provi'd edb>y memo. No su b t flal h San c anges made.

NRR 088

[OFFICE LPL1-1/PM LPL1-1/LA CSGB/BC SRXB/BC LPL 1-1/BC NAME RGuzman SUttle RTaylor' AUlses' NSalgado DATE 2/9/11 2/9/11 1/20/11 Memo DTD 1/12/11 Memo DTD 219/11