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| number = ML093210248
| number = ML093210248
| issue date = 12/01/2009
| issue date = 12/01/2009
| title = Millstone Power Station, Unit No. 3 - Request for Additional Information Regarding Third 10-Year Interval Inservice Inspection Program Relief Request IR-3-01 (TAC No. ME1254)
| title = Request for Additional Information Regarding Third 10-Year Interval Inservice Inspection Program Relief Request IR-3-01
| author name = Sanders C J
| author name = Sanders C
| author affiliation = NRC/NRR/DORL/LPLI-2
| author affiliation = NRC/NRR/DORL/LPLI-2
| addressee name = Heacock D A
| addressee name = Heacock D
| addressee affiliation = Dominion Nuclear Connecticut, Inc
| addressee affiliation = Dominion Nuclear Connecticut, Inc
| docket = 05000423
| docket = 05000423
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555*0001 December 1, 2009 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Nuclear Connecticut, Inc. Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711 MILLSTONE POWER STATION, UNIT NO.3 -REQUEST FOR ADDITIONAL INFORMATION REGARDING THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST IR-3-01 (TAC NO. ME1254)  
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 December 1, 2009 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Nuclear Connecticut, Inc.
Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711
 
==SUBJECT:==
MILLSTONE POWER STATION, UNIT NO.3 - REQUEST FOR ADDITIONAL INFORMATION REGARDING THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST IR-3-01 (TAC NO. ME1254)


==Dear Mr. Heacock:==
==Dear Mr. Heacock:==


By letter dated April 28, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML091310666), Dominion Nuclear Connecticut, Inc. (DNC), submitted relief request IR-3-01 for Millstone Power Station, Unit NO.3 (MPS3). DNC requested relief from certain examination requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section XI, and proposed alternative examination criterion for the third 10-year in-service inspection interval which began on April 23, 2009, and ends on April 22, 2019. IR-3-01 requests alternatives to the examination and testing requirements of Code Class 1, 2, 3, and MC Snubbers. To complete its review, the Nuclear Regulatory Commission staff requests responses to the enclosed questions. The draft questions were sent to Mr. William Bartron, of your staff, to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. On November 19, 2009, Mr. Muhamed Elmaghrabi, of your staff, agreed that you would provide a response by Decernberts.
By letter dated April 28, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML091310666), Dominion Nuclear Connecticut, Inc. (DNC), submitted relief request IR-3-01 for Millstone Power Station, Unit NO.3 (MPS3). DNC requested relief from certain examination requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section XI, and proposed alternative examination criterion for the third 10-year in-service inspection interval which began on April 23, 2009, and ends on April 22, 2019. IR-3-01 requests alternatives to the examination and testing requirements of Code Class 1, 2, 3, and MC Snubbers. To complete its review, the Nuclear Regulatory Commission staff requests responses to the enclosed questions.
2009. If you have any questions regarding this matter, please contact me at 301-415-1603.  
The draft questions were sent to Mr. William Bartron, of your staff, to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. On November 19, 2009, Mr. Muhamed Elmaghrabi, of your staff, agreed that you would provide a response by Decernberts. 2009.
'r:   3. anders, Project Manager Plant Li e sing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-423  
If you have any questions regarding this matter, please contact me at 301-415-1603.
                                              'r:                   ~
                                                ~e        3. anders, Project Manager Plant Li e sing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-423


==Enclosure:==
==Enclosure:==
As stated cc w/encl: Distribution via Listserv REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST NO. IR-3-01 SNUBBER INSPECTION AND TESTING THIRD 10-YEAR INSERVICE INSPECTION INTERVAL DOMINION NUCLEAR CONNECTICUT, INC MILLSTONE POWER STATION, UNIT NO.3 DOCKET NO. 50-423 By letter dated April 28, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML09131 0666), Dominion Nuclear Connecticut, Inc. (DNC or the licensee), submitted relief request IR-3-01 for Millstone Power Station, Unit NO.3 (MPS3). DNC requested relief from certain examination requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section XI, and proposed alternative examination criterion for the third 1O-year in-service inspection (lSI) interval which began on April 23, 2009, and ends on April 22, 2019. IR-3-01 requests alternatives to the examination and testing requirements of Code Class 1,2,3, and MC Snubbers. To complete its review, the Nuclear Regulatory Commission (NRC) staff requests responses to the questions provided below. The licensee requested an alternative to the requirements of IWF-5300 of Article 5000. Article IWF-5000 also contains requirements for snubber preservice examinations and tests in IWF-5200. Please explain how the requirements of IWF-5200(a), (b), and (c) will be met. The second paragraph of Section 5 of IR-3-01 states that "An alternative schedule for visual inspections has been developed that maintains the same confidence level as the existing schedule and generally will allow performance of inspections and corrective actions during plant outages. This schedule is given in [TS] Table 4.7-2 [Snubber Visual Inspection Interval], invoked from MPS3 TS 4.7.10.b. Because it will reduce future occupational radiation exposure and is highly cost effective, this is consistent with NRC policy." Please explain how TS Table 4.7-2 meets the schedule as specified in OM-4. IWF-5000, Subarticle IWF-5400, "Repairs and Replacement," requires that repair or replacement of snubbers shall be in accordance with IWA-4000 and that repaired or replacement snubbers shall be examined and tested in accordance with the applicable requirements of Subarticle IWF-5200 prior to return to service. Please explain how MPS3, TS SR 4.7.10, meets the requirements of IWF-5400. Please explain how snubber functional tests, in accordance with MPS3 TS Figure 4.7-1, as specified in TS SR 4.7.10.e(2), meets the functional test requirements of the "37 testing sample plan" Figure C1 of Appendix C of the OMa-1988. MPS3 TS SR 4.7.1 O.e uses functional testing sample plans: (1) 10% sample plan; (2) sample plan based on Figure 4.7-1; and (3) 55 sample plan. Please explain when using Figure 4.7-1 (see question 5 above) or the 55 sample plan, that the additional sampling Enclosure
 
-2of at least one-half the size of the initial sample lot requirement of Section 3.2.3.2(b) of the OM-4 will be met. The requested alternative and TS SR 4.7.10 do not address the requirements of OM-4, Section 3.2.4, related to functional testing of snubbers, specifically Section 3.2.4.2, "Test Failure Mode Groups." Please explain how the MPS3 TS meets this requirement. The applicable Code for the MPS3 lSI program is ASME Section XI, 2004 Edition. Please explain how MPS3 meets the requirements of IWA-6230, "Summary Report Preparation," for snubber visual examination and testing.
As stated cc w/encl: Distribution via Listserv
December 1, 2009 Mr. David A.
 
Heacock President and Chief Nuclear Officer Dominion Nuclear Connecticut, Inc. Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711 MILLSTONE POWER STATION, UNIT NO.3 -REQUEST FOR ADDITIONAL INFORMATION REGARDING THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST IR-3-01 (TAC NO. ME1254)  
REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST NO. IR-3-01 SNUBBER INSPECTION AND TESTING THIRD 10-YEAR INSERVICE INSPECTION INTERVAL DOMINION NUCLEAR CONNECTICUT, INC MILLSTONE POWER STATION, UNIT NO.3 DOCKET NO. 50-423 By letter dated April 28, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML091310666), Dominion Nuclear Connecticut, Inc. (DNC or the licensee), submitted relief request IR-3-01 for Millstone Power Station, Unit NO.3 (MPS3). DNC requested relief from certain examination requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section XI, and proposed alternative examination criterion for the third 1O-year in-service inspection (lSI) interval which began on April 23, 2009, and ends on April 22, 2019. IR-3-01 requests alternatives to the examination and testing requirements of Code Class 1,2,3, and MC Snubbers. To complete its review, the Nuclear Regulatory Commission (NRC) staff requests responses to the questions provided below.
: 1.      The licensee requested an alternative to the requirements of IWF-5300 of Article IWF 5000. Article IWF-5000 also contains requirements for snubber preservice examinations and tests in IWF-5200. Please explain how the requirements of IWF-5200(a), (b), and (c) will be met.
: 2.      The second paragraph of Section 5 of IR-3-01 states that "An alternative schedule for visual inspections has been developed that maintains the same confidence level as the existing schedule and generally will allow performance of inspections and corrective actions during plant outages. This schedule is given in [TS] Table 4.7-2 [Snubber Visual Inspection Interval], invoked from MPS3 TS 4.7.10.b. Because it will reduce future occupational radiation exposure and is highly cost effective, this is consistent with NRC policy." Please explain how TS Table 4.7-2 meets the schedule as specified in OM-4.
: 3.      IWF-5000, Subarticle IWF-5400, "Repairs and Replacement," requires that repair or replacement of snubbers shall be in accordance with IWA-4000 and that repaired or replacement snubbers shall be examined and tested in accordance with the applicable requirements of Subarticle IWF-5200 prior to return to service. Please explain how MPS3, TS SR 4.7.10, meets the requirements of IWF-5400.
: 4.      Please explain how snubber functional tests, in accordance with MPS3 TS Figure 4.7-1, as specified in TS SR 4.7.10.e(2), meets the functional test requirements of the "37 testing sample plan" Figure C1 of Appendix C of the OMa-1988.
: 5.      MPS3 TS SR 4.7.1O.e uses functional testing sample plans: (1) 10% sample plan; (2) sample plan based on Figure 4.7-1; and (3) 55 sample plan. Please explain when using Figure 4.7-1 (see question 5 above) or the 55 sample plan, that the additional sampling Enclosure
 
                                              -2 of at least one-half the size of the initial sample lot requirement of Section 3.2.3.2(b) of the OM-4 will be met.
: 7. The requested alternative and TS SR 4.7.10 do not address the requirements of OM-4, Section 3.2.4, related to functional testing of snubbers, specifically Section 3.2.4.2, "Test Failure Mode Groups." Please explain how the MPS3 TS meets this requirement.
: 8. The applicable Code for the MPS3 lSI program is ASME Section XI, 2004 Edition.
Please explain how MPS3 meets the requirements of IWA-6230, "Summary Report Preparation," for snubber visual examination and testing.
 
December 1, 2009 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Nuclear Connecticut, Inc.
Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711
 
==SUBJECT:==
MILLSTONE POWER STATION, UNIT NO.3 - REQUEST FOR ADDITIONAL INFORMATION REGARDING THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST IR-3-01 (TAC NO. ME1254)


==Dear Mr. Heacock:==
==Dear Mr. Heacock:==
By letter dated April 28, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML091310666), Dominion Nuclear Connecticut, Inc. (DNC), submitted relief request IR-3-01 for Millstone Power Station, Unit NO.3 (MPS3). DNC requested relief from certain examination requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section XI, and proposed alternative examination criterion for the third 10-year in-service inspection interval which began on April 23, 2009, and ends on April 22, 2019. IR-3-01 requests alternatives to the examination and testing requirements of Code Class 1,2,3, and MC Snubbers. To complete its review, the Nuclear Regulatory Commission staff requests responses to the enclosed questions. The draft questions were sent to Mr. William Bartron, of your staff, to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed.
 
On November 19, 2009, Mr. Bartron agreed that you would provide a response by December 18, 2009. If you have any questions regarding this matter, please contact me at 301-415-1603.
By letter dated April 28, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML091310666), Dominion Nuclear Connecticut, Inc. (DNC), submitted relief request IR-3-01 for Millstone Power Station, Unit NO.3 (MPS3). DNC requested relief from certain examination requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section XI, and proposed alternative examination criterion for the third 10-year in-service inspection interval which began on April 23, 2009, and ends on April 22, 2019. IR-3-01 requests alternatives to the examination and testing requirements of Code Class 1,2,3, and MC Snubbers. To complete its review, the Nuclear Regulatory Commission staff requests responses to the enclosed questions.
Sincerely, Ira! Carleen J. Sanders, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-423  
The draft questions were sent to Mr. William Bartron, of your staff, to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. On November 19, 2009, Mr. Bartron agreed that you would provide a response by December 18, 2009.
If you have any questions regarding this matter, please contact me at 301-415-1603.
Sincerely, Ira!
Carleen J. Sanders, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-423


==Enclosure:==
==Enclosure:==
As stated cc w/encl:
 
Distribution via Listserv Distribution:
As stated cc w/encl: Distribution via Listserv Distribution:
PUBLIC Branch Reading RidsAcrsAcnw MailCTR Resource RidsNrrDorlDpr Resource RidsNrrDorlLpl1-2 Resource RidsNrrCptb Resource RidsNrrLAABaxter Resource RidsNrrPMMilistone Resource RidsOgcRp Resource RidsRgn1 MailCenter Resource GBedi, NRR ADAMS Accession No 'ML09321 0248
PUBLIC                                                   Branch Reading RidsAcrsAcnw MailCTR Resource                             RidsNrrDorlDpr Resource RidsNrrDorlLpl1-2 Resource                               RidsNrrCptb Resource RidsNrrLAABaxter Resource                                 RidsNrrPMMilistone Resource RidsOgcRp Resource                                       RidsRgn1 MailCenter Resource GBedi, NRR ADAMS Accession No ..'ML093210248 OFFICE                 LPL 1-2/PM         LPL 1-2/LA           DCI/CPTB/BC       LPL 1-2/BC NAME                   CSanders           ABaxter               STingen for       HChernoff JMcHaie DATE                   11/20/09; 11/30/09 11/24/09             08/04/2009         12/1/09 Official Record Copy}}
.. OFFICE LPL 1-2/PM LPL 1-2/LA DCI/CPTB/BC LPL1-2/BC NAME CSanders ABaxter STingen for JMcHaie HChernoff DATE 11/20/09; 11/30/09 11/24/09 08/04/2009 12/1/09 ..Official Record Copy}}

Latest revision as of 21:21, 21 March 2020

Request for Additional Information Regarding Third 10-Year Interval Inservice Inspection Program Relief Request IR-3-01
ML093210248
Person / Time
Site: Millstone Dominion icon.png
Issue date: 12/01/2009
From: Sanders C
Plant Licensing Branch 1
To: Heacock D
Dominion Nuclear Connecticut
Sandeers, Carleen, NRR/DORL, 415-1603
References
TAC ME1254, FOIA/PA-2011-0115
Download: ML093210248 (4)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 December 1, 2009 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Nuclear Connecticut, Inc.

Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

MILLSTONE POWER STATION, UNIT NO.3 - REQUEST FOR ADDITIONAL INFORMATION REGARDING THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST IR-3-01 (TAC NO. ME1254)

Dear Mr. Heacock:

By letter dated April 28, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML091310666), Dominion Nuclear Connecticut, Inc. (DNC), submitted relief request IR-3-01 for Millstone Power Station, Unit NO.3 (MPS3). DNC requested relief from certain examination requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, and proposed alternative examination criterion for the third 10-year in-service inspection interval which began on April 23, 2009, and ends on April 22, 2019. IR-3-01 requests alternatives to the examination and testing requirements of Code Class 1, 2, 3, and MC Snubbers. To complete its review, the Nuclear Regulatory Commission staff requests responses to the enclosed questions.

The draft questions were sent to Mr. William Bartron, of your staff, to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. On November 19, 2009, Mr. Muhamed Elmaghrabi, of your staff, agreed that you would provide a response by Decernberts. 2009.

If you have any questions regarding this matter, please contact me at 301-415-1603.

'r: ~

~e 3. anders, Project Manager Plant Li e sing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-423

Enclosure:

As stated cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST NO. IR-3-01 SNUBBER INSPECTION AND TESTING THIRD 10-YEAR INSERVICE INSPECTION INTERVAL DOMINION NUCLEAR CONNECTICUT, INC MILLSTONE POWER STATION, UNIT NO.3 DOCKET NO. 50-423 By letter dated April 28, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML091310666), Dominion Nuclear Connecticut, Inc. (DNC or the licensee), submitted relief request IR-3-01 for Millstone Power Station, Unit NO.3 (MPS3). DNC requested relief from certain examination requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, and proposed alternative examination criterion for the third 1O-year in-service inspection (lSI) interval which began on April 23, 2009, and ends on April 22, 2019. IR-3-01 requests alternatives to the examination and testing requirements of Code Class 1,2,3, and MC Snubbers. To complete its review, the Nuclear Regulatory Commission (NRC) staff requests responses to the questions provided below.

1. The licensee requested an alternative to the requirements of IWF-5300 of Article IWF 5000. Article IWF-5000 also contains requirements for snubber preservice examinations and tests in IWF-5200. Please explain how the requirements of IWF-5200(a), (b), and (c) will be met.
2. The second paragraph of Section 5 of IR-3-01 states that "An alternative schedule for visual inspections has been developed that maintains the same confidence level as the existing schedule and generally will allow performance of inspections and corrective actions during plant outages. This schedule is given in [TS] Table 4.7-2 [Snubber Visual Inspection Interval], invoked from MPS3 TS 4.7.10.b. Because it will reduce future occupational radiation exposure and is highly cost effective, this is consistent with NRC policy." Please explain how TS Table 4.7-2 meets the schedule as specified in OM-4.
3. IWF-5000, Subarticle IWF-5400, "Repairs and Replacement," requires that repair or replacement of snubbers shall be in accordance with IWA-4000 and that repaired or replacement snubbers shall be examined and tested in accordance with the applicable requirements of Subarticle IWF-5200 prior to return to service. Please explain how MPS3, TS SR 4.7.10, meets the requirements of IWF-5400.
4. Please explain how snubber functional tests, in accordance with MPS3 TS Figure 4.7-1, as specified in TS SR 4.7.10.e(2), meets the functional test requirements of the "37 testing sample plan" Figure C1 of Appendix C of the OMa-1988.
5. MPS3 TS SR 4.7.1O.e uses functional testing sample plans: (1) 10% sample plan; (2) sample plan based on Figure 4.7-1; and (3) 55 sample plan. Please explain when using Figure 4.7-1 (see question 5 above) or the 55 sample plan, that the additional sampling Enclosure

-2 of at least one-half the size of the initial sample lot requirement of Section 3.2.3.2(b) of the OM-4 will be met.

7. The requested alternative and TS SR 4.7.10 do not address the requirements of OM-4, Section 3.2.4, related to functional testing of snubbers, specifically Section 3.2.4.2, "Test Failure Mode Groups." Please explain how the MPS3 TS meets this requirement.
8. The applicable Code for the MPS3 lSI program is ASME Section XI, 2004 Edition.

Please explain how MPS3 meets the requirements of IWA-6230, "Summary Report Preparation," for snubber visual examination and testing.

December 1, 2009 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Nuclear Connecticut, Inc.

Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

MILLSTONE POWER STATION, UNIT NO.3 - REQUEST FOR ADDITIONAL INFORMATION REGARDING THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST IR-3-01 (TAC NO. ME1254)

Dear Mr. Heacock:

By letter dated April 28, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML091310666), Dominion Nuclear Connecticut, Inc. (DNC), submitted relief request IR-3-01 for Millstone Power Station, Unit NO.3 (MPS3). DNC requested relief from certain examination requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, and proposed alternative examination criterion for the third 10-year in-service inspection interval which began on April 23, 2009, and ends on April 22, 2019. IR-3-01 requests alternatives to the examination and testing requirements of Code Class 1,2,3, and MC Snubbers. To complete its review, the Nuclear Regulatory Commission staff requests responses to the enclosed questions.

The draft questions were sent to Mr. William Bartron, of your staff, to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. On November 19, 2009, Mr. Bartron agreed that you would provide a response by December 18, 2009.

If you have any questions regarding this matter, please contact me at 301-415-1603.

Sincerely, Ira!

Carleen J. Sanders, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-423

Enclosure:

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

PUBLIC Branch Reading RidsAcrsAcnw MailCTR Resource RidsNrrDorlDpr Resource RidsNrrDorlLpl1-2 Resource RidsNrrCptb Resource RidsNrrLAABaxter Resource RidsNrrPMMilistone Resource RidsOgcRp Resource RidsRgn1 MailCenter Resource GBedi, NRR ADAMS Accession No ..'ML093210248 OFFICE LPL 1-2/PM LPL 1-2/LA DCI/CPTB/BC LPL 1-2/BC NAME CSanders ABaxter STingen for HChernoff JMcHaie DATE 11/20/09; 11/30/09 11/24/09 08/04/2009 12/1/09 Official Record Copy