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| number = ML15065A320
| number = ML15065A320
| issue date = 03/06/2015
| issue date = 03/06/2015
| title = Ltr 03/06/15 LaSalle, Units 1 & 2 - Notification of an NRC Triennial Heat Sink Performance Inspection - Request for Information Inspection Report 05000373/2015002; 05000374/2015002
| title = Notification of an NRC Triennial Heat Sink Performance Inspection - Request for Information Inspection Report 05000373/2015002; 05000374/2015002
| author name = Lipa C A
| author name = Lipa C
| author affiliation = NRC/RGN-III/DRS/EB2
| author affiliation = NRC/RGN-III/DRS/EB2
| addressee name = Hanson B C
| addressee name = Hanson B
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| docket = 05000373, 05000374
| docket = 05000373, 05000374
Line 14: Line 14:
| page count = 8
| page count = 8
}}
}}
See also: [[followed by::IR 05000373/2015002]]
See also: [[see also::IR 05000373/2015002]]


=Text=
=Text=
{{#Wiki_filter:UNITED STATES
{{#Wiki_filter:UNITED STATES
NUCLEAR REGULATORY COMMISSION
                            NUCLEAR REGULATORY COMMISSION
REGION III 2443 WARRENVILLE RD. SUIT
                                                REGION III
E 210 LISLE, IL 60532
                                    2443 WARRENVILLE RD. SUITE 210
-4352 March 6, 2015
                                          LISLE, IL 60532-4352
  Mr. Bryan C. Hanson
                                            March 6, 2015
Senior VP, Exelon Generation Company,  
Mr. Bryan C. Hanson
LLC President and CNO, Exelon Nuclear
Senior VP, Exelon Generation Company, LLC
4300 Winfield Road
President and CNO, Exelon Nuclear
Warrenville, IL 60555
4300 Winfield Road
SUBJECT: LASALLE COUNTY STATION, UNITS 1 AND 2
Warrenville, IL 60555
- NOTIFICATION OF AN N
SUBJECT: LASALLE COUNTY STATION, UNITS 1 AND 2 - NOTIFICATION OF AN NRC
RC TRIENNIAL HEAT SINK PERFORMANCE INSPECTION
              TRIENNIAL HEAT SINK PERFORMANCE INSPECTION - REQUEST FOR
- REQUEST FO
              INFORMATION INSPECTION REPORT 05000373/2015002; 05000374/2015002
R INFORMATION
Dear Mr. Hanson:
INSPECTION
On April 20, 2015, the U.S. Nuclear Regulatory Commission (NRC) will begin the onsite
REPORT 05000373/20
portion of the Triennial Heat Sink Performance Inspection at your LaSalle County Station,
15002; 05000374/20
Units 1 and 2. This inspection will be performed in accordance with NRC Baseline Inspection
15002 Dear Mr. Hanson:
Procedure (IP) 71111.07.
On April 20, 2015, the U.S. Nuclear Regulatory Commission (
In order to minimize the impact that the inspection has on the site, and to ensure a productive
NRC) will begin the onsite portion of the  
inspection, we have enclosed a request for documents needed for the inspection. The
Triennial Heat Sink Performance Inspection at your LaSalle County Station, Units 1 and 2. This inspection will be performed in accordance with NRC Baseline Inspection Procedure
documents have been divided into three groups:
(IP) 71111.07.
The first group lists information necessary for our initial inspection scoping activities. This
In order to minimize the impact that the inspection has on the site
information should be available to the lead inspector no later than March 25, 2015. By
, and to ensure a productive inspection, we have enclosed a request for documents needed for the inspection. The  
April 1, 2015, the inspector will communicate the initial selected set of approximately
documents have been divided into three groups
: The first group lists information necessary for our initial inspection scoping activities. This information should be available to the lead inspector no later than March 25, 2015. By April 1, 2015, the inspector will communicate the initial selected set of approximately  
1-2 risk-significant heat exchangers.
1-2 risk-significant heat exchangers.
The second group  
The second group is needed to support our in-office preparation activities. This set of
is needed to support our in
documents, including the calculations associated with the selected heat exchangers, should
-office preparation activities. This set of documents, including the calculations associated with the selected heat exchangers, should
be available at the Regional Office no later than April 10, 2015. This information should be
be available at the Regional Office no later than April 10, 2015. This information should be separated for each selected component, especially if provided electronically (e.g., folder with  
separated for each selected component, especially if provided electronically (e.g., folder with
component name that includes calculations, condition reports, maintenance history, etc
component name that includes calculations, condition reports, maintenance history, etc.).
.). During the in
During the in-office preparation activities, the inspector may identify additional information
-office preparation activities, the inspector may identify additional information needed to support the inspection.
needed to support the inspection.
The last group includes the additional information above as well as plant
The last group includes the additional information above as well as plant-specific reference
-specific reference material. This information should be available onsite to the inspector
material. This information should be available onsite to the inspector on April 20, 2015. It is
on April 20, 2015. It is also requested that corrective action documents and/or questions developed during the inspection be provided to
also requested that corrective action documents and/or questions developed during the
the inspector as the documents are generated.
inspection be provided to the inspector as the documents are generated.
All requested documents are to be for the time period from the onsite inspection period back to documents that were provided in response to the previous
All requested documents are to be for the time period from the onsite inspection period back to
Heat Sink Performance  
documents that were provided in response to the previous Heat Sink Performance Inspection.
Inspection
If no activities were accomplished in that time period, then the request applies to the last
If no activities were
applicable document in the previous time period. It is important that these documents be as
accomplished
complete as possible, in order to minimize the number of documents requested during the
in that time period, then the request applies to the last applicable document in the previous time period.
  It is important that these documents be as complete as possible, in order to minimize the number of documents requested during the  
preparation week or during the onsite inspection.
preparation week or during the onsite inspection.
 
 
B. Hanson
B. Hanson                                     -2-
-2- The lead inspector for this inspection is Mr. Andrew Dunlop
The lead inspector for this inspection is Mr. Andrew Dunlop. We understand that our regulatory
. We understand that our regulatory contact for this inspection is Mr. Larry Blunk
contact for this inspection is Mr. Larry Blunk of your organization. If there are questions about
of your organization
the material requested, or the inspection, please call Mr. Andrew Dunlop at (630) 829-9726.
. If there are questions about the material requested, or the inspection, please call Mr. Andrew Dunlop
Please send the information to the following e-mail address: Andrew.Dunlop@nrc.gov.
at (630) 829
A hard-copy with the required information is also an acceptable option.
-9726. Please send the information to the following e
This letter does not contain new or amended information collection requirements subject
-mail address
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information
: Andrew.Dunlop@nrc.gov
collection requirements were approved by the Office of Management and Budget, Control
A hard-copy with the required information is also an acceptable option.
Number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to
This letter does not contain new or amended information collection requirements subject
respond to, a request for information or an information collection requirement unless the
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.).
requesting document displays a currently valid Office of Management and Budget Control
  Existing information collection requirements were approved by the Office of Management and Budget,  
Number.
Control Number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Office of Management and Budget  
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public
Control Number. In accordance with Title 10 of the Code of Federal Regulations
Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy
  (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," of the NRC's "Rules of Practice," a copy  
of this letter, its enclosure, and your response (if any) will be available electronically for public
of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide
inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)
Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading
component of the NRC's Agencywide Documents Access and Management System (ADAMS).
-rm/adams.html
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html
(the Public Electronic Reading Room).
(the Public Electronic Reading Room).
Sincerely,
                                              Sincerely,
  /RA/   Christine  
                                              /RA/
A. Lipa, Chief Engineering Branch 2
                                              Christine A. Lipa, Chief
Division of Reactor Safety  
                                              Engineering Branch 2
Docket Nos. 50
                                              Division of Reactor Safety
-373; 50-374 License Nos.
Docket Nos. 50-373; 50-374
NPF-11; NPF-18 Enclosure:  
License Nos. NPF-11; NPF-18
Triennial Heat Sink Performance Inspection
Enclosure:
  Document Request
Triennial Heat Sink Performance Inspection
cc w/encl: Distribution via LISTSERV
  Document Request
 
cc w/encl: Distribution via LISTSERV
TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST
 
Enclosure
      TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST
Inspection Report
Inspection Report:             05000373/2015002; 05000374/2015002
: 05000373/2015002; 05000374/2015002 Inspection Dates
Inspection Dates:               April 20 - 24, 2015
: April 20  
Inspection Procedure:           IP 71111.07, Heat Sink Performance
- 24, 2015 Inspection
Lead Inspector:                 Andrew Dunlop
Procedure
                                (630) 829-9726
: IP 71111.07, "Heat Sink Performance"
                                Andrew.Dunlop@nrc.gov
Lead Inspector
I.     Information Requested By March 25, 2015
: Andrew Dunlop
    1.     List of the Generic Letter (GL) 89-13, Service Water System Problems Affecting
(630) 829
            Safety-Related Equipment, heat exchangers in order of risk significance.
-9726 Andrew.Dunlop@nrc.gov
    2.     Copy of heat exchanger performance trending data tracked for each GL 89-13 heat
I. Information Requested By March 25, 2015
            exchanger.
1. List of the Generic Letter (GL) 89
    3.     List of Corrective Action Program (CAP) documents (with a short description)
-13, "Service Water System Problems Affecting Safety-Related Equipment,"
            associated with GL 89-13 heat exchangers, heat sinks, silting, corrosion, fouling, or
heat exchangers in order of risk significance.
            heat exchanger testing, from the previous 3 years or since the last CAP document
2. Copy of heat exchanger performance trending data tracked for each GL 89
            list was sent to the NRC for the previous heat sink performance inspection. The list
-13 heat exchanger.
            should include all CAP documents not on the last CAP document list.
3. List of Corrective Action Program
    4.     Copy of any self-assessment done on any of GL 89-13 heat exchangers.
(CAP) documents (with a short description) associated with GL 89
    5.     Last 2 System Health Reports and maintenance rule system notebooks for all the
-13 heat exchangers, heat sinks, silting, corrosion, fouling, or heat exchanger testing, from the previous  
            GL 89-13 heat exchangers.
3 years or since the last CAP document list was sent to the NRC for the previous heat sink performance inspection. The list should include all  
    6.     List of engineering-related operator workarounds (with a short description)
CAP documents not on the last CAP document list.
            associated with GL 89-13 heat exchangers. The requested documents are to be for
4. Copy of any self
            the time period from the onsite inspection period back to the documents that were
-assessment done on any of GL 89
            provided in response to the previous Heat Sink Performance Inspection.
-13 heat exchangers.
    7.     List of permanent and temporary modifications (with a short description) associated
5. Last 2 System Health Reports and maintenance rule system notebooks for all the GL 89-13 heat exchangers.
            with GL 89-13 heat exchangers. The requested documents are to be for the time
6. List of engineering
            period from the onsite inspection period back to the documents that were provided in
-related operator workarounds
            response to the previous Heat Sink Performance Inspection.
(with a short description)
II.     Information Requested By April 10, 2015
associated with GL 89
    1.     Copies of the GL 89-13 responses.
-13 heat exchangers
    2.     Copy of the Updated Final Safety Analysis Report (UFSAR) section applicable to the
. The requested documents are to be for the time period from the onsite inspection period back to the
            GL 89-13 Heat Exchanger Program.
documents that were provided in response to the previous
    3.     Copies of procedures developed to implement the recommendations of GL 89-13
Heat Sink Performance  
            (e.g., the GL 89-13 Heat Exchanger Program description).
Inspection. 7. List of permanent and temporary modifications
                                                                                        Enclosure
(with a short description)
 
associated with GL 89
  TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST
-13 heat exchangers
4.     Copies of the selected CAP documents.
. The requested documents are to be for the time period from the onsite inspection period back to the
5.     For the specific heat exchangers selected:
documents that were provided in response to the previous
      a.       Copies of the UFSAR sections applicable for each heat exchanger.
Heat Sink Performance  
      b.       Copy of system description and design basis document for the heat
Inspection. II. Information Requested By April 10, 2015 1. Copies of the GL 89
                exchangers (as applicable).
-13 responses
      c.       Provide a list of calculations (with a short description) which currently apply
2. Copy of the Updated Final Safety Analysis Report  
                to each heat exchanger.
(UFSAR) section applicable to
              i.           Establish the limiting design basis heat load required to be removed
the GL 89-13 Heat Exchanger Program.
                          by each of these heat exchangers;
3. Copies of procedures developed to implement the recommendations of GL 89
            ii.           Demonstrate the heat exchangers capacity to remove the limiting
-13 (e.g., the GL 89
                          heat load;
-13 Heat Exchanger Program description).
            iii.           Correlate surveillance testing and/or inspection results from these
 
                          heat exchangers with design basis heat removal capability (e.g., basis
TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST
                          for surveillance test and/or inspection acceptance criteria);
  2 4. Copies of the selected CAP documents.
            iv.           Evaluate the potential for water hammer in each heat exchanger or
5. For the specific heat exchangers selected:
                          associated piping; and
a. Copies of the UFSAR sections applicable
            v.           Evaluate excessive tube vibration in each heat exchanger.
for each heat exchanger.
      d.       Copy of any operability determinations or other documentation of degradation
b. Copy of system description and design basis document for the heat exchangers (as applicable).
                associated with the heat exchangers or the systems that support the
c. Provide a list of calculations  
                operation for the selected heat exchangers.
(with a short description
      e.       Copy of the construction code, Design Specification, heat exchanger data
) which currently apply  
                sheets, and vendor documents including component drawings applicable for
to each heat exchanger
                the heat exchangers.
. i. Establish the limiting design basis heat load required to be removed by each of these heat exchangers;
      f.       Copies of normal, abnormal, and emergency operating procedures
ii. Demonstrate the heat exchangers capacity to remove the limiting  
                associated with the selected heat exchangers.
heat load; iii. Correlate surveillance testing and/or inspection results from these heat exchangers with design basis heat removal capability (e.g., basis for surveillance test and/or inspection acceptance criteria);
8.     For the ultimate heat sink (UHS) and the safety-related service water system
iv. Evaluate the potential for water hammer in each heat exchanger or associated piping; and  
      (or equivalent):
v. Evaluate excessive tube vibration in each heat exchanger.
      a.       Copies of the applicable UFSAR sections.
d. Copy of any operability determinations or other documentation of degradation associated with the heat exchangers or the systems that support the operation for the selected heat exchangers.
      b.       Copy of system description and design basis document (as applicable).
e. Copy of the construction code, Design Specification, heat exchanger data sheets, and vendor documents including component drawings applicable for the heat exchangers.
      c.       Copy of any operability determinations or other documentation of degradation
f. Copies of normal, abnormal, and emergency operating procedures associated with the selected heat exchangers.
                associated with the UHS and the safety-related service water system.
8. For the ultimate heat sink (UHS) and the safety
      d.       Copy of the document (e.g., UFSAR or Technical Requirements Manual)
-related service water system (or equivalent):
                that states the maximum cooling water system inlet temperature limit that
a. Copies of the applicable UFSAR sections
                still allows full licensed power operation of the nuclear reactor.
. b. Copy of system description and design basis document (as applicable).
      e.       Copy of system description and design basis document (as applicable).
c. Copy of any operability determinations or other documentation of degradation associated with the UHS and the safety
                                              2
-related service water system
 
. d. Copy of the document (e.g.
        TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST
, UFSAR or Technical Requirements Manual) that states the maximum cooling water system inlet temperature limit that still allows full licensed power operation of the nuclear reactor.
            f.     Copy of the construction code and Design Specification.
e. Copy of system description and design basis document (as applicable).
            g.     Copies of normal, abnormal, and emergency operating procedures
 
                    associated with the UHS and safety-related service water systems including
TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST
                    procedures for loss of these systems.
  3 f. Copy of the construction code and Design Specification.
            h.     Copy of any operability determinations or other documentation of degradation
g. Copies of normal, abnormal, and emergency operating procedures associated with the UHS and safety
                    associated with the UHS and the safety-related service water system.
-related service water systems including procedures for loss of these systems.
            i.     Copies of corrective action documents associated with water hammer or
h. Copy of any operability determinations or other documentation of degradation  
                    hydraulic transients in the service water system since the last Heat Sink
associated with the UHS and the safety
                    Inspection.
-related service water system.
            j.     If available, provide an electronic copy of piping and instrumentation
i. Copies of corrective action documents associated with water
                    diagrams (P&IDs) for the service water system, including the intake structure.
hammer or hydraulic transients in the service water system since the last Heat Sink Inspection.
            k.     Provide a list of calculations (with a short description), which currently apply
j. If available, provide an
                    to UHS and service water system.
electronic copy of piping and instrumentation diagrams (P&IDs) for the service water system, including the intake structure.
            l.     Provide a list of instruments (with a short description) associated with
k. Provide a list of calculations (with a short description), which currently apply  
                    automatic or alarm functions for the safety-related service water system
to UHS and service water system.
                    and/or UHS.
l. Provide a list of instruments (with a short description) associated with automatic or alarm functions for the safety
            m.     Provide a list of any design change (with a short description) performed on
-related service water system and/or UHS.
                    the UHS or safety-related service water system since the last heat sink
m. Provide a list of any design change (with a short description) performed on the UHS or safety
                    performance inspection.
-related service water system since the last heat sink performance inspection
    6.     A schedule of all inspections, cleanings, maintenance, or testing of any
. 6. A schedule of all inspections, cleanings, maintenance, or testing of  
            safety-related plant heat exchanger to be performed during the onsite
any safety-related plant
            portion of the inspection.
heat exchanger to be performed
III.     Information Requested to be Available on First Day of Inspection, April 20, 2015
during the onsite portion of
    1.     For the specific heat exchangers selected:
the inspection
            a.     Copy of the calculation which correlates surveillance testing results from
. III. Information Requested to be Available on First Day of Inspection, April 20, 2015
                    these heat exchangers with design basis heat removal capability (e.g., basis
1. For the specific heat exchangers selected:
                    for surveillance test acceptance criteria).
a. Copy of the calculation which correlates surveillance testing results from these heat exchangers with design basis heat removal capability (e.g.
            b.     Copies of the 2 most recent completed tests and evaluation data confirming
, basis for surveillance test acceptance criteria).
                    thermal performance for those heat exchangers which are performance
b. Copies of the  
                    tested.
2 most recent completed tests and evaluation data confirming thermal performance for those heat exchangers which are performance tested.   c. Documentation and procedures that identify the types, accuracy, and location of any special instrumentation used for the  
            c.     Documentation and procedures that identify the types, accuracy, and location
2 most recently completed thermal performance tests for the heat exchangers (e.g., high accuracy ultrasonic flow instruments or temperature instruments). Include calibration records for the instruments used during these tests.
                    of any special instrumentation used for the 2 most recently completed thermal
  d. Information regarding any alarms which monitor on
                    performance tests for the heat exchangers (e.g., high accuracy ultrasonic
-line performance.
                    flow instruments or temperature instruments). Include calibration records for
  e. Copy of the document describing the inspection results
                    the instruments used during these tests.
of each heat exchanger
            d.     Information regarding any alarms which monitor on-line performance.
. The requested documents are to be for the time
            e.     Copy of the document describing the inspection results of each heat
period from the
                    exchanger. The requested documents are to be for the time period from the
TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST
                                                3
  4 onsite inspection period back to the documents that were provided in response to the previous heat sink performance inspection.
 
  f. The cleaning and inspection maintenance schedule for each heat exchanger for the next  
  TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST
5 years.   g. Copy of the design specification and heat exchanger data sheets for each heat exchanger
              onsite inspection period back to the documents that were provided in
h. Copy of the vendor manuals including component drawings for each heat exchanger
              response to the previous heat sink performance inspection.
i. Copy of the calculation which establishes the limiting (maximum) design basis heat load which is required to be removed by each of these heat exchangers
      f.     The cleaning and inspection maintenance schedule for each heat exchanger
j. Copy of the operating procedure that ensures that the maximum cooling water system inlet temperature limit is not exceeded.
              for the next 5 years.
k. Copy of the calculations or documents which evaluate the potential for water hammer in each heat exchanger or associated piping.
      g.     Copy of the design specification and heat exchanger data sheets for each
l. Copy of the calculations that evaluate excessive tube vibration in each heat  
              heat exchanger.
exchanger
      h.     Copy of the vendor manuals including component drawings for each heat
, and the documents that describe the controls that prevent heat exchanger degradation due to excessive flow induced vibration during  
              exchanger.
operation.
      i.     Copy of the calculation which establishes the limiting (maximum) design
m. Copy of the periodic flow testing at or near maximum design flow. The requested documents are to be for the time period from the onsite inspection period back to the documents that were provided in response to the previous Heat Sink Performance Inspection
              basis heat load which is required to be removed by each of these heat
n. Copy of the document which identifies the current number of tubes in service for each heat exchanger and the supporting calculation which establishes the maximum number of tubes which can be plugged in each heat exchanger
              exchangers.
o. Copy of the document establishing the repair criteria (plugging limit) for degraded tubes which are identified in each heat exchanger
      j.     Copy of the operating procedure that ensures that the maximum cooling
p. Copies of the documents that verify the structural integrity of the heat exchanger
              water system inlet temperature limit is not exceeded.
(e.g., eddy current summary sheets, ultrasonic testing results, and visual inspection results
      k.     Copy of the calculations or documents which evaluate the potential for water
).   q. Copies of those documents that describe the methods taken to control water chemistry in the heat exchangers
              hammer in each heat exchanger or associated piping.
2. For the UHS:   a. Copies of the inspection
      l.     Copy of the calculations that evaluate excessive tube vibration in each heat
procedures for the verification of the structural integrity of underwater UHS
              exchanger, and the documents that describe the controls that prevent heat
, and the associated results. The requested documents are to be for the time period from the onsite inspection period  
              exchanger degradation due to excessive flow induced vibration during
back to the
              operation.
documents that were provided in response to the previous
      m.     Copy of the periodic flow testing at or near maximum design flow. The
Heat Sink Performance  
              requested documents are to be for the time period from the onsite inspection
Inspection.  
              period back to the documents that were provided in response to the previous
TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST
              Heat Sink Performance Inspection.
  5 b. Copies of the maintenance  
      n.     Copy of the document which identifies the current number of tubes in service
and/or inspection
              for each heat exchanger and the supporting calculation which establishes the
procedures for underwater UHS sediment intrusion
              maximum number of tubes which can be plugged in each heat exchanger.
, and the associated results including underwater diving inspections
      o.     Copy of the document establishing the repair criteria (plugging limit) for
and/or sediment removal activities
              degraded tubes which are identified in each heat exchanger.
. The requested documents are to be for the time period from the onsite inspection period back to the
      p.     Copies of the documents that verify the structural integrity of the heat
documents that were provided in response to the previous
              exchanger (e.g., eddy current summary sheets, ultrasonic testing results, and
heat Sink Performance  
              visual inspection results).
Inspection.   c. Copies of calculations and surveillances that determine the UHS reservoir capacity, and heat transfer capability.
      q.     Copies of those documents that describe the methods taken to control water
  d. Copies of surveillance procedures and testing results performed
              chemistry in the heat exchangers.
on the instrumentation relied upon to determine UHS reservoir capability. The requested documents are to be for the time period from the onsite inspection  
2.     For the UHS:
period back to the
      a.     Copies of the inspection procedures for the verification of the structural
documents that were provided in response to the previous
              integrity of underwater UHS, and the associated results. The requested
Heat Sink Performance  
              documents are to be for the time period from the onsite inspection period
Inspection.   3. For the review of the performance testing of the safety
              back to the documents that were provided in response to the previous Heat
-related service water system (or equivalent)
              Sink Performance Inspection.
and the UHS:
                                          4
a. Copies of the last 2 performance tests, such as the American  
 
Society of  
        TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST
Mechanical  
            b.     Copies of the maintenance and/or inspection procedures for underwater UHS
Engineers in-service test
                    sediment intrusion, and the associated results including underwater diving
, for the pumps, valves, and, if applicable, the towers
                    inspections and/or sediment removal activities. The requested documents
fans in the safety
                    are to be for the time period from the onsite inspection period back to the
-related service water system. If the components are not performance tested, please provide documentation verifying performance by the methods actually used.
                    documents that were provided in response to the previous heat Sink
  b. Copies of the documents that demonstrate that flow balance testing was performed during the last  
                    Performance Inspection.
3 years. If the last flow test was performed longer than 3 years, then provide the last flow test.
            c.     Copies of calculations and surveillances that determine the UHS reservoir
c. Copies of the documents that demonstrate that flow balance testing will continue to be periodically done in the future.
                    capacity, and heat transfer capability.
d. Copies of procedures used to monitor interface valves between the safety  
            d.     Copies of surveillance procedures and testing results performed on the
related section of the service water system and the non
                    instrumentation relied upon to determine UHS reservoir capability. The
-safety related section, and the associated results. The requested documents are to be fo
                    requested documents are to be for the time period from the onsite inspection
r the time period from the onsite inspection period back to the documents that were provided in response to the previous Heat Sink Performance Inspection
                    period back to the documents that were provided in response to the previous
e. Copies of the procedures that verify the performance of risk significant non
                    Heat Sink Performance Inspection.
-safety functions
    3.     For the review of the performance testing of the safety-related service water system
, and the associated results
            (or equivalent) and the UHS:
. The requested documents are to be for the time
            a.     Copies of the last 2 performance tests, such as the American Society of
period from the onsite inspection period back to the
                    Mechanical Engineers in-service test, for the pumps, valves, and, if
documents that were provided in response to the previous
                    applicable, the towers fans in the safety-related service water system. If the
Heat Sink Performance  
                    components are not performance tested, please provide documentation
Inspection.   If the information requested above will not be available, please contact Andrew Dunlop
                    verifying performance by the methods actually used.
as soon as possible at (630) 8
            b.     Copies of the documents that demonstrate that flow balance testing was
29-9726 or email Andrew.Dunlop@nrc.gov
                    performed during the last 3 years. If the last flow test was performed longer
.
                    than 3 years, then provide the last flow test.
  B. Hanson
            c.     Copies of the documents that demonstrate that flow balance testing will
-2- The lead inspector for this inspection is Mr. Andrew Dunlop. We understand that our regulatory contact for this inspection is Mr. Larry Blunk of your organization.  
                    continue to be periodically done in the future.
If there are questions about the material requested, or the inspection, please call Mr. Andrew Dunlop at (630) 829
            d.     Copies of procedures used to monitor interface valves between the safety
-9726. Please send the information to the following e
                    related section of the service water system and the non-safety related
-mail address Andrew.Dunlop@nrc.gov. A hard-copy with the required information is also an acceptable option.
                    section, and the associated results. The requested documents are to be for
This letter does not contain new or amended information collection requirements subject
                    the time period from the onsite inspection period back to the documents that
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, Control Number
                    were provided in response to the previous Heat Sink Performance Inspection.
3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Office of Management and Budget Control Number.
            e.     Copies of the procedures that verify the performance of risk significant non-
In accordance with Title 10 of the Code of Federal Regulations
                    safety functions, and the associated results. The requested documents are
  (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," of the NRC's "Rules of Practice," a copy of
                    to be for the time period from the onsite inspection period back to the
this letter, its enclosure, and your response (if any) will be available
                    documents that were provided in response to the previous Heat Sink
electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide
                    Performance Inspection.
Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading
If the information requested above will not be available, please contact Andrew Dunlop as soon
-rm/adams.html
as possible at (630) 829-9726 or email Andrew.Dunlop@nrc.gov.
(the Public Electronic Reading Room).
                                                5
Sincerely,
 
/RA/ Christine A.
B. Hanson                                                                       -2-
Lipa, Chief
The lead inspector for this inspection is Mr. Andrew Dunlop. We understand that our regulatory contact
Engineering Branch 2
for this inspection is Mr. Larry Blunk of your organization. If there are questions about the material
Division of Reactor Safety  
requested, or the inspection, please call Mr. Andrew Dunlop at (630) 829-9726. Please send the
Docket Nos. 50
information to the following e-mail address Andrew.Dunlop@nrc.gov. A hard-copy with the required
-373; 50-374 License Nos. NPF-11; NPF-18 Enclosure:  
information is also an acceptable option.
Triennial Heat Sink Performance Inspection
This letter does not contain new or amended information collection requirements subject
  Document Request
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection
cc w/encl: Distribution via LISTSERV
requirements were approved by the Office of Management and Budget, Control Number 3150-0011. The
DISTRIBUTION
NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or
: Kimyata MorganButler
an information collection requirement unless the requesting document displays a currently valid Office of
RidsNrrDorlLpl3
Management and Budget Control Number.
-2 Resource
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections,
  RidsNrrPMLaSalle
Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its
RidsNrrDirsIrib Resource
enclosure, and your response (if any) will be available electronically for public inspection in the NRCs
Cynthia Pederson
Public Document Room or from the Publicly Available Records (PARS) component of the NRC's
Darrell Roberts
Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the
Richard Skokowski
NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Allan Barker
                                                                                Sincerely,
Carole Ariano
                                                                                /RA/
Linda Linn
                                                                                Christine A. Lipa, Chief
DRPIII DRSIII Jim Clay Carmen Olteanu
                                                                                Engineering Branch 2
    ADAMS Accession Number ML15065A320
                                                                                Division of Reactor Safety
  Publicly Available
Docket Nos. 50-373; 50-374
  Non-Publicly Available
License Nos. NPF-11; NPF-18
  Sensitive
Enclosure:
  Non-Sensitive
Triennial Heat Sink Performance Inspection
To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl; "E" = Copy with attach/en
  Document Request
cl "N" = No copy
                                                             
OFFICE RIII RIII     NAME JCorujo-Sandin for ADunlop:cl CLipa  DATE 03/06/15 03/06/15   OFFICIAL RECORD COPY
cc w/encl: Distribution via LISTSERV
DISTRIBUTION:
Kimyata MorganButler                                                                         Allan Barker
RidsNrrDorlLpl3-2 Resource                                                                   Carole Ariano
RidsNrrPMLaSalle                                                                             Linda Linn
RidsNrrDirsIrib Resource                                                                     DRPIII
Cynthia Pederson                                                                             DRSIII
Darrell Roberts                                                                               Jim Clay
Richard Skokowski                                                                             Carmen Olteanu
ADAMS Accession Number ML15065A320
    Publicly Available                               Non-Publicly Available                         Sensitive                 Non-Sensitive
To receive a copy of this document, indicate in the concurrence box C = Copy without attach/encl; E = Copy with attach/encl N = No copy
  OFFICE                       RIII                                                         RIII
  NAME                         JCorujo-Sandin for ADunlop:cl CLipa
   DATE                         03/06/15                                                     03/06/15
                                                              OFFICIAL RECORD COPY
}}
}}

Latest revision as of 02:25, 17 November 2019

Notification of an NRC Triennial Heat Sink Performance Inspection - Request for Information Inspection Report 05000373/2015002; 05000374/2015002
ML15065A320
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 03/06/2015
From: Christine Lipa
NRC/RGN-III/DRS/EB2
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
References
IR 2015002
Download: ML15065A320 (8)


See also: IR 05000373/2015002

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE RD. SUITE 210

LISLE, IL 60532-4352

March 6, 2015

Mr. Bryan C. Hanson

Senior VP, Exelon Generation Company, LLC

President and CNO, Exelon Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: LASALLE COUNTY STATION, UNITS 1 AND 2 - NOTIFICATION OF AN NRC

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION - REQUEST FOR

INFORMATION INSPECTION REPORT 05000373/2015002; 05000374/2015002

Dear Mr. Hanson:

On April 20, 2015, the U.S. Nuclear Regulatory Commission (NRC) will begin the onsite

portion of the Triennial Heat Sink Performance Inspection at your LaSalle County Station,

Units 1 and 2. This inspection will be performed in accordance with NRC Baseline Inspection

Procedure (IP) 71111.07.

In order to minimize the impact that the inspection has on the site, and to ensure a productive

inspection, we have enclosed a request for documents needed for the inspection. The

documents have been divided into three groups:

The first group lists information necessary for our initial inspection scoping activities. This

information should be available to the lead inspector no later than March 25, 2015. By

April 1, 2015, the inspector will communicate the initial selected set of approximately

1-2 risk-significant heat exchangers.

The second group is needed to support our in-office preparation activities. This set of

documents, including the calculations associated with the selected heat exchangers, should

be available at the Regional Office no later than April 10, 2015. This information should be

separated for each selected component, especially if provided electronically (e.g., folder with

component name that includes calculations, condition reports, maintenance history, etc.).

During the in-office preparation activities, the inspector may identify additional information

needed to support the inspection.

The last group includes the additional information above as well as plant-specific reference

material. This information should be available onsite to the inspector on April 20, 2015. It is

also requested that corrective action documents and/or questions developed during the

inspection be provided to the inspector as the documents are generated.

All requested documents are to be for the time period from the onsite inspection period back to

documents that were provided in response to the previous Heat Sink Performance Inspection.

If no activities were accomplished in that time period, then the request applies to the last

applicable document in the previous time period. It is important that these documents be as

complete as possible, in order to minimize the number of documents requested during the

preparation week or during the onsite inspection.

B. Hanson -2-

The lead inspector for this inspection is Mr. Andrew Dunlop. We understand that our regulatory

contact for this inspection is Mr. Larry Blunk of your organization. If there are questions about

the material requested, or the inspection, please call Mr. Andrew Dunlop at (630) 829-9726.

Please send the information to the following e-mail address: Andrew.Dunlop@nrc.gov.

A hard-copy with the required information is also an acceptable option.

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget, Control

Number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to

respond to, a request for information or an information collection requirement unless the

requesting document displays a currently valid Office of Management and Budget Control

Number.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public

Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy

of this letter, its enclosure, and your response (if any) will be available electronically for public

inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)

component of the NRC's Agencywide Documents Access and Management System (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html

(the Public Electronic Reading Room).

Sincerely,

/RA/

Christine A. Lipa, Chief

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 50-373; 50-374

License Nos. NPF-11; NPF-18

Enclosure:

Triennial Heat Sink Performance Inspection

Document Request

cc w/encl: Distribution via LISTSERV

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

Inspection Report: 05000373/2015002; 05000374/2015002

Inspection Dates: April 20 - 24, 2015

Inspection Procedure: IP 71111.07, Heat Sink Performance

Lead Inspector: Andrew Dunlop

(630) 829-9726

Andrew.Dunlop@nrc.gov

I. Information Requested By March 25, 2015

1. List of the Generic Letter (GL) 89-13, Service Water System Problems Affecting

Safety-Related Equipment, heat exchangers in order of risk significance.

2. Copy of heat exchanger performance trending data tracked for each GL 89-13 heat

exchanger.

3. List of Corrective Action Program (CAP) documents (with a short description)

associated with GL 89-13 heat exchangers, heat sinks, silting, corrosion, fouling, or

heat exchanger testing, from the previous 3 years or since the last CAP document

list was sent to the NRC for the previous heat sink performance inspection. The list

should include all CAP documents not on the last CAP document list.

4. Copy of any self-assessment done on any of GL 89-13 heat exchangers.

5. Last 2 System Health Reports and maintenance rule system notebooks for all the

GL 89-13 heat exchangers.

6. List of engineering-related operator workarounds (with a short description)

associated with GL 89-13 heat exchangers. The requested documents are to be for

the time period from the onsite inspection period back to the documents that were

provided in response to the previous Heat Sink Performance Inspection.

7. List of permanent and temporary modifications (with a short description) associated

with GL 89-13 heat exchangers. The requested documents are to be for the time

period from the onsite inspection period back to the documents that were provided in

response to the previous Heat Sink Performance Inspection.

II. Information Requested By April 10, 2015

1. Copies of the GL 89-13 responses.

2. Copy of the Updated Final Safety Analysis Report (UFSAR) section applicable to the

GL 89-13 Heat Exchanger Program.

3. Copies of procedures developed to implement the recommendations of GL 89-13

(e.g., the GL 89-13 Heat Exchanger Program description).

Enclosure

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

4. Copies of the selected CAP documents.

5. For the specific heat exchangers selected:

a. Copies of the UFSAR sections applicable for each heat exchanger.

b. Copy of system description and design basis document for the heat

exchangers (as applicable).

c. Provide a list of calculations (with a short description) which currently apply

to each heat exchanger.

i. Establish the limiting design basis heat load required to be removed

by each of these heat exchangers;

ii. Demonstrate the heat exchangers capacity to remove the limiting

heat load;

iii. Correlate surveillance testing and/or inspection results from these

heat exchangers with design basis heat removal capability (e.g., basis

for surveillance test and/or inspection acceptance criteria);

iv. Evaluate the potential for water hammer in each heat exchanger or

associated piping; and

v. Evaluate excessive tube vibration in each heat exchanger.

d. Copy of any operability determinations or other documentation of degradation

associated with the heat exchangers or the systems that support the

operation for the selected heat exchangers.

e. Copy of the construction code, Design Specification, heat exchanger data

sheets, and vendor documents including component drawings applicable for

the heat exchangers.

f. Copies of normal, abnormal, and emergency operating procedures

associated with the selected heat exchangers.

8. For the ultimate heat sink (UHS) and the safety-related service water system

(or equivalent):

a. Copies of the applicable UFSAR sections.

b. Copy of system description and design basis document (as applicable).

c. Copy of any operability determinations or other documentation of degradation

associated with the UHS and the safety-related service water system.

d. Copy of the document (e.g., UFSAR or Technical Requirements Manual)

that states the maximum cooling water system inlet temperature limit that

still allows full licensed power operation of the nuclear reactor.

e. Copy of system description and design basis document (as applicable).

2

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

f. Copy of the construction code and Design Specification.

g. Copies of normal, abnormal, and emergency operating procedures

associated with the UHS and safety-related service water systems including

procedures for loss of these systems.

h. Copy of any operability determinations or other documentation of degradation

associated with the UHS and the safety-related service water system.

i. Copies of corrective action documents associated with water hammer or

hydraulic transients in the service water system since the last Heat Sink

Inspection.

j. If available, provide an electronic copy of piping and instrumentation

diagrams (P&IDs) for the service water system, including the intake structure.

k. Provide a list of calculations (with a short description), which currently apply

to UHS and service water system.

l. Provide a list of instruments (with a short description) associated with

automatic or alarm functions for the safety-related service water system

and/or UHS.

m. Provide a list of any design change (with a short description) performed on

the UHS or safety-related service water system since the last heat sink

performance inspection.

6. A schedule of all inspections, cleanings, maintenance, or testing of any

safety-related plant heat exchanger to be performed during the onsite

portion of the inspection.

III. Information Requested to be Available on First Day of Inspection, April 20, 2015

1. For the specific heat exchangers selected:

a. Copy of the calculation which correlates surveillance testing results from

these heat exchangers with design basis heat removal capability (e.g., basis

for surveillance test acceptance criteria).

b. Copies of the 2 most recent completed tests and evaluation data confirming

thermal performance for those heat exchangers which are performance

tested.

c. Documentation and procedures that identify the types, accuracy, and location

of any special instrumentation used for the 2 most recently completed thermal

performance tests for the heat exchangers (e.g., high accuracy ultrasonic

flow instruments or temperature instruments). Include calibration records for

the instruments used during these tests.

d. Information regarding any alarms which monitor on-line performance.

e. Copy of the document describing the inspection results of each heat

exchanger. The requested documents are to be for the time period from the

3

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

onsite inspection period back to the documents that were provided in

response to the previous heat sink performance inspection.

f. The cleaning and inspection maintenance schedule for each heat exchanger

for the next 5 years.

g. Copy of the design specification and heat exchanger data sheets for each

heat exchanger.

h. Copy of the vendor manuals including component drawings for each heat

exchanger.

i. Copy of the calculation which establishes the limiting (maximum) design

basis heat load which is required to be removed by each of these heat

exchangers.

j. Copy of the operating procedure that ensures that the maximum cooling

water system inlet temperature limit is not exceeded.

k. Copy of the calculations or documents which evaluate the potential for water

hammer in each heat exchanger or associated piping.

l. Copy of the calculations that evaluate excessive tube vibration in each heat

exchanger, and the documents that describe the controls that prevent heat

exchanger degradation due to excessive flow induced vibration during

operation.

m. Copy of the periodic flow testing at or near maximum design flow. The

requested documents are to be for the time period from the onsite inspection

period back to the documents that were provided in response to the previous

Heat Sink Performance Inspection.

n. Copy of the document which identifies the current number of tubes in service

for each heat exchanger and the supporting calculation which establishes the

maximum number of tubes which can be plugged in each heat exchanger.

o. Copy of the document establishing the repair criteria (plugging limit) for

degraded tubes which are identified in each heat exchanger.

p. Copies of the documents that verify the structural integrity of the heat

exchanger (e.g., eddy current summary sheets, ultrasonic testing results, and

visual inspection results).

q. Copies of those documents that describe the methods taken to control water

chemistry in the heat exchangers.

2. For the UHS:

a. Copies of the inspection procedures for the verification of the structural

integrity of underwater UHS, and the associated results. The requested

documents are to be for the time period from the onsite inspection period

back to the documents that were provided in response to the previous Heat

Sink Performance Inspection.

4

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

b. Copies of the maintenance and/or inspection procedures for underwater UHS

sediment intrusion, and the associated results including underwater diving

inspections and/or sediment removal activities. The requested documents

are to be for the time period from the onsite inspection period back to the

documents that were provided in response to the previous heat Sink

Performance Inspection.

c. Copies of calculations and surveillances that determine the UHS reservoir

capacity, and heat transfer capability.

d. Copies of surveillance procedures and testing results performed on the

instrumentation relied upon to determine UHS reservoir capability. The

requested documents are to be for the time period from the onsite inspection

period back to the documents that were provided in response to the previous

Heat Sink Performance Inspection.

3. For the review of the performance testing of the safety-related service water system

(or equivalent) and the UHS:

a. Copies of the last 2 performance tests, such as the American Society of

Mechanical Engineers in-service test, for the pumps, valves, and, if

applicable, the towers fans in the safety-related service water system. If the

components are not performance tested, please provide documentation

verifying performance by the methods actually used.

b. Copies of the documents that demonstrate that flow balance testing was

performed during the last 3 years. If the last flow test was performed longer

than 3 years, then provide the last flow test.

c. Copies of the documents that demonstrate that flow balance testing will

continue to be periodically done in the future.

d. Copies of procedures used to monitor interface valves between the safety

related section of the service water system and the non-safety related

section, and the associated results. The requested documents are to be for

the time period from the onsite inspection period back to the documents that

were provided in response to the previous Heat Sink Performance Inspection.

e. Copies of the procedures that verify the performance of risk significant non-

safety functions, and the associated results. The requested documents are

to be for the time period from the onsite inspection period back to the

documents that were provided in response to the previous Heat Sink

Performance Inspection.

If the information requested above will not be available, please contact Andrew Dunlop as soon

as possible at (630) 829-9726 or email Andrew.Dunlop@nrc.gov.

5

B. Hanson -2-

The lead inspector for this inspection is Mr. Andrew Dunlop. We understand that our regulatory contact

for this inspection is Mr. Larry Blunk of your organization. If there are questions about the material

requested, or the inspection, please call Mr. Andrew Dunlop at (630) 829-9726. Please send the

information to the following e-mail address Andrew.Dunlop@nrc.gov. A hard-copy with the required

information is also an acceptable option.

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection

requirements were approved by the Office of Management and Budget, Control Number 3150-0011. The

NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or

an information collection requirement unless the requesting document displays a currently valid Office of

Management and Budget Control Number.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections,

Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its

enclosure, and your response (if any) will be available electronically for public inspection in the NRCs

Public Document Room or from the Publicly Available Records (PARS) component of the NRC's

Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the

NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Christine A. Lipa, Chief

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 50-373; 50-374

License Nos. NPF-11; NPF-18

Enclosure:

Triennial Heat Sink Performance Inspection

Document Request

cc w/encl: Distribution via LISTSERV

DISTRIBUTION:

Kimyata MorganButler Allan Barker

RidsNrrDorlLpl3-2 Resource Carole Ariano

RidsNrrPMLaSalle Linda Linn

RidsNrrDirsIrib Resource DRPIII

Cynthia Pederson DRSIII

Darrell Roberts Jim Clay

Richard Skokowski Carmen Olteanu

ADAMS Accession Number ML15065A320

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

To receive a copy of this document, indicate in the concurrence box C = Copy without attach/encl; E = Copy with attach/encl N = No copy

OFFICE RIII RIII

NAME JCorujo-Sandin for ADunlop:cl CLipa

DATE 03/06/15 03/06/15

OFFICIAL RECORD COPY