ML090330391

Susquehanna Steam Electric Station, Unit 2-Issuance of Amendment Changes in MCPR Safety Limits (TAC No. ME0067)

ML090330391
Person / Time
Site:	Susquehanna
Issue date:	02/26/2009
From:	Bhalchandra Vaidya Plant Licensing Branch 1
To:	Spence W H PPL Corp
vaidya b k
References
TAC ME0067
Download: ML090330391 (14)

Text

UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 FeOOBtY 26, xrn Mr. William H.

Spence Executive Vice President Chief Operating Officer/Chief Nuclear Officer PPL Corporation Two North Ninth Street, GENTW16 Allentown, PA 18101-1179 SUSQUEHANNA STEAM ELECTRIC STATION, UNIT 2 -ISSUANCE OF AMENDMENT RE: CHANGES IN MCPR SAFETY LIMITS (TAC NO. ME0067)

Dear Mr. Spence:

The Commission has issued the enclosed Amendment No. 2:0 to Facility Operating License (FOL) No. NPF-22 for the PPL Susquehanna, LLC, Susquehanna Steam Electric Station, Unit 2 (PPL). This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated October 30,2008, as supplemented by letters dated November 21, 2008, and January 23, 2009.

This amendment request revised PPL, TS 2.1.1.2, Minimum Critical Power Ratio Safety Limits (MCPRSLs) for two-loop and single-loop operation, and adds an associated License Condition in the FOL. A copy of our safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's Biweekly Federal Register Notice. Sincerely, Bhalchandra K. Vaidya, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-388

Enclosures:

1. Amendment No. 230 to License No. NPF-22

2. Safety Evaluation cc w/encls:

Distribution via Listserv UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 PPL SUSQUEHANNA. ALLEGHENY ELECTRIC COOPERATIVE, DOCKET NO.

SUSQUEHANNA STEAM ELECTRIC STATION, UNIT AMENDMENT TO FACILITY OPERATING Amendment No. 2.'l1 License No. NPF-22 The Nuclear Regulatory Commission (the Commission or the NRC) having found that: The application for the amendment filed by PPL Susquehanna, LLC, dated October 30, 2008, as supplemented by letters dated November 21, 2008, and January 23, 2009, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's regulations set forth in 10 CFR Chapter I; The facility will operate in conformity with the application, the provisions of the Act, and the regulations of the Commission; There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of the Facility Operating License No. NPF-22 is hereby amended to read as follows: Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 231 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. PPL Susquehanna, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. This license amendment is effective as of its date of issuance and shall be implemented upon start up following the Susquehanna, Unit 2, 14th Refueling and Inspection Outage. FOR THE NUCLEAR REGULATORY COMMISSION c Mark G. Kowal, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance:Febrt:my 2fi, 2!TA ATTACHMENT TO LICENSE AMENDMENT NO. 230 FACILITY OPERATING LICENSE NO.

NPF-22 DOCKET NO. 50-388 Replace the following page of the Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

REMOVE INSERT Page 3 Page 3 Page 14 Page 14 Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT TS 2.0-1 TS 2.0-1

-3PPL Susquehanna, LLC, pursuant to the Act and 10 CFR Parts 30,40, and 70, to receive. possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and PPL Susquehanna, LLC, pursuant to the Act and 10 CFR Parts 30,40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below: Maximum Power Level PPL Susquehanna, LLC is authorized to operate the facility at reactor core power levels not in excess of 3952 megawatts thermal in accordance with the conditions specified herein. The preoperational tests, startup tests, and other items identified in License Conditions 2.C.(20), 2.C.(21), 2.C.(22), and 2.C.(22) to this license shall be completed as specified. Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 230, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. PPL Susquehanna, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. For Surveillance Requirements (SRs) that are new in Amendment 151 to Facility Operating License No. NPF-22, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 151. For SRs that existed prior to Amendment 151, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the Surveillance was last performed prior to implementation of Amendment 151. PPL Susquehanna, LLC shall implement and maintain in effect all provisions of the approved fire protection program as described in the Fire Protection Review Report for the facility and as approved in Fire Protection Program, Section 9.5, SER, SSER#1, SSER#2, SSER#3, SSER#4, SSER#6, Safety Evaluation of Fire Protection Report dated August 9, 1989, Safety Evaluation.

Amendment No.4, 2, 400, tse, 454. 453, -'1-62, 469, 242, rt3, rt4, 245, -24*, 2+1, 248, rr9, 22B,Z24,zzz,rra,ZZ4,2Z5, 226, 227, 228, 230

-14 (23) Containment Operability for EPU PPL shall ensure that the CPPU containment analysis is consistent with the SSES 1 and 2 operating and emergency procedures. Prior to operation above CLTP, PPL shall notify the NRC project manager that all appropriate actions have been completed.

(24) Primary Containment Leakage Rate Testing Program Those primary containment local leak rate program tests (Type B -boundary and Type C -

containment isolation valves) as modified by approved exemptions, required by 10 CFR Part 50, Appendix J, Option B and Technical Specification 5.5.12, are not required to be performed at the CPPU peak calculated containment internal pressure of 48.6 psig (Amendment No. 224 to this Operating License) until their next required performance.

(25) Critical Power Correlation Additive Constants AREVA NP has submitted EMF-2209(P), Revision 2, Addendum 1 (ML081260442) for NRC review to correct the critical power correlation additive constants due to a prior Part 21 notification (ML072830334).

The report is currently under NRC review. The license shall apply additional margin to the cycle specific OLMCPR, consistent in magnitude with the non-conservatism reported in the Part 21 report, thus imposing the appropriate MCPR penalty on the OLMCPR. This compensatory measure is to be applied until the approved version of 2209(P) Revision 2, Addendum 1 is published and PPL verifies that the additive constants from the approved report have been incorporated in the cycle specific analyses.

2. The operating licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plan, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Physical Security Plan, Training and Qualification Plan, Safeguards Contingency Plan and Security and Contingency Plan for Independent Spent Fuel Storage Facility," and was submitted October 8,2004. Deleted Amendment No. aas. 2])

PPL Rev. SLs 2.0 SAFETY LIMITS (SLs) 2.1 SLs 2.1.1 Reactor Core SLs 2.1.1.1 With the reactor steam dome pressure < 785 psig or core flow < 10 million Ibm/hr:

THERMAL POWER shall be s 23% RTP.

2.1.1.2 With the reactor steam dome pressure 785 psig and core flow 10 million Ibm/hr: MCPR shall be 1.08 for two recirculation loop operation or 1.11 for single recirculation loop operation.

2.1.1.3 Reactor vessel water level shall be greater than the top of active irradiated fuel.

2.1.2 Reactor Coolant System Pressure SL Reactor steam dome pressure shall be s 1325 psig. SL Violations With any SL violation, the following actions shall be completed within 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s: Restore compliance with all SLs; and Insert all insertable control rods.

SUSUQUEHANNA

-UNIT 2 TS 12.0-1 Amendment

+5-1-, 94, +84, +9+, +94, m UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. m TO FACILITY OPERATING LICENSE NO. NPF-22 PPL SUSQUEHANNA, LLC ALLEGHENY ELECTRIC COOPERATIVE INC. SUSQUEHANNA STEAM ELECTRIC STATION, UNIT 2 DOCKET NO. 50-388

1.0 INTRODUCTION

By application dated October 30,2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML083181117), as supplemented by letters dated November 21,2008, and January 23,2009 (ADAMS Accession No. ML083430311 and IVIL090420275, respectively), PPL Susquehanna, LLC (the licensee), requested changes to the Technical Specifications (TSs) for Susquehanna Steam Electric Station, Unit 2 (SSES-2).

The supplements dated November 21, 2008, and January 23, 2009, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC) staff's original proposed no significant hazards consideration determination as published in the Federal Register on January 23, 2008 (74 FR 4254).

The proposed changes would revise PPL, TS 2.1.1.2, Minimum Critical Power Ratio Safety Limits (MCPRSLs, or SLMCPR) for two-loop and single-loop operation, and adds an associated License Condition in the FOL.

2.0 REGULATORY EVALUATION

In its regulatory evaluation, the NRC staff considered the applicable General Design Criteria (GDC), the licensee's use and application of NRC-approved methods, and limitations applied thereto. Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix A, GDC 10 states that the reactor core and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that specified acceptable fuel design limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences (AOOs). Additionally, Section 4.4, "Thermal and Hydraulic Design," of NUREG-0800, Revision 3, "NRC Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," dated June 1996, states, in part, that the critical power ratio (CPR) is to be established such that at least 99.9 percent of the fuel rods in the core would not be expected to experience departure from nucleate boiling or boiling transition during normal operation or AOOs.

-2 The NUREG-0800 guides the basis for the NRC staff's review and ensures that the requirements of GDC 10 are met.

3.0 TECHNICAL EVALUATION The licensee in its request, proposed to change the MCPRSL value in TS 2.1.1.2 for SSES U2C15 operation from 1.11 to 1.08 for two-loop recirculation and from 1.14 to 1.11 for loop recirculation operation with the reactor steam dome pressure 785 pounds per square-inch gauge (psig) and core flow 10 million pound-mass per hour (Ibm/hr).

3.1 Use of NRC-Approved Methods and Limitations The licensee's submittals described the approved methodologies used to calculate the MCPRSL values for the proposed TS change. AREVA performed the U2C15 MCPRSL analysis using SSES-2 plant-and cycle-specific fuel and core parameters provided by the licensee. The licensee used the NRC-approved methodologies documented in the following topical reports: ANF-524-P-A, Rev. 2 and Supplements 1 and 2 "ANF Critical Power Methodology for Boiling Water Reactors," EMF-2209-P-A, Rev. 2, "SPCB Critical Power Correlation," and EMF-2158-P-A, Rev. 0 "Siemens Power Corporation Methodology for Boiling Water Reactors:

Evaluation and Validation of CASMO-4/MICROBURN-B2" (References 2, 3, and 4).

In accordance with 10 CFR Part 21, "Reporting of Defects and Noncompliance," AREVA submitted the notice that identified potential non-conservatisms related to the SPCB CPR correlation additive constants (Reference 6). The licensee, in its submittals, stated that the U2C15 MCPRSL analysis applied the corrected additive constants that have been submitted to the NRC in EMF-2209-P, Rev. 2, Addendum 1 (Reference 7). The NRC staff determined that because EMF-2209-P, Rev. 2, Addendum 1 is currently under staff review, referencing an unapproved topical report is not appropriate.

Therefore, the licensee should maintain the operating limit maximum critical power ratio (OLMCPR) margin consistent with the Part 21 report compensatory action until EMF-2209, Rev. 2 Addendum 1 is approved. In a letter dated January 23, 2009 (Reference 8), SSES proposed the following license condition:

(25) Critical Power Correlation Additive Constants AREVA NP has submitted EMF-2209(P), Revision 2, Addendum 1 (ML081260442) for NRC review to correct the critical power correlation additive constants due to a prior Part 21 notification (ML 072830334). The report is currently under NRC review. The licensee shall apply additional margin to the cycle specific OLMCPR, consistent in magnitude with the non-conservatism

-reported in the Part 21 report, thus imposing the appropriate MCPR penalty on the OLMCPR. This compensatory measure is to be applied until the approved version of EMF-2209(P) Revision 2, Addendum 1 is published and PPL verifies that the additive constants from the approved report have been incorporated in the cycle specific analyses. The NRC staff finds the proposed license condition acceptable.

SSES-2 is approved to operate at an extended power uprate (EPU) power level of 3,952 MWt (Reference 5). In the review of the EPU application, the NRC staff had found that AREVA's SLMCPR methodology is acceptable for EPU provided that increased power distribution uncertainties are applied. The NRC staff finds that the licensee applied the increased power distribution uncertainties to calculate the U2C15 SLMCPR values, consistent with the EPU license condition. Therefore, the NRC staff finds that the U2C15 SLMCPR values were determined based on an acceptable methodology.

3.2 Impact of Channel Bow Channel bow introduces an uncertainty in the calculation of the local power peaking which affects the SLMCPR. Due to the significant channel bow experienced at SSES-2, the licensee had used twice the mean channel bow values for the U2C14 analyses. The licensee has since identified the root cause as shadow-corrosion-induced channel bow in Zirconium (Zr)-2 fuel channels. The licensee rechanneled all once-burned fuel assemblies with new 100 mil Zr-4 fuel channels and all fresh fuel assemblies received new 100 mil Zr-4 fuel channels. In addition, the licensee's submittal stated that new Zr-4 fuel channels will be placed on fresh fuel for U2C15.

The licensee's submittal further stated that the U2C15 core will contain no Zr-2 channels and all fuel channels in the U2C15 core will have had no more than one cycle's worth of irradiation prior to U2C15.

AREVA calculated the U2C15 SLMCPR values based on above information, and based on their normal mean channel bow values. The NRC staff finds this approach, acceptable.

3.3 Technical Conclusion The licensee's determination of SLMCPR, 1.08 for two recirculation loop operation, and 1.11 for single recirculation loop operation, reflects the recently analyzed values based on acceptable methodology and design assumptions. Further, the licensee has provided adequate justification to ensure that 99.9% of the fuel rods in the core will not experience boiling transition, which satisfies the requirements of GDC-10. Based on the discussion in Sections 3.1 through 3.2, and the discussion above, the NRC staff finds that the proposed amendment is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendment. The State official had no comments.

-4 5.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION (NSHCD) The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration, and published for public comments, such finding on January 23,2009 (74 FR 4254).

Because this amendment is being issued after the 30-day comment period and before the expiration of the 60-day period providing opportunity to request a hearing, a final no significant hazards consideration determination, is included in this safety evaluation. As required by 10 CFR 50.91(a), the licensee, in its submission, provided its analysis of the issue of no significant hazards consideration. The NRC staff has reviewed the licensee's analysis against the standards of 10 CFR 50.92(c). The NRC staffs review is presented below: Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? Response: No. The proposed changes to the two-loop and single-loop MCPRSLs do not directly or indirectly affect any plant system, equipment, or component, or change the processes used to operate the plant. Further, the proposed MCPRSLs were generated using NRC approved methodology and meet the applicable acceptance criteria. Thus, this proposed amendment does not involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated. Prior to the startup of U2C15, licensing analyses are performed (using NRC approved methodology referenced in TS Section 5.6.5.b) to determine changes in the CPR as a result of anticipated operational occurrences. These results are added to the MCPRSL values to generate the MCPROLs in the COLR [Core Operating Limits Report], These limits could be different from those specified for the previous Unit 2 COLR. The COLR operating limits thus assure that the MCPRSL will not be exceeded during normal operation or AOOs [anticipated operational occurrences].

Postulated accidents are also analyzed prior to the startup and the results shown to be within the NRC approved criteria.

Therefore, this proposed amendment does not involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated? Response: No. The changes to the two-loop and single-loop MCPRSLs do not directly or indirectly affect any plant system, equipment, or component and therefore does not affect the failure modes of any of these items. Thus, the proposed change does not create the possibility of a previously unevaluated operator error or a new single failure.

-5 Therefore, this proposed amendment does not create the possibility of a new or different kind of accident from any previously evaluated. Does the proposed amendment involve a significant reduction in a margin of safety? Response:

No. Since the proposed changes do not alter any plant system, equipment, component, or processes used to operate the plant, the proposed change will not jeopardize or degrade the function or operation of any plant system or component governed by TS. The proposed two-loop and single-loop MCPRSLs do not involve a significant reduction in the margin of safety as currently defined in the Bases of the applicable TS sections, because the proposed MCPRSLs preserve the required margin of safety. Therefore, the proposed changes do not involve a significant reduction in a margin of safety. 6.0 ENVIRONMENTAL CONSIDERATION The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (74 FR 4254).

Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

8.0 REFERENCES

Letter from Britt T.

McKinney, Sr. Vice President

& Chief Nuclear Officer, PPL Susquehanna, LLC, to the U.S.

Nuclear Regulatory Commission, "Susquehanna Steam Electric Station Proposed Amendment No. 274 to Unit 2 License NPF-22: MCPR Safety Limits PLA-6438," dated October 30,2008.

ANF-524(P)(A), Revision 2 and Supplements 1 and 2, "ANF Critical Power Methodology for Boiling Water Reactors," Advanced Nuclear Fuels Corporation, November 1990. EMF-2209(P)(A)

Revision 2, "SPCB Critical Power Correlation," Framatome ANP, September 2003. EMF-2158(P)(A)

Revision 0, "Siemens Power Corporation Methodology for Boiling Water Reactors:

Evaluation and Validation of CASMO-4/MICROBURN-B2," Siemens Power Corporation, October 1999. Letter from RV. Guzman (USNRC) to B. T. McKinney (PPL), "Susquehanna Steam Electric Station, Units 1 and 2 -

Issuance of Amendment Regarding the 13-Percent Extended Power Uprate (TAC Nos. MD3309 and MD3310)," dated January 30,2008. Part 21 Notification, "Notification of Potential Part 21 Report -AREVA Minimum Critical Power Ratio," dated October 8,2007 (ADAMS No. ML072830334). Request for Review and Approval of EMF-2209(P), Revision 2, Addendum 1, "SPCB Additive Constants for ATRIUM-10 Fuel," dated May 1,2008 (ADAMS No. ML081260442) Letter from William H. Spence, Executive Vice President, Chief Operating Officer/Chief Nuclear Officer, PPL Corporation, to the U.S.

Nuclear Regulatory Commission, "Susquehanna Steam Electric Station Proposed Amendment No. 274 to Unit 2 License No. NPF-22: MCPR Safety Limits PLA-6475," dated January 23,2009. Principal Contributors:

T. Nakanishi P. Yarsky A. Attard Date: February 26, 2Jr'f)

February 26, 2009 Mr. William H. Spence Executive Vice President Chief Operating Officer/Chief Nuclear Officer PPL Corporation Two North Ninth Street, GENTW16 Alientown,PA 18101-1179 SUSQUEHANNA STEAM ELECTRIC STATION, UNIT 2 -ISSUANCE OF AMENDMENT RE: CHANGES IN MCPR SAFETY LIMITS (TAC NO. ME0067)

Dear Mr. Spence:

The Commission has issued the enclosed Amendment No. 230 to Facility Operating License (FOL) No. NPF-22 for the PPL Susquehanna, LLC, Susquehanna Steam Electric Station, Unit 2 (PPL). This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated October 30, 2008, as supplemented by letters dated November 21, 2008, and January 23, 2009.

This amendment request revised PPL, TS 2.1.1.2, Minimum Critical Power Ratio Safety Limits (MCPRSLs) for two-loop and single-loop operation, and adds an associated License Condition in the FOL. A copy of our safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's Biweekly Federal Register Notice. Sincerely, IRA! Bhalchandra Vaidya, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-388

Enclosures:

1. Amendment No. 230 to License No. NPF-22 2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION PUBLIC PDI-1 RtF RidsNrrDorlLPL1-1 RidsNrrPMBVaidya (Paper copy) RidsNrrLASLittle (hard copy)

RidsOGCRp RidsNrrSrxb " RidsNrrSnpb RidsNRRDorlDPR RidsAcrsAcnw&mMailCenter RidsRg1MailCenter T, Nakanishi, SRXB P. Yarsky, SNPB A. Attard, SNPB ADAMS Accession No.: ML090330391

(*) No substantial Changes in the SE Memorandum OFFICE LPLI-1/PM LPLI-1/LA SRXB/BC(*)

SNPB/BC(*)

OGC LPLI-1/BC NAME BVaidya SLittie GCranston AMendiola MSmith MKowal DATE 2/19/09 2/19/09 01/27/09 01/27/09 2/23/09 2/26/09 OFFICIAL RECORD COpy