RIS 2008-26, Clarified Requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(Y) When Implementing 10 CFR Section 50.54(x) to Depart from a License Condition or Technical Specification: Difference between revisions

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{{#Wiki_filter:UNITED STATES
{{#Wiki_filter:UNITED STATES  
                            NUCLEAR REGULATORY COMMISSION
NUCLEAR REGULATORY COMMISSION  
                        OFFICE OF NUCLEAR REACTOR REGULATION
OFFICE OF NUCLEAR REACTOR REGULATION  
                                  WASHINGTON, DC 20555-0001 October 29, 2008 NRC REGULATORY ISSUE SUMMARY 2008-26 CLARIFIED REQUIREMENTS OF TITLE 10 OF THE CODE OF FEDERAL
WASHINGTON, DC 20555-0001  
    REGULATIONS (10 CFR) SECTION 50.54(Y) WHEN IMPLEMENTING 10 CFR
 
  SECTION 50.54(X) TO DEPART FROM A LICENSE CONDITION OR TECHNICAL
October 29, 2008  
                                        SPECIFICATION
 
NRC REGULATORY ISSUE SUMMARY 2008-26 CLARIFIED REQUIREMENTS OF TITLE 10 OF THE CODE OF FEDERAL  
REGULATIONS (10 CFR) SECTION 50.54(Y) WHEN IMPLEMENTING 10 CFR  
SECTION 50.54(X) TO DEPART FROM A LICENSE CONDITION OR TECHNICAL  
SPECIFICATION  


==ADDRESSEES==
==ADDRESSEES==
Line 26: Line 30:


==INTENT==
==INTENT==
The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS)
The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS)  
to clarify the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section
to clarify the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section  
50.54(y) when licensees implement 10 CFR Section 50.54(x) to depart from a license condition or technical specification in an emergency. This RIS requires no action or written response on the part of the addressees.
50.54(y) when licensees implement 10 CFR Section 50.54(x) to depart from a license condition or technical specification in an emergency. This RIS requires no action or written response on the part of the addressees.


==BACKGROUND==
==BACKGROUND==
Section 50.54(y) states, "Licensee actions permitted by paragraph (x) of this section shall be approved, as a minimum, by a licensed senior operator..." This describes the lowest ranking individual authorized to approve the departure from a license condition or technical specification. An individual other than a licensed senior operator could make such a decision, as long as the person is in a position of authority greater than the licensed senior operator. The Statements of Consideration (SOC) that accompanied the final rule for 10 CFR Part 50,
Section 50.54(y) states, "Licensee actions permitted by paragraph (x) of this section shall be approved, as a minimum, by a licensed senior operator..." This describes the lowest ranking individual authorized to approve the departure from a license condition or technical specification. An individual other than a licensed senior operator could make such a decision, as long as the person is in a position of authority greater than the licensed senior operator. The Statements of Consideration (SOC) that accompanied the final rule for 10 CFR Part 50,  
Applicability of License; Conditions and Technical Specifications in an Emergency, in 48 FR
Applicability of License; Conditions and Technical Specifications in an Emergency, in 48 FR  
13966, April 1, 1983, stated that the decision to depart from the license could be made by any licensed senior operator for the unit involved. However, in an emergency, that decision would pass to more senior licensee personnel, if available, as higher authorities in the chain of command. That interpretation was reiterated by Mr. John A. Zwolinski, Director, BWR Project Directorate #1, to Consumers Power Company in a November 5, 1986 letter with the subject, AConsumers Power Company (CPC) Request for Interpretation of 10 CFR 50.54(y).
13966, April 1, 1983, stated that the decision to depart from the license could be made by any licensed senior operator for the unit involved. However, in an emergency, that decision would pass to more senior licensee personnel, if available, as higher authorities in the chain of command. That interpretation was reiterated by Mr. John A. Zwolinski, Director, BWR Project Directorate #1, to Consumers Power Company in a November 5, 1986 letter with the subject, AConsumers Power Company (CPC) Request for Interpretation of 10 CFR 50.54(y).  
In 2004, the staff approved Nuclear Energy Institute (NEI) 03-12, ATemplate for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan,@ which licensees used as a template for making security plan changes. Some industry personnel questioned whether this document was contrary to the staffs earlier position, in that the template required the highest ranking licensee official (e.g., Emergency Director (ED)) to receive approval from a licensed senior operator to depart from the license.
 
In 2004, the staff approved Nuclear Energy Institute (NEI) 03-12, ATemplate for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan,@ which licensees used as a template for making security plan changes. Some industry personnel questioned whether this  
 
document was contrary to the staffs earlier position, in that the template required the highest ranking licensee official (e.g., Emergency Director (ED)) to receive approval from a licensed senior operator to depart from the license.
 
DISCUSSION


DISCUSSION
Section 50.54(y) of 10 CFR does not require that the decision to depart from the license or technical specifications be made only by a licensed senior operator or that the individual making the decision possess a senior operators license. Rather, such a decision could be made either by any licensed senior operator or any individual in a superior position to a licensed senior operator. As stated in the SOC, if "more senior licensee personnel" are available, "the decision to depart from the license in an emergency would pass to them (as higher authorities in the chain of command)." There is nothing in the rule to indicate that the "more senior licensee personnel" are also required to be licensed senior operators. In addition, there is nothing in the rule that would require the "more senior licensee personnel" to obtain the concurrence of a licensed senior operator to make such a decision, and the SOC does not contain any discussion suggesting such Commission intent.
Section 50.54(y) of 10 CFR does not require that the decision to depart from the license or technical specifications be made only by a licensed senior operator or that the individual making the decision possess a senior operators license. Rather, such a decision could be made either by any licensed senior operator or any individual in a superior position to a licensed senior operator. As stated in the SOC, if "more senior licensee personnel" are available, "the decision to depart from the license in an emergency would pass to them (as higher authorities in the chain of command)." There is nothing in the rule to indicate that the "more senior licensee personnel" are also required to be licensed senior operators. In addition, there is nothing in the rule that would require the "more senior licensee personnel" to obtain the concurrence of a licensed senior operator to make such a decision, and the SOC does not contain any discussion suggesting such Commission intent.


With respect to the language in the NEI template, which states that the departure decision would be made by the ED, with approval, at a minimum, from a licensed senior reactor operator, the NRC notes that the NEI template is not an NRC interpretation of its regulations. This template, once approved, described one way to comply with NRC requirements. A licensee is free to utilize other approaches which comply with the requirements of the regulation as interpreted and applied by the Commission. Also, the fact that the NRC has approved a document that seems to employ more stringent measures (e.g., both the ED and senior reactor operator must concur on the departure) does not mean that less stringent measures would be insufficient in order to comply with the regulations. Each individual licensee is free to determine whether or not it wants to employ such a concurrence process.
With respect to the language in the NEI template, which states that the departure decision would be made by the ED, with approval, at a minimum, from a licensed senior reactor operator, the NRC notes that the NEI template is not an NRC interpretation of its regulations. This template, once approved, described one way to comply with NRC requirements. A licensee is free to utilize other approaches which comply with the requirements of the regulation as interpreted and applied by the Commission. Also, the fact that the NRC has approved a document that seems to employ more stringent measures (e.g., both the ED and senior reactor operator must concur on the departure) does not mean that less stringent measures would be insufficient in order to comply with the regulations. Each individual licensee is free to determine whether or not it wants to employ such a concurrence process.


==SUMMARY OF ISSUE==
==SUMMARY OF ISSUE==
The decision to depart from the license or a technical specification in an emergency shall be approved, as a minimum, by a licensed senior operator. If more senior licensee personnel are available, the decision to depart from the license in an emergency would pass to them as higher authorities in the chain of command. The rule does not specify that the senior licensee personnel be licensed senior operators or that they obtain the concurrence of a licensed senior operator to make such a decision.
The decision to depart from the license or a technical specification in an emergency shall be approved, as a minimum, by a licensed senior operator. If more senior licensee personnel are available, the decision to depart from the license in an emergency would pass to them as higher authorities in the chain of command. The rule does not specify that the senior licensee personnel be licensed senior operators or that they obtain the concurrence of a licensed senior operator to make such a decision.


==BACKFIT DISCUSSION==
==BACKFIT DISCUSSION==
This RIS does not represent a new or different staff position regarding the implementation of
This RIS does not represent a new or different staff position regarding the implementation of
10 CFR 50.54(x) and is consistent with the SOC for 10 CFR 50.54(x) and (y), and the staff guidance in the November, 1986 Zwolinski letter. It requires no action or written response. Any action by addressees to implement changes to their security or emergency plans, or procedures in accordance with the guidance in this RIS is strictly voluntary and therefore, is not a backfit under 10 CFR 50.109, Backfitting. Consequently, the NRC staff did not perform a backfit analysis.
10 CFR 50.54(x) and is consistent with the SOC for 10 CFR 50.54(x) and (y), and the staff guidance in the November, 1986 Zwolinski letter. It requires no action or written response. Any action by addressees to implement changes to their security or emergency plans, or procedures in accordance with the guidance in this RIS is strictly voluntary and therefore, is not a backfit under 10 CFR 50.109, Backfitting. Consequently, the NRC staff did not perform a backfit analysis.


===FEDERAL REGISTER NOTIFICATION===
===FEDERAL REGISTER NOTIFICATION===
A notice of opportunity for public comment on this RIS was published in the Federal Register
A notice of opportunity for public comment on this RIS was published in the Federal Register  
(73 FR 47853) on August 15, 2008 for a 60-day comment period. That period closed on October 14, 2008, and no comments were received.
(73 FR 47853) on August 15, 2008 for a 60-day comment period. That period closed on October 14, 2008, and no comments were received.


===CONGRESSIONAL REVIEW ACT===
===CONGRESSIONAL REVIEW ACT===
This RIS is not a rule as designated by the Congressional Review Act (5 U.S.C. §§ 801-886)
This RIS is not a rule as designated by the Congressional Review Act (5 U.S.C. §§ 801-886)  
and therefore, is not subject to the Act.
and therefore, is not subject to the Act.


===PAPERWORK REDUCTION ACT STATEMENT===
===PAPERWORK REDUCTION ACT STATEMENT===
This RIS does not contain any information collections and, therefore, is not subject to the requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.).
This RIS does not contain any information collections and, therefore, is not subject to the requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.).  


===PUBLIC PROTECTION NOTIFICATION===
===PUBLIC PROTECTION NOTIFICATION===
Line 65: Line 73:
Please direct any questions about this matter to the technical contact listed below.
Please direct any questions about this matter to the technical contact listed below.


/RA by TBlount for/
/RA by TBlount for/
                                    Michael J. Case, Director Division of Policy and Rulemaking Office of Nuclear Reactor Regulation  
 
Michael J. Case, Director Division of Policy and Rulemaking Office of Nuclear Reactor Regulation  


===Technical Contact:===
===Technical Contact:===
F. J. Laughlin, NSIR/DPR
F. J. Laughlin, NSIR/DPR  
                          301-415-1113 E-mail: jeff.laughlin@nrc.gov  
 
301-415-1113  
 
E-mail: jeff.laughlin@nrc.gov  


===FEDERAL REGISTER NOTIFICATION===
===FEDERAL REGISTER NOTIFICATION===
A notice of opportunity for public comment on this RIS was published in the Federal Register
A notice of opportunity for public comment on this RIS was published in the Federal Register  
  (73 FR 47853) on August 15, 2008 for a 60-day comment period. That period closed on October 14, 2008, and no comments were received.
(73 FR 47853) on August 15, 2008 for a 60-day comment period. That period closed on October 14, 2008, and no comments were received.


===CONGRESSIONAL REVIEW ACT===
===CONGRESSIONAL REVIEW ACT===
This RIS is not a rule as designated by the Congressional Review Act (5 U.S.C. §§ 801-886)
This RIS is not a rule as designated by the Congressional Review Act (5 U.S.C. §§ 801-886)  
  and therefore, is not subject to the Act.
and therefore, is not subject to the Act.


===PAPERWORK REDUCTION ACT STATEMENT===
===PAPERWORK REDUCTION ACT STATEMENT===
This RIS does not contain any information collections and, therefore, is not subject to the requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.).
This RIS does not contain any information collections and, therefore, is not subject to the requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.).  


===PUBLIC PROTECTION NOTIFICATION===
===PUBLIC PROTECTION NOTIFICATION===
Line 89: Line 101:
Please direct any questions about this matter to the technical contact listed below.
Please direct any questions about this matter to the technical contact listed below.


/RA by TBlount for/
/RA by TBlount for/  
                                        Michael J. Case, Director Division of Policy and Rulemaking Office of Nuclear Reactor Regulation  
Michael J. Case, Director Division of Policy and Rulemaking Office of Nuclear Reactor Regulation  


===Technical Contact:===
===Technical Contact:===
F. J. Laughlin, NSIR/DPR
F. J. Laughlin, NSIR/DPR  
                            301-415-1113 E-mail: jeff.laughlin@nrc.gov Distribution: RIS File Accession No.: ML 080590124 OFFICE         DPR:NSIR     Tech Editor     TL:DPR:NSIR     BC:DPR:NSIR   DD:DPR:NSIR     D:DPR:NSIR
 
NAME           JLaughlin     CHsu             KBrock       AMcMurtray       CMiller         MLeach DATE           03/06/08     03/04/08         03/06/08       03/13/08     03/20/08         03/26/08 OFFICE     BC:RSPLB:DSP   BC:IOLB:DIRS     BC:ITSB:DIRS   D:DORL:NRR         OE           OGC(CRA)
301-415-1113  
NAME             DHuyck     NSalgado           RElliott       CHaney       DStarkey         SHamrick DATE           04/08/08     04/03/08         04/08/08       04/24/08     03/31/08         04/09/08 OFFICE         OGC(NLO)       PMDA               OIS       LA:PGCB:DPR   PGCB:DPR:NRR     BC:PGCB:DPR
 
NAME             BJones       LHill         GTrussell         CHawes       AWMarkley       MMurphy DATE             04/09/08     04/30/08         05/06/08         05/7/08         05/7/08       05/15/08 OFFICE         D:DPR:NRR
E-mail: jeff.laughlin@nrc.gov Distribution:   RIS File Accession No.: ML 080590124  
NAME           TBlount for MCase DATE             10/29/08
 
OFFICE  
 
DPR:NSIR  
 
Tech Editor  
 
TL:DPR:NSIR  
 
BC:DPR:NSIR  
 
DD:DPR:NSIR  
 
D:DPR:NSIR  
 
NAME  
 
JLaughlin  
 
CHsu  
 
KBrock  
 
AMcMurtray  
 
CMiller  
 
MLeach  
 
DATE  
 
03/06/08  
 
03/04/08  
 
03/06/08  
 
03/13/08  
 
03/20/08  
 
03/26/08  
 
OFFICE  
 
BC:RSPLB:DSP  
 
BC:IOLB:DIRS  
 
BC:ITSB:DIRS  
 
D:DORL:NRR  
 
OE  
 
OGC(CRA)  
 
NAME  
 
DHuyck  
 
NSalgado  
 
RElliott  
 
CHaney  
 
DStarkey  
 
SHamrick  
 
DATE  
 
04/08/08  
 
04/03/08  
 
04/08/08  
 
04/24/08  
 
03/31/08  
 
04/09/08  
 
OFFICE  
 
OGC(NLO)  
 
PMDA  
 
OIS  
 
LA:PGCB:DPR  
 
PGCB:DPR:NRR  
 
BC:PGCB:DPR  
 
NAME  
 
BJones  
 
LHill  
 
GTrussell  
 
CHawes  
 
AWMarkley  
 
MMurphy  
 
DATE  
 
04/09/08  
 
04/30/08  
 
05/06/08  
 
05/7/08  
 
05/7/08  
 
05/15/08  
 
OFFICE  
 
D:DPR:NRR  
 
NAME  
 
TBlount for MCase  
 
DATE  
 
10/29/08
}}
}}


{{RIS-Nav}}
{{RIS-Nav}}

Latest revision as of 17:56, 14 January 2025

Clarified Requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(Y) When Implementing 10 CFR Section 50.54(x) to Depart from a License Condition or Technical Specification
ML080590124
Person / Time
Issue date: 10/29/2008
From: Michael Case
Division of Policy and Rulemaking
To:
References
RIS-08-026
Download: ML080590124 (4)
v • d • e


UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, DC 20555-0001

October 29, 2008

NRC REGULATORY ISSUE SUMMARY 2008-26 CLARIFIED REQUIREMENTS OF TITLE 10 OF THE CODE OF FEDERAL

REGULATIONS (10 CFR) SECTION 50.54(Y) WHEN IMPLEMENTING 10 CFR

SECTION 50.54(X) TO DEPART FROM A LICENSE CONDITION OR TECHNICAL

SPECIFICATION

ADDRESSEES

All holders of operating licenses for nuclear power reactors, except those who have permanently ceased operations and have certified that fuel has been permanently removed from the reactor vessel.

INTENT

The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS)

to clarify the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section

50.54(y) when licensees implement 10 CFR Section 50.54(x) to depart from a license condition or technical specification in an emergency. This RIS requires no action or written response on the part of the addressees.

BACKGROUND

Section 50.54(y) states, "Licensee actions permitted by paragraph (x) of this section shall be approved, as a minimum, by a licensed senior operator..." This describes the lowest ranking individual authorized to approve the departure from a license condition or technical specification. An individual other than a licensed senior operator could make such a decision, as long as the person is in a position of authority greater than the licensed senior operator. The Statements of Consideration (SOC) that accompanied the final rule for 10 CFR Part 50,

Applicability of License; Conditions and Technical Specifications in an Emergency, in 48 FR

13966, April 1, 1983, stated that the decision to depart from the license could be made by any licensed senior operator for the unit involved. However, in an emergency, that decision would pass to more senior licensee personnel, if available, as higher authorities in the chain of command. That interpretation was reiterated by Mr. John A. Zwolinski, Director, BWR Project Directorate #1, to Consumers Power Company in a November 5, 1986 letter with the subject, AConsumers Power Company (CPC) Request for Interpretation of 10 CFR 50.54(y).

In 2004, the staff approved Nuclear Energy Institute (NEI) 03-12, ATemplate for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan,@ which licensees used as a template for making security plan changes. Some industry personnel questioned whether this

document was contrary to the staffs earlier position, in that the template required the highest ranking licensee official (e.g., Emergency Director (ED)) to receive approval from a licensed senior operator to depart from the license.

DISCUSSION

Section 50.54(y) of 10 CFR does not require that the decision to depart from the license or technical specifications be made only by a licensed senior operator or that the individual making the decision possess a senior operators license. Rather, such a decision could be made either by any licensed senior operator or any individual in a superior position to a licensed senior operator. As stated in the SOC, if "more senior licensee personnel" are available, "the decision to depart from the license in an emergency would pass to them (as higher authorities in the chain of command)." There is nothing in the rule to indicate that the "more senior licensee personnel" are also required to be licensed senior operators. In addition, there is nothing in the rule that would require the "more senior licensee personnel" to obtain the concurrence of a licensed senior operator to make such a decision, and the SOC does not contain any discussion suggesting such Commission intent.

With respect to the language in the NEI template, which states that the departure decision would be made by the ED, with approval, at a minimum, from a licensed senior reactor operator, the NRC notes that the NEI template is not an NRC interpretation of its regulations. This template, once approved, described one way to comply with NRC requirements. A licensee is free to utilize other approaches which comply with the requirements of the regulation as interpreted and applied by the Commission. Also, the fact that the NRC has approved a document that seems to employ more stringent measures (e.g., both the ED and senior reactor operator must concur on the departure) does not mean that less stringent measures would be insufficient in order to comply with the regulations. Each individual licensee is free to determine whether or not it wants to employ such a concurrence process.

SUMMARY OF ISSUE

The decision to depart from the license or a technical specification in an emergency shall be approved, as a minimum, by a licensed senior operator. If more senior licensee personnel are available, the decision to depart from the license in an emergency would pass to them as higher authorities in the chain of command. The rule does not specify that the senior licensee personnel be licensed senior operators or that they obtain the concurrence of a licensed senior operator to make such a decision.

BACKFIT DISCUSSION

This RIS does not represent a new or different staff position regarding the implementation of

10 CFR 50.54(x) and is consistent with the SOC for 10 CFR 50.54(x) and (y), and the staff guidance in the November, 1986 Zwolinski letter. It requires no action or written response. Any action by addressees to implement changes to their security or emergency plans, or procedures in accordance with the guidance in this RIS is strictly voluntary and therefore, is not a backfit under 10 CFR 50.109, Backfitting. Consequently, the NRC staff did not perform a backfit analysis.

FEDERAL REGISTER NOTIFICATION

A notice of opportunity for public comment on this RIS was published in the Federal Register

(73 FR 47853) on August 15, 2008 for a 60-day comment period. That period closed on October 14, 2008, and no comments were received.

CONGRESSIONAL REVIEW ACT

This RIS is not a rule as designated by the Congressional Review Act (5 U.S.C. §§ 801-886)

and therefore, is not subject to the Act.

PAPERWORK REDUCTION ACT STATEMENT

This RIS does not contain any information collections and, therefore, is not subject to the requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.).

PUBLIC PROTECTION NOTIFICATION

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 OMB control number.

CONTACT

Please direct any questions about this matter to the technical contact listed below.

/RA by TBlount for/

Michael J. Case, Director Division of Policy and Rulemaking Office of Nuclear Reactor Regulation

Technical Contact:

F. J. Laughlin, NSIR/DPR

301-415-1113

E-mail: jeff.laughlin@nrc.gov

FEDERAL REGISTER NOTIFICATION

A notice of opportunity for public comment on this RIS was published in the Federal Register

(73 FR 47853) on August 15, 2008 for a 60-day comment period. That period closed on October 14, 2008, and no comments were received.

CONGRESSIONAL REVIEW ACT

This RIS is not a rule as designated by the Congressional Review Act (5 U.S.C. §§ 801-886)

and therefore, is not subject to the Act.

PAPERWORK REDUCTION ACT STATEMENT

This RIS does not contain any information collections and, therefore, is not subject to the requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.).

PUBLIC PROTECTION NOTIFICATION

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 OMB control number.

CONTACT

Please direct any questions about this matter to the technical contact listed below.

/RA by TBlount for/

Michael J. Case, Director Division of Policy and Rulemaking Office of Nuclear Reactor Regulation

Technical Contact:

F. J. Laughlin, NSIR/DPR

301-415-1113

E-mail: jeff.laughlin@nrc.gov Distribution: RIS File Accession No.: ML 080590124

OFFICE

DPR:NSIR

Tech Editor

TL:DPR:NSIR

BC:DPR:NSIR

DD:DPR:NSIR

D:DPR:NSIR

NAME

JLaughlin

CHsu

KBrock

AMcMurtray

CMiller

MLeach

DATE

03/06/08

03/04/08

03/06/08

03/13/08

03/20/08

03/26/08

OFFICE

BC:RSPLB:DSP

BC:IOLB:DIRS

BC:ITSB:DIRS

D:DORL:NRR

OE

OGC(CRA)

NAME

DHuyck

NSalgado

RElliott

CHaney

DStarkey

SHamrick

DATE

04/08/08

04/03/08

04/08/08

04/24/08

03/31/08

04/09/08

OFFICE

OGC(NLO)

PMDA

OIS

LA:PGCB:DPR

PGCB:DPR:NRR

BC:PGCB:DPR

NAME

BJones

LHill

GTrussell

CHawes

AWMarkley

MMurphy

DATE

04/09/08

04/30/08

05/06/08

05/7/08

05/7/08

05/15/08

OFFICE

D:DPR:NRR

NAME

TBlount for MCase

DATE

10/29/08


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