Information Notice 2005-30, Safe Shutdown Potentially Challenged by Unanalyzed Internal Flooding Events and Inadequate Design: Difference between revisions

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{{#Wiki_filter:UNITED STATES
{{#Wiki_filter:ML052020249


===UNITED STATES===
NUCLEAR REGULATORY COMMISSION
NUCLEAR REGULATORY COMMISSION


OFFICE OF NUCLEAR REACTOR REGULATION
===OFFICE OF NUCLEAR REACTOR REGULATION===
WASHINGTON, D.C.  20555


WASHINGTON, D.C. 20555 November 7, 2005 NRC INFORMATION NOTICE 2005-30:                 SAFE SHUTDOWN POTENTIALLY
===November 7, 2005===
NRC INFORMATION NOTICE 2005-30:


===SAFE SHUTDOWN POTENTIALLY===
CHALLENGED BY UNANALYZED INTERNAL
CHALLENGED BY UNANALYZED INTERNAL


FLOODING EVENTS AND INADEQUATE DESIGN
===FLOODING EVENTS AND INADEQUATE DESIGN===


==ADDRESSEES==
==ADDRESSEES==
Line 45: Line 49:
It is expected that recipients will review the information for applicability to their facilities and
It is expected that recipients will review the information for applicability to their facilities and


consider corrective actions, as appropriate. However, suggestions contained in this information
consider corrective actions, as appropriate. However, suggestions contained in this information


notice are not NRC requirements; therefore, no specific action or written response is required.
notice are not NRC requirements; therefore, no specific action or written response is required.
Line 56: Line 60:
distribution switchgear) are located at the same elevation and immediately adjacent to the
distribution switchgear) are located at the same elevation and immediately adjacent to the


turbine building (TB) basement. Water from a TB flood could have flowed into these spaces
turbine building (TB) basement. Water from a TB flood could have flowed into these spaces


through non-watertight doors and through the floor drain system, which consisted of an open
through non-watertight doors and through the floor drain system, which consisted of an open


pipe connecting the spaces to the turbine building sump. Several non-safety related systems
pipe connecting the spaces to the turbine building sump. Several non-safety related systems


are located within the turbine building that have the potential to release large volumes of water
are located within the turbine building that have the potential to release large volumes of water


in the event of a pressure boundary failure. These systems include the circulating water, condensate storage, and fire protection systems. In the case of the fire protection system, a
in the event of a pressure boundary failure. These systems include the circulating water, condensate storage, and fire protection systems. In the case of the fire protection system, a


large volume of water could be released from system actuation. Although infrequent, U.S.
large volume of water could be released from system actuation. Although infrequent, U.S.


nuclear power plant operating experience includes internal flooding events initiated by
nuclear power plant operating experience includes internal flooding events initiated by
Line 77: Line 81:
(SSCs) be protected against damage from a pipe or tank rupture that releases enough water or
(SSCs) be protected against damage from a pipe or tank rupture that releases enough water or


steam to impair the safety function. In a letter to the NRC, dated October 31, 1972, the
steam to impair the safety function. In a letter to the NRC, dated October 31, 1972, the


licensee previously reported that the consequences of failure of non-safety related systems
licensee previously reported that the consequences of failure of non-safety related systems


could adversely affect the performance of engineered-safety systems. However, based on
could adversely affect the performance of engineered-safety systems. However, based on


safety equipment redundancy and design arrangement, and on an assessment that appropriate
safety equipment redundancy and design arrangement, and on an assessment that appropriate
Line 89: Line 93:
that the functional purpose of the safety equipment would not be jeopardized.
that the functional purpose of the safety equipment would not be jeopardized.


During performance of baseline inspection procedure 71111.06, Flood Protection Measures, NRC inspectors at KPS identified a potential internal flooding vulnerability. Following
During performance of baseline inspection procedure 71111.06, Flood Protection Measures, NRC inspectors at KPS identified a potential internal flooding vulnerability. Following


discussions with the inspectors and NRC staff, the licensee reported, in Event Notification
discussions with the inspectors and NRC staff, the licensee reported, in Event Notification
Line 95: Line 99:
41496, that the KPS design might not mitigate the consequences of piping system failures and, in Licensee Event Report (LER) 2005-004 (ML051440302), that safe shutdown was potentially
41496, that the KPS design might not mitigate the consequences of piping system failures and, in Licensee Event Report (LER) 2005-004 (ML051440302), that safe shutdown was potentially


challenged by unanalyzed flooding events and inadequate design. Additionally, in the LER, the
challenged by unanalyzed flooding events and inadequate design. Additionally, in the LER, the


licensee reported that a complete internal plant flooding analysis was not developed during or
licensee reported that a complete internal plant flooding analysis was not developed during or
Line 111: Line 115:
systems, including high energy line breaks, random pipe failures, and seismically induced pipe
systems, including high energy line breaks, random pipe failures, and seismically induced pipe


failures. These corrective actions include:
failures. These corrective actions include:
1.     Compilation of design and licensing bases for internal flooding to support current and
1.
 
Compilation of design and licensing bases for internal flooding to support current and


future flooding design
future flooding design


2.     Seismic qualification of selected piping and components
2.


3.     Design modifications to protect Class I plant SSCs as defined in the KPS Updated
Seismic qualification of selected piping and components
 
3.
 
Design modifications to protect Class I plant SSCs as defined in the KPS Updated


Safety Analysis Report (USAR), including:
Safety Analysis Report (USAR), including:
        a. installation of check valves in selected floor drains
a. installation of check valves in selected floor drains


b. auxiliary feedwater pump lube oil cooler and drain flow path revisions
b. auxiliary feedwater pump lube oil cooler and drain flow path revisions


c. installation of a circulating water pump trip on high TB basement water level
c.


d. flood barriers at doors to safety-related equipment rooms (safeguards alley)
installation of a circulating water pump trip on high TB basement water level
        e. enhanced supports for auxiliary feedwater pump steam supply piping 4.       The following interim protective actions were implemented pending completion of
 
d. flood barriers at doors to safety-related equipment rooms (safeguards alley)
e. enhanced supports for auxiliary feedwater pump steam supply piping 4.
 
The following interim protective actions were implemented pending completion of


appropriate measures to ensure protection of Class I plant SSCs:
appropriate measures to ensure protection of Class I plant SSCs:
        a. The plant operating mode was restricted to refueling or cold shutdown.
a. The plant operating mode was restricted to refueling or cold shutdown.


b. The maximum combined inventory of the condensate storage tanks and the reactor
b. The maximum combined inventory of the condensate storage tanks and the reactor
Line 137: Line 151:
makeup tanks was restricted.
makeup tanks was restricted.


c. Restrictions were placed on operation of the circulating water and condensate
c.
 
Restrictions were placed on operation of the circulating water and condensate


systems.
systems.
Line 144: Line 160:
Numerous flood-related vulnerabilities and events have been identified at nuclear power
Numerous flood-related vulnerabilities and events have been identified at nuclear power


facilities both domestically and internationally. Flooding due to internal causes has been shown
facilities both domestically and internationally. Flooding due to internal causes has been shown


to be a significant contributor to risk at some facilities. It has the potential to make multiple
to be a significant contributor to risk at some facilities. It has the potential to make multiple


trains of equipment and support equipment inoperable, significantly increasing plant risk.
trains of equipment and support equipment inoperable, significantly increasing plant risk.
Line 152: Line 168:
Flooding also has the significant consequence of preventing or limiting operator mitigation and
Flooding also has the significant consequence of preventing or limiting operator mitigation and


recovery actions. A review of domestic and international operating experience revealed
recovery actions. A review of domestic and international operating experience revealed


hundreds of flood-related events and findings, several of which were very similar to the event at
hundreds of flood-related events and findings, several of which were very similar to the event at
Line 162: Line 178:
plant areas and inspect internal flood protection features for risk-significant SSCs in accordance
plant areas and inspect internal flood protection features for risk-significant SSCs in accordance


with Inspection Procedure Attachment 71111.06 Flood Protection Measures. A review of
with Inspection Procedure Attachment 71111.06 Flood Protection Measures. A review of


findings documented under this inspection procedure from January 2000 through March 2005 turned up 39 findings (28 non-cited violations, 2 severity level IV violations, 8 GREEN findings, and 1 WHITE finding).
findings documented under this inspection procedure from January 2000 through March 2005 turned up 39 findings (28 non-cited violations, 2 severity level IV violations, 8 GREEN findings, and 1 WHITE finding).


NRC generic communications that have addressed flood protection issues:
NRC generic communications that have addressed flood protection issues:
1. Circular       Potential Common Mode Flooding of ECCS Equipment Rooms
1. Circular


CR 78-06      at BWR Facilities
Potential Common Mode Flooding of ECCS Equipment Rooms


2. IN 83-44        Potential Damage to Redundant Safety Equipment as a Result of Backflow
CR 78-06 at BWR Facilities


Through the Equipment and Floor Drain System
2. IN 83-44 Potential Damage to Redundant Safety Equipment as a Result of Backflow


3. IN 83-44 S1 Supplement 1: Potential Damage to Redundant Safety Equipment as a
===Through the Equipment and Floor Drain System===
3. IN 83-44 S1 Supplement 1: Potential Damage to Redundant Safety Equipment as a


Result of Backflow Through the Equipment and Floor Drain System
Result of Backflow Through the Equipment and Floor Drain System


4. IN 87-49       Deficiencies in Outside Containment Flooding Protection 5. IN 92-69       Water Leakage from Yard Area Through Conduits into Buildings
4. IN 87-49 Deficiencies in Outside Containment Flooding Protection 5. IN 92-69 Water Leakage from Yard Area Through Conduits into Buildings


6. IN 94-27       Facility Operating Concerns Resulting from Local Area Flooding
6. IN 94-27 Facility Operating Concerns Resulting from Local Area Flooding


7. IN 98-31       Fire Protection System Design Deficiencies and Common-mode Flooding of
7. IN 98-31 Fire Protection System Design Deficiencies and Common-mode Flooding of


Emergency Core Cooling System Rooms at Washington Nuclear Project
Emergency Core Cooling System Rooms at Washington Nuclear Project


Unit 2
Unit 2
8. IN 2005-11     Internal Flooding/spray-down of Safety-related Equipment Due to Unsealed
 
8. IN 2005-11 Internal Flooding/spray-down of Safety-related Equipment Due to Unsealed


Equipment Hatch Floor Plugs And/or Blocked Floor Drains
Equipment Hatch Floor Plugs And/or Blocked Floor Drains
Line 196: Line 214:


Through Floor Drains (Rev. 1)
Through Floor Drains (Rev. 1)
2. NUREG-0933 ITEM A-17 System Interactions in Nuclear Power Plants (Rev. 2)
2. NUREG-0933 ITEM A-17 System Interactions in Nuclear Power Plants (Rev. 2)
CONCLUSION
CONCLUSION


Line 203: Line 221:
made these systems vulnerable to flooding originating from failures of non-safety related
made these systems vulnerable to flooding originating from failures of non-safety related


systems located in the turbine building. An NRC-identified condition at KPS revealed a less- than-effective application of operating experience to address safety-significant flooding-design
systems located in the turbine building. An NRC-identified condition at KPS revealed a less- than-effective application of operating experience to address safety-significant flooding-design


vulnerabilities. This was based, in part, on the licensees misunderstanding of the KPS
vulnerabilities. This was based, in part, on the licensees misunderstanding of the KPS


licensing basis for the plant flooding analysis and design and on an erroneous assumption
licensing basis for the plant flooding analysis and design and on an erroneous assumption
Line 213: Line 231:
Consequently, the ability to achieve safe-shutdown for credible internal flooding events was not
Consequently, the ability to achieve safe-shutdown for credible internal flooding events was not


reasonably assured. The licensee and NRC found that the KPS USAR and other plant-specific
reasonably assured. The licensee and NRC found that the KPS USAR and other plant-specific


NRC correspondence provided sufficiently clear guidance on the requirements to protect
NRC correspondence provided sufficiently clear guidance on the requirements to protect


safety-related equipment from the effects of internal flooding. No safety-related equipment at
safety-related equipment from the effects of internal flooding. No safety-related equipment at


KPS was flooded, but correcting the deficiencies of internal flooding design took a large part of
KPS was flooded, but correcting the deficiencies of internal flooding design took a large part of
Line 224: Line 242:


==CONTACT==
==CONTACT==
This information notice requires no specific action or written response. Please direct any
This information notice requires no specific action or written response. Please direct any


questions about this matter to the technical contacts listed below or the appropriate Office of
questions about this matter to the technical contacts listed below or the appropriate Office of
Line 231: Line 249:


/RA/ By Patrick L. Hiland For/
/RA/ By Patrick L. Hiland For/
                                    Michael J. Case, Director


===Michael J. Case, Director===
Division of Inspection & Regional Support
Division of Inspection & Regional Support


Office of Nuclear Reactor Regulation
Office of Nuclear Reactor Regulation


Technical Contacts: Ross Telson, NRR/DIPM                   Pat Higgins, RIII
Technical Contacts: Ross Telson, NRR/DIPM
 
===Pat Higgins, RIII===
301-415-2256
923-388-3156 E-mail:  rdt@nrc.gov
 
E-mail:  pch1@nrc.gov
 
Note:  NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.
 
ML052020249 OFFICE
 
R-III/DRP
 
Tech Editor
 
R-III/DRP/TL
 
R-III/DRP/BR-5 R-III/DRP/BR-5 NAME
 
MSatorious
 
(by e-mail)
PKleene
 
TKozak


301-415-2256                          923-388-3156 E-mail: rdt@nrc.gov                    E-mail: pch1@nrc.gov
(by e-mail)
JGiessner


Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.
(by e-mail)
SBurton (by e-mail)
DATE


ML052020249 OFFICE    R-III/DRP            Tech Editor          R-III/DRP/TL        R-III/DRP/BR-5 R-III/DRP/BR-5 NAME      MSatorious          PKleene              TKozak              JGiessner      SBurton (by e-mail)
08/19/2005
          (by e-mail)                                (by e-mail)        (by e-mail)
07/25/2005
DATE      08/19/2005           07/25/2005           08/25/2005         08/19/2005     08/19/2005 OFFICE   R-III/DRP/BR-5        A:SC:SPLB:DSSA                  SPLB:DSSA              LPD3-1:DLPM
08/25/2005
08/19/2005
08/19/2005 OFFICE


NAME      PHiggins (by e-mail)  SJones (by e-mail)              JSGuo (by e-mail)      JStang (by e-mail)
R-III/DRP/BR-5 A:SC:SPLB:DSSA
DATE      08/19/2005            08/19/2005                      08/22/2005              08/25/2005 OFFICE    OES:IROB:DIPM TL:IOEB:DIRS                BC:IOEB:DIRS DD:DIRS                D:DIRS


NAME     RDTelson             EJBenner           MJRoss-Lee           PLHiland       MJCase/For
SPLB:DSSA
 
LPD3-1:DLPM
 
NAME
 
PHiggins (by e-mail)
SJones (by e-mail)
JSGuo (by e-mail)
JStang (by e-mail)
DATE
 
08/19/2005
08/19/2005
08/22/2005
08/25/2005 OFFICE
 
OES:IROB:DIPM
 
TL:IOEB:DIRS
 
BC:IOEB:DIRS
 
DD:DIRS
 
D:DIRS
 
NAME
 
RDTelson
 
EJBenner
 
MJRoss-Lee
 
PLHiland
 
MJCase/For


PLHiland)
PLHiland)
DATE     08/26/2005           11/03/2005           11/03/2005         11/07/2005     11/07/2005}}
DATE
 
08/26/2005
11/03/2005
11/03/2005
11/07/2005
11/07/2005}}


{{Information notice-Nav}}
{{Information notice-Nav}}

Latest revision as of 18:10, 15 January 2025

Safe Shutdown Potentially Challenged by Unanalyzed Internal Flooding Events and Inadequate Design
ML052020249
Person / Time
Issue date: 11/07/2005
From: Michael Case
NRC/NRR/ADRO/DIRS
To:
Telson, R - NRR/DIPM/IROB - 415-2256
References
TAC MC7265 IN-05-030
Download: ML052020249 (6)
v • d • e


ML052020249

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555

November 7, 2005

NRC INFORMATION NOTICE 2005-30:

SAFE SHUTDOWN POTENTIALLY

CHALLENGED BY UNANALYZED INTERNAL

FLOODING EVENTS AND INADEQUATE DESIGN

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.

PURPOSE

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to alert

addressees to the importance of establishing and maintaining the plant flooding analysis and

design, consistent with NRC requirements and principles of effective risk management, to

ensure that internal flooding risk is effectively managed.

It is expected that recipients will review the information for applicability to their facilities and

consider corrective actions, as appropriate. However, suggestions contained in this information

notice are not NRC requirements; therefore, no specific action or written response is required.

DESCRIPTION OF CIRCUMSTANCES

At the Kewaunee Power Station (KPS), multiple trains of safety-related systems necessary for

safe-shutdown (e.g., auxiliary feedwater, emergency diesel generators, and electrical

distribution switchgear) are located at the same elevation and immediately adjacent to the

turbine building (TB) basement. Water from a TB flood could have flowed into these spaces

through non-watertight doors and through the floor drain system, which consisted of an open

pipe connecting the spaces to the turbine building sump. Several non-safety related systems

are located within the turbine building that have the potential to release large volumes of water

in the event of a pressure boundary failure. These systems include the circulating water, condensate storage, and fire protection systems. In the case of the fire protection system, a

large volume of water could be released from system actuation. Although infrequent, U.S.

nuclear power plant operating experience includes internal flooding events initiated by

circulating water expansion joint failure and fire protection system pressure boundary failure.

DISCUSSION

The design basis for KPS requires that safety-related systems, structures, and components

(SSCs) be protected against damage from a pipe or tank rupture that releases enough water or

steam to impair the safety function. In a letter to the NRC, dated October 31, 1972, the

licensee previously reported that the consequences of failure of non-safety related systems

could adversely affect the performance of engineered-safety systems. However, based on

safety equipment redundancy and design arrangement, and on an assessment that appropriate

control room operator action could effectively mitigate such events, the licensee had determined

that the functional purpose of the safety equipment would not be jeopardized.

During performance of baseline inspection procedure 71111.06, Flood Protection Measures, NRC inspectors at KPS identified a potential internal flooding vulnerability. Following

discussions with the inspectors and NRC staff, the licensee reported, in Event Notification 41496, that the KPS design might not mitigate the consequences of piping system failures and, in Licensee Event Report (LER) 2005-004 (ML051440302), that safe shutdown was potentially

challenged by unanalyzed flooding events and inadequate design. Additionally, in the LER, the

licensee reported that a complete internal plant flooding analysis was not developed during or

subsequent to the plants original design.

The potential for flooding to affect safety-related systems at KPS was demonstrated in 2003 when a minor turbine building flooding event caused less than an inch of water to collect at low

points in some safety-related equipment rooms.

Corrective actions have been implemented or are in progress to ensure safety-related

equipment will be adequately protected against postulated failures of non-safety related piping

systems, including high energy line breaks, random pipe failures, and seismically induced pipe

failures. These corrective actions include:

1.

Compilation of design and licensing bases for internal flooding to support current and

future flooding design

2.

Seismic qualification of selected piping and components

3.

Design modifications to protect Class I plant SSCs as defined in the KPS Updated

Safety Analysis Report (USAR), including:

a. installation of check valves in selected floor drains

b. auxiliary feedwater pump lube oil cooler and drain flow path revisions

c.

installation of a circulating water pump trip on high TB basement water level

d. flood barriers at doors to safety-related equipment rooms (safeguards alley)

e. enhanced supports for auxiliary feedwater pump steam supply piping 4.

The following interim protective actions were implemented pending completion of

appropriate measures to ensure protection of Class I plant SSCs:

a. The plant operating mode was restricted to refueling or cold shutdown.

b. The maximum combined inventory of the condensate storage tanks and the reactor

makeup tanks was restricted.

c.

Restrictions were placed on operation of the circulating water and condensate

systems.

GENERIC IMPLICATIONS

Numerous flood-related vulnerabilities and events have been identified at nuclear power

facilities both domestically and internationally. Flooding due to internal causes has been shown

to be a significant contributor to risk at some facilities. It has the potential to make multiple

trains of equipment and support equipment inoperable, significantly increasing plant risk.

Flooding also has the significant consequence of preventing or limiting operator mitigation and

recovery actions. A review of domestic and international operating experience revealed

hundreds of flood-related events and findings, several of which were very similar to the event at

KPS.

To address the generic implications of flooding, NRC inspectors semiannually select one or two

plant areas and inspect internal flood protection features for risk-significant SSCs in accordance

with Inspection Procedure Attachment 71111.06 Flood Protection Measures. A review of

findings documented under this inspection procedure from January 2000 through March 2005 turned up 39 findings (28 non-cited violations, 2 severity level IV violations, 8 GREEN findings, and 1 WHITE finding).

NRC generic communications that have addressed flood protection issues:

1. Circular

Potential Common Mode Flooding of ECCS Equipment Rooms

CR 78-06 at BWR Facilities

2. IN 83-44 Potential Damage to Redundant Safety Equipment as a Result of Backflow

Through the Equipment and Floor Drain System

3. IN 83-44 S1 Supplement 1: Potential Damage to Redundant Safety Equipment as a

Result of Backflow Through the Equipment and Floor Drain System

4. IN 87-49 Deficiencies in Outside Containment Flooding Protection 5. IN 92-69 Water Leakage from Yard Area Through Conduits into Buildings

6. IN 94-27 Facility Operating Concerns Resulting from Local Area Flooding

7. IN 98-31 Fire Protection System Design Deficiencies and Common-mode Flooding of

Emergency Core Cooling System Rooms at Washington Nuclear Project

Unit 2

8. IN 2005-11 Internal Flooding/spray-down of Safety-related Equipment Due to Unsealed

Equipment Hatch Floor Plugs And/or Blocked Floor Drains

Other NRC References Addressing Flooding-Related Issues:

1. NUREG-0933 ISSUE 77 Flooding of Safety Equipment Compartments by Backflow

Through Floor Drains (Rev. 1)

2. NUREG-0933 ITEM A-17 System Interactions in Nuclear Power Plants (Rev. 2)

CONCLUSION

The physical arrangement of safety-related systems essential to achieve safe-shutdown at KPS

made these systems vulnerable to flooding originating from failures of non-safety related

systems located in the turbine building. An NRC-identified condition at KPS revealed a less- than-effective application of operating experience to address safety-significant flooding-design

vulnerabilities. This was based, in part, on the licensees misunderstanding of the KPS

licensing basis for the plant flooding analysis and design and on an erroneous assumption

regarding the ability of control room operators to mitigate certain flooding events.

Consequently, the ability to achieve safe-shutdown for credible internal flooding events was not

reasonably assured. The licensee and NRC found that the KPS USAR and other plant-specific

NRC correspondence provided sufficiently clear guidance on the requirements to protect

safety-related equipment from the effects of internal flooding. No safety-related equipment at

KPS was flooded, but correcting the deficiencies of internal flooding design took a large part of

an outage of approximately four months.

CONTACT

This information notice requires no specific action or written response. Please direct any

questions about this matter to the technical contacts listed below or the appropriate Office of

Nuclear Reactor Regulation (NRR) project manager.

/RA/ By Patrick L. Hiland For/

Michael J. Case, Director

Division of Inspection & Regional Support

Office of Nuclear Reactor Regulation

Technical Contacts: Ross Telson, NRR/DIPM

Pat Higgins, RIII

301-415-2256

923-388-3156 E-mail: rdt@nrc.gov

E-mail: pch1@nrc.gov

Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.

ML052020249 OFFICE

R-III/DRP

Tech Editor

R-III/DRP/TL

R-III/DRP/BR-5 R-III/DRP/BR-5 NAME

MSatorious

(by e-mail)

PKleene

TKozak

(by e-mail)

JGiessner

(by e-mail)

SBurton (by e-mail)

DATE

08/19/2005

07/25/2005

08/25/2005

08/19/2005

08/19/2005 OFFICE

R-III/DRP/BR-5 A:SC:SPLB:DSSA

SPLB:DSSA

LPD3-1:DLPM

NAME

PHiggins (by e-mail)

SJones (by e-mail)

JSGuo (by e-mail)

JStang (by e-mail)

DATE

08/19/2005

08/19/2005

08/22/2005

08/25/2005 OFFICE

OES:IROB:DIPM

TL:IOEB:DIRS

BC:IOEB:DIRS

DD:DIRS

D:DIRS

NAME

RDTelson

EJBenner

MJRoss-Lee

PLHiland

MJCase/For

PLHiland)

DATE

08/26/2005

11/03/2005

11/03/2005

11/07/2005

11/07/2005


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