ML062430337

Pilgrim, License Amendment 225 Regarding Revised Reactor Coolant System Leakage Detection Instrumentation Requirements and Actions

ML062430337
Person / Time
Site:	Pilgrim
Issue date:	09/20/2006
From:	Shea J J NRC/NRR/ADRO/DORL/LPLI-1
To:	Kansler M Entergy Nuclear Operations
SHea J J, NRR/DORL, 415-1388
References
TAC MC7255
Download: ML062430337 (13)

Text

September 20, 2006Mr. Michael KanslerPresident Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

PILGRIM NUCLEAR POWER STATION - ISSUANCE OF AMENDMENT RE: REVISED REACTOR COOLANT SYSTEM LEAKAGE DETECTION INSTRUMENTATION REQUIREMENTS AND ACTIONS (TAC NO. MC7255)

Dear Mr. Kansler:

The Commission has issued the enclosed Amendment No. 225 to Facility Operating LicenseNo. DPR-35 for the Pilgrim Nuclear Power Station. This amendment is in response to your application dated June 2, 2005, as supplemented on June 14, 2006.The amendment relocates and revises the Technical Specifications (TSs) associated with thestation reactor coolant system leakage detection instrumentation requirements and actions.These changes are consistent with the Standard TSs for Boiling Water Reactors (NUREG-1433Revision 3). A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included inthe Commission's biweekly Federal Register Notice. Sincerely,/RA/James J. Shea, Project ManagerPlant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-293

Enclosures:

1. Amendment No. 225 to License No. DPR-35

2. Safety Evaluationcc w/encls: See next page September 20, 2006Mr. Michael KanslerPresident Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

PILGRIM NUCLEAR POWER STATION - ISSUANCE OF AMENDMENT RE: REVISED REACTOR COOLANT SYSTEM LEAKAGE DETECTION INSTRUMENTATION REQUIREMENTS AND ACTIONS (TAC NO. MC7255)

Dear Mr. Kansler:

The Commission has issued the enclosed Amendment No. 225 to Facility Operating LicenseNo. DPR-35 for the Pilgrim Nuclear Power Station. This amendment is in response to your application dated June 2, 2005, as supplemented on June 14, 2006.The amendment relocates and revises the Technical Specifications (TSs) associated with thestation reactor coolant system leakage detection instrumentation requirements and actions.These changes are consistent with the Standard TSs for Boiling Water Reactors (NUREG-1433Revision 3). A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included inthe Commission's biweekly Federal Register Notice. Sincerely,/RA/James J. Shea, Project ManagerPlant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-293

Enclosures:

1. Amendment No. 225 to License No. DPR-35

2. Safety Evaluationcc w/encls: See next page DISTRIBUTION

PUBLICRidsNrrDorlLpl1-1RPowell, RIRidsOGC RP RHernandez PDI-I R/FRidsNrrLASLittle RidsNrrPMJSheaGHill (2) ALewin RidsAcrsAcnwMailPackage: Accession Number: ML062430337 *No significant changes to SE OFFICELPL1-1/PMLPL1-1/LA SBPB/BCITSB/BCOGC LPL1-1/BCNAMEJSheaSLittleJSegala*TKobetzMZobler RLauferDATE8/30/068/31/0608/16/069/01/069/12/069/18/06OFFICIAL RECORD COPY ENTERGY NUCLEAR GENERATION COMPANYENTERGY NUCLEAR OPERATIONS, INC.DOCKET NO. 50-293PILGRIM NUCLEAR POWER STATIONAMENDMENT TO FACILITY OPERATING LICENSEAmendment No. 225License No. DPR-351. The Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment filed by Entergy Nuclear Operations, Inc. (thelicensee) dated June 2, 2005, as supplemented on June 14, 2006, complies withthe standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations;B.The facility will operate in conformity with the application, the provisions of theAct, and the rules and regulations of the Commission;C.There is reasonable assurance: (i) that the activities authorized by thisamendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with theCommission's regulations;D.The issuance of this amendment will not be inimical to the common defense andsecurity or to the health and safety of the public; andE.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied.

2.Accordingly, the license is amended by changes to the Technical Specifications asindicated in the attachment to this license amendment, and paragraph 3.B of FacilityOperating License No. DPR-35 is hereby amended to read as follows:B.Technical SpecificationsThe Technical Specifications contained in Appendix A, as revised throughAmendment No. 225, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.3.This license amendment is effective as of the date of issuance and shall beimplemented within 60 days.FOR THE NUCLEAR REGULATORY COMMISSION/RA/Richard J. Laufer, ChiefPlant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical SpecificationsDate of Issuance: September 20, 2006 ATTACHMENT TO LICENSE AMENDMENT NO. 225 FACILITY OPERATING LICENSE NO. DPR-35DOCKET NO. 50-293Replace the following page of the Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

RemoveInsert 33Replace the following pages of the Appendix A Technical Specifications with the attachedrevised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

RemoveInsert3/4.6-43/4.6-4 3/4.6-53/4.6-5 3/4.6-63/4.6-6 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TO AMENDMENT NO. 225 TO FACILITY OPERATING LICENSE NO. DPR-35ENTERGY NUCLEAR GENERATION COMPANYENTERGY NUCLEAR OPERATIONS, INC.PILGRIM NUCLEAR POWER STATIONDOCKET NO. 50-29

31.0INTRODUCTION

By letter dated June 2, 2005, (Agencywide Documents Access and Management System(ADAMS) Accession No. ML051720406) as supplemented on June 14, 2006 (ADAMS Accession No. ML061720084), Entergy Nuclear Operations, Inc. (the licensee) submitted a request for changes to the Pilgrim Nuclear Power Station (Pilgrim) Technical Specifications (TSs). The amendment relocates and revises the TSs associated with the station reactor coolant system leakage detection instrumentation requirements and actions. These proposedchanges are consistent with the Standard Technical Specifications (STS) for Boiling WaterReactors (BWRs) (NUREG-1433, "STS General Electric Plants, BWR/4," Revision 3). Thesupplement dated June 14, 2006, provided additional information that did not expand the scopeof the application as originally noticed, and did not change the staff's original proposed nosignificant hazards consideration determination as published in the Federal Register on May 23, 2006 (71 FR 29676).

2.0REGULATORY EVALUATION

Title 10 of the Code of Federal Regulations (10 CFR 50.36)(c)(2)(ii) states that a technicalspecification limiting condition for operation (LCO) of a nuclear reactor must be established for each item meeting one or more of the following criteria:Criterion 1. Installed instrumentation that is used to detect, and indicate in the controlroom, a significant abnormal degradation of the reactor coolant pressure boundary.Criterion 2. A process variable, design feature, or operating restriction that is an initialcondition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.Criterion 3. A structure, system, or component that is part of the primary successpath and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Criterion 4. A structure, system, or component which operating experience orprobabilistic risk assessment has shown to be significant to public healthand safety.The Nuclear Regulatory Commission (NRC) staff and nuclear steam supply owners groupsdeveloped the STS that established models of the Commission's policy for TSs, and improved the format and clarity of the specifications. NUREG-1433, Revision 3, was approved andissued for use by the NRC on June 30, 2004. Many nuclear power plants such as Pilgrim haverelocated various specifications that are not required explicitly by 10 CFR 50.36 to otherlicensing basis documents such as a plants Final Safety Analysis Report (FSAR) utilizing theSTS as a model. Generic Letter (GL) 88-01, "NRC POSITION ON IGSCC IN BWR AUSTENITIC STAINLESSSTEEL PIPING," Supplement 1, position (3) states that manual leak rate measurements can be acceptable alternatives during the period (30 days) when the drain sump monitori ng system isbeing restored, provided the licensee demonstrates their suitability with regard to accuracy andinspectability.The NRC staff reviewed the licensee's proposed changes for compliance with 10 CFR 50.36,for adherence with GL 88-01, and with the precedent as established in the STS.

3.0TECHNICAL EVALUATION

3.1Proposed Changes to the Pilgrim TS RequirementsThe licensee's submittal contains the following proposed changes:3.1.1 Revision of TS 4.6.C.1 to eliminate "by monitoring the coolant leakage detection systems required to be operable by 3.6.C.2."3.1.2Revision of TS 3.6.C.2.a.1 and 4.6.C.2.a by adding the limitation "floor drain" such thatthe requirement reads "drywell floor drain sump monitori ng system." The Bases arealso clarified consistent with this change, which results in relocating the drywell equipment drain sump portion of the monitori ng system from the TS requirements to theFSAR. Additional editorial changes to revise "one" and "each" to "the."3.1.3Revision of TS 3.6.C.2.b.1 to replace "At least one drywell sump monitori ng system shallbe Operable;" with the following insert: "With the drywell floor drain monitoring systemrequired by 3.6.C.2.a.1 inoperable, restore it to Operable status within 30 days."3.1.4Revision of TS 3.6.C.2.b.2 to change the allowed restoration time from "31" days to "30"days and replace "At least one gaseous or particulate radioactivity monitoring channel must be operable; otherwise..." with the following insert: 'With both the gaseous and particulate radioactivity monitoring channels required by 3.6.C.2.a.2 and 3.6.C.2.a.3inoperable,"Additionally in TS 3.6.C.2.b.2, replace "provided grab samples are obtained andanalyzed" with "provided drywell atmosphere grab samples are analyzed" and reword

"..., or be in Hot Shutdown..." to read "...; otherwise, be in Hot Shutdown...." Also, the specified grab sample frequency is changed from every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.3.1.5Revision of TS 3.6.C.2.c to include an intermediate shutdown requirement by adding"...in Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and... ." Additionally, add "the following" before "24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" such that TS 3.6.C.2.c reads as follows:"With no required leakage detection systems Operable, be in Hot Shutdown within thenext 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in Cold Shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."3.1.6Revision of the frequency for TS Surveillance Requirement 4.6.C.2.b.1 to perform aninstrument check from at least once "per day," to at least once "every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."3.2Staff Evaluation of Proposed Changes3.2.1Proposed Revision of TS 4.6.C.1 Since the drywell equipment drain sump monitoring system is being deleted from the TS(proposed change 3.1.2), the reference in TS 4.6.C.1 to TS 3.6.C.2 would be incomplete. Deletion of the phrase in TS 4.6.C.1 is considered an editorial change that is consistent withproposed change 3.1.2, enhances clarity and avoids potential misinterpretation. The resultingTSs would be consistent with the STS.3.2.2Proposed Revision of 3.6.C.2.a.1 and 4.6.C.2.aThe proposed revision to TS 3.6.C.2.a.1 and TS 4.6.C.2.a and its Bases results in removingrequirements for the drywell equipment drain sump portion of the monitoring system from theTSs and relocating these requirements to the Pilgrim FSAR. The licensee states that the equipment drain sump monitoring instrumentation does not meet any of the criteria set forth in 10 CFR 50.36(c)(2)(ii).The equipment drain sump monitoring instrumentation is not "instrumentation that isused to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary." This function is met by monitoring the unidentified leakage using the drywell floor drain sump monitoring equipment as well as the containment atmospheric monitoring instrumentation. The equipment drain sumpmonitoring instrumentation is used to monitor the leakage from known sources. The equipment drain sump monitoring instrumentation are not used as an initial condition of a design-basis accident or transient analysis that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier. The equipment drain sump monitoring instrumentation are not used as part of the primary success path which functions or actuates to mitigate a design-basis accident or transient. Operating experiences or probabilistic safety assessments have not shown the equipment drainsump monitoring instrumentation to be significant to public health and safety.TS 4.6.C.1 requires the licensee to demonstrate that the drywell leakage is within specifiedlimits. In order to comply with this requirement, the licensee currently uses the drain sump monitoring instrumentation to monitor identified leakage. By letter dated May 18, 2006 (ADAMS Accession No. ML061210172), the NRC staff requested the licensee to explain how the totalleakage limits as specified in TS 3.4.C.1.a.3 would be verified during plant operation. By letterdated June 14, 2006, the licensee responded that the drywell equipment drain sump willcontinue to be used to verify total leakage is within limits. In addition, the licensee stated that Pilgrim will use manual leak rate determination methods consistent with position (3) describedin the NRC GL 88-01, Supplement 1. The proposed relocated TSs are not required to be in TSs under 10 CFR 50.36 and do notmeet any of the four criteria in the regulation. They are not needed to obviate the possibilitythat an abnormal situation or event will give rise to an immediate threat to the public health andsafety. The NRC staff has also concluded that appropriate controls have been established forthe specification, information, and requirements that are being relocated to the Pilgrim UFSAR. The relocatoin is the subject of a licensing commitment established in the licensee's submittal on June 2, 2005. Following implementation, the NRC will audit the removed provisions toensure that an appropriate level of control has been achieved. The NRC staff has concluded that, in accordance with the above, sufficient regulatory controlsexist under the regulations, particularly 10 CFR 50.59. Accordingly, these specifications related to the equipment sump LCO may be relocated from Pilgrim TSs and placed in the Pilgrim FSAR Appendix B.2.The licensee's submittal also stated that the equipment drain sump monitoring instrumentationfunctional test and calibration requirements specified in TS 4.6.C.2.a will be relocated to theFSAR. Additionally, changes from "one" and "each" to "the" drywell floor drain sump monitoring system are considered editorial changes that enhanced clarity without introducing any technicalchange. The resulting TSs will also be consistent with STS. 3.2.3Proposed Revision of TS 3.6.C.2.b.1 Current TS 3.6.C.2.b.1 does not allow any repair time on discovery of the required drywell sumpmonitoring system being inoperable; requiring the plant to be in Hot Shutdown within 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />sand Cold Shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The licensee's proposed revision of TS 3.6.C.2.b.1 would provide a 30-day restoration time for the drywell sump monitoring system. This 30-day restoration time will add flexibility without a reduction in safety, which may allow foravoiding unnecessary plant shutdown transients.TS 4.6.C.1 continues to require demonstration that drywell leakage is within limits once every8 hours. By letter dated May 18, 2006, the NRC staff requested the licensee to explain how thetotal leakage limits as specified in TS 3.4.C.1.a.3 would be verified when the drain sump is inoperable. The licensee stated in its June 14, 2006, submittal that they will use manual leakrate determination method consistent with position (3) described in GL 88-01 Supplement 1. This method is valid for Pilgrim because sump volume is known and the sump has installed level instruments that can be used to calculate leak rates. The staff finds that the resulting TSswill be consistent with the STS.3.2.4 Proposed Revision of 3.6.C.2.b.2 TS 3.6.C.2.b.2 allows a 31-day repair time on discovery that the required gaseous or particulateradioactivity monitoring channel is inoperable provided drywell atmosphere grab samples are analyzed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The licensee proposes to make this repair time and grab sample frequency more restrictive byrequiring restoration within 30 days provided grab samples are obtained and analyzed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The licensee stated that the proposed change will not impose an undue burden onthe operating staff. This proposed change is consistent with that provided in the STS. Additionally in TS 3.6.C.2.b.2, the licensee proposes to make several editorial changes forgreater consistency with the STS. These editorial changes consist of replacing "provided grab samples are obtained and analyzed" with "provided drywell atmosphere grab samples are analyzed" and rewording "..., or be in Hot Shutdown..." to read "...; otherwise, be in Hot Shutdown...". These editorial changes involve no technical or administrative impact. 3.2.5 Proposed Revision of TS 3.6.C.2.c The licensee proposed changes to TS 3.6.C.2.c, makes the TS more restrictive by alsoincluding an intermediate shutdown step, such that TS 3.6.C.2.c reads as follows:"With no required leakage detection system Operable, be in Hot Shutdown within thenext 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in Cold Shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />." Each of the required actions throughout TS 3.6.C (i.e., 1.b, 1.c, 2.b.1, and 2.b.2), whenimposing a requirement to proceed to Cold Shutdown, include an intermediate shutdown requirement "...be in Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />." The proposed change to TS 3.6.C.2.c will provide consistency between shutdown requirements associated with reactorcoolant leakage and leakage detection systems. This change is also consistent with actionsprovided in the STS, for Specification 3.4.6 Action E. 3.2.6 Proposed Revision of TS 4.6.C.2.b.1 Current TS Surveillance Requirement 4.6.C.2.b.1 requires an instrument check at a frequencyof at least once per day. The licensee's proposed change makes this frequency more restrictive by requiring the instrument check to be performed at least once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The licensee stated that this change will not impose an undue burden on the operating staff. This proposedchange is to require an instrument check frequency consistent with that provided in the STS. The NRC staff finds that the changes and the TS relocation as discussed above are incompliance with the requirements of 10 CFR 50.36 and are consistent with the STS. Therefore,the staff finds that all the proposed changes are acceptable.

4.0STATE CONSULTATION

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

5.0ENVIRONMENTAL 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 and changessurveillance requirements. The NRC staff has determined that the amendment involves nosignificant increase in the amounts, and no significant change in the types, of any effluents thatmay 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 nopublic comment on such finding (71 FR 29676). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR51.22(b), no environmental impact statement or environmental assessment need be preparedin connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) thereis reasonable assurance that the health and safety of the public will not be endangered byoperation in the proposed manner, (2) such activities will be conducted in compliance with theCommission's regulations, and (3) the issuance of the amendment will not be inimical to thecommon defense and security or to the health and safety of the public.Principal Contributor: R. Hernandez Date: September 20, 2006 Pilgrim Nuclear Power Station cc:

Regional Administrator, Region IU. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415Senior Resident InspectorU. S. Nuclear Regulatory Commission Pilgrim Nuclear Power Station Post Office Box 867 Plymouth, MA 02360Chairman, Board of Selectmen11 Lincoln Street Plymouth, MA 02360ChairmanNuclear Matters Committee Town Hall 11 Lincoln Street Plymouth, MA 02360Chairman, Duxbury Board of SelectmenTown Hall 878 Tremont Street Duxbury, MA 02332Office of the CommissionerMassachusetts Department of Environmental Protection One Winter Street Boston, MA 02108Office of the Attorney GeneralOne Ashburton Place 20th Floor Boston, MA 02108MA Department of Public HealthRadiation Control Program Schrafft Center, Suite 1M2A 529 Main Street Charlestown, MA 02129Secretary of Public SafetyExecutive Office of Public Safety One Ashburton Place Boston, MA 02108 Director, Massachusetts EmergencyManagement Agency Attn: James Muckerheide 400 Worcester Road Framingham, MA 01702-5399Mr. William D. MeinertNuclear Engineer Massachusetts Municipal Wholesale Electric Company

P.O. Box 426 Ludlow, MA 01056-0426Mr. Kevin H. BronsonGeneral Manager, Plant Operations Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill RoadPlymouth, MA 02360-5508Mr. Michael A. BalduzziSite Vice President Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill RoadPlymouth, MA 02360-5508Mr. Stephen J. BethayDirector, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill RoadPlymouth, MA 02360-5508Mr. Bryan S. FordManager, Licensing Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill RoadPlymouth, MA 02360-5508

Pilgrim Nuclear Power Station cc:Mr. Gary J. Taylor Chief Executive Officer Entergy Operations 1340 Echelon Parkway Jackson, MS 39213Mr. John T. HerronSr. VP and Chief Operating Officer Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. Oscar LimpiasVice President, Engineering Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. Christopher SchwarzVice President, Operations Support Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. Michael KanslerPresident Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. John F. McCannDirector, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

Ms. Charlene D. Faison Manager, Licensing Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. Michael J. ColombDirector of Oversight Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Assistant General CounselEntergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Ms. Stacey LousteauTreasury Department Entergy Services, Inc.

639 Loyola Avenue New Orleans, LA 70113Mr. James Sniezek5486 Nithsdale Drive Salisbury, MD 21801-2490Mr. Michael D. Lyster5931 Barclay Lane Naples, FL 34110-7306Mr. Garrett D. Edwards814 Waverly Road Kennett Square, PA 19348