ML13325A891
| ML13325A891 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley, Hatch, Calvert Cliffs, Dresden, Davis Besse, Browns Ferry, Fermi, Catawba, Grand Gulf, Cooper, Byron, Arkansas Nuclear, Braidwood, Columbia, Diablo Canyon, Callaway, Duane Arnold, Clinton, Cook, Comanche Peak, Fort Calhoun  |
| Issue date: | 12/23/2013 |
| From: | Robert Pascarelli Plant Licensing Branch II |
| To: | Calvert Cliffs, Detroit Edison, Co, Duke Energy Carolinas, Energy Northwest, Entergy Operations, Exelon Generation Co, FirstEnergy Nuclear Operating Co, Indiana Michigan Power Co, Luminant Generation Co, Nebraska Public Power District (NPPD), NextEra Energy Duane Arnold, Omaha Public Power District, Pacific Gas & Electric Co, Southern Nuclear Operating Co, Tennessee Valley Authority, Union Electric Co |
| Kuntz R, NRR/JLD, 415-3733 | |
| References | |
| Download: ML13325A891 (12) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 23, 2013 To Those on the Enclosed List
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION ASSOCIATED WITH NEAR-TERM TASK FORCE RECOMMENDATION 2.3, FLOODING WALKDOWNS On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) staff issued a letter requesting additional information per Title 1 0 of the Code of Federal Regulations, Section 50.54(f) (hereafter called the 50.54(f) letter). The 50.54(f) letter requested that licensees conduct flooding hazard walkdowns to verify the plant configuration with the current licensing basis. The licensees stated by letter that the flooding walkdowns would be performed in accordance with Nuclear Energy Institute 12-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features," May 2012. Following the NRC staff's initial review of the walkdown reports, regulatory site audits were conducted at a sampling of plants. Based on the walkdown report reviews and site audits, the staff identified additional information necessary to allow the staff to complete its assessments.
Enclosed is a request for additional information (RAI) related to flooding walkdowns.
The NRC staff requests that you respond no later than January 31, 2014. If you have any questions related to the enclosed RAI or the requested submission date, please contact your assigned plant Project Manager.
Enclosures:
- 1. Request for Additional Information
- 2. Addressee List cc w/encls: Listserv &..J).d( for( /<,'JP Robert J. Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation REQUEST FOR ADDITIONAL INFORMATION Flooding Walkdowns On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) staff issued a letter (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12053A340) requesting additional information per Title 1 0 of the Code of Federal Regulations, Section 50.54(f) (hereafter called the 50.54(f) letter). The 50.54(f) letter requested that licensees conduct flooding hazard walkdowns to identify and address plant-specific degraded, nonconforming, or unanalyzed conditions through the corrective action program (CAP). All licensees stated by letter that the flooding walkdowns would be performed in accordance with Nuclear Energy Institute (NEI) 12-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features," May 2012 (ADAMS Accession No. ML12172A038).
Following the NRC staff's initial review of the reports documenting the results of the licensees' walkdowns, regulatory site audits were conducted at a sample of plants. Based on the walkdown report reviews and site audits, the staff identified additional information necessary to allow the staff to complete its assessments.
Determination and documentation of available physical margin (APM)
Background:
The NRC staff observed that several licensees did not consistently determine and/or document available physical margin (APM) in a manner that met the expected interpretation of NEI 12-07 during audits associated with review of the NTTF Recommendation 2.3 report submittals.
APM is defined in section 3.13 of NEI 12-07 and the process for obtaining and evaluating APM values is described in section 5.8 of NEI 12-07. Consistent with NEI 12-07, a numerical value for APM should be determined and documented for every applicable flood protection feature (e.g., wall, penetration, berm, door, etc.). This would normally be a numerical value reflecting the difference between the licensing basis flood height at the location of the feature and the point at which the function of the flood protection feature is compromised (e.g., the top of a barrier or the height of the first unsealed penetration in a barrier) such that the resulting flood can affect a structures, systems, and components important to safety. Next, in accordance with Section 5.8 of NEI12-07, if the APM appears to be small and the consequences of flooding appear to be significant, the licensee should enter the condition into the CAP and appropriate action be taken. While NEI 12-07 does not require that a specific numerical threshold value for "small" APM be defined for each site, doing so establishes a consistent basis for determining what instances need to be entered into the CAP. If a numerical APM value cannot be determined for any flood protection feature, the licensee should perform an assessment of the ability of the barrier to withstand the licensing basis flood plus the contribution of the additional water corresponding to the pre-established small-margin threshold value. If the barrier can withstand this flood, the APM for the feature is "not small" and further evaluation in accordance with Section 5.8 of NEI 12-07 is not required.
It is further noted that conclusions regarding "large" values of APM should be based on engineering evaluations or existing design documents.
Licensees should ensure that the process for APM determination and evaluation used during their flooding walkdowns is consistent with the guidance in NEI 12-07. The intent of this RAI is not to repeat the flooding walkdowns or perform an extensive revision of the walkdown record Enclosure 1 forms and other paperwork.
Instead the purpose is to verify or modify the process used to determine APM such that every site is aware of the margin at each of its flood protection features and take appropriate interim actions when the APM is small and the consequences are significant.
Instances where numerical values for APM were not determined, or where the basis for the APM was found to be questionable, should be rectified by either the documentation of a specific value or an explanation of why a non-numerical value is appropriate.
Request: Please provide the following:
- 1. Confirmation that the process for evaluating APM was reviewed;
- 2. Confirmation that the APM process is now or was always consistent with the guidance in NEI 12-07 and discussed in this RAI; 3. If changes are necessary, a general description of any process changes to establish this consistency;
- 4. As a result of the audits and subsequent interactions with industry during public meetings, NRC staff recognized that evaluation of APM for seals (e.g., flood doors, penetrations, flood gates, etc.) was challenging for some licensees.
Generally, licensees were expected to use either Approach A or Approach B (described below) to determine the APM for seals: a) If seal pressure ratings were known, the seal ratings were used to determine APM (similar to example 2 in Section 3.13 of NEI 12-07). A numerical value for APM was documented.
No further action was performed if the APM value was greater than the pre-established small-margin threshold value. If the APM value was small, an assessment of "significant consequences" was performed and the guidance in NEI 12-07 Section 5.8 was followed.
b) If the seal pressure rating was not known, the APM for seals in a flood barrier is assumed to be greater than the pre-established small-margin threshold value if the following conditions were met: (1) the APM for the barrier in which the seal is located is greater than the small-margin threshold value and there is evidence that the seals were designed/procured, installed, and controlled as flooding seals in accordance with the flooding licensing basis. Note that in order to determine that the seal has been controlled as a flooding seal, it was only necessary to determine that the seal configuration has been governed by the plant's design control process since installation.
In this case, the APM for the seal could have been documented as "not small". As part of the RAI response, state if either Approach A or Approach B was used as part of the initial walkdowns or as part of actions taken in response to this RAI. No additional actions are necessary if either Approach A orB was used. If neither Approach A orB was used to determine the APM values for seals (either as part of the walkdowns or as part of actions taken in response to this RAI), then perform the following two actions:
- Enter the condition into the CAP (note: it is acceptable to utilize a single CAP entry to capture this issue for multiple seals). CAP disposition of "undetermined" APM values for seals should consider the guidance provided in NEI 12-07, Section 5.8. The CAP disposition should confirm all seals can perform their intended safety function against floods up to the current licensing basis flood height. Disposition may occur as part of the Integrated Assessment.
If an Integrated Assessment is not performed, determine whether there are significant consequences associated with exceeding the capacity of the seals and take interim action(s), if necessary, via the CAP processes.
These actions do not need to be complete prior to the the RAI response.
List of Addressees Arkansas Nuclear One. Units 1 and 2 Docket Nos. 50-313 and 50-368 Vice President, Operations Arkansas Nuclear One Entergy Operations, Inc. 1448 S.R. 333 Russellville, AR 72802 Beaver Valley Power Station. Units 1 and 2 Docket Nos. 50-334 and 50-412 Mr. Eric A. Larson, Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB1 P.O. Box 4, Route 168 Shippingport, PA 15077 Browns Ferry Nuclear Plant. Units 1. 2. and 3 Docket Nos. 50-259. 50-260 and 50-296 Mr. Joseph W. Shea Vice President, Nuclear Licensing Tennessee Valley Authority 1101 Market Street, LP 3D-C Chattanooga, TN 37402-2801 Byron Station. Units 1 and 2/Braidwood Station. Units 1 and 2 Docket Nos. 50-454, 50-455. 50-456. and 50-457 Mr. Michael J. Pacilio, Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Office (CNO) -Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 Callaway Plant, Unit 1 Docket No. 50-483 Mr. Adam C. Heflin Senior Vice President and Chief Nuclear Officer Union Electric Company Ameren Missouri P.O. Box620 Fulton, MO 65251 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Docket Nos. 50-317 and 50-318 Mr. George H. Gellrich, Vice President Calvert Cliffs Nuclear Power Plant, LLC. Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702 Catawba Nuclear Station. Units 1 and 2 Docket Nos. 50-413 and 50-414 Mr. Kelvin Henderson, Site Vice President Duke Energy Carolinas, LLC Catawba Nuclear Station, Units 1 & 2 4800 Concord Road York, SC 297 45 Clinton Power Station, Unit No. 1 Docket No. 50-461 Mr. Michael J. Pacilio, Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Office (CNO) Exelon Nuclear 4300 Winfield Rd. Warrenville, IL 60555 Columbia Generating Station Docket No. 50-397 Mr. Mark E. Reddemann, Chief Executive Officer Energy Northwest MD 1023, North Power Plant Loop P.O. Box 968 Richland, WA 99352 Comanche Peak Nuclear Power Plant, Units 1 and 2 Docket Nos. 50-445 and 50-445 Mr. Rafael Flores Senior Vice President
& Chief Nuclear Officer Attention:
Regulatory Affairs Luminant Generation Company LLC P.O. Box 1002 Glen Rose, TX 76043 Enclosure 2
Cooper Nuclear Station Docket No. 50-298 Mr. Oscar A Limpias, Vice President-Nuclear and Chief Nuclear Officer Nebraska Public Power District Cooper Nuclear Station 72676 648A Avenue P.O. Box 98 Brownville, NE 68321 Davis-Besse Nuclear Power Station, Unit 1 Docket No. 50-346 Mr. Ray Lieb, Vice President FirstEnergy Nuclear Operating Company c/o Davis-Besse NPS 5501 N. State Route 2 Oak Harbor, OH 43449-9760 Donald C. Cook Nuclear Plant, Units 1 and 2 Docket Nos. 50-315 and 50-316 Mr. Lawrence J. Weber Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, Ml 49106 Diablo Canyon Power Plant. Unit Nos. 1 and 2 Docket Nos. 50-275 and 50-323 Mr. Edward D. Halpin, Senior Vice President and Chief Nuclear Officer Pacific Gas and Electric Company P.O. Box 56 Mail Code 1 04/6 Avila Beach, CA 93424 Dresden Nuclear Power Station, Units 2 and 3 Docket Nos. 50-237 and 50-249 Mr. Michael J. Pacilio, Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Office Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 Duane Arnold Energy Center Docket No. 50-331 Mr. Rich Anderson, Site Vice President Next Era Energy Duane Arnold Energy Center 3277 DAEC Road Palo, lA 52324-9785 Edwin I. Hatch Nuclear Plant Units 1 and 2 Docket Nos. 50-321 and 50-366 Mr. C. R. Pierce, Regulatory Affairs Director Southern Nuclear Operating Co., Inc. P.O. Box 1295 I BIN B038 Birmingham, AL 35201-1295 Fermi. Unit 2 Docket No. 50-341 Mr. Joseph H. Plena, Senior VP and Chief Nuclear Officer Detroit Edison Company Fermi 2-210 NOC 6400 North Dixie Highway Newport, Ml 48166 Fort Calhoun Station, Unit 1 Docket No. 50-285 Mr. Louis Cortopassi, Vice President and Chief Nuclear Officer Omaha Public Power District Fort Calhoun Station Mail Stop FC-2-4 9610 Power Lane Blair, NE 68008 Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 Vice President, Operations Entergy Operations, Inc. Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150 H. B. Robinson Steam Electric Plant. Unit No.2 Docket No. 50-261 Mr. William R. Gideon, Vice President H.B. Robinson Steam Electric Plant Duke Energy Progress, Inc. 3581 West Entrance Road Hartsville, SC 29550 Indian Point Nuclear Generating Unit Nos. 2 and 3 Docket Nos. 50-247and 50-286 Vice President, Operations Entergy Nuclear Operations, Inc. Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 James A FitzPatrick Nuclear Power Plant Docket No. 50-333 Mr. Chris Adner, Licensing Manager Entergy Nuclear Operations, Inc. James A FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 13093 Joseph M. Farley Nuclear Plant, Units 1 and 2 Docket Nos. 50-348 and 50-364 Mr. C. R. Pierce, Regulatory Affairs Director Southern Nuclear Operating Co., Inc. P.O. Box 1295/ BIN 038 Birmingham, AL 35201-1295 LaSalle County Station. Units 1 and 2 Docket Nos. 50-373 and 50-374 Mr. Michael J. Pacilio, Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Office (CNO) Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 Limerick Generating Station. Units 1 and 2 Docket Nos. 50-352 and 50-353 Mr. Michael J. Pacilio, President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Rd. Warrenville, IL 60555 Monticello Nuclear Generating Plant. Unit 1 Docket No. 50-263 Ms. Karen D. Fili, Site Vice President Northern States Power Company -Minnesota Monticello Nuclear Generating Plant 2807 West County Road 75 Monticello, MN 55362-9637 Nine Mile Point Nuclear Station, Units 1 and 2 Docket Nos. 50-220 and 50-410 Mr. Christopher Costanzo, Vice President Nine Mile Point Nuclear Station LLC P. 0. Box 63 ' Lycoming, NY 13093 North Anna Power Station, Units 1 and 2 Docket Nos. 50-338 and 50-339 Mr. David A Heacock, President and Chief Nuclear Officer Virginia Electric & Power Company lnnsbrook Technical Center 5000 Dominion Blvd. Glen Allen, VA 23060 Oconee Nuclear Station. Units 1, 2 and 3 Docket Nos. 50-236, 50-270 and 50-287 Mr. Scott Batson Vice President, Oconee Nuclear Station Duke Energy Carolinas, LLC 7800 Rochester Highway Seneca, SC 29672 Palisades Nuclear Plant Docket No. 50-355 Mr. Anthony J. Vitale, Vice President, Operations Entergy Nuclear Operations, Inc. Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, Ml 49043-9530 Palo Verde Nuclear Generating Station, Units 1, 2, and 3 Docket Nos. 50-528, 50-529 and 50-530 Mr. Randall K. Edington Executive Vice President Nuclear/CNO Arizona Public Service Company P.O. Box 52034, MS 7602 Phoenix, AZ 85072-2034 Peach Bottom Atomic Power Station, Units 2 and 3 Docket Nos. 50-277 and 50-278 Mr. Michael J. Pacilio, President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 Perry Nuclear Power Plant. Unit 1 Docket No. 50-440 Mr. Ernest J. Harkness, President and Chief Nuclear Officer FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant 10 Center Road, A290 Perry, OH 44081 Pilgrim Nuclear Power Station Unit No. 1 Docket No. 50-293 Mr. John Dent, Jr., Vice President-Site VP Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Point Beach Nuclear Plant. Units 1 and 2 Docket Nos. 50-266 and 50-301 Mr. Larry Meyer, Site Vice President NextEra Energy Point Beach, LLC Point Beach Nuclear Plant, Units 1 & 2 6610 Nuclear Road Two Rivers, WI 54241-9516 Prairie Island Nuclear Generating Plant, Units 1 and 2 Docket Nos. 50-282 and 50-306 Mr. James E. Lynch, Site Vice President Northern States Power Company -Minnesota Prairie Island Nuclear Generating Plant 1717 Wakonade Drive East Welch, MN 55089-9642 R. E. Ginna Nuclear Power Plant Docket No. 50-244 Mr. Joseph E. Pacher, Vice President R.E. Ginna Nuclear Power Plant R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, NY 14519 River Bend Station. Unit 1 Docket No. 50-458 Vice President, Operations Entergy Operations, Inc. River Bend Station 5485 U.S. Highway 61 N St. Francisville, LA 70775 Seabrook Station, Unit No. 1 Docket No. 50-443 Mr. Kevin Walsh, Site Vice President c/o Michael Ossing Seabrook Station NextEra Energy Seabrook, LLC P.O Box 300 Seabrook, NH 03874 Sequoyah Nuclear Plant. Units 1 and 2 Docket Nos. 50-327 and 50-328 Mr. Joseph W. Shea Vice President, Corporate Nuclear Licensing Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37 402-2801 Shearon Harris Nuclear Power Plant. Unit 1 Docket No. 50-400 Mr. Ernest J. Kapopoulos, Jr., Vice President Duke Energy Progress, Inc. Shearon Harris Nuclear Power Plant P.O. Box 165, Mail Zone 1 New Hill, NC 27562-0165 South Texas Project, Units 1 and 2 Docket Nos. 50-498 and 50-499 Mr. Dennis L. Koehl, President and CEO/CNO STP Nuclear Operating Company South Texas Project Electric Generating Station P.O. Box 289 Wadsworth, TX 77483 St. Lucie Plant Units 1 and 2 Docket Nos. 50-335 and 50-289 Mr. Mano Nazar, Executive VP and Chief Nuclear Officer NextEra Energy P. 0. Box 14000 700 Universe Boulevard Juno Beach, FL 33408-0420 Surry Power Station. Unit Nos. 1 and 2 Docket Nos. 50-280 and 50-281 Mr. David A Heacock, President
& Chief Nuclear Officer Virginia Electric & Power Company 5000 Dominion Blvd. Glen Allen, VA 23060 Susquehanna Steam Electric Station. Units 1 and 2 Docket Nos. 50-387 and 50-388 Mr. Timothy S. Rausch, Senior Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Boulevard NUCSB3 Berwick, PA 18603-0467 Three Mile Island Nuclear Station. Unit 1 Docket No. 50-289 Mr. Michael J. Pacilio, President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Mr. Mano Nazar, Executive VP and Chief Nuclear Officer NextEra Energy P. 0. Box 14000 Juno Beach, FL 33408-0420 Virgil C. Summer Nuclear Station. Unit 1 Docket No. 50-395 Mr. Thomas D. Gatlin, Vice President Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 800 Jenkinsville, SC 29065 Vogtle Electric Generating Plant. Units 1 and 2 Docket Nos. 50-424 and 50-425 Mr. C. R. Pierce, Regulatory Affairs Director Southern Nuclear Operating Co., Inc. P.O. Box 1295/ BIN 038 Birmingham, AL 35201-1295 Waterford Steam Electric Station. Unit 3 Docket No. 50-382 Vice President, Operations Entergy Operations, Inc. Waterford Steam Electric Station, Unit 3 17265 River Road Killona, LA 70057-0751 Watts Bar Nuclear Plant. Unit 1 Docket No. 50-390 Mr. Joseph W. Shea, Corporate Manager, Nuclear Licensing Tennessee Valley Authority 1101 Market Street, LP 3D-C Chattanooga, TN 37 402-2801 William B. McGuire Nuclear Station. Units 1 and 2 Docket Nos. 50-369 and 50-370 Mr. Steven D. Capps, Vice President McGuire Site Duke Energy Carolinas, LLC McGuire Nuclear Station 12700 Hagers Ferry Road Huntersville, NC 28078-8985 Wolf Creek Generating Station. Unit 1 Docket No. 50-482 Mr. Matthew W. Sunseri President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box411 Burlington, KS 66839 December 23, 2013 To Those on the Enclosed List
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION ASSOCIATED WITH NEAR-TERM TASK FORCE RECOMMENDATION 2.3, FLOODING WALKDOWNS On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) staff issued a letter requesting additional information per Title 1 0 of the Code of Federal Regulations, Section 50.54(f) (hereafter called the 50.54(f) letter). The 50.54(f) letter requested that licensees conduct flooding hazard walkdowns to verify the plant configuration with the current licensing basis. The licensees stated by letter that the flooding walkdowns would be performed in accordance with Nuclear Energy Institute 12-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features," May 2012. Following the NRC staffs initial review of the walkdown reports, regulatory site audits were conducted at a sampling of plants. Based on the walkdown report reviews and site audits, the staff identified additional information necessary to allow the staff to complete its assessments.
Enclosed is a request for additional information (RAI) related to flooding walkdowns.
The NRC staff requests that you respond no later than January 31, 2014. If you have any questions related to the enclosed RAI or the requested submission date, please contact your assigned plant Project Manager.
Enclosures:
Sincerely, Ira/ (G. E. Miller for) Robert J. Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
- 1. Request for Additional Information
- 2. Addressee List cc w/encls: Listserv DISTRIBUTION:
See next page ADAMS Accession No. ML13325A891
- via e-mail OFFICE NRR/JLD/PMB NRR/DORULPL4-1/LA NRO/DSEA/RHMB/BC NAME RKuntz JBurkhardt SFianders" DATE 11/22/13 11/22/13 12/19/13 OFFICE NRR/JLD/PMB/BC NRR/DORULPLII-1/BC (GMiller for) NAME LMR for MMitchell RPascarelli DATE 12/23113 12/23/13 OFFICIAL RECORD COPY Letter to Selected Power Reactor Licensees from Robert J. Pascarelli dated December 23, 2013
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION ASSOCIATED WITH NEAR-TERM TASK FORCE RECOMMENDATION 2.3, FLOODING WALKDOWNS DISTRIBUTION:
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