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MONTHYEARML0603800332006-02-0909 February 2006 RAI, Response to Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design-Basis Accidents at Pressurized-Water Reactors. Project stage: RAI ML0625002692006-09-0707 September 2006 Approval of Generic Letter 2004-02 Extension Request Project stage: Other ML0735201452007-12-19019 December 2007 Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors, Extension Request Approval (TAC Nos. MC4727 and MC4728) Project stage: Other NL-07-1777, Supplemental Response to NRC Generic Letter 2004-022008-02-28028 February 2008 Supplemental Response to NRC Generic Letter 2004-02 Project stage: Request NL-08-0670, Supplemental Response to NRC Generic Letter 2004-022008-05-21021 May 2008 Supplemental Response to NRC Generic Letter 2004-02 Project stage: Request NL-08-1155, Supplemental Response to NRC Generic Letter 2004-022008-07-31031 July 2008 Supplemental Response to NRC Generic Letter 2004-02 Project stage: Request NL-08-1195, Generic Letter 2004-02 Response Extension Request2008-07-31031 July 2008 Generic Letter 2004-02 Response Extension Request Project stage: Request NL-08-1228, Supplemental Response to NRC Generic Letter 2004-022008-08-22022 August 2008 Supplemental Response to NRC Generic Letter 2004-02 Project stage: Supplement ML0825602332008-09-17017 September 2008 Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors. Project stage: Other ML0831001422008-12-0202 December 2008 Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors, Request for Additional Information (TAC Nos. MC4727.. Project stage: RAI ML15126A2562015-05-0606 May 2015 GSI-191 Program Chemical Effects Testing Strainer Headloss Testing NRC Public Meeting - November 6, 2014 Project stage: Request ML15126A3032015-05-0808 May 2015 Summary of Meeting with SNC on GSI-191 Program for the VEGP Project stage: Meeting 2008-05-21
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Category:Letter type:NL
MONTHYEARNL-24-0337, Interim 10 CFR 21.21(a)(2) Report Regarding Operation Technology, Inc., ETAP Software Error in Transient Stability Program2024-09-0909 September 2024 Interim 10 CFR 21.21(a)(2) Report Regarding Operation Technology, Inc., ETAP Software Error in Transient Stability Program NL-24-0299, Exemption Request: Final Safety Analysis Report Update Schedule, Response to Request for Additional Information2024-08-14014 August 2024 Exemption Request: Final Safety Analysis Report Update Schedule, Response to Request for Additional Information NL-24-0282, License Amendment Request and Exemption Request: Remove Tier 1 and Tier 2* Requirements2024-07-25025 July 2024 License Amendment Request and Exemption Request: Remove Tier 1 and Tier 2* Requirements NL-24-0126, – Units 3 and 4, License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Action a and SR 3.7.6.62024-07-25025 July 2024 – Units 3 and 4, License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Action a and SR 3.7.6.6 NL-24-0286, Emergency Request to Revise Technical Specification 3.7.9 for a One-Time Change to Support a Unit 1 Nuclear Service Cooling Water Transfer Pump Repair2024-07-20020 July 2024 Emergency Request to Revise Technical Specification 3.7.9 for a One-Time Change to Support a Unit 1 Nuclear Service Cooling Water Transfer Pump Repair NL-24-0261, 10 CFR 50.46 ECCS Evaluation Model Annual Report for 20232024-07-19019 July 2024 10 CFR 50.46 ECCS Evaluation Model Annual Report for 2023 NL-24-0227, Proposed Inservice Inspection Alternative GEN-ISI-AL T-2024-03 for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1)2024-07-0303 July 2024 Proposed Inservice Inspection Alternative GEN-ISI-AL T-2024-03 for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1) NL-24-0234, Application to Revise Technical Specifications to Adopt TSTF-589, Eliminate Automatic Diesel Generator Start During Shutdown2024-06-28028 June 2024 Application to Revise Technical Specifications to Adopt TSTF-589, Eliminate Automatic Diesel Generator Start During Shutdown NL-24-0143, Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/ Replacement Activities in2024-06-27027 June 2024 Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/ Replacement Activities in NL-24-0087, License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Air Storage Tanks2024-06-21021 June 2024 License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Air Storage Tanks NL-24-0201, Proposed Inservice Inspection Alternative GEN-ISI-ALT-2024-002 for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1)2024-06-18018 June 2024 Proposed Inservice Inspection Alternative GEN-ISI-ALT-2024-002 for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1) NL-24-0243, Registration of Spent Fuel Cask Use2024-06-18018 June 2024 Registration of Spent Fuel Cask Use NL-24-0202, SNC Response to Regulatory Issue Summary 2024-01: Preparation and Scheduling of Operator Licensing Examinations2024-05-24024 May 2024 SNC Response to Regulatory Issue Summary 2024-01: Preparation and Scheduling of Operator Licensing Examinations NL-24-0191, Annual Radiological Environmental Operating Reports for 20232024-05-10010 May 2024 Annual Radiological Environmental Operating Reports for 2023 NL-24-0194, Revised Request for Relief and Alternative Requirements for Squib Valves First Test Interval (V34-IST-ALT-03-R1)2024-05-0707 May 2024 Revised Request for Relief and Alternative Requirements for Squib Valves First Test Interval (V34-IST-ALT-03-R1) NL-24-0170, Responses to Second Round NRC Request for Additional Information for Refueling Outage 1 R24 Steam Generator Tube Inspection Report2024-04-25025 April 2024 Responses to Second Round NRC Request for Additional Information for Refueling Outage 1 R24 Steam Generator Tube Inspection Report NL-24-0165, Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 20232024-04-25025 April 2024 Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 2023 NL-24-0154, Preservice Inspection Progam Owners Activity Report2024-04-16016 April 2024 Preservice Inspection Progam Owners Activity Report NL-24-0128, License Amendment Request: Technical Specification 5.5.13, Ventilation Filter Testing Program (VFTP) Testing Frequency2024-04-0404 April 2024 License Amendment Request: Technical Specification 5.5.13, Ventilation Filter Testing Program (VFTP) Testing Frequency NL-24-0115, Response to Request for Additional Information Exemption Requests for Physical.2024-04-0404 April 2024 Response to Request for Additional Information Exemption Requests for Physical. NL-24-0116, Nuclear Property Insurance Coverage as of April 1, 2024 and Licensee Guarantees of Payment of Deferred.2024-03-29029 March 2024 Nuclear Property Insurance Coverage as of April 1, 2024 and Licensee Guarantees of Payment of Deferred. NL-24-0098, Report on Status of Decommissioning Funding2024-03-28028 March 2024 Report on Status of Decommissioning Funding NL-24-0112, Request for Revision to NRC Staff Assessment of Vogtle Site Updated Seismic Hazards2024-03-28028 March 2024 Request for Revision to NRC Staff Assessment of Vogtle Site Updated Seismic Hazards NL-24-0097, Exemption Request: Final Safety Analysis Report Update Schedule2024-03-22022 March 2024 Exemption Request: Final Safety Analysis Report Update Schedule NL-22-0267, License Amendment Request to Revise Diesel Generator Frequency and Voltage Ranges for Technical Specification 3.8.1, AC Sources – Operating, Surveillance Requirements2024-03-20020 March 2024 License Amendment Request to Revise Diesel Generator Frequency and Voltage Ranges for Technical Specification 3.8.1, AC Sources – Operating, Surveillance Requirements NL-24-0060, Request for Relief and Alternative Requirements for Squib Valves First Test Interval (V34-IST-ALT-03)2024-02-15015 February 2024 Request for Relief and Alternative Requirements for Squib Valves First Test Interval (V34-IST-ALT-03) NL-24-0042, Response to Request for Additional Information Exemption Requests for Physical Barriers2024-02-13013 February 2024 Response to Request for Additional Information Exemption Requests for Physical Barriers NL-24-0045, Supplement to Response to Requests for Additional Information for Proposed Alternative ALT-VR-022024-02-0808 February 2024 Supplement to Response to Requests for Additional Information for Proposed Alternative ALT-VR-02 NL-24-0033, Response to Question for Withholding Information from Public Disclosure Exemption Requests for Physical Barriers2024-02-0505 February 2024 Response to Question for Withholding Information from Public Disclosure Exemption Requests for Physical Barriers NL-24-0038, National Pollutant Discharge Elimination System (NPDES) Permit Renewal Application2024-02-0202 February 2024 National Pollutant Discharge Elimination System (NPDES) Permit Renewal Application NL-24-0031, Inservice Inspection Program Owners Activity Report (OAR-1) for Outage 2R232024-01-29029 January 2024 Inservice Inspection Program Owners Activity Report (OAR-1) for Outage 2R23 NL-24-0020, Plan, Unit 1 Responses to NRC Request for Additional Information for Refueling Outage 1R24 Steam Generator Tube Inspection Report2024-01-22022 January 2024 Plan, Unit 1 Responses to NRC Request for Additional Information for Refueling Outage 1R24 Steam Generator Tube Inspection Report NL-23-0926, Correction of Technical Specification Typographical Error2024-01-12012 January 2024 Correction of Technical Specification Typographical Error NL-23-0878, Request for Exemption from Security Event Notification Implementation2023-11-29029 November 2023 Request for Exemption from Security Event Notification Implementation NL-23-0827, Response to Requests for Additional Information for a License Amendment Request and a Proposed Alternative Related to TS 3.4.142023-11-17017 November 2023 Response to Requests for Additional Information for a License Amendment Request and a Proposed Alternative Related to TS 3.4.14 NL-23-0750, Response to Second Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the Colr2023-10-0404 October 2023 Response to Second Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the Colr NL-23-0745, Refueling Outage 1R24 Steam Generator Tube Inspection Report2023-09-22022 September 2023 Refueling Outage 1R24 Steam Generator Tube Inspection Report NL-23-0742, to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC Fo Surveillance Technical Specifications2023-09-20020 September 2023 to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC Fo Surveillance Technical Specifications NL-23-0695, Response to Round 2 Request for Additional Information Regarding License Amendment Request for Technical Specification 3.8.3, Inverters Operating, Completion Time Extension (LAR-22-002S2)2023-08-31031 August 2023 Response to Round 2 Request for Additional Information Regarding License Amendment Request for Technical Specification 3.8.3, Inverters Operating, Completion Time Extension (LAR-22-002S2) NL-23-0666, License Amendment Request: Remove Combined License Appendix C (LAR 23-008)2023-08-28028 August 2023 License Amendment Request: Remove Combined License Appendix C (LAR 23-008) NL-23-0670, Response to Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the COLR Consistent with WCAP-144832023-08-11011 August 2023 Response to Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the COLR Consistent with WCAP-14483 NL-23-0658, Southern Nuclear Operating Company - Response to Request for Additional Information Regarding Quality Assurance Topical Report Submittal2023-08-11011 August 2023 Southern Nuclear Operating Company - Response to Request for Additional Information Regarding Quality Assurance Topical Report Submittal NL-23-0672, Licensee Guarantees of Payment of Deferred Premiums2023-08-10010 August 2023 Licensee Guarantees of Payment of Deferred Premiums NL-23-0542, CFR 50.46 ECCS Evaluation Model Annual Report for 20222023-08-0909 August 2023 CFR 50.46 ECCS Evaluation Model Annual Report for 2022 NL-23-0624, Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis2023-08-0404 August 2023 Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis NL-23-0611, Core Operating Limits Report, Cycle 11 Version 12023-07-19019 July 2023 Core Operating Limits Report, Cycle 11 Version 1 NL-23-0584, Preservice Inspection Program Owner'S Activity Report2023-07-10010 July 2023 Preservice Inspection Program Owner'S Activity Report NL-23-0555, Request for Exemption from Physical Barrier Requirement2023-07-0707 July 2023 Request for Exemption from Physical Barrier Requirement NL-23-0506, to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC Fq Surveillance Technical Specifications2023-07-0505 July 2023 to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC Fq Surveillance Technical Specifications NL-23-0541, Inservice Inspection Program Owners Activity Report for Outage 1R242023-06-28028 June 2023 Inservice Inspection Program Owners Activity Report for Outage 1R24 2024-09-09
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Southern Nuclear Operating Company, Inc.40 Inverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.5776 Fax 205.992.5363 July 31, 2008 SOUTHERNAM COMPANY Energy to Serve Your WorldSM Docket Nos.: 50-424 NL-08-1195 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant Generic Letter 2004-02 Response Extension Request Ladies and Gentlemen:
By letter dated May 22, 2008, (NL-08-0818)
Southern Nuclear Operating Company (SNC) requested an extension for the final response to Generic Letter 2004-02 for the completion of:* Downstream effects evaluations in accordance with WCAP-1 6406-P Rev.1, "Evaluation of Downstream Sump Debris Effects in Support of GSI-191" and WCAP-16793-NP, "Evaluation of Long-Term Cooling Considering Particulate, Fibrous and Chemical Debris in the Recirculating Fluid."" Completion of chemical effects testing and evaluation of test results.An extension was granted by the NRC to July 31, 2008, in a letter dated May 29, 2008.In May 2008 the sump screen vendor, General Electric Hitachi, expected to receive the final Chemical Effects Testing (CE) Summary Report from our 3rd party vendor (Alion) on June 24, 2008. GEH was to incorporate the results and provide the final Hydraulic Sizing Report to SNC by July 11, 2008. GEH did not receive the final CE Summary Report until July 25, 2008 causing a delay in issuance of the Vogtle S100 Report. The CE Summary report was delayed for the following reasons:-The original test results for the 8D fiber case produced non-conclusive results.Alion and GEH took additional time to work though an acceptable solution using the second test results.-Alion worked with SNC and other utilities involved in VUEZ testing to address NRC questions regarding VUEZ Testing during preparation of the Vogtle CE Summary report. Additional effort was provided to consider these issues in the report.
U. S. Nuclear Regulatory Commission NL-08-1195 Page 2-Alion received an NRC visit and a NUPIC audit during this time frame. In house visitors consumed more resources than anticipated.
-The test report from the VUEZ test facility, which is used as a basis for the CE Summary Report, was delayed due to several jobs at the test facility competing for resources.
The CE Summary Report was provided to GEH on July 25, 2008.GEH will expedite incorporation of the results and is expected to issue their final S100 report to SNC by Aug 2, 2008.A review of the CE report and SNC calculations indicates margin exists. SNC has reasonable assurance that positive margin is maintained throughout the anticipated sump temperature range. Preliminary numbers indicate a minimum of approximately 7.5 feet of margin. This conclusion will be incorporated into our final design documentation as appropriate once the final S100 report is received.The bases for the previous extension requests, letters dated December 7, 2007 (NL-07-1969) and May 22, 2008, (NL-08-0818) remain valid and SNC has reasonable assurance that the new VEGP sump screens will perform their design basis function under the original design bases considerations.
This extension request will allow SNC to complete the documentation updates required to support the GL/GSI-1 91 considerations.
It is anticipated that with the above deliverable schedule, an extension request until August 2 9 th is needed to perform a review of the final S100 report and incorporate the results into our design documentation.
Therefore, SNC is requesting an extension of the final submittal for GL 2004-02 to August 29, 2008 based on the above schedule of vendor and in-house deliverables.
These matters were discussed with members of your staff on July 28, 2008.Mr. M. J. Ajluni states he is Nuclear Licensing Manager for Southern Nuclear Operating Company and is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.The NRC commitments contained in this letter are provided as a table in the Enclosure.
If you have any questions, please advise.Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY Mark J. Ajluni Manager-Nuclear Licensing U. S. Nuclear Regulatory Commission NL-08-1195 Page 3 Sworn to and subscribed before me this 3L day of 3u / 1,2008.Notary Public My commission expires: / /MJA/DWM/cag
Enclosures:
cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. T. E. Tynan, Vice President
-Vogtle Mr. D. H. Jones, Vice President
-Engineering RType: CVC7000 U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. R. A. Jervey, NRR Project Manager -Vogtle Mr. G. J. McCoy, Senior Resident Inspector
-Vogtle State of Georgia Mr. N. Holcomb, Commissioner
-Department of Natural Resources Vogtle Electric Generating Plant Generic Letter 2004-02 Response Extension Request Enclosure List of Regulatory Commitments Enclosure List of Regulatory Commitments The following table identifies those actions committed by Southern Nuclear Operating Company in this document for Vogtle Electric Generating Plant. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
Regulatory Commitments Due Date / Event VEGP Units 1 and 2 will be in compliance with the regulatory requirements listed in the Applicable August 29, 2008 Regulatory Requirements section of GL 2004-02.
Text
Southern Nuclear Operating Company, Inc.40 Inverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.5776 Fax 205.992.5363 July 31, 2008 SOUTHERNAM COMPANY Energy to Serve Your WorldSM Docket Nos.: 50-424 NL-08-1195 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant Generic Letter 2004-02 Response Extension Request Ladies and Gentlemen:
By letter dated May 22, 2008, (NL-08-0818)
Southern Nuclear Operating Company (SNC) requested an extension for the final response to Generic Letter 2004-02 for the completion of:* Downstream effects evaluations in accordance with WCAP-1 6406-P Rev.1, "Evaluation of Downstream Sump Debris Effects in Support of GSI-191" and WCAP-16793-NP, "Evaluation of Long-Term Cooling Considering Particulate, Fibrous and Chemical Debris in the Recirculating Fluid."" Completion of chemical effects testing and evaluation of test results.An extension was granted by the NRC to July 31, 2008, in a letter dated May 29, 2008.In May 2008 the sump screen vendor, General Electric Hitachi, expected to receive the final Chemical Effects Testing (CE) Summary Report from our 3rd party vendor (Alion) on June 24, 2008. GEH was to incorporate the results and provide the final Hydraulic Sizing Report to SNC by July 11, 2008. GEH did not receive the final CE Summary Report until July 25, 2008 causing a delay in issuance of the Vogtle S100 Report. The CE Summary report was delayed for the following reasons:-The original test results for the 8D fiber case produced non-conclusive results.Alion and GEH took additional time to work though an acceptable solution using the second test results.-Alion worked with SNC and other utilities involved in VUEZ testing to address NRC questions regarding VUEZ Testing during preparation of the Vogtle CE Summary report. Additional effort was provided to consider these issues in the report.
U. S. Nuclear Regulatory Commission NL-08-1195 Page 2-Alion received an NRC visit and a NUPIC audit during this time frame. In house visitors consumed more resources than anticipated.
-The test report from the VUEZ test facility, which is used as a basis for the CE Summary Report, was delayed due to several jobs at the test facility competing for resources.
The CE Summary Report was provided to GEH on July 25, 2008.GEH will expedite incorporation of the results and is expected to issue their final S100 report to SNC by Aug 2, 2008.A review of the CE report and SNC calculations indicates margin exists. SNC has reasonable assurance that positive margin is maintained throughout the anticipated sump temperature range. Preliminary numbers indicate a minimum of approximately 7.5 feet of margin. This conclusion will be incorporated into our final design documentation as appropriate once the final S100 report is received.The bases for the previous extension requests, letters dated December 7, 2007 (NL-07-1969) and May 22, 2008, (NL-08-0818) remain valid and SNC has reasonable assurance that the new VEGP sump screens will perform their design basis function under the original design bases considerations.
This extension request will allow SNC to complete the documentation updates required to support the GL/GSI-1 91 considerations.
It is anticipated that with the above deliverable schedule, an extension request until August 2 9 th is needed to perform a review of the final S100 report and incorporate the results into our design documentation.
Therefore, SNC is requesting an extension of the final submittal for GL 2004-02 to August 29, 2008 based on the above schedule of vendor and in-house deliverables.
These matters were discussed with members of your staff on July 28, 2008.Mr. M. J. Ajluni states he is Nuclear Licensing Manager for Southern Nuclear Operating Company and is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.The NRC commitments contained in this letter are provided as a table in the Enclosure.
If you have any questions, please advise.Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY Mark J. Ajluni Manager-Nuclear Licensing U. S. Nuclear Regulatory Commission NL-08-1195 Page 3 Sworn to and subscribed before me this 3L day of 3u / 1,2008.Notary Public My commission expires: / /MJA/DWM/cag
Enclosures:
cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. T. E. Tynan, Vice President
-Vogtle Mr. D. H. Jones, Vice President
-Engineering RType: CVC7000 U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. R. A. Jervey, NRR Project Manager -Vogtle Mr. G. J. McCoy, Senior Resident Inspector
-Vogtle State of Georgia Mr. N. Holcomb, Commissioner
-Department of Natural Resources Vogtle Electric Generating Plant Generic Letter 2004-02 Response Extension Request Enclosure List of Regulatory Commitments Enclosure List of Regulatory Commitments The following table identifies those actions committed by Southern Nuclear Operating Company in this document for Vogtle Electric Generating Plant. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
Regulatory Commitments Due Date / Event VEGP Units 1 and 2 will be in compliance with the regulatory requirements listed in the Applicable August 29, 2008 Regulatory Requirements section of GL 2004-02.