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MONTHYEARML0603903012006-02-0909 February 2006 GSI Letter RAI Response to GL 2004-02 (TAC Nos. MC4676 and 4677) Project stage: RAI ML0817601002008-06-27027 June 2008 Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors, Approval of Extension Request Project stage: Other ML0835004652008-11-26026 November 2008 Comanche Peak - Supplement to Response to NRC Generic Letter (GL) 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors, Cover Letter Project stage: Request ML0916604102009-05-11011 May 2009 E-mail Draft Request for Additional Information, Licensee'S Supplemental Responses Dated February 29 and November 26, 2008, to GL 2004-02 Project stage: Draft RAI ML0916604222009-05-11011 May 2009 Request for Additional Information Supplemental Responses to Generic Letter (GL) 2004-02 Dated 02/29/2008 and 11/26/2008 Project stage: RAI ML0918207102009-07-0202 July 2009 Revised Notice of Meeting with Representatives of Luminant Generation Co., LLC, Comanche Peak to Discuss Draft Request for Information for Generic Letter 2004-02 Response Project stage: Draft RAI ML0919604492009-07-0808 July 2009 Alion Meeting Presentations on RAI 9 - Pool Fill Transport, & RAI 6 - Fiber Erosion Testing Project stage: Request ML0919400842009-07-0909 July 2009 Luminant RAI 22 and 23 SBLOCA, Vortex, Air Ingestion, Void Fraction and Flashing Issues Project stage: Request ML0919402762009-07-0909 July 2009 NRC Opening Remarks Discuss the Draft Us Nuclear Regulatory Commission Request for Additional Information for Generic Letter GL-2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressur Project stage: Draft RAI ML0919402772009-07-0909 July 2009 Luminant Holistic Overview: Presentation Will Cover Information Related to RAIs 1 - 5, 7, 12 - 14,16 - 19, 21, 25 - 36 and Overall Response to GL 2004-02 Project stage: Request ML0919400832009-07-0909 July 2009 Pci RAI 8, Test Protocol, Erosion Issue, RAI 15, Test Protocol, Latent Fiber Issue, Areva RAI 20, Test Flume, Fiberglass Larges Question Project stage: Request ML0919400852009-07-0909 July 2009 Luminant RAI 24 and 37, Secondary Line Breaks, Debris Load and Testing Project stage: Request ML0916707382009-07-15015 July 2009 Request for Additional Information Supplemental Responses to GL 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors Project stage: RAI ML0920203432009-07-22022 July 2009 Revised Conference Call with Luminant Generation Company, LLC, to Discuss Draft Request for Additional Information Re Generic Letter 2004-02, Dated May 11, 2009 Project stage: Draft RAI ML0919705782009-07-31031 July 2009 Summary of Category 1 Meeting with Luminant Generation Company LLC, Resolution of Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors Project stage: Meeting ML0926107912009-09-10010 September 2009 Comanche Peak Supplement Response to NRC Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors. Project stage: Request CP-200901396, Supplement to Response to NRC Generic Letter (GL) 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basic Accidents at Pressurized-water Reactors.2009-10-12012 October 2009 Supplement to Response to NRC Generic Letter (GL) 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basic Accidents at Pressurized-water Reactors. Project stage: Supplement ML0930800032009-10-13013 October 2009 Comanche Peak - Supplement to Response to NRC Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors Project stage: Request ML1009505642010-04-19019 April 2010 Generic Letter 2004-02 Supplemental Response Project stage: Other ML13045A4102013-02-15015 February 2013 2/28/13 Notice of Meeting Via Conference Call with Luminant to Discuss Generic Safety Issue 191, Assessment of Debris Accumulation on PWR (Pressurized-Water Reactor) Sump Performance, for Comanche Peak, Units 1 and 2 Project stage: Meeting ML13059A2022013-02-28028 February 2013 Email Licensee Slides for 2/28/13 Meeting Via Conference Call Project stage: Meeting ML13059A1812013-02-28028 February 2013 Licensee Slides for 2/28/13 Meeting Via Conference Call with Luminant Generation Company, LLC, Project stage: Meeting ML13067A0292013-03-15015 March 2013 2/28/13 - Summary of Meeting Via Conference Call with Luminant to Discuss Generic Safety Issue 191, Assessment of Debris Accumulation on PWR (Pressurized-Water Reactor) Sump Performance, for Comanche Peak, Units 1 and 2 Project stage: Meeting CP-201300670, Closure Options for Generic Safety Issue 191 (GSI-191), Assessment of Debris Accumulation on Pressurized Water Reactor Sump Performance2013-05-16016 May 2013 Closure Options for Generic Safety Issue 191 (GSI-191), Assessment of Debris Accumulation on Pressurized Water Reactor Sump Performance Project stage: Other ML13267A1972013-09-30030 September 2013 Request for Additional Information, Closure of Option 2a to Address In-Vessel Mitigative Measures for Potential In-Vessel Blockage; Related to Generic Safety Issue 191 Project stage: RAI CP-201301214, Response to Request for Additional Information Regarding Closure Options for Generic Safety Issue 1912013-10-31031 October 2013 Response to Request for Additional Information Regarding Closure Options for Generic Safety Issue 191 Project stage: Response to RAI 2009-07-31
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Category:Letter
MONTHYEARCP-202400030, License Renewal Application Revision 0 - Supplement 3, Revision 12024-01-31031 January 2024 License Renewal Application Revision 0 - Supplement 3, Revision 1 IR 05000445/20230042024-01-29029 January 2024 Integrated Inspection Report 05000445/2023004 and 05000446/2023004 CP-202400034, (CPNPP) - Core Operating Limits Report (Colr), Unit 2 Cycle 21, (ERX-23-001, Revision 1)2024-01-29029 January 2024 (CPNPP) - Core Operating Limits Report (Colr), Unit 2 Cycle 21, (ERX-23-001, Revision 1) ML24024A2102024-01-29029 January 2024 Summary of Regulatory Audit Regarding a License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors ML24025A0052024-01-25025 January 2024 Review of the Spring 2023 Steam Generator Tube Inspection Report ML24023A0242024-01-24024 January 2024 Correction to Amendment Nos. 185 and 185 Regarding Implementation of Full Spectrum Loss-of-Coolant Accident Methodology ML24018A1072024-01-18018 January 2024 Notification of Commercial Grade Dedication Inspection (05000445/2024012 and 05000446/2024012) and Request for Information ML23159A2082023-12-20020 December 2023 Request for Withholding Information from Public Disclosure ML23319A3872023-12-20020 December 2023 Issuance of Amendment Nos. 185 and 185 Regarding Implementation of Full Spectrum Loss-of-Coolant Accident (Fsloca) Methodology ML23348A2392023-12-19019 December 2023 Nonacceptance of License Amendment Request to Relocate Technical Specification 3.9.3, Nuclear Instrumentation, to the Technical Requirements Manual CP-202300575, (Cpnpp), License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors Supplement 22023-12-13013 December 2023 (Cpnpp), License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors Supplement 2 ML23333A0872023-12-13013 December 2023 Transmittal of Dam Safety Inspection Report - Public CP-202300566, (Cpnpp), Special Report 1-SR-23-001-00, Inoperable Post Accident Monitoring Instrumentation2023-12-12012 December 2023 (Cpnpp), Special Report 1-SR-23-001-00, Inoperable Post Accident Monitoring Instrumentation CP-202300494, License Renewal Application Revision 0, Supplement 32023-12-0606 December 2023 License Renewal Application Revision 0, Supplement 3 ML23313A0732023-12-0606 December 2023 Issuance of Amendment Nos. 184 and 184 Regarding Revision to Technical Specifications to Implement WCAP-17661-P-A, Rev. 1, Improved Roac and CAOC Fq Surveillance Technical Specifications ML23291A4382023-11-30030 November 2023 Notice of Availability of the Draft Plant-Specific Supplement 60, to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Comanche Peak Nuclear Power Plant, Unit Numbers 1 and 2, License Renewal Applica ML23325A0182023-11-30030 November 2023 Schedule Revision for the License Renewal Application Review IR 05000445/20234022023-11-30030 November 2023 NRC Security Inspection Report 05000445/2023402 and 05000446/2023402 CP-202300349, License Amendment Request (Lar) 23-004 Technical Specifications (TS) 3.9.3, Nuclear Instrumentation2023-11-20020 November 2023 License Amendment Request (Lar) 23-004 Technical Specifications (TS) 3.9.3, Nuclear Instrumentation ML23308A0032023-11-17017 November 2023 Letter to R. Nelson, Executive Director; Achp; Re., Comanche Peak Draft Environmental Impact Statement ML23308A0022023-11-17017 November 2023 Letter to M. Wolfe, Executive Director; Shpo; Re., Comanche Peak Draft Environmental Impact Statement ML23317A3002023-11-13013 November 2023 Letter to R. Sylestine, Chairman, Alabama-Coushatta Tribe of Texas Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2972023-11-13013 November 2023 Letter to R. Martin, President, Tonkawa Tribe of Oklahoma Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2872023-11-13013 November 2023 Letter to J. Garza, Chairman, Kickapoo Traditional Tribe of Texas Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2832023-11-13013 November 2023 Letter to D. Dotson, President, Delaware Nation Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2852023-11-13013 November 2023 Letter to E. Martinez, President, Mescalero Apache Tribe Regarding Comanche Peak Draft Environmental Impact Statement ML23306A0302023-11-13013 November 2023 Letter to J. Cernek, Chairman; Coushatta Tribe of Louisiana Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2902023-11-13013 November 2023 Letter to M. Pierite, Chairman, Tunica Biloxi Tribe of Louisiana Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2982023-11-13013 November 2023 Letter to R. Morrow, Town King, Thlopthlocco Tribal Town Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2842023-11-13013 November 2023 Letter to D. Kaskaske, Chairman, Kickapoo Tribe of Oklahoma Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2822023-11-13013 November 2023 Letter to D. Cooper, Chairman, Apache Tribe of Oklahoma Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2962023-11-13013 November 2023 Letter to M. Woommavovah, Chairman, Comanche Nation Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2812023-11-13013 November 2023 Letter to C. Hoskin, Principal Chief, Cherokee Nation; Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2862023-11-13013 November 2023 Letter to J. Bunch, Chief, United Keetoowah Band of Cherokee Indians Regarding Comanche Peak Draft Environmental Impact Statement ML23317A3032023-11-13013 November 2023 Letter to W. Yargee, Chief, Alabama-Quassarte Tribal Town Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2882023-11-13013 November 2023 Letter to L. Johnson, Chief, Seminole Nation of Oklahoma Regarding Comanche Peak Draft Environmental Impact Statement ML23317A3012023-11-13013 November 2023 Letter to S. Yahola, Mekko, Kialegee Tribal Town Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2792023-11-13013 November 2023 Letter to B. Gonzalez, Chairman, Caddo Nation Regarding Comanche Peak Draft Environmental Impact Statement ML23317A3022023-11-13013 November 2023 Letter to T. Parton, President, Wichita and Affiliated Tribes Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2892023-11-13013 November 2023 Letter to L. Spottedbird, Chairman, Kiowa Indian Tribe Regarding Comanche Peak Draft Environmental Impact Statement ML23311A2082023-11-0909 November 2023 Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV ML23360A6312023-10-26026 October 2023 FEMA, Submittal of Radiological Emergency Preparedness Final Report for the Comanche Peak Nuclear Power Plant Medical Services Drill Evaluated on August 23, 2023 CP-202300416, Supplemental Information to Facilitate Acceptance of Licensee Amendment Request 23-002, Application Regarding GDC-5 Shared System Requirements2023-10-12012 October 2023 Supplemental Information to Facilitate Acceptance of Licensee Amendment Request 23-002, Application Regarding GDC-5 Shared System Requirements CP-202300432, Response to Request for Additional Information Regarding the Safety Review of the License Renewal Application - Set 42023-10-0404 October 2023 Response to Request for Additional Information Regarding the Safety Review of the License Renewal Application - Set 4 ML23237B4222023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Letter Regarding Order Approving Transfer of Licenses and Draft Conforming License Amendments ML23263A0242023-09-21021 September 2023 Revision of Schedule for the Environmental Review of the Comanche Peak Nuclear Power Plant Units 1 and 2 License Renewal Application 2024-01-31
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Text
June 27, 2008
Mr. M. R. Blevins Executive Vice President
& Chief Nuclear Officer Luminant Generation Company LLC ATTN: Regulatory Affairs P. O. Box 1002 Glen Rose, TX 76043
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 - GENERIC LETTER 2004-02, "POTENTIAL IMPACT OF DEBRIS BLOCKAGE ON EMERGENCY RECIRCULATION DURING DESIGN BASIS ACCIDENTS AT PRESSURIZED WATER REACTORS," EXTENSION REQUEST (TAC NOS.
MC4676 AND MC4677)
Dear Mr. Blevins:
The U.S. Nuclear Regulatory Commission (NRC) has evaluated the information provided in Luminant Generation Company LLC letter, dated June 19, 2008, supporting a request for an extension of the due date for certain Comanche Peak Steam Electric Station (CPSES), Units 1 and 2 corrective actions for Generic Letter 2004-02, "Potential Impact Of Debris Blockage On Emergency Recirculation During Design Basis Accidents At Pressurized Water Reactors." The NRC has determined that for CPSES, Units 1 and 2, it is acceptable to extend the due date for completion of certain corrective actions, as described in the enclosure, until August 31, 2008.
If you have any questions regarding this matter, I may be reached at 301-415-3016.
Sincerely,
/RA/
Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos. 50-445 and 50-446
Enclosure:
As stated
cc w/encl: See next page
ML081760100
- Memo dated 6/23/2008 OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/SSIB/BC NRR/LPL4/BC NRR/LPL4/PM NAME BSingal JBurkhardt MScott (*) THiltz BSingal DATE 6/25/08 6/24/08 6/23/08 6/27/08 6/27/08 Comanche Peak Steam Electric Station 6/10/2008
cc:
Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 2159 Glen Rose, TX 76403-2159
Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 612 E Lamar Blvd., Suite 400 Arlington, TX 76011-4125
Mr. Fred W. Madden, Director Regulatory Affairs Luminant Generation Company LLC P.O. Box 1002 Glen Rose, TX 76043
Timothy P. Matthews, Esq.
Morgan Lewis 1111 Pennsylvania Avenue, NW Washington, DC 20004
County Judge P.O. Box 851 Glen Rose, TX 76043
Environmental and Natural Resources Policy Director Office of the Governor P.O. Box 12428 Austin, TX 78711-3189Mr. Richard A. Ratliff, Chief Bureau of Radiation Control Texas Department of Health 1100 West 49th Street Austin, TX 78756-3189
Mr. Brian Almon Public Utility Commission William B. Travis Building P.O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326
Ms. Susan M. Jablonski Office of Permitting, Remediation and Registration Texas Commission on Environmental Quality MC-122 P.O. Box 13087 Austin, TX 78711-3087
Anthony P. Jones Chief Boiler Inspector Texas Department of Licensing and Regulation Boiler Division E.O. Thompson State Office Building P.O. Box 12157 Austin, TX 78711
___________________
1 As of the date of issuance of this letter and enclosure, document not yet placed into ADAMS. Enclosure EXTENSION REQUEST TO COMPLETE CORRECTIVE ACTIONS GENERIC SAFETY ISSUE-191 ASSESSMENT OF DEBRIS ACCUMULATION ON PRESSURIZED-WATER REACTOR SUMP PUMP PERFORMANCE GENERIC LETTER 2004-02, "POTENTIAL IMPACT OF DEBRIS BLOCKAGE ON EMERGENCY RECIRCULATION DURING DESIGN BASIS ACCIDENTS AT PRESSURIZED WATER REACTORS" COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 DOCKET NOS. 50-445 AND 50-446
By letter dated June 19, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML08xxxxxxx 1), Luminant Generation Company LLC (the licensee) requested an extension to the U.S. Nuclear Regulatory Commission (NRC) Generic Letter (GL) 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors," corrective action due date for Comanche Peak Steam Electric Station (CPSES), Units 1 and 2. The stated intent of this extension was to allow for additional time to complete revisions to downstream effects analyses; documentation of plant-specific testing; and formal verification of design inputs, assumptions, and conclusions of calculations and evaluations. The licensee requested an extension to August 31, 2008, for completion of these activities.
By letter dated December 3, 2007, the licensee had previously submitted a request for extension of the CPSES, Units 1 and 2 sump clogging corrective actions due date of December 31, 2007, stated in the GL 2004-02. The licensee stated that the schedule for chemical testing for support of resolution of GL 2004-02 had been extended from December 2007 into the first quarter of 2008. The NRC staff reviewed the information provided and determined that it was acceptable to extend the due date for completion of corrective actions at CPSES, Units 1 and 2 for GL 2004-02 to June 30, 2008 (NRC letter dated December 27, 2007, ADAMS Accession No. ML073600874).
The licensee stated in its June 19, 2008, letter that it has successfully completed testing that showed adequate head-loss margin for all tested configurations, that the test protocol was established based on input from the NRC staff, and that testing confirmed the effectiveness of the new strainer design and its resistance to blockage from miscellaneous debris and labels.
The licensee also stated that the design-basis debris load did not result in a thin bed condition, and that the head loss increase due to chemical effects was minimal. Bypass testing was also performed. The licensee concluded, therefore, that corrective actions are substantially complete.
The licensee noted, however, that additional time is needed to perform the following:
- Complete revisions to the various downstream effects analyses, scheduled for July 2008.
- Complete numerous additional actions that are required prior to the vendor completing a final test report that meets the procurement specifications requirements, including those of Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix B for control of purchased services and procurement document control. These actions are expected to be completed in July 2008.
- Complete formal verification of design inputs, assumptions, and conclusions of calculations and evaluations conducted in response to issues identified in GL 2004-02. These activities include finalizing the assessment of the impact of the test results on strainer net positive suction head (NPSH) calculations, strainer bypass sampling input to downstream effects analyses (in-vessel and ex-vessel),
as well as the potential impact on other GL 2004-02 corrective action evaluations.
These activities also include compliance with 10 CFR 50, Appendix B requirements for design control, document control, procedures and quality assurance records. These actions will be completed in August 2008.
The NRC has based its reviews for granting extensions to the due date for completion of GL 2004-02 corrective actions on the criteria stated in SECY-06-0078. Specifically, an extension may be granted if:
- the licensee has a plant-specific technical/experimental plan with milestones and schedule to address outstanding technical issues with enough margin to account for uncertainties, and
- the licensee identifies mitigative measures to be put in place prior to December 31, 2007, and adequately describes how these mitigative measures will minimize the risk of degraded emergency core cooling system (ECCS) and containment spray system functions during the extension period.
SECY-06-0078 also states that for proposed extensions beyond several months, a licensee's request will more likely be accepted if the proposed mitigative measures include temporary physical improvements to the ECCS sump or materials inside containment to better ensure a high level of ECCS sump performance.
With regard to the first extension criterion, the licensee has provided a plant-specific technical/experimental plan, with milestones and schedules, to complete the GL 2004-02 corrective actions, as discussed above.
With regard to the second extension criterion, the licensee stated in its letter dated June 19, 2008, that the following mitigative measures are in place:
- Plant hardware modifications, developed in response to issues identified in GL 2004-02, are installed at CPSES, Units 1 and 2 and are actively supporting compliance with the regulatory requirements for long-term cooling following a design-basis loss-of-coolant accident. Hardware modifications include the following:
- ECCS sump screens were replaced with new strainers increasing the effective surface area from 200 square feet to almost 4000 square feet per emergency sump. The new strainers are contained within a 1-foot-tall
solid debris interceptor, which will significantly reduce the quantity of debris which could reach the strainers. Modifications which divert water and debris from entering the recirculation pool near the strainers are complete. The design approach is to maximize the capability of the strainer while minimizing the debris load.
- The Refueling Water Storage Tank (RWST) low-low setpoint and the RWST switchover procedure were revised to support the new strainers.
The RWST to Containment Spray Isolation valves were replaced to reduce closing time for switchover from injection to recirculation. Control board instruments and controls and alarm were modified to support the setpoint change and enhance the operator interface for ECCS and spray switchover.
- Various modifications were made to reduce recirculation water holdup volumes and to assure that blockage would not occur in critical areas such as the refueling cavity. These modifications, in combination with the RWST changes above, increase the minimum post accident flood levels from 4 feet to over 5 feet resulting in a corresponding increase in NPSH margin.
- Implementation is complete for CPSES, Units 1 and 2 plant administrative procedures and processes to support the GL 2004-02 hardware modifications and revised operating practices.
, remain in effect to minimize interim risks associated with post-accident debris blockage while GL 2004-02 evaluations are being completed. In accordance with NRC
Bulletin 2003-01, these measures will rema in in place at a minimum until all corrective actions for GL 2004-02 are complete.
In summary, the licensee has stated that it believes it has substantially completed corrective actions for GL 2004-02 and that it has demonstrated adequate NPSH through testing. Given this situation and the mitigation measures and plant improvements already in place, the additional time requested in the licensee's June 19, 2008, letter to complete remaining evaluations and documentation is considered to be of low safety concern. Based on the licensee having satisfactorily addressed the NRC GL 2004-02 due date extension criteria as discussed above, the NRC staff finds it acceptable to extend the completion date for GL 2004-02 corrective actions associated with strainer performance testing, final analysis and related licensing activities, as described in this enclosure, for CPSES, Units 1 and 2 to August 31, 2008.