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MONTHYEARML0510302832005-04-0101 April 2005 Response to Request for Additional Information Regarding Permanent Relief from Inservice Inspection Requirements of 10 CFR 50.55a(g) and Request to Revise Pressure/Temperature Curves of Technical Specification 3.4.11 Project stage: Response to RAI ML0513100912005-06-0101 June 2005 Columbia Generating Station (CGS) - Safety Evaluation for CGS on Relief Request for Alternative to Volumetric Examination of Reactor Pressure Vessel Circumferential Shell Welds in Accordance with BWRVIP-05 Project stage: Approval 2005-04-01
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Category:Legal-Affidavit
MONTHYEARGO2-22-075, Response to Request for Additional Information Related to Revised Pressure-Temperature Limit Curves2022-07-11011 July 2022 Response to Request for Additional Information Related to Revised Pressure-Temperature Limit Curves GO2-20-146, Erratum to Fourth Ten-Year Inservice Inspection (ISI) Program Relief Request 4ISI-092020-11-17017 November 2020 Erratum to Fourth Ten-Year Inservice Inspection (ISI) Program Relief Request 4ISI-09 GO2-20-127, Response to Request for Additional Information Related to Fourth Interval Inservice Inspection (ISI) Program Request 4ISI-092020-10-22022 October 2020 Response to Request for Additional Information Related to Fourth Interval Inservice Inspection (ISI) Program Request 4ISI-09 ML20114E2352020-04-22022 April 2020 Columbia,Fourth Ten-Year Interval Inservice Inspection Program Relief Request 4ISI-09 ML17047A7492017-02-16016 February 2017 Response to Request for Additional Information, Columbia Mur LAR Evib Rais ML15238A7422015-08-13013 August 2015 Resubmittal of Deviation from BWRVIP Flaw Evaluation Requirements for Jet Pump Riser Indication GO2-15-035, Global Nuclear Fuel - Americas Affidavit for Withholding Information2014-10-21021 October 2014 Global Nuclear Fuel - Americas Affidavit for Withholding Information GO2-14-110, Response to Request for Additional Information on License Amendment Request to Change Emergency Core Cooling System Surveillance Requirements2014-09-0909 September 2014 Response to Request for Additional Information on License Amendment Request to Change Emergency Core Cooling System Surveillance Requirements ML14204A7092014-07-23023 July 2014 Enclosure 3, Affidavit of Peter M. Yandow ML11308A0232011-10-27027 October 2011 License Renewal Reactor Pressure Vessel (RPV) Nozzle Upper Shelf Energy (Use) NRC Request for Additional Information RAI 4.2-7 Support: Data Cover Letter 0000-0138-8826-R2, Data and Affidavit ML1127000682011-09-26026 September 2011 Enclosure 3, Mfn 10-245 R4, Affidavit ML11234A5292011-08-17017 August 2011 Declaration of Standing of Tom Bailie ML11234A5262011-08-15015 August 2011 Declaration of Standing from Bruce Smartlowit ML11234A5272011-08-0909 August 2011 Declaration of Standing of Scott Madison ML11234A5312011-08-0808 August 2011 Declaration of Dr. Arjun Makhijani Regarding Safety and Environmental Significance of NRC Task Force Report Regarding Lessons Learned from Fukushima Daiichi Nuclear Power Station Accident ML0520003282005-07-14014 July 2005 Surveillance Program for Channel-Control Blade Interference ML0510302832005-04-0101 April 2005 Response to Request for Additional Information Regarding Permanent Relief from Inservice Inspection Requirements of 10 CFR 50.55a(g) and Request to Revise Pressure/Temperature Curves of Technical Specification 3.4.11 ML18191A1891978-09-18018 September 1978 Forwarding Proprietary Information Consisting of Addenda No. 1 to Air Products Post LOCA Recombiner Test Summary Report No. APCI-78-6P. in Accordance with Sec. 2.790, Request Withholding Pursuant from Public, Pending Review ML18191A1981978-07-10010 July 1978 Letter Submitting 4 Copies of Air Products and Chemicals, Inc., Report APCI-78-6 and APCI-78-6P ML18191A4751978-05-17017 May 1978 Wppss Nuclear Project No. 2 Environmental Report - Operating License Stage Amendment No. 1 ML18191A2381977-12-16016 December 1977 Advising of Intention to Complete Evaluation Regarding BWR Relief Valve Control System & Associated Containment Loads for Wppss Nuclear Project No. 2 Is Scheduled During 2nd Quarter of 1978 ML18191A4831977-03-21021 March 1977 Wpps Nuclear Project No. 2 Environmental Report - Operating License Stage Submittal for Docketing ML18191A8081976-11-28028 November 1976 Request for Extension of Construction Permit No. CPPR-93 Wppss Nuclear Project No. 2 ML18191A2691976-08-17017 August 1976 Wppss Nuclear Project No. 2 Annual Financial Data ML18191A2711976-06-16016 June 1976 Wppss Nuclear Project No. 2. Compliance to 10 CFR Part 50, Appendix I ML18191A8101976-04-28028 April 1976 Wppss Nuclear Project No. 2 Post-Construction Permit Item Drywell/Wetwell Leakage Study ML18191A2321976-03-18018 March 1976 Attached Wppss Nuclear Project No. 2 Mark II Containment Design Evaluation. Will Continue to Provide Updated Information on Status of Generic Mark II Owners Range Program in Support of Dffr Design Basis Information ML18191A2741976-01-12012 January 1976 Wppss Nuclear Project No. 2. Clarification of Criteria, Pipe Rupture Protection Inside Containment ML18191A2331975-08-19019 August 1975 Response to Request for Additional Information, Dated 7/8/1974, to Resolve Remaining NRC Concerns on Sacrificial Shield Wall Design ML18191A8131975-08-18018 August 1975 Wppss Nuclear Project No. 2 Response to Request for Information Main Steam Isolation Valve Leakage Control System ML18191A2341975-07-25025 July 1975 Attached Wppss Nuclear Project No. 2 Suppression Pool Current Design Drawings, Which Do Not Reflect Any Design Changes That May Be Needed to Accommodate Loads Resulting from Pool Dynamic Forces During SRV Actuation or LOCA ML18191A2861975-06-26026 June 1975 Wppss Nuclear Project No. 2. Response to Questions Sacrificial Shield Wall Design ML18191A2351975-03-26026 March 1975 Response to Request for Additional Information Protection Against Pipe Breaks Outside Containment ML18191A2971975-02-21021 February 1975 Wppss Nuclear Project No. 2, Post Construction Permit Item, Piping and Instrumentation Diagrams ML18191A3641975-02-11011 February 1975 Response to Questions Regarding Sacrificial Shield Wall Design 2022-07-11
[Table view] Category:Letter
MONTHYEARGO2-24-004, License Amendment Request to Revise Emergency Plan2024-01-30030 January 2024 License Amendment Request to Revise Emergency Plan IR 05000397/20230042024-01-29029 January 2024 Integrated Inspection and Independent Spent Fuel Storage Installation Report 05000397/2023004 and 07200035/2023001 GO2-24-003, Relief Requests for the Columbia Generating Station Fifth Ten-Year Interval Inservice Testing2024-01-29029 January 2024 Relief Requests for the Columbia Generating Station Fifth Ten-Year Interval Inservice Testing ML24011A1522024-01-10010 January 2024 March 2024 Emergency Preparedness Exercise Inspection-Request for Information GO2-24-005, Docket No. 50-397 Supplement to Reply to a Notice of Violation; EA-21-1702024-01-0808 January 2024 Docket No. 50-397 Supplement to Reply to a Notice of Violation; EA-21-170 GO2-23-136, Guarantee of Payment of Deferred Premium2023-12-20020 December 2023 Guarantee of Payment of Deferred Premium GO2-23-135, Notice of Readiness for Supplemental Inspection2023-12-14014 December 2023 Notice of Readiness for Supplemental Inspection GO2-23-130, Reply to a Notice of Violation; EA-23-0542023-12-14014 December 2023 Reply to a Notice of Violation; EA-23-054 GO2-23-105, Licensing Basis Document Update and Biennial Commitment Change Report2023-12-12012 December 2023 Licensing Basis Document Update and Biennial Commitment Change Report ML23288A0002023-12-0707 December 2023 Issuance of Amendment No. 272 to Adopt TSTF-541, Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position GO2-23-107, Application to Revise Technical Specifications to Adopt TSTS-584, Eliminate Automatic RWCU System Isolation on SLC Initiation2023-12-0505 December 2023 Application to Revise Technical Specifications to Adopt TSTS-584, Eliminate Automatic RWCU System Isolation on SLC Initiation GO2-23-126, Docket No. 50-397 Voluntary Response to Regulatory Issue Summary 2023-012023-11-28028 November 2023 Docket No. 50-397 Voluntary Response to Regulatory Issue Summary 2023-01 GO2-23-121, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-27027 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation IR 05000397/20230122023-11-20020 November 2023 Commercial Grade Dedication Inspection Report 05000397/2023012 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 IR 05000397/20230102023-11-0909 November 2023 Biennial Problem Identification and Resolution Inspection Report 05000397/2023010 IR 05000397/20230932023-11-0101 November 2023 Final Significance Determination of a White Finding, Notice of Violation and Follow-Up Assessment Letter; NRC Inspection Report 05000397/2023093 ML23299A2072023-10-26026 October 2023 Biennial Requalification Inspection Request for Information IR 05000397/20230032023-10-25025 October 2023 Integrated Inspection Report 05000397/2023003 IR 05000397/20230112023-10-0404 October 2023 License Renewal Phase 2 Report 05000397/2023011 IR 05000397/20234012023-09-11011 September 2023 Security Baseline Inspection Report 05000397/2023401 GO2-23-097, In-Service Inspection Summary Report for the Twenty-Sixth Refueling Outage (R26)2023-09-0606 September 2023 In-Service Inspection Summary Report for the Twenty-Sixth Refueling Outage (R26) ML24032A2182023-09-0101 September 2023 Information Request, Security IR 2024401 GO2-23-100, Technical Specification Section 5.6.4 Post Accident Monitoring Instrumentation 14-Day Report for Inoperable Suppression Pool Level Indication2023-08-31031 August 2023 Technical Specification Section 5.6.4 Post Accident Monitoring Instrumentation 14-Day Report for Inoperable Suppression Pool Level Indication GO2-23-056, Application to Revise Technical Specifications to Adopt TSTF-230, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling2023-08-29029 August 2023 Application to Revise Technical Specifications to Adopt TSTF-230, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling IR 05000397/20230052023-08-22022 August 2023 Updated Inspection Plan for Columbia Generating Station (Report 05000397/2023005) - Mid Year Letter IR 05000397/20230022023-08-0101 August 2023 Integrated Inspection Report 05000397/2023002 GO2-23-093, Supplement to Reply to a Notice of Violation: EA-21-1702023-07-27027 July 2023 Supplement to Reply to a Notice of Violation: EA-21-170 ML23206A2442023-07-25025 July 2023 Energy Northwest Columbia Generating Station, Response to Apparent Violation in NRC Inspection Report 05000397/2023092; EA-23-054 GO2-23-068, Notification of Completion of Commitments Required Prior to Entry Into the Period of Extended Operation2023-07-19019 July 2023 Notification of Completion of Commitments Required Prior to Entry Into the Period of Extended Operation GO2-23-090, Reply to a Notice of Violation2023-07-12012 July 2023 Reply to a Notice of Violation ML23143A1202023-06-27027 June 2023 Request Number 4ISI-11 to the American Society of Mechanical Engineers Boiler and Pressure Vessel Code Regarding Alternate Examination of Reactor Vessel Welds GO2-23-073, Notification of NPDES Permit Issuance2023-06-26026 June 2023 Notification of NPDES Permit Issuance ML23163A2502023-06-12012 June 2023 Summary of Changes and Analysis for Revision 41 of Plant Procedures Manual 13.8.1 Emergency Dose Projection System Operations GO2-23-072, Cycle 27 Core Operating Limits Report2023-06-0505 June 2023 Cycle 27 Core Operating Limits Report ML23157A2702023-06-0101 June 2023 4-2022-011 -022 Letter - OI Closure to Licensee IR 05000397/20230922023-06-0101 June 2023 NRC Inspection Report 05000397/2023092 and Preliminary White Finding IR 05000397/20230902023-06-0101 June 2023 Final Significance Determination of a White Finding, Notice of Violation and Follow-Up Assessment Letter; NRC Inspection Report 05000397/2023090 GO2-23-055, Independent Spent Fuel Storage Installation, 2022 Annual Radiological Environmental Operating Report2023-05-15015 May 2023 Independent Spent Fuel Storage Installation, 2022 Annual Radiological Environmental Operating Report IR 05000397/20230012023-05-0505 May 2023 Integrated Inspection Report 05000397/2023001 - April 26, 2023 GO2-23-006, License Amendment Request to Clean-Up Operating License and Appendix a Technical Specifications2023-05-0101 May 2023 License Amendment Request to Clean-Up Operating License and Appendix a Technical Specifications IR 05000397/20233012023-05-0101 May 2023 NRC Examination Report 05000397/2023301 GO2-23-053, 2022 Annual Environmental Operating Report2023-04-26026 April 2023 2022 Annual Environmental Operating Report GO2-23-057, 2022 Annual Radioactive Effluent Release Report2023-04-25025 April 2023 2022 Annual Radioactive Effluent Release Report ML23110A2642023-04-20020 April 2023 Request for Information License Renewal Phase 2 Inspection GO2-23-012, Application to Revise Technical Specifications to Adopt Tstf-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position2023-03-27027 March 2023 Application to Revise Technical Specifications to Adopt Tstf-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position GO2-23-041, Generation Station - Level of Financial Protection - Annual Reporting Requirement2023-03-15015 March 2023 Generation Station - Level of Financial Protection - Annual Reporting Requirement GO2-23-038, Plant Decommissioning Fund Status Report2023-03-15015 March 2023 Plant Decommissioning Fund Status Report ML23013A0812023-03-15015 March 2023 Issuance of Amendment No. 270 Revision to Technical Specifications to Adopt TSTF 505, Revision 2, Provide Risk-Informed Extended Completion Times-RITSTF Initiative 4B GO2-23-034, Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.462023-03-13013 March 2023 Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.46 2024-01-08
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ENERGY A NORTHWEST People -Vision -Solutions P.O. Box 968
- 99352-0968 Confidential Trade Secret Information submitted pursuant to 10 CFR 2.390 April 1, 2005 G02-05-064 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING PERMANENT RELIEF FROM INSERVICE INSPECTION REQUIREMENTS OF 10 CFR 50.55a(g) AND REQUEST TO REVISE PRESSUREITEMPERATURE CURVES OF TECHNICAL SPECIFICATION 3.4.11
References:
(1) Letter Dated June 9, 2004, G02-04-107, DKAtkinson (Energy Northwest) to NRC, "License Amendment Request to Revise Technical Specification 3.4.11 Reactor Coolant System (RCS)
Pressure and Temperature (P/T) Limits."
(2) Letter Dated July 15, 2004, G02-04-125, DKAtkinson (Energy Northwest) to NRC, "Permanent Relief from Inservice Inspection Requirements of 10 CFR 50.55a(g) for the Volumetric Examination of Circumferential Reactor Pressure Vessel Welds."
Dear Sir or Madam:
Inthe letter of Reference 1, Energy Northwest requested an amendment to the Columbia Generating Station (Columbia) Technical Specifications (TS) Limiting Condition for Operation 3.4.11, "RCS Pressure and Temperature (P/T) Limits." Specifically, this proposed amendment would replace the PIT curves for Inservice Leak and Hydrostatic Testing, Non-Nuclear Heating and Cooldown, and Nuclear Heating and Cooldown currently illustrated in TS Figures 3.4.11-1, 3.4.11-2, and 3.4.11-3, respectively. Inthe letter of Reference 2, Energy Northwest requested NRC approval for permanent relief from inservice inspection requirements of 10 CFR 50.55a(g) for the volumetric examination of circumferential reactor pressure vessel welds for Columbia. This category of welds is specified in the American Society of Mechanical Engineers Code Section Xl, Table IWB-2500-1, Examination Category B-A, Item B1.11, Circumferential Shell Welds. ALO
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING PERMANENT RELIEF FROM INSERVICE INSPECTION REQUIREMENTS OF 10 CFR 50.55a(g) AND REQUEST TO REVISE PRESSURE/TEMPERATURE CURVES OF TECHNICAL SPECIFICATION 3.4.11 Page 2 of 2 Subsequent to submittal of the referenced requests, Energy Northwest received Requests for Additional Information (RAls) from NRC staff reviewing the referenced documents. Energy Northwest's responses to the RAls are contained herein as and Attachment 2 to this letter.
The tables on pages 2 and 3 of Attachment 1 and page 3 of Attachment 2 contain proprietary information. The Electric Power Research Institute (EPRI) requests this information be withheld from public disclosure. The enclosed affidavit from EPRI (the owner of the information) provides the basis for the request. The proprietary information is denoted as required by 10 CFR 2.390(b)(A)
If you have any questions or require additional information regarding this matter, please contact Mr. DW Coleman, Manager, Regulatory Programs, at (509) 377-4342.
Respectfully, Vice rident, Technical Services Mail op PE04
Enclosure:
EPRI Affidavit Attachments: (1) Response to RAI Regarding Columbia Generating Station Pressure and Temperature Limits (2) Response to RAI Regarding Relief Request from Volumetric Examination of Circumferential RPV Welds cc: BS Mallet - NRC - RIV BJ Benney - NRC - NRR NRC Sr. Resident Inspector - 988C RN Sherman - BPA/1 399 WA Horin - Winston & Strawn
EL EC TR IF Y T HE W OR L D 2 March 22, 2005 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Request for Withholding of Proprietary Information Entitled "BWRVIP Integrated Surveillance Data (ISP) for Heat 5P6756 (Fluence Values, and Unirradiated and Irradiated (T30 ) Transition Temperature Data)" (the "Information").
Attn Document Control Desk:
This is a request under 10 CFR 2.390 that the NRC withhold from public disclosure the Information identified in the enclosed affidavit consisting of EPRI owned proprietary information, entitled "BWRVIP Integrated Surveillance Data (ISP) for Heat 5P6756 (Fluence Values, and Unirradiated and Irradiated (T30) Transition Temperature Data" (the "Information").
A copy of the Information and the affidavit in support of this request are enclosed.
EPRI desires to disclose the Information in confidence to the NRC for informational purposes to assist the NRC. EPRI would welcome any discussions with the NRC related to the Information that the NRC desires to conduct.
The Information is for the NRC's internal use and may be used only for the purposes for which it is disclosed by EPRI. The Information should not be otherwise used or disclosed to any person outside the NRC without prior written permission from EPRI.
If you have any questions about the legal aspects of this request for withholding, please contact EPRI's Legal Department at 650-855-2000.
Sincerely, David J. Modeen Vice President & Chief Nuclear Officer Enclosures cc: Licensing 1300 W.T. Harris Boulevard I Charlotte, NC 28262 USA 1704.547.3774 1FAX 704.547.6168 1www.epri.com
AFFIDAVIT RE: Request for Withholding of Proprietary Information Entitled "BWRVIP Integrated Surveillance Data for Heat 5P6756 (Fluence Values, and Unirradiated and Irradiated (T30 )
Transition Temperature Data)" (the "Information")
I, DAVID MODEEN, being duly sworn, depose and state as follows:
I am the Vice President & Chief Nuclear Officer at the Electric Power Research Institute
("EPRI") and I specifically have been delegated responsibility for the Information listed above that is sought under this affidavit to be withheld (the "Information") and authorized to apply for its withholding on behalf of EPRI. This affidavit is submitted to the Nuclear Regulatory Commission ("NRC") pursuant to 10 CFR 2.790 (a)(4) based on the fact that the Information consists of trade secrets of EPRI and that the NRC will receive the Information from EPRI under privilege and in confidence.
The basis for withholding such Information from the public is set forth below:
(1) The Information has been held in confidence by EPRI, its owner. All those accepting copies of the Information must agree to preserve the confidentiality of the Information.
(2) The Information is a type customarily held in confidence by EPRI and there is a rational basis therefor. The Information is a type that EPRI holds in confidence by means of a trade secret(s). This information is held in confidence by EPRI because disclosing it would prevent EPRI from licensing the Information and collecting royalties. Such royalty fees allow EPRI to recover its investment. If consultants and/or other businesses providing services in the electric/nuclear power industry were able to publicly obtain the Information, they would be able to use it commercially for profit and avoid spending the large amount of money that EPRI was required to spend in preparation of the Information. The rational basis that EPRI has for classifying the Information as a trade secret(s) is justified by the Uniform Trade Secrets Act.
which California adopted in 1984 and which has been adopted by over twenty states. The Uniform Trade Secrets Act defines a "trade secret" as follows:
"Trade secret" means information, including a formula, pattern, compilation, program, device, method, technique, or process, that:
(i) Derives independent economic value, actual or potential, from not being generally known to the public or to other persons who can obtain economic value from its disclosure or use; and (ii) Is the subject of efforts that are reasonable under the circumstances to maintain its secrecy.
(3) The Information will be transmitted to the NRC in confidence.
(4) The Information is not available in public sources. EPRI developed the Information only after making a determination that the Information was not available from public sources.
Developing the Information required a large expenditure of dollars and EPRI employees' time.
The money spent, plus the value of EPRI's staff time in preparing the Information, shows that the Information is highly valuable to EPRI. Finally, the Information was developed only after a long period of effort of at least several months.
(5) A public disclosure of the Information would be highly likely to cause substantial harm to EPRI's competitive position and the ability of EPRI to license the Information both domestically and internationally. The Information can only be acquired and/or duplicated by others using an equivalent investment of time and effort.
I have read the foregoing, and the matters stated therein are true and correct to the best of my knowledge, information and belief. I make this affidavit under penalty of perjury under the laws of the United States of America and under the laws of the State of California.
Executed at 3412 Hillview Avenue, Palo Alto, being the premises and place of business of the Electric Power Research Institute.
March 22, 2005 David J. Modeen March 22, 2005 Huang fork, Notary Public iI htokco b rb Wirn5es J~rAt
SUBSCRIBING WITNESS JURAT
= S S S~~ ------- ~S State of California lSs.
County of Sdnfst Ckdu-On ,before me, the undersigned, a otar publi forth sta erso 11 DATE appeared I Iicho/& FVrdos ur, AV personally known4 Ioveto me SUBSCRIBINU WITNESS'S NAME me on me ULnI 01 wha-is-personally-knawnAo~in) to CREDIBLE WITNESS'S NAME be the person whose name is subscribed to the within instrument, as a witness there to, who, being by me duly sworn, deposed and said that he/she was present and saw David J. N'odleen the NAME(S) OF PRINCIPAL(S) same person(s) described in and whose name(s) is/are subscribed to the within and annexed instrument in his/her/their authorized capacity(ies) as (a) party(ies)
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2q beComm. Eip i,.S witness at the request of JAwvd J. modcn NAME(S) OF PRINCIPAL(S)
WITNESS my hand and officil seal.
NOTARY'S SIGNATURE OPTIONAL INFORMATION The information below is optional. However, it may prove valuable and could prevent fraudulent attachment of this form to an unauthorized document.
CAPACITY CLAIMED BY SIGNER (PRINCIPAL) DESCRIPTION OF ATTACHED DOCUMENT
[L INDIVIDUAL
[1 CORPORATE OFFICER TITLE OR TYPE OF DOCUMENT TITLE(S)
NUMBER OF PAGES Li PARTNER(S)
Li ATTORNEY-IN-FACT Li1TRUSTEE(S) DATE OF DOCUMENT Li GUARDIAN/CONSERVATOR Li SUBSCRIBING WITNESS OTHER Fi OTHER:
RIGHT THUMBPRINT 0.L
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