Enclosure 2 Sequoyah Units 1 & 2, Response to Request for Additional Information Regarding Application to Modify Technical Specifications for Use of Areva Advanced W17 Htp Fuel (TS-SQN-2011-07)ML11320A004 |
Person / Time |
---|
Site: |
Sequoyah |
---|
Issue date: |
11/14/2011 |
---|
From: |
AREVA NP |
---|
To: |
Office of Nuclear Reactor Regulation |
---|
References |
---|
ANP-3053(NP), Rev 0, TS-SQN-2011-07 |
Download: ML11320A004 (20) |
|
|
---|
Category:Letter
MONTHYEARML24032A0202024-01-31031 January 2024 NPDES Biocide/Corrosion Treatment Plan Annual Report, Cy 2023 ML23319A2452024-01-29029 January 2024 Issuance of Amendment Nos. 366 and 360; 164 and 71 Regarding the Adoption of TSTF-567, Revision 1, Add Containment Sump TS to Address GSI-191 Issues CNL-24-017, Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure and Emergency Preparedness Department Procedure Revisions2024-01-17017 January 2024 Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure and Emergency Preparedness Department Procedure Revisions ML24018A0142024-01-17017 January 2024 Engine Systems, Inc., Report No. 10CFR21-0137, Rev. 1, 56913-EN 56913 ML24011A3182024-01-11011 January 2024 Submittal of Discharge Monitoring Report (Dmr), October 2023 ML24011A3172024-01-11011 January 2024 Submittal of Discharge Monitoring Report (Dmr), September 2023 ML24011A3202024-01-11011 January 2024 Submittal of Discharge Monitoring Report (Dmr), December 2023 ML24011A3162024-01-11011 January 2024 Submittal of Discharge Monitoring Report (Dmr), August 2023 ML24011A3192024-01-11011 January 2024 Submittal of Discharge Monitoring Report (Dmr), November 2023 IR 05000327/20234422024-01-11011 January 2024 95001 Supplemental Inspection Report 05000327/2023442 and 05000328/2023442 and Follow-Up Assessment Letter ML24010A2132024-01-10010 January 2024 CFR 21.21 Final Report Regarding Siemens Medium Voltage Circuit Breakers ML24018A0952024-01-0404 January 2024 Engine Systems, Inc., 10CFR21 Reporting of Defects and Non-Compliance Report No. 10CFR21-0137, Rev. 0 ML24004A0332024-01-0303 January 2024 Interim Report of a Deviation or Failure to Comply Crompton Instruments Type 077 Ammeter ML24004A0402024-01-0303 January 2024 Response to NRCs November 8, 2023, Request for Additional Information - Related to Independent Spent Fuel Storage Installation CNL-23-068, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-21021 December 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation CNL-23-036, Application to Revise Function 5 of Technical Specification Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation, for the Sequoyah Nuclear Plant and Watts Bar Nuclear Plant (SQN-TS-23-02 and WBN-TS-23-08)2023-12-18018 December 2023 Application to Revise Function 5 of Technical Specification Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation, for the Sequoyah Nuclear Plant and Watts Bar Nuclear Plant (SQN-TS-23-02 and WBN-TS-23-08) ML23346A1222023-12-12012 December 2023 Annual Non-Radiological Environmental Operating Report - 2023 IR 05000327/20234202023-11-28028 November 2023 Security Baseline Inspection Report 05000327/2023420 and 05000328/2023420 CNL-23-067, Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2023-11-27027 November 2023 Central Emergency Control Center Emergency Plan Implementing Procedure Revisions ML23324A4362023-11-0909 November 2023 Exam Corporate Notification Letter Aka 210-day Letter ML23307A0822023-11-0808 November 2023 Request for Additional Information August 4, 2022, Exemption Request for Deviating from the Conditions of Certificate of Compliance No. 1032, Amendment No. 3, Related to Sequoyah Nuclear Plant Independent Spent Fuel Storage Installation IR 05000327/20230032023-11-0303 November 2023 Integrated Inspection Report 05000327/2023003 and 05000328/2023003 ML23306A1592023-11-0202 November 2023 Enforcement Action EA-22-129 Inspection Readiness Notification ML23292A0792023-10-19019 October 2023 Tennessee Valley Authority - Emergency Plan Implementing Procedure Revision, Includes EPIP-5, Revision 58, General Emergency IR 05000327/20230112023-10-16016 October 2023 Triennial Fire Protection Inspection Report 05000327/2023011 and 05000328/2023011 ML23285A0882023-10-12012 October 2023 Submittal of Sequoyah Nuclear Plant, Units 1 and 2, Submittal of Updated Final Safety Analysis Report Amendment 31 ML23284A4252023-10-11011 October 2023 10 CFR 50.59 and 10 CFR 72.48 Changes, Tests, and Experiments Summary Report; Commitment Summary Report; and Update to the Fire Protection Report ML23283A2792023-10-10010 October 2023 Revisions to the Sequoyah Nuclear Plant Units 1 and 2 Technical Requirements Manual ML23279A0612023-10-0505 October 2023 Paragon Energy Solutions LLC, Part 21 Final Report Re Potential Defect with Eaton Jd and Hjd Series Molded Case Circuit Breakers (Mccbs) ML23277A0462023-10-0404 October 2023 Revisions to the Sequoyah Nuclear Plant Units 1 and 2 Technical Specification Bases ML23275A0272023-09-29029 September 2023 Submittal of Discharge Monitoring Report (DMR) Quality Assurance Study 43 Final Report 2023 ML23271A1662023-09-28028 September 2023 Registration of Spent Fuel Storage Cask Pursuant to 10 CFR 72.212(b)(2) CNL-23-059, Supplement to Sequoyah Nuclear Plant, Units 1 and 2, and Watts Bar Nuclear Plant, Units 1 and 2, Application to Revise Technical Specifications to Adopt TSTF-567-A, Revision 1, Add Containment Sump TS to Address GSI-191 Issues (SQN-TS-23-2023-09-20020 September 2023 Supplement to Sequoyah Nuclear Plant, Units 1 and 2, and Watts Bar Nuclear Plant, Units 1 and 2, Application to Revise Technical Specifications to Adopt TSTF-567-A, Revision 1, Add Containment Sump TS to Address GSI-191 Issues (SQN-TS-23-03 CNL-23-061, Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure Revision2023-09-20020 September 2023 Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure Revision IR 05000327/20234032023-09-14014 September 2023 Cyber Security Inspection Report 05000327/2023403 and 05000328/2023403 (Cover Letter) ML23257A0062023-09-14014 September 2023 Enforcement Action EA-22-129 Inspection Postponement Request ML23254A2192023-09-11011 September 2023 Emergency Plan Implementing Procedure Revisions ML23254A0652023-09-0707 September 2023 Registration of Spent Fuel Storage Cask Pursuant to 10 CFR 72.212(b)(2) CNL-23-057, Central Emergency Control Center Emergency Plan Implementing Procedure Revisions. Includes CECC-EPIP-1, Revision 76 and CECC-EPIP-9, Revision 642023-09-0505 September 2023 Central Emergency Control Center Emergency Plan Implementing Procedure Revisions. Includes CECC-EPIP-1, Revision 76 and CECC-EPIP-9, Revision 64 IR 05000327/20230052023-08-29029 August 2023 Updated Inspection Plan for Sequoyah Nuclear Plant, Units 1 and 2 - Report 05000327/2023005 and 05000328/2023005 ML23233A0122023-08-17017 August 2023 Unit 1 Cycle 25 Refueling Outage - 90-Day Inservice Inspection Summary Report - Supplement ML23233A0142023-08-15015 August 2023 Discharge Monitoring Report (Dmr), July 2023 ML23215A1212023-08-0303 August 2023 301 Exam Administrative Items (2B) Normal Release ML23215A1572023-08-0303 August 2023 Enforcement Action EA-22-129 Inspection Readiness Notification CNL-23-028, Application to Revise Technical Specifications to Adopt TSTF-567-A, Revision 1, Add Containment Sump TS to Address GSI-191 Issues (SQN-TS-23-03 and WBN-TS-23-06)2023-08-0202 August 2023 Application to Revise Technical Specifications to Adopt TSTF-567-A, Revision 1, Add Containment Sump TS to Address GSI-191 Issues (SQN-TS-23-03 and WBN-TS-23-06) ML23192A4472023-07-31031 July 2023 Staff Assessment of Updated Seismic Hazards at TVA Sites Following the NRC Process for the Ongoing Assessment of Natural Hazards Information 2024-01-04
[Table view] Category:Report
MONTHYEARML23284A4252023-10-11011 October 2023 10 CFR 50.59 and 10 CFR 72.48 Changes, Tests, and Experiments Summary Report; Commitment Summary Report; and Update to the Fire Protection Report ML23192A4472023-07-31031 July 2023 Staff Assessment of Updated Seismic Hazards at TVA Sites Following the NRC Process for the Ongoing Assessment of Natural Hazards Information ML21246A2802021-09-29029 September 2021 Final Ea/Fonsi for Tva'S Initial and Updated Triennial Decommissioning Funding Plans for Sequoyah Nuclear Plant ISFSIs IR 05000327/20210052021-08-18018 August 2021 Updated Inspection Plan for Sequoyah Nuclear Plant, Units 1 and 2 Report 05000327/2021005 and 05000328/2021005 CNL-21-072, TVA Nuclear Calculation Coversheet/ Ecm Metadata Update2021-08-13013 August 2021 TVA Nuclear Calculation Coversheet/ Ecm Metadata Update ML21140A0282021-05-14014 May 2021 Gravel Lot Restoration Project, Construction General Permit, Notice of Intent CNL-20-102, 10 CFR 71.95 Report for 3-60B Casks User2020-12-16016 December 2020 10 CFR 71.95 Report for 3-60B Casks User ML20350B7202020-12-15015 December 2020 Discharge Monitoring Report Quality Assurance Study 40 Final Report 2020 ML20308A4762020-11-0202 November 2020 10 CFR 50.59 and 10 CFR 72.48 Changes, Tests, and Experiments Summary Report and Commitment Summary Report ML20304A4032020-10-28028 October 2020 Revisions to the Sequoyah Nuclear Plant Units 1 and 2 Technical Requirements Manual ML19156A2612019-06-0505 June 2019 10 CFR 50.59 and 10 CFR 72.48 Changes, Tests, and Experiments Summary Report and Commitment Summary Report ML18352A2292018-12-17017 December 2018 Pressure Temperature Limits Report, Revision 7 ML18340A0302018-11-30030 November 2018 Tennessee Valley Authority - Sequoyah, Study to Confirm Calibration of Numerical Model ML18136A4952018-05-15015 May 2018 Pressure Temperature Limits Report, Revision 6 ML18061A0362018-03-0202 March 2018 IAEA Report of the Operational Safety Review Team (Osart) Mission to the Sequoyah Nuclear Power Plant ML17278A7592017-10-0505 October 2017 Soarca Sequoyah Updated Draft Executive Summary ML15336A9402015-11-26026 November 2015 Submittal of 10 CFR 50.46 Combined Annual and 30-Day Report ML15321A4542015-11-13013 November 2015 Submittal of 10 CFR 71.95 Report on the 8-120B Cask CNL-15-143, the Tennessee Valley Authority (TVA) Nuclear Power Group Commercial Grade Dedication Recovery Project - Closure Report2015-07-31031 July 2015 the Tennessee Valley Authority (TVA) Nuclear Power Group Commercial Grade Dedication Recovery Project - Closure Report CNL-15-106, 3, Sequoyah and Watts Bar, Units 1 & 2 - Provides Service List Update for Routine Information2015-07-0808 July 2015 3, Sequoyah and Watts Bar, Units 1 & 2 - Provides Service List Update for Routine Information ML15156A3892015-04-28028 April 2015 LTR-SGMP-15-25 Np, Response to NRC Request for Additional Information on the Design Features of the Sequoyah, Unit 2, Replacement Steam Generators. ML14325A0692014-11-17017 November 2014 CFR 50.59 and 10 CFR 72.48 Changes, Tests, and Experiments Summary Report ML14283A5132014-11-17017 November 2014 NRC Staff Review Documentation Provided by TVA for the Sequoyah Nuclear Plant, Units 1 and 2 Concerning Resolution of GL2004-02 Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurizer-Wate ML14259A3382014-09-12012 September 2014 Plant(Sqn) - NPDES Permit No. TN0026450 - Discharge Monitoring Report(Dmr) for August 2014 CNL-14-130, Third Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) for Sequoyah Nuclear Plant2014-08-28028 August 2014 Third Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) for Sequoyah Nuclear Plant CNL-14-038, Tennessee Valley Authority'S Seismic Hazard & Screening Report (CEUS Sites), Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Recommendation 2.1 of Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Acc2014-03-31031 March 2014 Tennessee Valley Authority'S Seismic Hazard & Screening Report (CEUS Sites), Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Recommendation 2.1 of Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accid CNL-14-033, Second Six-Month Status Report and Revised Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses Re Requirements for Mitigation Strategies for Beyond-Design-Basis External Events2014-03-0505 March 2014 Second Six-Month Status Report and Revised Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses Re Requirements for Mitigation Strategies for Beyond-Design-Basis External Events ML14063A5422014-03-0404 March 2014 TVA Response to Request for Clarification to NRC Request for Additional Information Regarding the Review of the Sequoyah Nuclear Plant, Units 1 and 2, License Renewal Application, LRA B.1.31, B.1.25.1 B, B.1.34-Sa, B.1.34-9a, LRA Annual ... ML14002A1132014-02-19019 February 2014 Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) ML14041A1922014-02-16016 February 2014 Mega-Tech Services, LLC Technical Evaluation Report Regarding the Overall Integrated Plan for Sequoyah Nuclear Plant, Units 1 and 2, TAC Nos.: MF0864 and MF0865 ML14016A0392014-02-0606 February 2014 Staff Assessment of the Seismic Walkdown Report Supporting Implementation of Near-Term Task Force Recommendation 2.3 Related to the Fukushima Dai-Ichi Nuclear Power Plant Accident CNL-14-013, Highlights of Improvements to the Sequoyah Nuclear Plant IPEEE Seismic Analysis Results and Supplemental Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)Regarding...2014-01-31031 January 2014 Highlights of Improvements to the Sequoyah Nuclear Plant IPEEE Seismic Analysis Results and Supplemental Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)Regarding... CNL-13-117, 10 CFR 50.46 - Combined Annual and 30-Day Report2013-11-18018 November 2013 10 CFR 50.46 - Combined Annual and 30-Day Report ML13298A0312013-10-22022 October 2013 SQN Femp Energy and Ghg Reporting Tool: Results Summary Fy 2008 - Fy 2012 Listed in Letter from TVA, Dated Sep 20, 2013, in Response to RAI 6.a.i.9 (7 Pages) ML13294A4302013-09-26026 September 2013 Fukushima Near-Term Task Force Recommendation 2.3: Seismic Response Report, Revision 1 ML13282A2332013-09-26026 September 2013 Fukushima Near-Term Task Force Recommendation 2.3: Seismic Response Report ML13206A0042013-06-24024 June 2013 Methodology for Evaluating the Potential for Multiple Dam Failures Due to Seismic Events ML13144A5762013-05-22022 May 2013 Watt Bar, Units 1 & 2, Report of Drug Testing Error in Accordance with 10 CFR 26.719(c)(1) ML13142A1982013-05-16016 May 2013 Path Forward for Resolution of Generic Safety Issue (GSI)-191 ML13080A0732013-03-12012 March 2013 Extension Request Regarding the Flooding Hazard Reevaluation Report Required by NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendation.. ML13072A5802013-03-0505 March 2013 Storm Water Pollution Prevention Plan ML13032A2532013-01-10010 January 2013 WCAP-17539-NP, Revision 0, Sequoyah, Units 1 and 2 Time-Limited Aging Analysis on Reactor Vessel Integrity ML12335A3402012-11-27027 November 2012 Tennessee Valley Authority - Fleet Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding the Flooding Walkdown Results of Recommendation 2.3 of the Near-Term Task Force Review of ML12240A1742012-09-18018 September 2012 Review of the 2011 Refueling Outage Steam Generator Tube Inservice Inspection Reports ML1218500102012-06-30030 June 2012 Enclosure 2, Tennessee Valley Authority Sequoyah Nuclear Plant Units 1 and 2 - ANP-3053(NP), Revision 4, Sequoyah Htp Fuel Transition - NRC RAIs and Responses, June 2012 (Non-Proprietary Version) ML12153A3782012-05-31031 May 2012 Enclosure 2, Sequoyah Nuclear Plant, Units 1 & 2 - ANP-3053 (Np), Revision 3, Sequoyah Htp Fuel Transition - NRC RAIs and Responses ML12137A2982012-05-15015 May 2012 ANP-2970Q2(NP), Rev 0, Sequoyah, Units 1 and 2 Htp Fuel Realistic Large Break LOCA Analysis ML12118A1662012-04-26026 April 2012 ANP-2970Q1(NP), Revision 000, Htp Fuel Realistic Large Break LOCA Analysis, April 2012 (Non-Proprietary Version), Enclosure 2 ML12114A0612012-04-0505 April 2012 Technical Report, SQN2-SGR-TRI, Revision 3, Sequoyah Unit 2 Steam Generator Replacement Rigging and Heavy Load Handling. ML12088A1712012-03-31031 March 2012 ANP-3053(NP), Revision 2, Sequoyah Htp Fuel Transition - NRC RAIs and Responses, March 2012 (Non-Proprietary Version), Enclosure 2 2023-07-31
[Table view] Category:Miscellaneous
MONTHYEARML23284A4252023-10-11011 October 2023 10 CFR 50.59 and 10 CFR 72.48 Changes, Tests, and Experiments Summary Report; Commitment Summary Report; and Update to the Fire Protection Report IR 05000327/20210052021-08-18018 August 2021 Updated Inspection Plan for Sequoyah Nuclear Plant, Units 1 and 2 Report 05000327/2021005 and 05000328/2021005 ML19156A2612019-06-0505 June 2019 10 CFR 50.59 and 10 CFR 72.48 Changes, Tests, and Experiments Summary Report and Commitment Summary Report ML17278A7592017-10-0505 October 2017 Soarca Sequoyah Updated Draft Executive Summary ML15336A9402015-11-26026 November 2015 Submittal of 10 CFR 50.46 Combined Annual and 30-Day Report ML15321A4542015-11-13013 November 2015 Submittal of 10 CFR 71.95 Report on the 8-120B Cask CNL-15-106, 3, Sequoyah and Watts Bar, Units 1 & 2 - Provides Service List Update for Routine Information2015-07-0808 July 2015 3, Sequoyah and Watts Bar, Units 1 & 2 - Provides Service List Update for Routine Information ML15156A3892015-04-28028 April 2015 LTR-SGMP-15-25 Np, Response to NRC Request for Additional Information on the Design Features of the Sequoyah, Unit 2, Replacement Steam Generators. ML14325A0692014-11-17017 November 2014 CFR 50.59 and 10 CFR 72.48 Changes, Tests, and Experiments Summary Report ML14259A3382014-09-12012 September 2014 Plant(Sqn) - NPDES Permit No. TN0026450 - Discharge Monitoring Report(Dmr) for August 2014 CNL-14-130, Third Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) for Sequoyah Nuclear Plant2014-08-28028 August 2014 Third Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) for Sequoyah Nuclear Plant CNL-14-033, Second Six-Month Status Report and Revised Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses Re Requirements for Mitigation Strategies for Beyond-Design-Basis External Events2014-03-0505 March 2014 Second Six-Month Status Report and Revised Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses Re Requirements for Mitigation Strategies for Beyond-Design-Basis External Events ML14016A0392014-02-0606 February 2014 Staff Assessment of the Seismic Walkdown Report Supporting Implementation of Near-Term Task Force Recommendation 2.3 Related to the Fukushima Dai-Ichi Nuclear Power Plant Accident CNL-14-013, Highlights of Improvements to the Sequoyah Nuclear Plant IPEEE Seismic Analysis Results and Supplemental Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)Regarding...2014-01-31031 January 2014 Highlights of Improvements to the Sequoyah Nuclear Plant IPEEE Seismic Analysis Results and Supplemental Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)Regarding... CNL-13-117, 10 CFR 50.46 - Combined Annual and 30-Day Report2013-11-18018 November 2013 10 CFR 50.46 - Combined Annual and 30-Day Report ML13298A0312013-10-22022 October 2013 SQN Femp Energy and Ghg Reporting Tool: Results Summary Fy 2008 - Fy 2012 Listed in Letter from TVA, Dated Sep 20, 2013, in Response to RAI 6.a.i.9 (7 Pages) ML13294A4302013-09-26026 September 2013 Fukushima Near-Term Task Force Recommendation 2.3: Seismic Response Report, Revision 1 ML13144A5762013-05-22022 May 2013 Watt Bar, Units 1 & 2, Report of Drug Testing Error in Accordance with 10 CFR 26.719(c)(1) ML13080A0732013-03-12012 March 2013 Extension Request Regarding the Flooding Hazard Reevaluation Report Required by NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendation.. ML12335A3402012-11-27027 November 2012 Tennessee Valley Authority - Fleet Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding the Flooding Walkdown Results of Recommendation 2.3 of the Near-Term Task Force Review of ML12240A1742012-09-18018 September 2012 Review of the 2011 Refueling Outage Steam Generator Tube Inservice Inspection Reports ML1207203562012-02-21021 February 2012 Initial Exam 2012-301 Final Administrative JPMs ML11356A2442011-12-16016 December 2011 Revisions to the Technical Requirements Manual and Units 1 and 2 Technical Specification Bases ML11356A2332011-12-16016 December 2011 10 CFR 50.59 and 10 CFR 72.48 Changes, Tests, and Experiments Summary Report ML11320A0042011-11-14014 November 2011 Enclosure 2 Sequoyah Units 1 & 2, Response to Request for Additional Information Regarding Application to Modify Technical Specifications for Use of Areva Advanced W17 Htp Fuel (TS-SQN-2011-07) ML11213A1242011-07-26026 July 2011 Information Needs ML11165A0062011-06-10010 June 2011 NPDES Permit No. TN0026450 - Alternative Thermal Limit Study Plan ML1103400582011-01-31031 January 2011 2010 Biocide/Corrosion Treatment Plan (B/Ctp) Annual Report - NPDES Permit No. TN0026450 ML1100502822010-06-30030 June 2010 EPRI Groundwater Assessment for Tva'S Sequoyah Nuclear Plant - Assessment Final Report ML1100502882010-06-22022 June 2010 Investigation of Tritium Releases to Groundwater ML1014601152010-05-21021 May 2010 Commitment Summary Report NEI 99-04, Sequoyah Units 1 & 2, Commitment Summary Report2010-05-21021 May 2010 Sequoyah Units 1 & 2, Commitment Summary Report ML1019304172010-05-0606 May 2010 Tritium Database Report ML12171A1892010-03-31031 March 2010 Integrated Resource Plan, Tva'S Environmental & Energy Future ML0903401062009-01-27027 January 2009 NPDES Permit No. TN0026450 - Application for Renewal, WR2009-1-45-151, Section 4.0 Through Interceptor System Interim Monitoring and Trial Closure ML0730400112007-10-26026 October 2007 Pressurizer Weld Overlay Examination Results to Relief Request G-RR-1 ML0715606042007-06-0505 June 2007 Commitment Summary Report for Period of June 1, 2005 to February 28, 2007 ML0607406052006-03-0202 March 2006 Unit 2 Cycle 13 (U2C13) - 12-Month Steam Generator (SG) Inspection Report ML0607204302006-03-0101 March 2006 March 1, 2006 Public Meeting Slides for Proposed Generic Letter Post-Fire Safe-Shutdown Circuit Analysis Spurious Actuations. ML0626204272006-01-25025 January 2006 American Society of Mechanical Engineers Section XI Code Relief Request - Snubber Examination and Testing ML0534102362005-11-17017 November 2005 10 CFR 50.59, and 10 CFR 72.48 Changes, Tests, & Experiments Summary Report ML0727008492005-01-31031 January 2005 Caldon Experience in Nuclear Feedwater Flow Measurement ML0426804122004-09-21021 September 2004 Final Exercise Report - Sequoyah Nuclear Power Plant, June 23, 2004 ML0406803692004-04-20020 April 2004 Summary of Conference Call, Enclosure 2 - NRC Staff Initial Questions & TVA Responses ML0406803602004-04-20020 April 2004 Summary of Conference Calls, Enclosure 1 ML0406204492004-02-26026 February 2004 Fitness-for-Duty (FFD) Program Performance Data for July - December 2003 ML0319904002003-07-10010 July 2003 Emergency Response Data System Data Point Library Update ML0318904742003-07-10010 July 2003 Relaxation of the Order, Exercising Enforcement Discretion, and Extension of the Time to Submit an Answer or Request a Hearing Regarding Order EA-03-038, Fitness-for-Duty Enhancements for Nuclear Security Force Personnel for Browns Ferry, S ML0300301192002-12-31031 December 2002 Control Room Habitability Analysis for Design Basis Accidents - Tritium Production ML0232201132002-11-15015 November 2002 Units 1 and 2 - 10CFR 50.59, Changes, Tests and Experiments Summary Report 2023-10-11
[Table view] |
Text
ENCLOSURE 2 Sequoyah Nuclear Plant, Units 1 and 2 Response to Request for Additional Information Regarding Application to Modify Technical Specifications for Use of AREVA Advanced W17 HTP Fuel (TS-SQN-2011-07)
(Non-Proprietary Version)
ANP-3053(NP)
Revision 0 Sequoyah HTP Fuel Transition
- NRC RAIs and Responses November 2011 A
AREVA NP Inc. AR EVA
A AREVA ANP-3053(NP)
Revision 0 Sequoyah HTP Fuel Transition - NRC RAIs and Responses Page 2 AREVA NP Inc.
ANP-3053(NP)
Revision 0 Sequoyah HTP Fuel Transition
- NRC RAIs and Responses Copyright © 2011 AREVA NP Inc.
All Rights Reserved AREVA NP Inc.
A AREVA ANP-3053(NP)
Revision 0 Sequoyah HTP Fuel Transition - NRC RAIs and Responses Page 3 Nature of Changes Item Page Description and Justification
- 1. All Initial release.
AREVA NP Inc.
A AR EVA ANP-3053(NP)
Revision 0 Sequoyah HTP Fuel Transition - NRC RAIs and Responses Page 4 Table of Contents Nature of Changes ...................................................................................................................... 3 Table of Contents ........................................................................................................................ 4 No m e n c la tu re ............................................................................................................................. 5 1.0 Introd uctio n ...................................................................................................................... 6 2.0 NRC RAls ........................................................................................................................ 7 3.0 RAI Responses ...................................................................................................... 8 3.1 RAI Question 1 - Radiological Design-basis Accident (DBA) Analyses ............. 9 3.1.1 AREVA Response .......................................................................... 10 3.2 RAI Question 2 - Mechanical Design Comparison - Advanced W17 HTP vs. Mark-BW Fuel .............................................................................. ...... 11 3.2.1 AREVA Response - Mechanical Design ..................... 12 3.2.2 AREVA Response - Radiological ..................................................... 14 4.0 References ................................................................................................................... 15 AREVA NP Inc.
A AREVA ANP-3053(NP)
Revision 0 Sequoyah HTP Fuel Transition - NRC RAIs and Responses Page 5 Nomenclature AST Alternate Source Term CFR Code of Federal Regulations DBA Design-basis Accident DNB Departure from Nucleate Boiling EFPD Effective Full Power Days EOC End-of-cycle FA Fuel Assembly FHA Fuel Handling Accident ft Foot GWd Giga-watt-day IFM Intermediate Flow Mixing Grids kW kilowatt LAR License Amendment Request LHGR Linear Heat Generation Rate mtU Metric Tons of Uranium NAF Neutron Absorber Fuel NRC Nuclear Regulatory Commission RAI Request for Additional Information RG Regulatory Guide TVA Tennessee Valley Authority AREVA NP Inc.
A AREVA ANP-3053(NP)
Revision 0 Sequoyah HTP Fuel Transition - NRC RAIs and Responses Page 6 1.0 Introduction This document presents the Requests for Additional Information (RAls) that were generated by the Nuclear Regulatory Commission (NRC) following their review of the Sequoyah Units 1 and 2 proposed HTP fuel transition License Amendment Request (LAR). The Sequoyah Units 1 and 2 are switching to the AREVA Advanced W17 HTP fuel assembly design.
As discussed in Section 2.0, the NRC provided two RAls.
Section 3.0 presents the responses that were prepared by AREVA in support of the fuel transition effort.
AREVA NP Inc.
A AREVA ANP-3053(NP)
Revision 0 Sequoyah HTP Fuel Transition - NRC RAIs and Responses Page 7 2.0 NRC RAIs The NRC provided two RAls regarding the Sequoyah Units 1 and 2 proposed technical specifications changes to allow use of the AREVA Adv. W17 HTP Fuel. The first RAI addresses the impacts of the fuel type change on the source term for the radiological design-basis accident (DBA) analyses. The second RAI deals with the mechanical design differences between the proposed Adv. W17 HTP fuel assembly and the resident Mark-BW fuel assembly.
Responses to these RAls are provided in Section 3.0.
AREVA NP Inc.
A AR EVA ANP-3053(NP)
Revision 0 Sequoyah HTP Fuel Transition - NRC RAIs and Responses Page 8 3.0 RAI Responses This section presents responses to the NRC RAIs received by Tennessee Valley Authority (TVA).
The RAI responses are prepared by the engineering disciplines that are responsible for the subject matter.
The technical groups that have provided responses to the RAIs are shown below.
Engineering and Projects - Nuclear Analysis (EPNA)
Fuel Design -Mechanics (FDM)
The responses begin on the following page.
AREVA NP Inc.
A AR EVA ANP-3053(NP)
Revision 0 Sequoyah HTP Fuel Transition - NRC RAIs and Responses Page 9 3.1 RAI Question 1 - RadiologicalDesign-basisAccident (DBA) Analyses Title 10 of the Code of Federal Regulations (10 CFR), Section 100.11, "Determination of exclusion area, low population zone, and population center distance," and 10 CFR Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants," Criterion 19, "Control room," set regulatory dose limits for offsite and control room after a design basis accident. Section 50.67, "Accident source term," of 10 CFR, states that the NRC may issue amendments only if the applicant's analysis demonstrates that certain onsite and control room dose limits are met.
Regulatory Guide (RG) 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," (ADAMS Accession No. ML003716792) provides guidance to licensees on performing evaluations and reanalyses in support of meeting the dose limits in 10 CFR 50.67. RG 1.195, "Methods and Assumptions for Evaluating Radiological Consequences of Design Basis Accidents at Nuclear Power Reactors," (ADAMS Accession No. ML031490640) provides guidance to licensees for performing evaluations and reanalysis in support of meeting 10 CFR 100.11.
Standard Review Plan 15.0.1, "Radiological Consequence Analyses Using Alternative Source Terms," (ADAMS Accession No. ML003734190) states:
The reviewershould evaluate the AST [Alternative Source Term] proposed by the licensee againstthe guidance in RG-1.183. Differences between the licensee'sproposal and the guidance should be resolved with the licensee. Although the licensee is allowed to propose alternativesto the guidance, large amounts of staff resources were expended in developing the revised source term (Ref. 5) from which the RG-1. 183 source term was derived. Section 2.0 of RG- 1.183 provides generic guidance on what would be expected before the staff would approve an AST with deviations from the AST in Section 3.0 of the guide.
Standard Review Plan 15.0.1 also states:
The analysis methods and assumptions used by the licensee in determining the core inventory should be reviewed to ensure that they are based on current licensing basis rated thermal power, enrichment, and burnup.
A modification to the licensing basis fuel type can have the potential to change the core isotopic distribution and inventory assumed in post accident conditions. The impacts regarding the core inventory and enrichment are not discussed in the proposed amendment. The amendment states that burnup limits are "similar" to the current fuel, but does not provide the new burnup limits.
Please verify that the core inventory, enrichment, and burnup are not changed or are bounded by the proposed amendment. If these parameters are bounded, please provide a justification for the statement that they are bounded. Please confirm that the burnup and linear heat generation rates in footnote 11, Regulatory Position 3.2 of RG 1.183 are met, or justify the source terms used.
AREVA NP Inc.
A AR EVA ANP-3053(NP)
Revision 0 Sequoyah HTP Fuel Transition - NRC RAIs and Responses Page 10 3.1.1 AREVA Response The Alternative Source Term methodology was implemented for the Fuel Handling Accident (FHA) scenario only. In accordance with SQN UFSAR Section 15.1.7.1 and Section 15.5.6 and Table 15.5.6-1, the fission product inventory used for the Fuel Handling Accident is based on (a) a rated thermal power of 3479 MWth (3455 + 0.7%
uncertainty), the highest powered fuel assembly at End of Cycle (EOC) conditions for 1500 EFPD (i.e., maximum assembly burnup of 60 GWd/mtU), (b) a maximum enrichment of 5% U-235, (c) a radial peaking factor of 1.70, (d) 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> decay after shutdown prior to fuel movement, and maximum heavy metal loading of 470 kgU/FA.
The core inventory was calculated using ORIGEN-S computer code. None of these parameters have been changed and are all still applicable and bounding.
Table 2-1 of AREVA Report ANP-2986P Revision 003 compares HTP and the Mark-BW fuel assembly designs. As noted in Table 2-1, the fuel rod pitch and fuel rod length are identical. Likewise, Table 2-2 of AREVA Report ANP-2986P Revision 003 compares the HTP and Mark-BW fuel rod design parameters; From Table 2-2 the fuel rod length, active stack height, plenum volume, and pellet diameters are identical. Table 2-2 indicates that the fuel rod cladding material of M5TM for HTP and Mark-BW designs is identical. Only the guide tube material and instrument tube change from M5TM to recrystallized Zircaloy-4 and the addition of three Intermediate Flow Mixing Grids (IFMs) composed of recrystallized Zircaloy-4 (shown in Table 2-3 and Table 2-6 of AREVA Report ANP-2986P Revision 003) could impact the fission product inventory. The impact of this change on the neutron spectra and resulting fission product inventory is insignificant.
In Figure 3-8 and Figure 3-9 of AREVA Report ANP-2986P Revision 003 the transition core maximum EOC fuel assembly burnup is 52.189 GWd/mtU at location Al1 and 52.772 GWd/mtU at location C14, for the 1st and 2 nd HTP transition cores respectively.
In Figure 3-10 of AREVA Report ANP-2986P Revision 003, the maximum EOC fuel assembly burnup for a full HTP core is 46.842 GWd/mtU at locations G8 and H9. These burnups are well within the fuel assembly burnup limit of 60 GWd/mtU assumed in the analysis of record for the fission product inventory for the FHA.
Thus, design parameters important to fission product inventory of the maximum fuel enrichment of 5% U-235, rated thermal power, maximum fuel assembly and fuel rod burnup are not impacted by the transition to HTP fuel. Therefore, the fission product inventory used for the Fuel Handling Accident remains bounded for the HTP fuel.
In addition, as part of the normal reload analyses, cycle-specific input parameters important to source term and dose are compared to the analysis of record inputs as provided by the licensee. These include rated thermal power, maximum assembly burnup, maximum assembly heavy metal loading, maximum assembly enrichment, radial peaking factors, % DNB for locked rotor event, % DNB for rod cluster control assembly ejection accident, and spent fuel pool rod internal pressure. If maximum assembly average burnups are 54 GWd/mtU or greater, then a pin census at EOC conditions will be performed to ensure that Regulatory Guide 1.183, Table 3, Footnote 11 criterion is not exceeded. That is, the maximum linear heat generation rate (LHGR) is less than 6.3 kW/ft peak rod average power for burnups exceeding 54 GWd/mtU. If AREVA NP Inc.
A AR EVA ANP-3053(NP)
Revision 0 Sequoyah HTP Fuel Transition - NRC RAIs and Responses Page 11 fuel rod burnups were to exceed 54 GWd/mtU and any pins exceed the LHGR of 6.3 kW/ft, then the gap release fraction for the non-LOCA events would be conservatively doubled or evaluated using the ANSI/ANS-5.4 methodology based on the maximum burnup. Alternatively, the core design would be modified to ensure that the LHGR criterion is met.
Therefore, the core inventory, enrichment, burnup, and linear heat generation rates for the proposed HTP Fuel amendment will be verified to bound the license basis for radiological design for each reload.
3.2 RAI Question 2 - Mechanical Design Comparison- Advanced W17 HTP vs. Mark-BW Fuel Regulatory Position 1.3.2, "Re-Analysis Guidance," of RG 1.183 states:
Any implementation of an AST, full or selective, and any associatedfacility modification should be supported by evaluations of all significantradiologicaland nonradiological impacts of the proposed actions. This evaluation should consider the impact of the proposed changes on the facility's compliance with the regulationsand commitments listed above as well as any other facility-specific requirements. These impacts may be due to (1) the associated facility modifications or (2) the differences in the AST characteristics.The scope and extent of the re-evaluationwill necessarilybe a function of the specific proposed facility modification6 and whether a full or selective implementation is being pursued. The NRC staff does not expect a complete recalculationof all facility radiologicalanalyses, but does expect licensees to evaluate all impacts of the proposed changes and to update the affected analyses and the design bases appropriately.An analysis is considered to be affected if the proposed modification changes one or more assumptions or inputs used in that analysis such that the results, or the conclusions drawn on those results, are no longer valid.
The proposed amendment states that the fuel rod and fuel pellet materials and design are "similar" to the current fuel, but does not provide any specific details regarding the impact of the proposed change on the analysis of record. For example, changes to the structure of the fuel rod could impact the assumed amount of fuel damage as a result of a fuel handling accident. In order for the NRC staff to evaluate the impact of the proposed change, please provide any changes to the parameters, assumptions, or methodologies in the radiological design-basis accident (DBA) analyses and a justification for those changes. If there are changes to the radiological DBA analyses, please provide the resulting change to the calculated radiological consequence of the DBA.
AREVA NP Inc.
A AR EVA ANP-3053(NP)
Revision 0 Sequoyah HTP Fuel Transition - NRC RAIs and Responses Page 12 3.2.1 AREVA Response - Mechanical Design Fuel Assembly Design The Adv. W17 HTP and Mark-BW fuel assembly weights are [ ] lbs and
[ ]Ibs, respectively. There is only [ ]% ([ 1%)
increase in weight for Adv. W1 7 HTP fuel with respect to the Mark-BW fuel design. This increase is an insignificant change for fuel assembly handling accident condition analysis.
Fuel Rod Design The Adv. W17 fuel rod and fuel pellet materials are identical to the current fuel rod design of the Mark-BW fuel assembly. The cross sectional properties of the cladding, fuel column length, rod fill gas pressure (nominal initial fuel rod pressurization of
[ ] psig for U0 2 and [ ] psig for NAF rod), and upper end cap are identical (See Table 2-2 of AREVA Report ANP-2986P Revision 003). It should be noted that the Adv.
W17 HTP fuel rod overall length is only [ ] inch longer than the Mark-BW fuel rod design. This difference is insignificant.
There are no design changes in the fuel rod between the Adv. W17 HTP and the Mark-BW fuel rod that would impact the fuel handling accident. The only design difference between the Adv. W17 fuel rod and the Mark-BW fuel rod is between the lower end caps of the fuel rod. Because of the change in the bottom nozzle; from the current Trapper design to the Fuel Guard design, the tip diameter of the lower end cap is modified. This is due to the difference in the blocked area of the debris filtering feature.
The current design of the Mark-BW fuel rod lower end cap is shown in Figure 1.
Figure 1 - Mark-BW Fuel Rod Lower End Cap AREVA NP Inc.
A AREVA ANP-3053(NP)
Revision 0 Sequoyah HTP Fuel Transition - NRC RAIs and Responses Page 13 The lower end cap for the Adv. W17 HTP fuel rod is shown in Figure 2.
Figure 2 Adv. W17 HTP Fuel Rod Lower End Cap The difference in the two lower end cap designs is the diameter of the tip end flat,
[ ] inch (Mark-BW) vs. [ ] inch (Adv. W17 HTP). By keeping the same
[ ] angle, the barrel section of the two lower end caps is slightly different. The weight of the end cap is insignificantly affected. All other design attributes of the lower end caps are identical. This design change is insignificant.
Cage Structure Design The Adv. W17 HTP and Mark-BW fuel designs use the guide tube feature connected to spacer grids and tie plates to build the cage structure. The structural design of the Adv.
W17 HTP fuel cage is relatively stronger than the Mark-BW fuel cage (See Table 2-1, 2-3, and 2-6 of ANP-2968P Revision 003) for the following reasons:
- Adv. W17 HTP fuel uses the [
] design at the lower section. Both cage designs have the same guide tube section properties at the upper section of the cage.
- Guide tubes are welded to the spacer grid for the Adv. W17 HTP fuel design whereas Mark-BW fuel cage design allows some flexibility to displace spacer grids instead of somewhat rigid connection between guide tube and spacer grid. This provides additional cage structural strength for the Adv. W17 HTP fuel design.
AREVA NP Inc.
A AREVA ANP-3053(NP)
Revision 0 Sequoyah HTP Fuel Transition - NRC RAIs and Responses Page 14 Adv. W17 HTP fuel design uses total of [
] in a cage design whereas Mark-BW fuel design uses total of [
]. This makes the Adv. W17 HTP fuel cage design at least as strong as Mark-BW fuel cage design.
It can be concluded that the changes to the design parameters result in an Adv. W17 HTP fuel structure that is at least as strong as the Mark-BW fuel design. Therefore, the number of fuel rods damaged from a fuel assembly drop for an Adv. W17 HTP fuel assembly is expected to be bounded by the Mark-BW design.
3.2.2 AREVA Response - Radiological The Alternative Source Term methodology was implemented for the Fuel Handling Accident scenario only. The current licensing basis described in SQN UFSAR Section 15.5.6 and Table 15.5.6-1 for the fuel handling accident assumes a fuel assembly drop onto the fuel transfer pit floor resulting in the failure of 100% of the fuel rods in the fuel assembly dropped and a rod internal pressure of 1200 psi at spent fuel pool conditions after 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> of decay.
The HTP fuel assembly is designed with a welded cage and contains Intermediate Flow Mixing Grids (IFMs) constituting a more robust structural design than the Mark-BW fuel assembly design. Therefore, for the HTP fuel assembly design fewer fuel rods are expected to fail due to a fuel assembly drop within containment in the fuel transfer pit than the analysis of record. However, for conservatism 100% of the fuel rods are assumed to fail due to the fuel assembly drop inside containment.
As stated in Section 3.2.1 of this report, the HTP fuel rod design is identical to the Mark-BW fuel rod. Section 2.3, Table 2-2 of AREVA Report ANP-2986P Revision 003 shows that the back fill pressure is also identical, with the fuel rod internal pressure limits met in accordance with BAW-1 0183PA per Table 2-8 of AREVA Report ANP-2986P Revision 003. Therefore, rod internal pressure for the HTP at spent fuel pool conditions would be identical to that of the Mark-BW fuel. Cycle-specific affects on rod internal pressure such as burnup and enrichment are evaluated as part of the reload analyses to ensure that the rod internal pressure is less than 1200 psig.
Therefore, there are no changes to the radiological DBA analyses or radiological consequence of the DBA as a result of the proposed HTP Fuel amendment.
AREVA NP Inc.
A AREVA ANP-3053(NP)
Revision 0 Sequoyah HTP Fuel Transition - NRC RAIs and Responses Page 15 4.0 References None.
AREVA NP Inc.
ENCLOSURE 3 Sequoyah Nuclear Plant, Units I and 2 AREVA NP Affidavit Attached is the affidavit supporting the request to withhold the proprietary information included in Enclosure 1 from the public.
AFFIDAVIT COMMONWEALTH OF VIRGINIA )
) ss.
CITY OF LYNCHBURG )
- 1. My name is Gayle F. Elliott. I am Manager, Product Licensing, for AREVA NP Inc. (AREVA NP) and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary. I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA NP information contained in the report ANP-3053(P), Revision 0, entitled "Sequoyah HTP Fuel Transition - NRC RAIs and Responses," dated November 2011 and referred to herein as "Document." Information contained in this Document has been classified by AREVA NP as proprietary in accordance with the policies established by AREVA NP for the control and protection of proprietary and confidential information.
- 4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA NP and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.
- 5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is
requested qualifies under 10 CFR 2.390(a)(4) "Trade secret and commercial or financial information."
- 6. The following criteria are customarily applied by AREVA NP to determine whether information should be classified as proprietary:
(a) The information reveals details of AREVA NP's research and development plans and programs or their results.
(b) Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.
(c) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for AREVA NP.
(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability.
(e) The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP.
The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b) and 6(c) above.
- 7. In accordance with AREVA NP's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA NP policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
- 9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.
SUBSCRIBED before me this_ _
day of 2011.
Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/14 Reg. # 7079129 SHERRY L. MCFADEN Notary Public Commonwealth of Virginia 7079129 My Commission Expires Oct 31, 2014