ML13168A219

Monticello Nuclear Generating Plant - Issuance of Amendment No. 174 to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-484, Revision 0, Use of TS 3.10.1 for Scram Time Testing Activities (TAC No. MF0362)

ML13168A219
Person / Time
Site:	Monticello
Issue date:	08/09/2013
From:	Beltz T A Plant Licensing Branch III
To:	Schimmel M A Northern States Power Co
Beltz T A
References
TAC MF0362
Download: ML13168A219 (13)

Text

UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 August 9, 2013 Mr. Mark A. Schimmel Site Vice President Monticello Nuclear Generating Plant Northern States Power Company -Minnesota 2807 West County Road 75 Monticello, MN 55362-9637 MONTICELLO NUCLEAR GENERATING PLANT -ISSUANCE OF AMENDMENT NO. 174 TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE (TSTF) TRAVELER TSTF-484, REVISION 0, "USE OF TS 3.10.1 FOR SCRAM TIME TESTING ACTIVITIES (TAC NO. MF0362) Dear Mr. Schimmel: The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 174 to Renewed Facility Operating License No. DPR-22 for the Monticello Nuclear Generating. Plant (IVINGP). The amendment consists of changes to the technical specifications (TSs) in response to your application dated' December 6, 2012. . The amendment approves a revision to the MNGP TS Section 3.10.1, Inservice Leak and Hydrostatic Testing Operation." The proposed change would revise Limiting Condition for Operation 3.10.1 and associated TS Bases to expand its scope to include provisions for temperature excursions greater than 212 of as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4. The change is consistent with NRC-approved TSTF-484, Revision 0, "Use of TS 3.10.1 for Scram Tim'e Testing Activities." A copy of our related safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice. Sincerely, Terry A. Beltz, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating ReaCtor Licensing Office of Nuclear Reactor Regulation Docket No. 1.. Amendment No. 174 to 2. Safety Evaluation cc w/encls: Distribution via ListServ UNITED NUCLEAR REGULATORY . WASHINGTON, D.C. 20555-0001 NORTHERN STATES POWER DOCKET NO. MONTICELLO NUCLEAR GENERATING AMENDMENT TO RENEWED FACILITY OPERATING Amendment No. 174 License No. DPR-22. The U.S. Nuclear Regulatory Commission (the Gommission) has found that: The application for amendment by Northern States Power Company (NSPM, the licensee), dated December 6,2012, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.2 of Renewed Facility Operating License No. DPR-22 is hereby amended to read as follows: Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 174, are hereby incorporated in the license. NSPM shall operate the facility in accordance with the Technical Specifications.

-2 This license amendment is effective as of its date of issuance and shall be implemented within 120 days frem the date of issuance. FOR THE NUCLEAR REGULATORY COMMISSION cfCAZ.) Robert D. Carlson, Chief Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Attachment: Changes to Renewed Facility Operating License DPR-22 and Technical Specifications Date of Issuance: August 9, 2013 ATTACHMENT TO LICENSE AMENDMENT NO. RENEWED FACILITY OPERATING LICENSE NO. DOCKET NO. Replace the following page of Renewed Facility Operating License DPR-22 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change. REMOVE INSERT 3 3 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain a marginal line indicating the area of change. REMOVE INSERT 3.10.1-1 3.10.1-1

-3 Pursuant to the Act and 10 CFR Part 70, NSPM to receive, possess, and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operations, as described in the Final Safety Analysis Report, as supplemented and amended, and the licensee's filings dated August 16, 1974 (those portions dealing with handling of reactor fuel) and August 17, 1977 "(those portions dealing with fuel assembly storage capacity); .. Pursuant to the Act and 10 CFR Parts 30, 40 and 7.0, NSPM to receive. possess, and use at any time any byproduct. source and" special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation calibration, and as fission detectors in amounts as required; Pursuant to the Act and 10 CFR Parts 30. 40 and 70, NSPM to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and Pursuant to the Act and 10 CFR Parts 30 and 70, NSPM to possess, but not separate, such byproduct and special nuclear material as may be produced by operation of the facility. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission, now or hereafter in effect; and is subject to the additional conditions specified or incorporated below: Maximum Power Level NSPM is authorized to operate the facility at steady state reactor core power levels not in excess of 1775 megawatts (thermal). Technical Specifications The Technical Specifications contained in Appendix A. as revised through Amendment No. 174, are hereby incorporated in the license. NSPM shall operate the facility in accordance with the Technical Specifications. Physical Protection NSPM 'shall implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and'Search , Renewed License No. DPR-22 Amendment No. 4-tJ:::H:tl174 Inservice Leak and Hydrostatic Testing Operation 3.10.1 SPECIAL OPERATIONS 3.10.1 Inservice Leak and Hydrostatic Testing Operation LCO 3.10.1 APPLICABI LlTY: The average reactor coolant temperature specified in Table 1.1-1 for MODE 4 may be changed to "NA," and operation considered not to be in MODE 3; and the requirements of LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System -Cold Shutdown," may be suspended, to allow reactor coolant temperature> 212°F provided the specific activity of the reactor coolant is ::;; 0.02 J!Ci/gm DOSE -EQUIVALENT 1-131: For performance of an inservice leak or hydrostatic test, As a consequence of maintaining adequate pressure for inservice leak or hydrostatic test, As a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, provided the following MODE 3 LCOs are met: LCO 3.3.6.2, "Secondary Containment Isolation Instrumentation," Functions 1, 3, and 4 of Table 3.3.6.2-1; LCO 3.6.4.1, "Secondary Containment"; LCO 3.6.4.2, 'iSecondary Containment Isolation Valves (SCIVs)"; and LCO 3.6.4.3, "Standby Gas Treatment (SGT) System." MODE 4 with average reactor coolant temperature> 212°F. 3.10.1-1 Amendment No. 446,174 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555"()001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 174 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-22 NORTHERN STATES POWER COMPANY MONTICELLO NUCLEAR GENERATING PLANT DOCKET NO. 50-263 1.0 INTRODUCTION By application to the U.S. Nuclear Regulatory Commission (NRC, the Commission) dated December 6, 2012 (Agencywide Documents Access and Management System (ADAMS)* Accession No. ML 12346A01 0), Northern States Power Company -Minnesota (NSPM), doing business as Xcel Energy,lnc., (the licensee), submitted a license amendment request (LAR) regarding changes to the Monticello Nuclear Generating Plant (MNGP) Technical Specifications (TS). The proposed changes would revise Limiting Condition for Operation (LCO) 3.10.1 and the associated TS Bases to expand its scope to include provisions for temperature excursions greater than 212 OF as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated ir:1 conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4, The licensee states in its application that this change is consistent with NRC-approved Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler; TSTF-484, Revision 0, "Use of TS 3.10.1 for Scram Time Testing Activities." The availability of the TS 3.10.1 revision was announced in the Federal Register(FR) on October 27, 2006 (71 FR 63050), as part of the consolidated line item improvement process (CLlIP). The licensee further states that this LAR has been evaluated and has no impact on the pending Extended Power Uprate and Maximum Extended Load Line Limit Analysis Plus (MELLLA+) LARs currently under NRC review. 2.0 REGULATORY EVALUATION The TSTF-484 allows a licensee to implement LCO 3.10.1 while hydrostatic and leakage testing is being conducted, should average reactor coolant temperature exceeds 200 degrees Fahrenheit CF) during testing. This allowance does not alter current requirements for hydrostatic and leakage testing as required by Appendix G to Title 10 of the Code of Federal Regulations (10 CFR) Part 50.

-2 2.1 Inservice Leak and Hydrostatic Testing The reactor coolant system (RCS) serves as a pressure boundary and also serves to provide a flow path for the circulation of coolant past the fuel. In order to maintain .RCS integrity,Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) requires periodic hydrostatic and leakage testing. Hydrostatic tests are required to be performed once every 10 years and leakage tests are required to be performed each refueling outage. Appendix G to 10 CFR Part 50 states that pressure tests and leak tests of the reactor vessel that are required by Section XI of the ASME Code must be completed before the core is critical. The MNGP is a General Electric bOiling-water reactor (BWRl4) deSigned facility. Standard Technical Specifications (STS) (NUREG-1433), "General Electric Plants, BWRl4, Revision 4," specifies requirements for LCO 3.10.1 which are similar to those stated in the MNGP's TS LCO 3.10.1. The STS LCO was created to allow for hydrostatic and leakage testing to be conducted while in Mode 4 with average reactor coolant temperature greater.than 200°F (212°F in the MNGP TSs), provided certain secondary containment LCOs are met. Regarding compliance with the applicable regulatory requirements, the licensee's application provided the following: 10 CFR 50.36 Technical Specifications 10 CFR 50.36, Technical Specifications provides the regulatory requirements for content required in the TS. As stated in 10 CFR 50.36, the TS include Conditions for Operation (LCO) and Surveillance Requirements (SR) to assure the LCOs are met. The proposed changes to the TS LCOs and SRs for leakage and hydrostatic testing, and scram time testing will continue to meet requirements of 10 CFR The TSTF-484, Rev. 0 Traveler and model Safety Evaluation discuss the regulatory requirements and guidance, including the 10 CFR 50, Appendix General Oesign Criteria (GOC). MNGP was designed largely before the of the 70 General Oesign Criteria (GOC) for Nuclear Power Plant Permits proposed by the Atomic Energy Commission (AEC) for public comment July 1967, and constructed prior to the 1971 publication of the 10 CFR 50, A, GOC. As such, MNGP was not licensed to the Appendix The MNGP USAR [Updated Safety Analysis Report]. Section 1.2, lists the Oesign Criteria (POC) for the design, construction and operation of the plant. USAR Appendix E provides a plant comparative evaluation to the 70 proposed design criteria. It was concluded that the plant conforms to the intent of the The applicable GOC and POC are POC 1.2.2 -Reactor Core The reactor core is designed so that control rod action, with the maximum control rod fully withdrawn and unavailable for use, is capable of bringing

-3 reactor core subcritical and maintaining it so from any power level in the operating cycle. Redundant backup reactivity shutdown capability is provided independent of normal reactivity provisions. This system has the capability, with adequate margin, to shut down the reactor from any power level in the operating cycle. Per the licensee, applicable 70 Draft AEC General Design Criteria (AEC-GDC) are as follows: . . Criterion 6 -Reactor Core Design (Category A) The reactor core shall be designed to function throughout its design lifetime, without exceeding acceptable fuel damage limits which have been stipulated and justified. The core design, together with reliable process and decay heat removal systems, shall provide for this capability under all expected conditions of normal operation with appropriate margins for uncertainties and for transient situations which can be anticipated, including the effects of the loss of power to recirculation pumps, tripping out of a turbine generator set, isolation of the reactor from its primary heat sink, and loss of off-site power. Criterion 27 -Redundancy of Reactivity Control (Cateqory A) At least two independent reactivity control systems, preferable of different principles, shall be provided. Criterion 28 -Reactivity Hot Shutdown Capability (Cateqory A) At least two of the reactivity control systems provided shall independently be capable of making and holding the core subcritical from any hot standby or hot operating condition, including those resulting from power changes, sufficiently fast to prevent exceeding acceptable fuel damage limits. The licensee further states: As discussed in the model Safety Evaluation for TSTF-484, Revision a (71 FR 63050), 10 CFR 50, Appendix A, Criterion 10, states that the reactor core and associated coolant, control, and protection systems shall be designed with. appropriate margin to assure that specified acceptable fuel limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences. The scram reactivity used in design basis accidents (DBA) and transient analyses is based on an assumed control rod scram time. This modification to LCO 3.10.1 does not alter the means of compliance with Criterion 10 of Appendix A to 10 CFR 50. The licensee evaluated the proposed changes against the applicable regulatory requirements and acceptance criteria, and stated that the proposed TS changes will continue to assure that the design requirements and acceptance criteria for MNGP are met.

2.2 Control Rod Scram Time Testing Control rods function to control reactor power level and to provide adequate excess negative reactivity to shut down the reactor from any normal operating or accident condition at any time during core life. The control rods are scrammed by using hydraulic pressure exerted by the control rod drive (CRD) system. Criterion 10 of Appendix A to 10 CFR Part 50 states that the reactor core and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that specified acceptable fuel limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences. The scram reactivity used in DBA and transient analyses is based on an assumed control rod scram time. NUREG-1433 currently contains an SR to conduct scram time testing when certain conditions are met in order to ensure that Criterion 10 of Appendix A to 10 CFR Part 50 is satisfied. STS and MNGP's SRs 3.1.4.1 and 3.1.4.4 require scram time testing to be conducted following a shutdown greater than' 120 days, and scram time testing to be conducted following work on the CRD system or following fuel movement within the affected core cell, respectively. Both SRs must be performed at reactor steam dome pressure greater than or equal to 800 pounds per square inch gauge (psig) and prior to exceeding 40 percent rated thermal power (RTP). TSTF-484 would modify LCO 3.10.1 to allow SRs 3.1.4.1 and 3.1.4.4 to be conducted in Mode 4 with average reactor coolant temperature greater than 212°F. Scram time testing would still be performed in accordance with LCO 3.10.4, "Single Control Rod Withdrawal-Cold Shutdown." This modification does not alter the means of compliance with Criterion 10 of Appendix A to 10 CFR Part 50. 3.0 TECHNICAL EVALUATION The existing provisions of MNGP LCO 3.10.1 allow for hydrostatic and leakage testing to be conducted in Mode 4 with average RCS temperature greater than 212°F, while imposing Mode 3 secondary containment requirements. Under the current provision, LCO 3.10.1 would have to be implemented prior to hydrostatic and leakage testing. If LCO 3.10.1 was not implemented prior to the subject testing, then the testing would have to be terminated if average reactor coolant temperature exceeded 212°F during the conduct of the test. TSTF-484 modifies,LCO 3.10,1 to allow a licensee to implement LCO 3.10.1 while hydrostatic and leakage testing is being conducted, should average RCS temperature exceeds 212°F during testing. The modification will allow completion of testing without the potential for interrupting the test in order to (a) reduce reactor vessel pressure, (b) cool the RCS, and (c) restart the test below 212°F. Since the current LCO 3.10.1 allows testing, to be conducted while in Mode 4 with average RCS coolant temperature greater than 212°F, the proposed change does not introduce any new operational conditions beyond those currently allowed. MNGP SRs 3.1.4.1 and 3.1.4.4 require that control rod scram time be tested at reactor steam dome pressure greater than or equal to 800 psig and before exceeding 40 percent RTP. Performance of control rod scram time testing is typically scheduled concurrent with inservice leak or hydrostatic testing while the RCS is pressurized. Because of the number of control rods that must be tested, it is possible for the inservice leak or hydrostatic test to be completed prior to completing the scram time test. Under existing provisions, scram time testing must be

-5 suspended if the testing cannot be completed during the LCO 3.10.1 required inservice leak or hydrostatic test. Additionally, if LCO 3.10.1 is not implemented and average RCS temperature exceeds 212°F while performing the scram time test, scram time testing must also be suspended. In both situations, scram time testing is resumed during startup and is completed prior to exceeding 40 percent RTP. The allowance provided by TSTF-484, enables the licensee to complete scram time testing initiated during inservice leak or hydrostatic testing. As stated earlier, since the current LCO 3.10.1 allows testing to be conducted in Mode 4 with average RCS temperature greater than 212°F, the proposed change does not introduce any new operational conditions beyond those currently allowed. It should be noted that completion of scram time testing prior to reactor criticality and power operations results in a more conservative operating philosophy with attendant potential safety benefits. It is acceptable to perform other testing concurrent with the inservice leak or hydrostatic test provided that this testing can be performed safely and does not interfere with the leak or hydrostatic test. However, it is not permissible to remain in TS 3.10.1 solely to complete such testing following the completion of inservice leak or hydrostatic testing and scram time testing. Since the tests are performed with the reactor pressure vessel (RPV) nearly water solid, at low decay heat values, and near Mode 4 conditions, the stored energy in the reactor core will be very low. Small leaks from the RCS would be detected by inspections before a significant loss of inventory occurred. In addition, two low-pressure emergency core cooling systems (ECCS) injection/spray subsystems are required to be operable in Mode 4 by TS 3.5.2, ECCS . Shutdown. In the event of a large RCS leak, the RPV would rapidly depressurize and allow operation of the low pressure ECCS. The capability of the low pressure ECCS would be adequate to maintain the fuel covered under the low decay heat conditions during these tests. Also, LCO 3.10.1 requires that secondary containment (MNGP TS 3.6.4.1) and standby gas treatment system (MNGP TS 3.6.4.3) remain operable and capable of handling any airborne radioactivity or steam leaks that may occur during performance of testing. 3.1 Variations or Deviations from the TS Changes Described in TSTF-484. Revision 0: In its December 6, 2012, application, the licensee states the following: This application is being made in accordance with the CUIP. NSPM is not proposing variations or deviations from the TS changes described in TSTF-484, Revision 0, or the !\IRC staffs model safety evaluation (SE) published in the Federal Register on October 27, 2006 (71 FR 63050) as part of the CUIP Notice of Availability. The licensee further states: It is noted that the current MNGP TS LCO 3.10.1 varies slightly from the NUREG-1433, Revision 4, Standard Technical Specification, General Electric BWRl4 Plants. IVINGP TS 3.10.1 limits the specific activity of the reactor coolant during inservice leak and hydrostatic testing. MNGP has maintained the reactor coolant specific activity limit consistent with current TS LCO 3.10.1. This variation does not constitute a technical difference from the conclusions of the

-NRC staffs model Safety Evaluation (SE) published on October 27, 2006 (71 FR 63050) as part of the CUIP Notice of Availability that would preclude MNGP from adopting the provisions of TSTF-484, Rev. O. 3.2 Conclusion Based on the above, the NRC staff has determined the proposed change to be acceptable since the protection provided by the normally required Mode 4 applicable LCOs, in addition to the secondary containment requirements required to be met byLCO 3.10.1, minimizes potential consequences in the event of any postulated abnormal event during testing. In addition, the requested modification to LCO 3.10.1 does not create any new modes of operation or operating conditions that are not currently allowed. 4.0 STATE CONSULTATION In accordance with the Commission's regulations, the Minnesota State official was notified of the proposed issuance of the amendment. The State official had no comments. 5.0 ENVIRONMENTAL CONSIDERATION The amendment changes a requirement with respect to the use of facility components located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (78 FR 14132, dated March 4,2013). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment. 6.0 CONCLUSION The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. Principal Contributor: R. P. Grover, NRR Date of issuance: August 9, 2013 August 9, 2013 Site Vice President Monticello Nuclear Generating Plant Northern States Power Company -Minnesota 2807 West County Road 75 Monticello, MN 55362-9637 MONTICELLO NUCLEAR GENERATING PLANT -ISSUANCE OF AMENDMENT NO. 174 TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE (TSTF) TRAVELER TSTF-484, REVISION 0, "USE OF TS 3.10.1 FOR SCRAM TIME TESTING ACTIVITIES (TAC NO. MF0362) Dear Mr. Schimmel: The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 174 to Renewed Facility Operating License No. DPR-22 for the Monticello Nuclear Generating Plant (MNGP). The amendment consists of changes to the technical specifications (TSs) in response to your application dated December 6, 2012. The amendment approves a revision to the MNGP TS Section 3.10.1, Inservice Leak and Hydrostatic Testing Operation." The proposed change would revise Limiting Condition for Operation 3.10.1 and associated TS Bases to expand its scope to include provisions for temperature excursions greater than 212 OF as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4. The change is consistent with TSTF-484, Revision 0, "Use of TS 3.10.1 for Scram Time Testing Activities." A copy of our related safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice. Sincerely, IRAJ Terry A. Beltz, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-263 Enclosures: 1. Amendment No. 174 to DPR-22 2. Safety Evaluation cc Distribution via ListServ DISTRIBUTION: PUBLIC LPL3-1 rtf RidsNrrDorlLpl3-1 Resource RidsNrrDssStsb Resource RidsNrrPMMonticelio Resource RidsNrrLASRohrer Resource RidsAcrsAcnw_MailCTR Resource RidsRgn3MailCenter Resource RidsNrrDorlDpr Resource RGrover, NRR .ADA ML13168A219

• S lY memo dMS Accession Na ety eva uabon transmltte db ated 03/04/13 OFFICE LPL3-1/PM LPL3-1/LA STSB/BC

• LPL3-1/BC LPL3-1/PM NAME TBeltz SRohrer RElliott RCarlson /SWall for TBeltz DATE 06/17/13 06/27/13 03/04/13 08/08/13 08/09/13 OFFICIAL RECORD COPY