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Category:Letter
MONTHYEARBVY 24-005, Report of Investigation Pursuant to 10 CFR 20, Appendix G2024-01-30030 January 2024 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 24-004, Report of Investigation Pursuant to 10 CFR 20, Appendix G2024-01-23023 January 2024 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 24-003, Nuclear Onsite Property Damage Insurance2024-01-0404 January 2024 Nuclear Onsite Property Damage Insurance BVY 24-001, Pre-Notice of Disbursement from Decommissioning Trust2024-01-0202 January 2024 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-030, Report of Investigation Pursuant to 10 CFR 20, Appendix G2023-12-20020 December 2023 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 23-029, Proof of Financial Protection2023-12-12012 December 2023 Proof of Financial Protection BVY 23-028, Pre-Notice of Disbursement from Decommissioning Trust2023-11-28028 November 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-027, Report of Investigation Pursuant to 10 CFR 20, Appendix G2023-11-21021 November 2023 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 23-026, Report of Investigation Pursuant to 10 CFR 20, Appendix G2023-11-13013 November 2023 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 23-025, Pre-Notice of Disbursement from Decommissioning Trust2023-11-0202 November 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-023, License Amendment Request Addition of License Condition 3.K, License Termination Plan; Proposed Change No. 3172023-10-10010 October 2023 License Amendment Request Addition of License Condition 3.K, License Termination Plan; Proposed Change No. 317 IR 07200059/20234012023-10-0505 October 2023 Independent Spent Fuel Storage Installation Security Inspection Report 07200059/2023401 BVY 23-022, Pre-Notice of Disbursement from Decommissioning Trust2023-08-23023 August 2023 Pre-Notice of Disbursement from Decommissioning Trust IR 05000271/20230012023-08-15015 August 2023 Northstar Nuclear Decommissioning Company, Llc., Vermont Yankee Nuclear Power Station, - NRC Inspection Report 05000271/2023001 BVY 23-021, Report of Investigation Pursuant to 10 CFR 20, Appendix G2023-08-0202 August 2023 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 23-020, Pre-Notice of Disbursement from Decommissioning Trust2023-08-0202 August 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-019, Update to 2022 Radiological Effluent Release Report2023-07-24024 July 2023 Update to 2022 Radiological Effluent Release Report BVY 23-018, Update to Nuclear Onsite Property Damage Insurance2023-07-12012 July 2023 Update to Nuclear Onsite Property Damage Insurance BVY 23-017, Pre-Notice of Disbursement from Decommissioning Trust2023-06-29029 June 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-015, Report of Investigation Pursuant to 1O CFR 20, Appendix G2023-06-0505 June 2023 Report of Investigation Pursuant to 1O CFR 20, Appendix G BVY 23-016, 10 CFR 72.48 Report2023-06-0505 June 2023 10 CFR 72.48 Report BVY 23-014, Pre-Notice of Disbursement from Decommissioning Trust2023-05-31031 May 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-013, 2022 Radiological Environmental Operating Report2023-05-10010 May 2023 2022 Radiological Environmental Operating Report BVY 23-011, 2022 Radiological Effluent Release Report2023-05-10010 May 2023 2022 Radiological Effluent Release Report BVY 23-012, Pre-Notice of Disbursement from Decommissioning Trust2023-05-0202 May 2023 Pre-Notice of Disbursement from Decommissioning Trust ML23117A2172023-05-0101 May 2023 Safety Evaluation for Quality Assurance Program Manual Reduction in Commitment BVY 23-009, 2022 Individual Monitoring NRC Form 5 Report2023-04-24024 April 2023 2022 Individual Monitoring NRC Form 5 Report BVY 23-008, Pre-Notice of Disbursement from Decommissioning Trust2023-04-0606 April 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-007, Report of Investigation Pursuant to 10 CFR 20, Appendix G2023-03-29029 March 2023 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 23-006, Status of Decommissioning and Spent Fuel Management Fund for Year Ending 20222023-03-29029 March 2023 Status of Decommissioning and Spent Fuel Management Fund for Year Ending 2022 BVY 23-005, Nuclear Onsite Property Damage Insurance2023-03-13013 March 2023 Nuclear Onsite Property Damage Insurance BVY 23-004, Pre-Notice of Disbursement from Decommissioning Trust2023-03-0202 March 2023 Pre-Notice of Disbursement from Decommissioning Trust ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities IR 05000271/20220022023-02-22022 February 2023 Northstar Nuclear Decommissioning Company, LLC, Vermont Yankee Nuclear Power Station - NRC Inspection Report No. 05000271/2022002 BVY 23-003, Pre-Notice of Disbursement from Decommissioning Trust2023-01-31031 January 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 22-030, Documentary Evidence of Performance Bond2022-12-30030 December 2022 Documentary Evidence of Performance Bond ML22347A2792022-12-21021 December 2022 Independent Spent Fuel Storage Installation Security Inspection Plan Dated December 21, 2022 IR 05000271/20224012022-12-15015 December 2022 NRC Inspection Report No. 05000271/2022401, Northstar Nuclear Decommissioning Company, LLC, Vermont Yankee Nuclear Power Station, Vernon, Vermont (Letter Only) BVY 22-028, Re Proof of Financial Protection2022-11-28028 November 2022 Re Proof of Financial Protection BVY 22-027, Bvy 22-027; Pre-Notice of Disbursement from Decommissioning Trust for Vermont Yankee Nuclear Power Station2022-11-11011 November 2022 Bvy 22-027; Pre-Notice of Disbursement from Decommissioning Trust for Vermont Yankee Nuclear Power Station BVY 22-026, Pre-Notice of Disbursement from Decommissioning Trust2022-10-31031 October 2022 Pre-Notice of Disbursement from Decommissioning Trust ML22273A1492022-10-0404 October 2022 Review of Decommissioning Funding Status 2022 BVY 22-025, Pre-Notice of Disbursement from Decommissioning Trust2022-10-0404 October 2022 Pre-Notice of Disbursement from Decommissioning Trust BVY 22-023, Pre-Notice of Disbursement from Decommissioning Trust2022-09-0101 September 2022 Pre-Notice of Disbursement from Decommissioning Trust BVY 22-022, Report of Investigation Pursuant to 10 CFR 20, Appendix G2022-08-22022 August 2022 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 22-021, Report of Investigation Pursuant to 10 CFR 20, Appendix G2022-08-16016 August 2022 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 22-020, Pre-Notice of Disbursement from Decommissioning Trust2022-08-0101 August 2022 Pre-Notice of Disbursement from Decommissioning Trust IR 05000271/20220012022-08-0101 August 2022 NRC Inspection Report No. 05000271/2022001, Northstar Nuclear Decommissioning Company, LLC, Vermont Yankee Nuclear Power Station, Vernon, Vermont BVY 22-019, Pre-Notice of Disbursement from Decommissioning Trust2022-07-0606 July 2022 Pre-Notice of Disbursement from Decommissioning Trust BVY 22-013, Notification of Revised Decommissioning Cost Estimate2022-06-17017 June 2022 Notification of Revised Decommissioning Cost Estimate 2024-01-04
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML19224A4722019-08-26026 August 2019 VY Report on Status of Decommissioning Funding for Shutdown Reactors Enclosure ML18094B0922018-04-0505 April 2018 Enclosurequest for Additional Information (Letter to B. S. Ford RAI Regarding Entergy Operations, Inc.'S Decommissioning Funding Plan Update for ISFSI Docket Nos.: 72-43, 72-51, 72-1044, 72-07, 72-12, and 72-59) ML18045A8172018-04-0505 April 2018 Request for Additional Information on Vermont Yankee License Transfer Request (License DPR-28, Docket No. 50-271) ML17341A3842017-12-14014 December 2017 Request for Additional Information Regarding License Amendment Request to Change Physical Security Plan to Reflect an ISFSI-Only Configuration ML17313A4312017-11-0303 November 2017 NRC Request for Additional Information Regarding the Request for Direct and Indirect License Transfers from Entergy to Northstar ML17279B1452017-10-24024 October 2017 Request for Additional Information Regarding the License Amendment Request to Change the Emergency Plan and Emergency Action Level Scheme to Reflect an ISFSI-Only Configuration ML17244A0982017-10-12012 October 2017 NRC Request for Additional Information Regarding the Request for Direct and Indirect License Transfers from Entergy to Northstar ML17229B4842017-08-16016 August 2017 Request for Supplemental Documentation to Support Review of the Physical Security Plan ML16090A0292016-04-0505 April 2016 Request for Additional Information Related to Proposed Changes to Quality Assurance Program Manual, Vermont Yankee Nuclear Power Station ML16077A3452016-03-22022 March 2016 Request for Additional Information Related to 10 CFR 20.2002 Alternate Waste Disposal Request For Vermont Yankee Nuclear Power Station (CAC No. L53116) ML16069A0952016-03-0303 March 2016 Request for 20.2002 Disposal, Request for Additional Information CNRO-2015-00008, Responses to NRC Request for Additional Information Regarding Change in Corporate Form of Entergy Nuclear Holding Company2015-02-18018 February 2015 Responses to NRC Request for Additional Information Regarding Change in Corporate Form of Entergy Nuclear Holding Company ML14318A4002014-12-17017 December 2014 Vermont Yankee Nuclear and Big Rock Point - Request for Additional Information Regarding Change in Corporate Form of Entergy Nuclear Holding Company (Tac Nos. MF3218 - MF3221) ML14289A3942014-11-21021 November 2014 Redacted, Request for Additional Information, Review of Revision 14 to the Physical Security Plan, Safeguards Contingency Plan, and Training and Qualification Plan Pursuant to 10 CFR 50.54(p)(2) BVY 14-069, Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E - Supplement 22014-10-21021 October 2014 Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E - Supplement 2 ML14192A8352014-08-19019 August 2014 Request for Additional Information, Exemption from 10 CFR 50.47 and Appendix E to Allow Reduced Emergency Plan Requirements and Revise Radiological Emergency Response Plan Consistent with Permanently Defueled Reactor ML14231A0172014-08-13013 August 2014 Technical Specifications Proposed Change No. 309, Defueled Technical Specifications and Revised License Conditions for Permanently Defueled Condition - Supplement 4 ML14163A5902014-07-0101 July 2014 Request for Additional Information, Round 2, Amendment Request to Revise Site Emergency Plan for Permanently Defueled Condition to Reflect Change in On-Shift Staffing and Emergency Response Staffing ML14115A0292014-05-0505 May 2014 Request for Additional Information Regarding License Amendment Request for Emergency Plan Change ML14024A0412014-01-29029 January 2014 Request for Additional Information Regarding Entergy Request for Rescission of and Scheduler Relief from Order EA-13-109 on Reliable Hardened Containment Vents ML13311B0772013-11-26026 November 2013 Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation ML13304B4182013-11-0101 November 2013 Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns ML13218A0122013-08-0606 August 2013 E-mail from R.Guzman to P.Couture, Request for Additional Information - Relief Requests ISI-04 Dated March 27, 2013 - Bvy 13-018 ML13205A1762013-07-24024 July 2013 Supplemental Request for Additional Information - Relief Request ISI-03 ML13179A4622013-07-0505 July 2013 Entergy Nuclear Operations, Inc., Decommissioning Funding Status Report Request for Additional Information Regarding the Decommissioning Funding Status Report ML13186A1142013-07-0505 July 2013 Email from R. Guzman to P.Couture Request for Additional Information - Relief Request ISI-02, Application of Code Case N-716 ML13165A2792013-06-20020 June 2013 Request for Additional Information Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (NRC Order EA-12-051) ML13163A2582013-06-17017 June 2013 Request for Additional Information - Response to March 12, 2012, Commission Order EA-12-049 to Modify Licenses Requirements for Mitigating Strategies for Beyond Design Basis External Events ML13149A2652013-05-28028 May 2013 Email from R. Guzman to P. Couture - Request for Additional Information Relief Request ISI-05 (TAC No. MF1194) -Updated RAI-2 (Revision 2) ML13130A0562013-05-0909 May 2013 E-mail from R.Guzman to P.Couture Request for Additional Information - Relief Request RR-P02 Dated February 1, 2013 - Bvy 13-008 ML13130A0472013-05-0808 May 2013 Email from R.Guzman to P.Couture Request for Additional Information - Relief Requests ISI-01 and ISI-03 Dated March 27, 2013 - Bvy 13-018 (TAC Nos. MF1196/1198) ML13119A2462013-04-29029 April 2013 Request for Additional Information, E-mail from R. Guzman to P. Couture Relief Request ISI-05 ML13097A0032013-04-0808 April 2013 Request for Additional Information Change to 10 CFR 50.63 Licensing Basis - SBO EDG ML13087A3922013-04-0202 April 2013 Request for Additional Information to Support the Review of Relief Request RR-P-01 ML13081A7522013-03-22022 March 2013 Email from R.Guzman to P.Couture Request for Additional Information for License Amendment Request to Change 10 CFR 50.63 Licensing Basis ML13077A2062013-03-20020 March 2013 Request for Additional Information Regarding 10 CFR 50.33 Financial Qualification Review ML13067A0912013-03-0808 March 2013 Request for Additional Information Change to TS 3.3.B Inoperable Control Rods ML13050A4692013-02-21021 February 2013 Request for Additional Information Change to Licensing Basis for Station Blackout Diesel Generator ML13018A4592013-01-15015 January 2013 Request for Additional Information - E-mail from R.Guzman to P.Couture Relief Request ISI-PT-02 Alternative to the System Leakage Test for Rv Head Flange Leakoff Lines ML1228403332012-10-10010 October 2012 Request for Additional Information - E-mail from R. Guzman to P. Couture License Amendment Request to Revise License Condition 3.P and 3.Q ML12278A3862012-10-0404 October 2012 ANO 1 & 2, Big Rock, FitzPatrick, GGNS, Indian Point 1, 2, and 3, Palisades, Pilgrim, RBS, Vermont Yankee, and Waterford, Request for Additional Information, Round 2, Amendment Request to Revise QA Program Manual and Staff Qualification TSs ML13070A2032012-09-17017 September 2012 Email from R. Guzman to R. Wanczyk and P. Outure Draft Request for Additional Information - LAR to Revise License Renewal Commitments One Time Inspection Program ML13070A1742012-09-10010 September 2012 Email from R. Guzman to R. Wanczyk Draft Request for Additional Information - LAR to Revise License Renewal Commitments Selective Leaching Program ML12122A8072012-05-0707 May 2012 Request for Additional Information Regarding Physical Security, Safeguards Contingency and Training and Qualification Plan, Revision 11 ML1300902982012-04-10010 April 2012 E-mail from J. Kim to J. Devincentis Request for Additional Information - Rod Worth Minimizer Bypass Allowance Amendment ML1209604492012-04-0505 April 2012 ANO 1 & 2, Big Rock, FitzPatrick, GGNS, Indian Point 1, 2 & 3, Palisades, Pilgrim, RBS, Vermont Yankee, and Waterford - Request for Additional Information, Revise Quality Assurance Program Manual and Staff Qualification Technical Specificat ML12056A0482012-03-12012 March 2012 Enclosure 2 - Recommendation 2.1: Flooding ML12056A0502012-03-12012 March 2012 Enclosure 4 - Recommendation 2.3: Flooding ML12056A0512012-03-12012 March 2012 Enclosure 5 - Recommendation 9.3: Emergency Preparedness ML12056A0492012-03-12012 March 2012 Enclosure 3 - Recommendation 2.3: Seismic 2019-08-26
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UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 March 20, 2013 Site Vice President Entergy Nuclear Operations, Inc. Vermont Yankee Nuclear Power Station P.O. Box 250 Governor Hunt Road Vernon, VT 05354 VERMONT YANKEE NUCLEAR POWER STATION -REQUEST FOR ADDITIONAL INFORMATION REGARDING 10 CFR 50.33 FINANCIAL QUALIFICATION REVIEW (TAC NO. MF0947)
Dear Sir or Madam:
As posted on the U.S. Securities and Exchange Commission (SEC) Electronic Data Gathering, Analysis, and Retrieval system, Entergy Nuclear Operations, Inc. filed its quarterly 10-Q report dated November 6, 2012. The document is also captured in the Agencywide Documents and Access Management System at Accession no. ML 13072A 156. Title 10 of the Code of Federal Regulations (10 CFR) Section 50.33(f)(5) states that the Commission may request an established entity or newly-formed entity to submit additional or more detailed information respecting its financial arrangements and status of funds if the Commission considers this information appropriate.
This may include information regarding a licensee's ability to continue the conduct of the activities authorized by the license and to decommission the facility.
The Nuclear Regulatory Commission staff is reviewing the information provided in your quarterly10-Q SEC filing and has determined that more detailed information is needed to support its financial qualification review. Enclosed is the NRC staff's request for additional information (RAI). The RAI was discussed with your staff on February 14, 2013, and it was agreed that your response would be provided within 45 days of the date of this letter. Sincerely, Richard V. Guzman, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-271
Enclosure:
As stated cc w/encl: Distribution via Listserv REQUEST FOR ADDITIONAL INFORMATION FOR NRC STAFF EVALUATION OF LICENSEE'S FINANCIAL QUALIFICATION IN ACCORDANCE WITH 10 CFR 50.33 ENTERGY NUCLEAR OPERATIONS, INC. VERMONT YANKEE NUCLEAR POWER STATION DOCKET NO. 50-271 The request for additional information (RAI) is related to the financial qualifications requirements of 10 CFR 50.33 for the facility.
Regulatory Basis Title 10 of the Code of Federal Regulations (10 CFR) Section 50.33(f) states: Except for an electric utility applicant for a license to operate a utilization facility of the type described in § 50.21 (b) or § 50.22, information sufficient to demonstrate to the Commission the financial qualification of the applicant to carry out, in accordance with regulations in this chapter, the activities for which the permit or license is sought. Vermont Yankee Nuclear Power Station (Vermont Yankee) does not meet the definition of an electric utility per 10 CFR 50.2. Per the guidance in NUREG-1577, Revision 1, "Standard Review Plan on Power Reactor Licensee Financial Qualifications and Decommissioning Funding Assurance" (Agencywide Documents Access and Management System (ADAMS) Accession no. ML013330264), the NRC does not systematically review its power reactor licensees once it has issued an operating license, other than for transfers discussed in Section 1I1.1.e. However, section 50.33(f)(5) states: The Commission may request an established entity or newly-formed entity to submit additional or more detailed information respecting its financial arrangements and status of funds if the Commission considers this information to be appropriate.
This may include information regarding a licensee's ability to continue the conduct of the activities authorized by the license and to decommission the facility.
The NRC has used this provision only in limited situations and normally will not require licensees, including those that are not "electric utilities," to report on their financial qualifications at specified intervals.
However, reviewers have and will continue to conduct general follow-up reviews of all licensees by screening trade and financial press reports, and other sources of information.
Reviewers will use this information to determine whether to recommend any additional NRC action, including requests for additional information and the assignment of additional inspection resources to monitor the adequacy of plant safety performance.
Enclosure Vermont Yankee Impairment Vermont Yankee's quarterly 10-Q filing to the U.S. Securities and Exchange Commission (SEC) on November 6,2012, which was posted on the SEC's Electronic Data Gathering, Analysis, and Retrieval (EDGAR) system (and captured in the ADAMS at Accession no. ML 13072A156) stated the following:
Impairment Because of the uncertainty regarding the continued operation of Vermont Yankee, Entergy has tested the recoverability of the plant and related assets each quarter since the first quarter 2010. The determination of recoverability is based on the probability-weighted undiscounted net cash flows expected to be generated by the plant and related assets. Projected net cash flows primarily depend on the status of the pending legal and state regulatory matters, as well as projections of future revenues and expenses over the remaining life of the plant. Prior to the first quarter 2012, the probability-weighted undiscounted net cash flows exceeded the carrying value of the Vermont Yankee plant and related assets. The decline, however, in the overall energy market and the projected forward prices of power as of March 31, 2012, which are significant inputs in the determination of net cash flows, resulted in the probability-weighted undiscounted future cash flows being less than the asset group's carrying value. Entergy performed a fair value analysis based on the income approach, a discounted cash flow method, to determine the amount of impairment.
The estimated fair value of the plant and related assets at March 31,2012 was $162.0 million, while the carrying value was $517.5 million. Therefore, the assets were written down to their fair value and an impairment charge of $355.5 million ($223.5 million after-tax) was recognized.
Because an impairment is an indication that there has been a change in the cashflow and/or revenues generated by Vermont Yankee as determined by the company through periodic assessments, the NRC staff requires further information to insure that the licensee is meeting NRC requirements for financial qualifications.
Please provide updated proformas for the operations and maintenance and cashflow for Vermont Yankee for the period of 2013-2018.
March 20, 2013 Site Vice President Entergy Nuclear Operations, Inc. Vermont Yankee Nuclear Power Station P.O. Box 250 Governor Hunt Road Vernon, VT 05354 VERMONT YANKEE NUCLEAR POWER STATION -REQUEST FOR ADDITIONAL INFORMATION REGARDING 10 CFR 50.33 FINANCIAL QUALIFICATION REVIEW (TAC NO. MF0947)
Dear Sir or Madam:
As posted on the U.S. Securities and Exchange Commission (SEC) Electronic Data Gathering, Analysis, and Retrieval system, Entergy Nuclear Operations, Inc. filed its quarterly 10-Q report dated November 6,2012. The document is also captured in the Agencywide Documents and Access Management System at Accession no. ML 13072A 156. Title 10 of the Code of Federal Regulations (10 CFR) Section 50.33(f)(5) states that the Commission may request an established entity or newly-formed entity to submit additional or more detai/ed information respecting its financial arrangements and status of funds if the Commission considers this information appropriate.
This may include information regarding a licensee's ability to continue the conduct of the activities authorized by the license and to decommission the facility.
The Nuclear Regulatory Commission staff is reviewing the information provided in your quarterly10-Q SEC 'filing and has determined that more detailed information is needed to support its financial qualification review. Enclosed is the NRC staff's request for additional information (RAI). The RAI was discussed with your staff on February 14, 2013, and it was agreed that your response would be provided within 45 days of the date of this letter. Sincerely, Ira! Richard V. Guzman, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-271
Enclosure:
As stated cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC RidsNrrPMVermontYankee RidsNrrLAKGoldstein RidsNrrDorlLpl1-1 LPLI-1 RtF RidsOGCRp RidsRgn 1 MailCenter RidsNrrDirslfiab A. Simmons, NRR RidsNrrAcrsAcnw&mMailCenter ADAMS Accession No'.. ML 13077A206
- Concurrence via NRR-088 OFFICE LPL1-lIPM LPL 1*1/LA IFIAB/BC(A)*
LPL 1-1/BC(A)
NAME RGuzman KGoldstein ASimmons SMeighan DATE 3/18113 3/20/13 3/18/13 3/20/13 OFFICIAL RECORD COpy I