IR 05000133/2017003

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Inspection Report 05000133/2017003
ML17285A546
Person / Time
Site: Diablo Canyon, Humboldt Bay
Issue date: 10/19/2017
From: Ray Kellar
Division of Nuclear Materials Safety IV
To: Halpin E
Pacific Gas & Electric Co
R. Browder
References
IR 2017003
Download: ML17285A546 (15)
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Text

UNITED STATES ber 19, 2017

SUBJECT:

HUMBOLDT BAY POWER PLANT - NRC INSPECTION REPORT 05000133/2017-003

Dear Mr. Halpin:

This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection conducted on September 26-28, 2017, at the Humboldt Bay Power Plant, Unit 3 facility, located near Eureka, California. The purpose of the inspection was to determine whether decommissioning activities were being conducted safely and in conformance with NRC requirements and the conditions of your license. The NRC inspectors discussed the results of this inspection with Mr. J. Salmon and other members of your staff during an onsite final exit meeting conducted on September 28, 2017.

The inspection results are documented in the enclosure to this inspection report.

The NRC inspection examined activities conducted under your license as they relate to public health and safety, the common defense and security, to confirm compliance with the Commissions rules and regulations, and with the conditions of your license. Within these areas the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel. Specifically, the inspectors reviewed the decommissioning activities at the site, the final status survey program, and the transportation of radioactive materials program. No violations were identified and no response to this letter is required.

In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter, its enclosure, and your response if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRCs Website at http://www.nrc.gov/reading-rm/adams.html.

To the extent possible, your response should not include any personal privacy or proprietary, information so that it can be made available to the Public without redaction. If you have any questions regarding this inspection report, please contact Rachel Browder at 817-200-1452, or the undersigned at 817-200-1191.

Sincerely,

/RA/

Ray L. Kellar, P.E., Chief Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Docket: 50-133 License: DPR-7 Enclosure:

Inspection Report 05000133/2017-003; w/Attachment: Supplemental Information

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No. 05000133 License No. DPR-7 Report No. 05000133/2017-003 Licensee: Pacific Gas & Electric Company Facility: Humboldt Bay Power Plant, Unit 3 Location: 1000 King Salmon Avenue Eureka, California 95503 Dates: September 26 - 28, 2017 Inspectors: Rachel S. Browder, C.H.P., Senior Health Physicist Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Stephanie G. Anderson, Health Physicist Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Approved By: Ray L. Kellar, P.E., Chief Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Enclosure

EXECUTIVE SUMMARY Humboldt Bay Power Plant, Unit 3 NRC Inspection Report 05000133/2017-003 This U.S. Nuclear Regulatory Commission (NRC) inspection was a routine, announced inspection of decommissioning activities being conducted at the Humboldt Bay Power Plant, Unit 3 facility. In summary, the licensee was conducting these activities in accordance with site procedures, license requirements, and applicable NRC regulations.

Organization, Management, and Cost Controls at Permanently Shutdown Reactors

  • The licensee had implemented an organization in accordance with the License Termination Plan (LTP) Revision 1 and conducted its decommissioning activities in a reasonable manner consistent with the scheduled activities. (Section 1.2)

Decommissioning Performance and Status Review at Permanently Shutdown Reactors

  • The licensee was implementing the decommissioning and dismantlement activities in accordance with the LTP Revision 1. In addition, the licensee was implementing industrial safety precautions, applying safety communications, and utilizing personal protection equipment to minimize industrial safety hazards. (Section 2.2)

Occupational Radiation Exposure

  • The licensee adequately assessed its 2016 annual radiation protection program and was implementing the radiation protection training program in accordance with license requirements. (Section 3.2)

Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors

  • The licensing was conducting final status surveys of areas in accordance with regulatory requirements and the LTP Revision 1, and subsequently isolating and controlling the final status survey areas as required by the LTP Revision 1. (Section 4.2)

Solid Radioactive Waste Management and Transportation of Radioactive Materials

  • The licensee continued to process, package and ship radioactive wastes in accordance with regulatory requirements. (Section 5.2)

Report Details Summary of Plant Status On July 2, 1976, Humboldt Bay Power Plant (HBPP), Unit 3 was shut down for its annual refueling outage and to conduct seismic modifications. In 1983, an updated economic analysis indicated that restarting Unit 3 would probably not be cost-effective, and in June 1983, the Pacific Gas &

Electric Company (licensee) announced its intention to decommission the HBPP. On July 16, 1985, the U.S. Nuclear Regulatory Commission (NRC) issued Amendment No. 19 to the HBPP Unit 3 Operating License to change the status to possess-but-not-operate and the plant was placed into a SAFSTOR status. This status is a method of decommissioning in which a nuclear facility is placed and maintained in a condition that allows the facility to be safely stored and subsequently decontaminated to levels that permit release for unrestricted use.

The transfer of spent fuel from the spent fuel pool to the Independent Spent Fuel Storage Installation was completed in December 2008, and the decontamination and dismantlement phase of HBPP Unit 3 decommissioning commenced.

On July 19, 2013, the licensee submitted Revision 4 to its Post-Shutdown Decommissioning Activities Report (PSDAR) for HBPP (ADAMS Accession ML13213A160). The PSDAR was revised to include significant changes in the scope and cost estimate that primarily included the caisson removal and discharge canal remediation activities.

On January 29, 2016, the licensee issued Revision 11 to the Defueled Safety Analysis Report (DSAR), and Revision 33 to the HBPP Quality Assurance Plan (HBQAP) (ADAMS Accession ML16029A508). The changes provided a distinct organizational structure between HBPP Unit 3 and the ISFSI, as well as updated the programs and procedures that were established and controlled under the licensees administrative controls listed in Appendix B of the HBQAP.

On August 13, 2014, the licensee submitted Revision 1 to the HBPP, Unit 3, LTP (ADAMS Accession Package ML14246A164). The LTP is required to be submitted at least 2 years prior to license termination, under 10 CFR 50.82(a)(9). The LTP Revision 1 described the remaining activities that the licensee will perform to complete decommissioning and the methods used to demonstrate that the site meets the NRC radiological criteria for unrestricted use under 10 CFR 20.1402. On May 4, 2016, the NRC issued Amendment No. 45 to Facility Operating License No. DPR-7 (ML15090A339), to approve the LTP Revision 1, and established the criteria under which the licensee was allowed to make changes without prior NRC approval.

The activities observed during the inspection included excavation of material from the caisson, application of shotcrete on the inside of the cutter soil mixture (CSM) wall, excavation of soil from the discharge canal to support removal of the circulating water lines, final status surveys of areas of the facility, and packaging and transportation of material. The licensee currently plans to complete final status surveys and site restoration activities by early 2019.

1 Organization, Management, and Cost Controls at Permanently Shutdown Reactors (36801)

1.1 Inspection Scope The inspectors evaluated the licensees organizational structure as specified in the HBQAP, Revision 33, and the License Termination Plan (LTP) Revision 1, in order to support the decommissioning activities and regulatory requirements.

1.2 Observations and Findings The licensees HBQAP, Revision 33 described the organizational structure at Humboldt Bay as having a Director, Engineering Manager, Radiation Protection Manager, and independent safety reviewers. The inspectors reviewed the organizational structure and determined that it adequately met the requirements under the HBQAP.

In addition, the LTP Revision 1 provided the final status survey (FSS) quality assurance project plan (QAPP), which provided the responsibilities and key positions to support the final status surveys. The licensee implemented the requirements under licensee Procedure HBAP C-225, Final Status Survey Program, Revision 4. The key positions for conducting the FSS program included the Site Closure Manager, FSS Engineers, FSS Supervisor, FSS Technicians, and FSS Foreman. These positions were filled with individuals who met the qualification requirements specified in the LTP and as described in licensee Procedure HBAP C-225.

The licensee was performing cross-training for several of the key FSS positions in order to support expected turn-overs at the end of October 2017. The inspectors observed several individuals shadowing others as part of the licensees efforts in turn-over of certain positions, specifically, the FSS Foreman and FSS Supervisor positions.

The inspectors reviewed the remaining decommissioning activities captured on the licensees schedule and in the LTP. The NRC inspectors observed the licensees plan-of-the-day meetings and attended the subsequent craft and radiation protection daily meetings, and observed licensee activities performed during the inspection period. Based on the planned activities and the conduct and implementation of those activities, the inspectors concluded that the decommissioning activities were initiated, sequenced and performed in a reasonable manner to the scheduled activities.

1.3 Conclusion The licensee had implemented an organization in accordance with the LTP Revision 1 and conducted its decommissioning activities in a reasonable manner consistent with the scheduled activities.

2 Decommissioning Performance and Status Review at Permanently Shutdown Reactors (71801)

2.1 Inspection Scope The inspectors evaluated whether the licensee and its contracted workforce were conducting decommissioning activities in accordance with the LTP Revision 1, and regulatory requirements.

2.2 Observations and Findings Revision 1 of the LTP Chapter 3 states in part, that the licensee would dismantle and decontaminate the site in accordance with HBPP procedures and approved work packages. The licenses critical path was removing the caisson under work package (WP-15). At the time of the inspection, the licensee was performing excavation and concrete demolition at the -58 foot elevation. The licensee had recently modified its survey processes for the material being removed from the caisson. The revised process entailed storing the potential re-use soil material into a bullpen area and performing additional surveys of the material to ensure activated concrete was not present. Once the surveys were completed, then the re-use soil material was loaded into trucks for further survey through the licensees mobile assay system, EnergySolutionsTM gamma radiation detection and in-container analysis (GARDIAN) system. The soil was subsequently transferred to the discharge canal as re-use soil material, or staged for later use.

The licensee was continuing to excavate to the bottom of the CSM wall. This entailed excavation of approximately 1 foot depth of soil from the outside perimeter of the caisson that was sent for disposal and successively removing the next 5-foot layer of soil for re-use. Then the wire mesh and 12-inches of shotcrete combination was applied to the interior walls of the CSM structure for the respective 6-foot height. Once completed, then the licensee commenced with concrete excavation for the next 6-foot layer of the caisson and debris removal. Subsequently, the cycle for removing the soil, applying shotcrete, and demolishing the caisson continued as stated above, as the cycle progressed until the bottom of the excavation will be achieved. The licensee anticipated completing the excavation by the end of November 2017.

The licensee was also focused on the excavation of the discharge canal and removing the circulating water pipes under work package (WP-29). The licensee was working four different phases (A, B, C, and D) of the discharge canal under the work package, which included excavating, performing final status surveys, and backfilling. The licensee had removed several sections of the circulating water pipes from the discharge canal. The piping had been staged at the onsite soil management facility, where materials were processed and packaged for transportation.

The inspectors observed industrial safety and precautions throughout the site, including discussions during morning meetings, as part of the pre-job briefings and tailboards, during site work activities, and tours of the facility. The license had implemented pedestrian routes and traffic controls throughout the site. The inspectors observed that safety precautions for heavy vehicles and workloads were discussed during several tailboards. The licensee maintained visible precautions and personal protection

equipment requirements for work areas. The majority of heavy equipment had spotters for the travel paths.

2.3 Conclusion The licensee was implementing the decommissioning and dismantlement activities in accordance with the LTP Revision 1. In addition, the licensee was implementing industrial safety precautions, applying safety communications, and utilizing personal protection equipment to minimize industrial safety hazards.

3 Occupational Radiation Exposure (83750)

3.1 Inspection Scope The inspectors reviewed the 2016 annual radiation protection program assessment and evaluated the training and qualification of radiation protection personnel.

3.2 Observations and Findings The regulation under 10 CFR 20.1101(c) requires licensees to assess the radiation protection program content and implementation. The licensees Procedure HBAP C-250, Annual Radiological Reports, Revision 9A discussed the requirements for performing this assessment. The licensee issued its report dated August 24, 2017, that provided documentation for the 2016 calendar year. The inspectors reviewed the annual report and determined that the licensee performed a thorough assessment of its radiation protection program. In addition, the licensee made several recommendations, including an evaluation of methodologies for controlling the storage and movement of low level soils and concrete within the site boundary to ensure continued implementation of 10 CFR 20.1802, for control of licensed material that is not in storage.

The inspectors reviewed the training requirements for the radiation protection staff, as specified in the Defueled Safety Analysis Report, Revision 11 and the LTP Revision 1.

The minimum training requirements specified ANSI N18.1 - 1971, Standards for Selection and Training of Personnel for Nuclear Power Plants. In addition, licensee Procedure HBAP C-202, Final Status Survey Quality Assurance Project Plan, Revision 4A, specified that personnel conducting FSS activities shall be appropriately trained and qualified commensurate with their assigned duties.

The inspectors reviewed the training documentation for the radiation protection staff and for the individuals responsible for the final status survey program. The radiation protection staff met the minimum ANSI N18.1 requirements and the inspectors noted that the majority of staff exceeded the minimum requirements. In addition, the inspectors concluded that the staff supporting the final status survey positions met the training requirements outlined by the licensee for the specific positions described in the LTP and licensee Procedure HBAP C-202, Final Status Survey Quality Assurance Project Plan.

3.3 Conclusions The licensee adequately assessed its 2016 annual radiation protection program and was implementing the radiation protection training program in accordance with license requirements.

4 Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors (83801)

4.1 Inspection Scope The inspectors verified that the radiological measurements, surveys and documentation of final status surveys were conducted in accordance with the approved LTP Revision 1.

4.2 Observations and Findings The licensees LTP Revision 1 is the NRC approved methodology for the licensee to develop final status survey plans for the facility. A survey plan at a minimum, encompasses the establishment of survey units, development of a survey design and data quality objectives, specification of appropriate survey instruments and survey methods, collection and processing of data, assessment of the data results, and documentation of the final status survey report.

The licensee developed an overall procedure in HBAP C-225, Final Status Survey Program, Revision 4 and HBAP C-202, Final Status Survey Quality Assurance Project Plan, Revision 4A, that specified the elements necessary for the FSS program. In addition, the licensee developed a number of implementing procedures for each element of the program, including survey unit classification, determination of number and location of final status survey samples, collection of site characterization and final status survey samples, and statistical tests.

The inspectors reviewed three final status survey packages for Class 1 areas and an embedded pipe package located in a Class 3 area. Class 1 areas are defined in NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) Revision 1, and similarly in the licensees LTP Revision 1, as impacted areas that have, or had prior to remediation, a potential for concentration of residual radioactivity that exceed the derived concentration guideline level (DCGL); whereas, Class 3 areas are defined as impacted areas that have a low probability of containing residual radioactivity. The inspectors confirmed that the survey unit sizes for Class 1 open land soil areas reviewed were less than 2000 square meters (m2) as established by the LTP Revision 1.

  • HBPP-FSSP-NOL01-07-00, Turbine Building Footprint (424.5 m2)
  • HBPP-FSSP-NOL01-05-00, North Yard (1,036 m2)
  • HBPP-FSSP-OOL02-01, Intake Canal East (1,972 m2)
  • HBPP-FSSP-OOL10-16-00, Retention Pond Culvert (embedded pipe)

The inspectors reviewed each package and determined that the FSS packages met the criteria approved in the LTP Revision 1 and the Technical Basis Document for embedded and buried piping, Revision 1. The elements of the survey design reviewed included:

1) the sample size, the Type I decision error was equivalent to 0.05, the lower boundary

of the gray region was 50-percent of the DCGL, the relative shift was acceptable, the sample grid spacing was acceptable, and the instrumentation selected and the minimum detectable concentrations calculated adequately met the LTP Revision 1. In addition, the inspectors reviewed the survey and sample analyses and concluded that the FSSs demonstrated the respective survey units were less than the established DCGLs.

The inspectors also observed several pre-job briefings and in-process final status and surveillance surveys conducted for the following packages.

  • HBPP-FSSP-NOL01-06-02, Hot Machine Shop footprint, and adjacent excavation
  • HBPP-FSSP-OOL10-18-01, New Generation boundary area
  • HBPP-CHAR-OOL10-05-00, surveillance
  • HBPP-CHAR-OOL10-06-02, surveillance
  • HBPP-FSSP-OOL-01-00, surveillance The inspectors determined that individuals present for the pre-job briefings met the positions specified in the LTP Revision 1 to support the performance of the final status surveys. The briefings were thorough and there were opportunities provided for any questions by the participants. The inspectors observed portions of the survey and sampling methods and concluded that the licensee was adequately implementing its FSS procedures that supported the LTP Revision 1.

In addition, the licensee had developed Procedure RCP FSS-13, Area Surveillance Following Final Status Survey, Revision 3, which provided surveillance requirements to assure that land and structural survey areas or units having undergone successful final status surveys remained unchanged until final site release for unrestricted use. The licensee adequately demonstrated the implementation of several surveillance surveys during the inspection.

The HBQAP, Section 17, Quality Assurance Records states in part, that a management control system for the collection, storage, and maintenance of completed quality assurance records shall be maintained and designed to assure that the quality assurance records were readily retrievable, and protected from damage or destruction during storage by fire, flooding, theft, environmental conditions, or other causes. The LTP Revision 1, Section 5.8.1.14, established measures to ensure the FSS records were maintained as quality records. The licensees implementing procedure HBAP C-202, Final Status Survey Quality Assurance Project Plan, Revision 4A states in part, that the final FSS records were submitted to the records management system (RMS) to meet this requirement. In addition, the licensee required that in-process FSS records were protected by limited access and stored in a fire rated file cabinet. The inspectors confirmed that the records were being handled and maintained in accordance with these requirements.

4.3 Conclusions The licensing was conducting final status surveys of areas in accordance with regulatory requirements and the LTP Revision 1, and subsequently isolating and controlling the final status survey areas as required by the LTP Revision 1.

5 Solid Radioactive Waste Management and Transportation of Radioactive Materials (86750)

5.1 Inspection Scope The inspectors reviewed the licensee's radioactive waste management and transportation activities to determine whether the licensee properly processed, packaged, stored, and shipped radioactive materials.

5.2 Observations and Findings The inspectors reviewed the licensees 2017 shipment tracking summary as of September 28, 2017, which indicated a total of 591 shipments during the year. The licensee had made 220 truck shipments to U.S. Ecology, Idaho under Exemptions 1 & 2.

The NRC authorized Exemptions 1 & 2 alternate disposal requests under 10 CFR 20.2002 and the exemption provision under 10 CFR 30.11, for a total of 2.2M cubic feet (ft3). The licensee had shipped 39.5 percent of the allowable waste under these 2 exemptions to U.S. Ecology, Idaho. The exemptions authorized waste debris such as concrete, steel, insulation, roofing material and other debris from Units 1 and 2; and waste materials including soils, and debris containing low-activity radioactive debris generated during the demolition of structures, and remediation of activities at Unit 3. The authorized exemptions are dated November 2, 2010 (ADAMS Accession ML102870344) and April 25, 2012 (ML120620450), respectively.

The licensee had also performed 68 shipments under Exemption 3 to U.S. Ecology, Idaho. By letter dated December 19, 2012 (ADAMS Accession ML12299A056), the NRC authorized Exemption 3 alternate disposal request under 10 CFR 20.2002. The exemption authorized disposal of waste to U.S. Ecology, Idaho limited to 100,000 ft3 of soil, concrete, steel, insulation, roofing material, gravel and other debris and 50,000 ft3 of aqueous waste associated with the decommissioning of Unit 3. The water would be solidified with clay at U.S. Ecology, Idaho, prior to disposal. The source term included fission products, activation products, and special nuclear material (SNM) nuclides resulting from operations at Unit 3. The licensee had shipped 82.66 percent of the allowed volume for solid debris (non-aqueous) and 57.69 percent of solid (aqueous)

waste to U.S. Ecology, Idaho under this Exemption 3.

The licensee had also made 266 truck shipments to Waste Control Specialists, Texas; 36 truck shipments to EnergySolutionsTM Clive Facility, Utah; and 1 truck load was shipped to TOXCO, Oak Ridge, Tennessee, for recycling or re-use of materials. At the time of the inspection, the total number of hazardous materials shipments for the project had been 3,714 shipments.

The licensees administrative procedure that governed the shipment of Class A radioactive materials was HBAP D-510, Shipment of Radioactive Materials and Radioactive Waste, Revision 9. The inspectors reviewed several transportation packages for compliance with the regulations under 10 CFR 71.5, Transportation of Licensed Material and the licensees procedure, and concluded that the shipping

packages were generated in accordance with the requirements and contained thorough supporting documentation. The packages reviewed included:

  • RMS-17-395 (Shipment to EnergySolutionsTM) (UN 2912)
  • RMS-17-416 (Shipment to Waste Control Specialists) (UN 2912)
  • RMS-17-109 (Shipment to TOXCO) (UN 2910)

In addition, the inspectors observed the packaging and communications for one radioactive waste shipment to Waste Control Specialists, manifest number RMS-17-443, dated September 28, 2017. The inspectors observed the licensees survey of the shipment, which had a highest contact reading of 0.7 millirem per hour (mR/hr). The NRC inspectors compared the survey measurements on the transport package using a Ludlum Model 2401-S survey meter, serial number 079971, calibration due date March 13, 2018, and a Ludlum Model 19 survey meter, serial number 033906, calibration due date July 21, 2018, and determined that the observed survey measurements were consistent with the licensees survey measurements. The inspectors observed the marking and placarding of the package for exclusive-use transport. In addition, the inspectors observed the licensee brief the transport driver. The licensee further explained that the waste characterization and classification was based on the dose rate to curie calculation based on the standard characterizations of the facilitys waste streams. The inspectors concluded that the licensee was knowledgeable of the transportation requirements and provided a shipping package that satisfactorily met the procedure and regulatory requirement. The licensee demonstrated adequate skills to accomplish the package preparation requirements for public transport.

The inspectors verified and concluded that individuals involved in the packaging preparation and transport had received the proper and adequate training and that the training was appropriately documented in accordance with the requirements under 49 CFR Subpart H.

5.3 Conclusions The licensee continued to process, package and ship radioactive wastes in accordance with regulatory requirements.

6 Exit Meeting Summary On September 28, 2017, the NRC inspectors presented the final inspection results to Mr. J. Salmon, HBPP Deputy Director, and other members of the licensees staff. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was provided during the inspection.

SUPPLEMENTAL INSPECTION INFORMATION KEY POINTS OF CONTACT Licensee Personnel B. Barley, Site Closure Manager C. Donahue, CAP Champion C. Evenson, FSS Supervisor B. Jasen, Environmental Oversight K. Johnson, Waste Engineer M. Jones, Waste Shipper G. Madison, FSS Engineer M. Murdock, Environmental Oversight D. Randall, FSS Supervisor K. Rowberry, FSS/Site Closure J. Salmon, Deputy Director P. Soenen, PG&E Regulatory Services INSPECTION PROCEDURES USED IP 36801 Organization, Management and Cost Controls at Permanently Shutdown Reactors IP 71801 Decommissioning Performance and Status Review at Permanently Shutdown Reactors IP 83750 Occupational Radiation Exposure IP 83801 Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened/Closed None Discussed None Attachment

LIST OF ACRONYMS ADAMS Agencywide Documents Access and Management System CFR Code of Federal Regulations CSM Cutter Soil Mixture DCGL Derived Concentration Guideline Level DSAR Decommissioning Safety Analysis Report FSSP Final Status Survey Plan HBPP Humboldt Bay Power Plant LTP License Termination Plan NRC Nuclear Regulatory Commission PG&E Pacific Gas & Electric PSDAR Post-Shutdown Decommissioning Activities Report QAPP Quality Assurance Project Plan WP Work Package

ML17285A546 SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword By: RSB Yes No Non-Sensitive Publicly Available NRC-002 OFFICE DNMS/FCDB FCDB C:FCDB NAME RSBrowder SGAnderson RLKellar SIGNATURE /RA/ /RA/ /RA/

DATE 10/12/17 10/16/17 10/19/17

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