IR 05000400/2024001

Integrated Inspection Report 05000400/2024001

ML24123A173
Person / Time
Site:	Harris
Issue date:	05/05/2024
From:	Matthew Fannon Division Reactor Projects II
To:	Haaf T Duke Energy Progress
References
IR 2024001
Download: ML24123A173 (15)

Text

SUBJECT:

SHEARON HARRIS NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000400/2024001

Dear Thomas Haaf:

On March 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Shearon Harris Nuclear Plant. On April 30, 2024, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

One Severity Level IV violation without an associated finding is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

No NRC-identified or self-revealing findings were identified during this inspection.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Shearon Harris Nuclear Plant.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.May 5, 2024

Sincerely, Matthew S. Fannon, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket No. 05000400 License No. NPF-63

Enclosure:

As stated

Inspection Report

Docket Number: 05000400

License Number: NPF-63

Report Number: 05000400/2024001

Licensee: Duke Energy Progress, LLC

Facility: Shearon Harris Nuclear Plant

Location: New Hill, North Carolina

Inspection Dates: January 01, 2024 to March 31, 2024

Inspectors: P. Boguszewski, Senior Resident Inspector J. Copeland, Reactor Inspector J. Hickey, Senior Project Engineer M. Kay, Project Engineer M. Kennard, Senior Operations Engineer S. Roberts, Project Engineer J. Seat, Senior Project Engineer C. Smith, Technical Assistant J. Walker, Senior Emergency Preparedness Inspector A. Wilson, Senior Project Engineer

Approved By: Matthew S. Fannon, Chief Reactor Projects Branch 4 Division of Reactor Projects

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Shearon Harris Nuclear Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Inoperable Auxiliary Feedwater Pumps Result in Condition Prohibited by Technical Specifications Cornerstone Severity Cross-Cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71153 NCV 05000400/2024001-01 Open/Closed A self-revealed Severity Level IV non-cited violation (NCV) of Technical Specification (TS)3.7.1.2, "Auxiliary Feedwater System," and TS Limiting Condition for Operation (LCO) 3.0.4 was identified when Harris Nuclear Plant discovered that two auxiliary feedwater (AFW)pumps were inoperable for longer than the allowed outage time and that the plant changed modes without meeting the LCO associated with AFW pumps.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000400/2022-006-00 LER 2022-006-00 for 71153 Closed Shearon Harris Nuclear Power Plant, Unit 1, Auxiliary Feedwater Pump Inoperability

LER 05000400/2022-006-01 LER 2022-006-01 for 71153 Closed Shearon Harris Nuclear Power Plant, Unit 1, Auxiliary Feedwater Pump Inoperability

LER 05000400/2022-006-02 LER 2022-006-02 for 71153 Closed Shearon Harris Nuclear Power Plant, Unit 1, Auxiliary Feedwater Pump Inoperability

PLANT STATUS

Unit 1 operated at or near rated thermal power until Harris began a planned end of core life power coast down in preparation for a planned refueling outage on March 12, 2024. Harris ended the inspection period at 87 percent rated thermal power.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather including heavy rains and winds on January 9, 2024.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) 'B' emergency switchgear and emergency diesel generator on March 12, 2024 and March 13, 2024

(2) 'B' component cooling water on March 21, 2024

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Reactor auxiliary building 261' (fire zone: 1-A-4-CHLR) on February 8, 2024

(2) Reactor auxiliary building 261' (fire zone: 1A-4-COMC) on February 8, 2024

(3) Turbine building (fire zones 1-G-261, 1-G-286, and 1-G-314) on March 7, 2024

(4) Reactor auxiliary building 236' (fire zones 1-A-3-COR, 1-A-BAL-A, and 1-A-3-COMI)on March 14, 2024

(5) Reactor auxiliary building 305' (fire zone 12-A-6-HV7) on March 28, 2024

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the fire brigade performance during their response to a fire on March 14, 2024.

71111.06 - Flood Protection Measures

Flooding Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated internal and external flooding mitigation protections in the reactor auxiliary building elevation 261' the week of March 18, 2024.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during plant manipulations required to measure and validate moderator temperature coefficient at the end of core life on January 18, 2024.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated operator training in the simulator in preparation for plant manipulations required to measure and validate moderator temperature coefficient at the end of core life on January 17, 2024.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Chemical and volume control system orifice isolation valve failed close (nuclear condition report [NCR] 02498336) on February 15, 2024

(2) Anticipated transient without scram (ATWS) panel trouble alarm (NCR 02500989) on March 14, 2024

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Elevated risk during dedicated shutdown diesel generator maintenance on January 10, 2024 and January 11, 2024

(2) Elevated risk during 'A' motor driven auxiliary feedwater pump suction pressure transmitter maintenance on February 5, 2024

(3) Elevated risk during emergent 'A' sequencer equipment issues on January 11, 2024

(4) Elevated risk during 'B' essential services chilled water outage with the ATWS mitigation system actuating circuitry panel nonfunctional on January 23, 2024

(5) Elevated risk due to pressurizer level channel, LT-159, failed low, on March 7, 2024

(6) Elevated risk due to emergent 'B' emergency diesel generator maintenance on March 27, 2024 and March 28, 2024

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (8 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) 'B' charging pump seal leakage (NCR 02499466) on February 8, 2024

(2) Reactor auxiliary building 236' mechanical penetration room door seal damage (NCR

===02502002) on February 9, 2024

(3) Reactor auxiliary building 236' scaffolds built in close proximity to sensitive safety-related equipment (NCR 02504893) on February 13, 2024

(4) 'B' emergency service water pump differential pressure degrading trend (NCR 2503430) on February 29, 2024

(5) Inaccurate battery load profile (NCR 02507517) on March 5, 2024

(6) Snubber CS-H-3349 (NCR 02505661) on March 6, 2024

(7) Mechanical equipment room cooler bypass valve, 1CH-630:002, exceeded equipment qualification life span (NCR 02497919) on March 29, 2024

(8) Lower than expected oil flow on 'B' emergency diesel generator left turbocharger oil flow sight glass (NCR 20261451) on March 29, 2024

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (PMT) (IP Section 03.01)===

(1) MPT-I0049, "ATWS Mitigation System Actuation Circuitry Functional Tests," after power supply replacement on January 23, 2024

(2) OPT-1530, "Dedicated Shutdown Diesel Generator Operability Test," after scheduled maintenance on January 10, 2024

(3) OST-1008, "Residual Heat Removal (RHR) Pump Operability Test," following maintenance on the 'A' RHR pump motor on February 8, 2024

(4) OPT-1512, "Essential Chilled Water Turbopak Units Quarterly Inspection/Checks,"

following maintenance on January 25, 2024

(5) OST-1141, "B Train HVAC Safety Related ESCW TVCS ISI Operability Test," after air handler temperature control valve replacement on January 23, 2024

(6) OST-1041, "A" Train HVAC Safety-Related ESCW TCVS ISI Operability Test,"

following solenoid valve replacement on February 7, 2024

(7) OST-1017, "Pressurizer PORV Block Valve Full Stroke Test," on March 6, 2024

(8) OST-1073, "1B-SB Emergency Diesel Generator Operability Test," following replacement of synchronizing circuit relays on March 28, 2024

Surveillance Testing (IP Section 03.01) (4 Samples)

(1) MST-I0320, "Train B Solid State Protection System Actuation Logic & Master Relay Test," on January 31, 2024

(2) MST-I0041, "Refueling Water Storage Tank Level (L-0991) Calibration Test," on February 26, 2024

(3) OST-1191, "Steam Generator PORV and Block Valve Operability Test," following discovery of minor leakage on 'B" Steam Generator PORV on February 6, 2024

(4) MST-I0661 "Nuclear Instrumentation System Power Range N43 Detector Current Calibration" on February 29, 2024

Inservice Testing (IST) (IP Section 03.01) (1 Sample)

(1) OST-1215, "Emergency Service Water System Operability Train B," on February 29, 2024

71114.02 - Alert and Notification System Testing

Inspection Review (IP Section 02.01-02.04) (1 Sample)

(1) The inspectors evaluated the maintenance and testing of the alert and notification system during the week of March 18, 2024.

71114.03 - Emergency Response Organization Staffing and Augmentation System

Inspection Review (IP Section 02.01-02.02) (1 Sample)

(1) The inspectors evaluated the readiness of the Emergency Response Organization (ERO) during the week of March 18, 2024.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated submitted Emergency Action Level (EAL), Emergency Plan, and Emergency Plan Implementing Procedure changes during the week of March 18, 2024. This evaluation does not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness

Inspection Review (IP Section 02.01 - 02.11) (1 Sample)

(1) The inspectors evaluated the maintenance of the emergency preparedness program during the week of March 18,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===

(1) January 1, 2023 through December 31, 2023

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (1 Sample)

(1) January 1, 2023 through December 31, 2023

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)

(1) January 1, 2023 through December 31, 2023

EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)

(1) January 1, 2023 through December 31, 2023

EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)

(1) January 1, 2023 through December 31, 2023

EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)

(1) January 1, 2023 through December 31, 2023

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Auxiliary feedwater flow control valve, 1AF-51, not controlling properly (NCR

===02447356)

71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)===

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 2022-006-00/01/02, Auxiliary Feedwater Pump Inoperability (ADAMS Accession No. ML23192A759). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section. This LER is Closed.

INSPECTION RESULTS

Inoperable Auxiliary Feedwater Pumps Result in Condition Prohibited by Technical Specifications Cornerstone Severity Cross-Cutting Report Aspect Section Not Severity Level IV Not 71153 Applicable NCV 05000400/2024001-01 Applicable Open/Closed A self-revealed Severity Level IV non-cited violation (NCV) of Technical Specification (TS)3.7.1.2, "Auxiliary Feedwater System," and TS Limiting Condition for Operation (LCO) 3.0.4 was identified when Harris Nuclear Plant discovered that two auxiliary feedwater (AFW)pumps were inoperable for longer than the allowed outage time and that the plant changed modes without meeting the LCO associated with AFW pumps.

Description:

Valve 1AF-51, motor driven AFW B steam generator flow control valve, is a normally open flow control valve located in the discharge piping of the motor driven AFW pumps to the 'B' steam generator. It has a safety function to automatically open upon generation of any signal which starts the motor driven AFW pumps. This function is necessary to provide a path for AFW flow to the associated steam generator. The valve fails to the open position on loss of control signal, electrical power, or hydraulic failure. This valve also has a safety function in the close position. 1AF-51 must be capable of automatic closure on receipt of an AFW isolation signal. The closure of the valve on a AFW isolation signal protects against feeding AFW to a faulted steam generator and assures that minimum required flow is directed to the unaffected steam generators for reactor coolant system cooldown. Isolation of AFW flow to the faulted steam generator will occur within about 60 seconds, but the Harris steam line break analysis conservatively delays AFW isolation until 10 minutes.

On October 30, 2022, with Shearon Harris Unit 1 operating at 16 percent power following a refueling outage, an automatic reactor trip occurred. During the scram response, 1AF-51, motor driven AFW B steam generator flow control valve, did not initially throttle closed when demanded by operators. After operators stabilized the plant, 1AF-51 did go closed as demanded by operators. Based on the slow response of 1AF-51, the valve was declared inoperable. Since 1AF-51 operation can impact AFW flow control from the common header of the motor driven AFW pumps, both motor driven AFW pumps were declared inoperable.

Based upon investigation, it was determined that the 1AF-51 valve actuator installed during the refueling outage on October 20, 2022, needed to be replaced and that the valve was not operable while Harris Nuclear Plant was in Modes 1, 2, and 3 from October 27, 2022, through October 30, 2022.

Corrective Actions: The actuator for valve 1AF-51 was replaced to restore proper flow control capability and restore both motor driven AFW pump trains to operable.

Corrective Action References: NCR 02447356

Performance Assessment:

The NRC determined this violation was not reasonably foreseeable and preventable by the licensee and therefore is not a performance deficiency.

The 1AF-51 actuator that failed was installed during the refuel outage, which concluded on October 30, 2022. After the new actuator was installed, 1AF-51 was stroked successfully multiple times and passed post maintenance testing. The inspectors did not identify a deficiency associated with the valve installation or testing requirements. Based on this information, the inspectors concluded that this violation was not reasonably within the licensee's ability to foresee and correct.

Enforcement:

This issue is considered within the traditional enforcement process because there was no performance deficiency associated with the violation of NRC requirements. The NRC Enforcement Manual, Section 1.2.8.E.3 states, in part, that, traditional enforcement is used for violations with no associated performance deficiencies.

Severity: The inspectors informed significance using IMC 0609, Appendix A, The SDP For Findings At-Power, and determined that the condition represented very low safety significance because the component maintained its PRA functionality. The inspectors reviewed Section 6.1.d.1 of the NRC Enforcement Policy and determined this violation is characterized as a Severity Level IV violation because it involved a failure to comply with a technical specification action requirement and was of very low safety significance.

Violation: Harris Nuclear Plant TS 3.7.1.2 requires, in part, with two AFW pumps inoperable, action must be taken to be in at least hot standby within six hours and in hot shutdown within the following six hours. Harris Nuclear Plant TS LCO 3.0.4, requires, in part, that when an LCO is not met, entry into a mode or other specified condition in the applicability shall only be made when the associated actions to be entered permit continued operation in the mode or other specified condition in the applicability for an unlimited period of time.

Contrary to the above, two required AFW pumps were inoperable from October 27, 2022 to October 30, 2022 and Harris Nuclear Plant did not enter hot standby within six hours or hot shutdown within the following six hours. Additionally, on October 27, 2022, Harris Nuclear Plant entered a TS 3.7.1.2 applicable mode when TS LCO 3.7.1.2 required actions were not met.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On April 30, 2024, the inspectors presented the integrated inspection results to Thomas Haaf and other members of the licensee staff.

• On March 21, 2024, the inspectors presented the emergency preparedness program inspection results to Thomas Haaf and other members of the licensee staff.

THIRD PARTY REVIEWS

Inspectors reviewed the Institute on Nuclear Power Operations (INPO) report that was issued during the inspection period.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.06 Calculations PRA-F-E-0006 Reactor Auxiliary Building Unit 1 El. 261' Internal Flooding Revision 4

Analysis

Corrective Action NCR 02495634 Penetration (P580) between TB and RAB 261' unfinished

Documents

Drawings 1364 093071 Penetration Seal Typicals, MS-1, MS-2, MS-3, MS-4 Revision 3

Procedures AP-046 Control of Environmental Protective Features Revision 10

71111.12 Corrective Action 02503432

Documents

Resulting from

Inspection

71111.15 Corrective Action NCR 02504893

Documents

71114.02 Corrective Action NCR 02495754 Siren H05 Partial Activation 11/29/2023

Documents

Miscellaneous WPS-2900 Series High Power Voice & Siren System

Shaeron Harris Nuclear Power Plant Site-specific Offsite 04/23/1990

Radiological Emergency Preparedness Alert and Notification

System Quality Assurance Verification

FEMA to NRC FEMA letter to NRC related to analysis of Harris ANS QA 08/03/1990

Letter report

Procedures AD-EP-ALL-0305 Fleet Emergency Preparedness (EP) Alert and Notification Rev. 5

System (ANS) Siren Program

EP-HNP-EPLAN Duke Energy Harris Emergency Plan Annex Rev. 1

Self-Assessments KLD TR-1390 Siren Acoustical Analysis 12/20/2023

71114.04 Miscellaneous EREG 02487477 10 CFR 50.54(q) Review Form for EP-ALL-EPLAN, Rev 5 09/29/2023

EREG 02492594 10 CFR 50.54(q) Review Form for AD-EP-ALL-0105, 11/08/2023

"Activation and Operation of the Technical Support Center,"

Rev 11

Procedures AD-EP-ALL-0101 Emergency Classification Rev. 5

AD-EP-ALL-0109 Offsite Protective Action Recommendations Rev. 9

AD-EP-ALL-0202 Emergency Response Offsite Dose Assessment Rev. 9

AD-EP-ALL-0304 State and County Notifications Rev. 7

Inspection Type Designation Description or Title Revision or

Procedure Date

CSD-EP-HNP-EAL Technical Basis Document Rev. 5

0101-01

CSD-EP-HNP-EAL Wallchart (Hot and Cold) Rev. 2

0101-02

71114.05 Corrective Action NCR 02440181 HNP NRC EP Program Inspection Corrected EAL Deficiency 08/31/2022

Documents NCR 02441069 NRC Concerns with Accident Gas Effluent Radiation 09/09/2022

Monitors

NCR 02443167 Common Emergency Plan EREG review 09/26/2022

NCR 02452895 Failure of ENMON Radios During Annual Testing 12/13/2022

NCR 02460616 23-01 Practice Exercise: Untimely Notification of All OROs02/14/2023

NCR 02461450 Drill Participation KPI Data Did Not Meet Requirements of 02/20/2023

AD-EP-ALL-0002

NCR 02485181 NOS Audit: Drill Documentation Deficiencies 08/30/2023

NCR 02486446 NOS Audit: EP Siren Discrepancies in Governing Documents09/12/2023

NCR 02486503 NOS Audit: Records missing drill documentation 09/12/2023

NCR 02486589 NOS Audit: EP Equipment Inventory List Minimum not Met 09/13/2023

NCR 02486775 NOS Audit: Documents are Not Being Sent to Fusion as QA 09/14/2023

Records

NCR 02487626 NOS Finding 2023-HNP-EMP-01-F1: Objective Evidence for 09/21/2023

EP Activities

NCR 02495901 NOS Audit: MNS Graded Exercise Documentation 11/28/2023

Deficiencies

NCR 02496925 AD-EP-HNP-0401: Containment Hydrogen Analyzers 12/06/2023

NRC 02495281 HNP OPS Escalation: Weaknesses in Drill and Exercise 11/19/2023

Performance

Miscellaneous 23-04 NRC Graded Exercise Drill Package 4/25/2023

KLD TR - 1400 Harris Nuclear Plant 2024 Population Update Analysis 01/13/24

Self-Assessments 2022-HNP-EMP-NUCLEAR OVERSIGHT - CONDITIONAL AUDIT 09/28/2022

LSA-01 HARRIS EMERGENCY PREPAREDNESS

23-HNP-EMP-NUCLEAR OVERSIGHT - AUDIT 09/21/2023

HARRIS EMERGENCY PREPAREDNESS

Work Orders WO 20620124 PERFORM MST-I0378 PLANT VENT STACK ACCIDENT 08/19/23

MONITOR RM-21AV-3509-1SA

OPERATIONAL TEST

Inspection Type Designation Description or Title Revision or

Procedure Date

WO 20622014 RM-3509-1 LOSS OF COMMUNICATIONS 09/01/23

71151 Corrective Action NCR 02488707 Missed DEP Opportunity During Week 4 of the 2023 LOCT 09/29/2023

Documents Annual Operating Exam

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