IR 05000440/2023004

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Integrated Inspection Report 05000440/2023004
ML24026A197
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 01/30/2024
From: Billy Dickson
NRC/RGN-III/DORS/RPB2
To: Penfield R
Energy Harbor Nuclear Corp
References
IR 2023004
Download: ML24026A197 (1)


Text

SUBJECT:

PERRY NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000440/2023004

Dear Rod Penfield:

On December 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Perry Nuclear Power Plant. On January 11, 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.

No findings or violations of more than minor significance were identified during this inspection.

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.

Sincerely, Billy C. Dickson, Jr., Chief Reactor Projects Branch 2 Division of Operating Reactor Safety Docket No. 05000440 License No. NPF-58

Enclosure:

As stated

Inspection Report

Docket Number: 05000440

License Number: NPF-58

Report Number: 05000440/2023004

Enterprise Identifier: I-2023-004-0054

Licensee: Energy Harbor Nuclear Corp.

Facility: Perry Nuclear Power Plant

Location: Perry, OH

Inspection Dates: October 01, 2023 to December 31, 2023

Inspectors: J. Beavers, Senior Resident Inspector R. Cassara, Resident Inspector T. Ospino, Resident Inspector T. Taylor, Senior Resident Inspector

Approved By: Billy C. Dickson, Jr., Chief Reactor Projects Branch 2 Division of Operating Reactor Safety

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Perry Nuclear Power 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

No findings or violations of more than minor significance were identified.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000440/2022-001-00 LER 2022-001-00: Low 71153 Closed Pressure Core Spray Inoperable due to Loss of Minimum Flow Valve

PLANT STATUS

Unit 1 began the inspection period at rated thermal power and remained at or near rated thermal power for the remainder of the inspection period.

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.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following systems on November 1, 2023:
  • building heating system
  • fire protection system

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (8 Samples)

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

(1) high pressure core spray rooms at elevations 620', and 574', and the control room on November 2, 2023
(2) standby liquid control system, 'A' on November 8, 2023
(3) division 1 emergency diesel generator fuel oil system on November 17, 2023
(4) division 1 emergency diesel generator air system on November 17, 2023
(5) control rod drive hydraulic system on November 21, 2023
(6) 'A' combustible gas control system on November 21, 2023
(7) emergency diesel generator 3 (high pressure core spray) on November 29, 2023
(8) residual heat removal 'A' on December 14, 2023

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (11 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) fire zone TP-647 on October 18, 2023
(2) fire zone 1CC-3a, Division 2 4.16kV and 480V switchgear room, on October 25, 2023
(3) fire zone 1AB-1F, HPCS system, on October 23, 2023
(4) fire zone 1AB-2, 599' elevation, on October 27, 2023
(5) fire zone 1DG-1B on November 1, 2023
(6) verification of the fire zone 1AB-1F on November 2, 2023
(7) fire zone SW-620 on November 6, 2023
(8) fire zone SW-600 and SW 581 on November 6, 2023
(9) fire zone 0EW-1a emergency service water building on November 7, 2023
(10) fire zone FPI-1RB (containment elevation 642) on November 8, 2023
(11) fire zone 1DG-1C emergency diesel generator 3 on November 29, 2023

71111.06 - Flood Protection Measures

Flooding Sample (IP Section 03.01) (1 Sample)

(1) review of the safety-related electrical manhole #1 during the week of November 10, 2023

71111.07A - Heat Exchanger/Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) 'A' residual heat removal heat exchanger on November 6, 2023

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered between October 30, 2023 and December 15, 2023.

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 the control room during 24-hour run of the division 3 diesel generator on October 31 and November 1, 2023.

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

(1) The inspectors observed and evaluated an annual simulator operator requalification on November 8, 2023.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

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

(1) division 2 control room ventilation outage on November 7, 2023

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (1 Sample)

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) division 1 emergency diesel generator extended outage, November 20 through 22, 2023

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

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

(1) operability review of the division 3 emergency diesel generator fuel consumption challenges during the October 24-hour run on November 7, 2023
(2) operability review after the failure of the control room ventilation fan 'B' breaker on November 26 and 27, 2023
(3) operability review of the division 1 emergency diesel generator challenges during the outage window ended on November 25, 2023
(4) operability review after the failure of a power supply in the division 1 emergency diesel generator triggered multiple unplanned alarms on December 3, 2023

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) (3 Samples)

(1) replacement of the alternating current soakback pump as part of the high pressure core spray system on August 9, 2023
(2) replacement of a flow card associated with the average power range monitor 'F' due to a surveillance challenge on October 19, 2023
(3) replacement of a transponder/branch amplifier card associated with the rod control and information system after a system lockup on December 1, 2023

71114.04 - Emergency Action Level and Emergency Plan Changes

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

(1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes.
  • PY-2022-028-00 Q2; 10 CFR 50.54(q)2 Analysis - PSI-0019, Revision 22 and Emergency Action Level (EAL) Bases Document Changes; October 18, 2022
  • PY-2022-028-00 Q3; 10 CFR 50.54(q)3 Screen/Evaluation - PSI-0019, Revision 22 and Emergency Action Level (EAL) Bases Document Changes; October 27, 2022
  • PY-2022-036-00 Q2; 10 CFR 50.54(q)2 Analysis - PSI-0019, Revision 23 and Emergency Action Level (EAL) Bases Document Changes; November 6, 2022
  • PY-2022-036-00 Q3; 10 CFR 50.54(q)3 Screen/Evaluation - PSI-0019, Revision 23 and Emergency Action Level (EAL) Bases Document Changes; December 5, 2022

This evaluation does not constitute NRC approval.

71114.06 - Drill Evaluation

Integrated Inspection Report 05000440/2023003 credited an inspection sample to IP 71114.06 Section 03.01 rather than 03.02. The Reactor Program System has been updated to properly account for that inspection sample under IP Section

OTHER ACTIVITIES - BASELINE

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) local power range monitor failure corrective action prioritization and timely completion during the annual inspection period
(2) reactor protection system power distribution voltage control corrective action prioritization and timely completion during the annual inspection period
(3) reactor water cleanup system steam leak work planning and execution during the annual inspection period

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 05000440/2022-001-00, (ADAMS Accession No. ML22229A090). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section 71153. This LER is Closed.

INSPECTION RESULTS

Observation: Local Power Range Monitor Failures 71152A The inspectors selected local power range monitor (LPRM) failure corrective action prioritization and timely completion based on the number of failures and the systems used by various plant systems to ensure the protection of the fuel cladding and to aid in evaluating the nuclear and thermal-hydraulic performance of the reactor core.

Perry completed their refueling outage in April of 2023: by September 2023, approximately 10 percent of the individual LPRM detectors were out of service. Individual failures resulted in unplanned automatic power reduction using reactor recirculating pump flow when the instrument was associated with Average Power Range Monitor (APRM) A.' Failures in any channel can and have initiated partial logic for the automatic reactor trip system. However, no full reactor SCRAM has occurred as the complementary logic must also be initiated. The inspectors evaluated these events under the initiating events safety cornerstone of the reactor oversight process. During October 2023, the licensee created a Plan of Action to restore as many LPRM instruments as possible, restoring six with the remaining ten out of service. The remaining instruments require reactor cavity access for repair and are scheduled for the next refueling outage in the spring of 2025. There are 164 individual LPRM detectors feeding into eight channels of APRMs. Each APRM channel must have two good LPRM detectors at each of the four levels and a minimum of 14 good LPRM detectors. On average, that comes to roughly five detectors per level per channel for each operable APRM. One instrument has been out of service for over eight years. The questioning attitude (QA)behavior in Safety Culture Common Language, NUREG-2165, states that individuals avoid complacency and continuously challenge existing conditions and activities to identify discrepancies that might result in an error or inappropriate action. Overall, the inspectors found the corrective action program to be generally effective in identification and resolution, with the timeliness of the corrective actions worthy of note.

The inspectors noted that the licensee had yet to declare a single APRM channel inoperable due to inadequate LPRM's detector numbers during the inspection period. The inspectors evaluated LPRM failure corrective action prioritization and timely completion and identified no more than minor findings with the licensees problem identification and resolution efforts.

Observation: Reactor Protection System Power Distribution Voltage Control 71152A Issues The inspectors selected the Reactor Protection System (RPS) power distribution corrective action prioritization and timely resolution based on the number of issues with a system providing control power to the reactor protection and reactor coolant system isolation systems. The inspectors observed extended issues with erratic RPS motor generator voltages throughout the sample period. No protective features regarding voltage or frequency were activated due to these anomalies. Additional temporary guidance provided control room response to more significant degradations, but that criterion was not met. The inspectors evaluated the questioning attitude behavior in Safety Culture Common Language, NUREG-2165, regarding avoiding complacency and continuously challenging existing conditions and activities to identify discrepancies that might result in error or inappropriate action.

The inspectors found the corrective actions to be generally effective in identification and resolution, with the timeliness of the corrective actions worthy of note. The inspection did not identify more than minor findings with the licensees problem identification and resolution efforts.

Observation: Reactor Water Clean Up System Work Planning and Execution 71152A The inspectors selected the reactor water cleanup system corrective action prioritization and timely resolution based on the number of issues with a system providing reactor coolant system and containment fission product barrier functions. System performance struggled throughout the year with multiple valve performance issues, controller issues, and integrity issues with leakage in both the B reactor water cleanup pump to the nuclear-closed cooling system and later in the inlet to the regenerative heat exchanger. No immediate safety function impact resulted from the variety of issues with the system. However, multiple efforts and system manipulations impacted scheduled maintenance activities and challenged overall reactor coolant chemistry control. The heat exchanger leak in containment increased all task performance difficulties within containment, adding humidity and airborne activity concerns during the recovery effort. The licensee generated a roll-up corrective action program document in May of 2023, but the year ended with system performance problems carrying on into 2024. The inspectors closely monitored potential impacts on the coolant and containment fission product barriers, the risk of the emergency work, and the effects on weekly planned work.

The inspectors found the corrective actions worthy of note to be generally effective in identification and resolution, with the timeliness of the corrective actions noteworthy. The inspectors did not identify more than minor findings with the licensees problem identification and resolution efforts.

Observation: LER 2022-001-00: Low Pressure Core Spray Inoperable due to 71153 Loss of Minimum Flow Valve The inspectors performed a detailed review of the licensees causal evaluation associated with CR-2022-05107, LPCS Minimum Flow Valve blew two mainline fuses.

On June 24, 2022, at 1257 hours0.0145 days <br />0.349 hours <br />0.00208 weeks <br />4.782885e-4 months <br />, and with the reactor in MODE 1 at 100% rated thermal power, a surveillance test was performed to verify the operation of the low pressure core spray (LPCS) system. During the surveillance test, operators observed that the LPCS minimum flow valve experienced a loss of position indication while stroking closed. After investigating the motor control center disconnect for the low pressure core spray minimum flow valve, licensee troubleshooting identified two of the three mainline power fuses blown. Examination of the LPCS minimum flow valve revealed that the motor-operated actuator had separated from the valve. This condition resulted in the LPCS system being declared inoperable.

The licensees corrective action program evaluation subsequently attributed the cause of the failed adapter-to-actuator bolts to fatigue failure due to loss of preload. Additionally, previous changes to adapter-to-actuator bolt torque requirements in the early 1990s resulted in joint assembly specifications that were not fully effective in precluding a loss of preload in all fasteners. No visible precursors or testing issues regarding this failure manifested in the subsequent three decades of testing before the actuator to valve body bolt failures.

The inspectors determined that the cause of the condition described in the LER was not reasonably within the licensees ability to foresee and correct and, therefore, was not reasonably preventable. During this review, the inspectors identified no performance deficiency or violation of NRC requirements.

EXIT MEETINGS AND DEBRIEFS

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

  • On January 11, 2024, the inspectors presented the integrated inspection results to R. Penfield, Site Vice President, and other members of the licensee staff.
  • On December 19, 2023, the inspectors presented the Emergency Action Level and Emergency Plan change review inspection results to J. Archer, Emergency Preparedness Response Supervisor, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Miscellaneous Certification of Perry Site Certification Letter for Winter Readiness 2023 10/31/2023

Winter Readiness

71111.04 Corrective Action CR 2023-08388 NRC ID: Locking Device Installed Incorrectly on SLC Disch 11/08/2023

Documents Outboard DW Drain Line

Resulting from CR 2023-08390 NRC ID: Potential Leakby into SLC Test Tank 11/08/2023

Inspection

Procedures VLI-C11 (CRDH) Control Rod Drive Hydraulic System (CRDH) 11/21/2023

VLI-C41 Standby Liquid Control System 11/08/2023

VLI-E12 Residual Heat Removal System 12/14/2023

VLI-E22 High Pressure Core Spray 11/02/2023

VLI-M51 Combustible Gas Control System 11/21/2023

VLI-R44/E22B Division 3 Diesel Generator Starting Air System 11/29/2023

VLI-R47/E22B Division 3 Diesel Generator Lube Oil System (Unit 1) 11/29/2023

71111.05 Corrective Action CR 2023-08352 Structural Support Members in Electrical Manhole #1 Are 11/07/2023

Documents Degraded

Corrective Action 2023-08340 NRC Identified Incorrect Functional Location Number on 11/07/2023

Documents Service Water Pre-Fire Plan (FPI-SWB)

Resulting from 2023-08345 NRC Identified: Fire Extinguisher Missing Tamper Tab 11/07/2023

Inspection

Fire Plans 0EW-1a Emergency Service Water Pump House 11/07/2023

1AB-1F Unit 1 - HPCS System 09/07/2018

1AB-2 Unit 1 599' Elevation 09/07/2018

1DB-1B Unit 1 - Division 3 Diesel Generator Building 620' 6" and 646' 11/29/2023

6"

1DG-1B Unit 1 - Division 3 Diesel Generator Building 620 6 and 11/01/2023

646 6

AB-1F Unit 1 - HPCS System 574 - 10 Elevation 11/01/2023

FPI-RB1 Reactor Building 11/08/2023

FZ SW-600 and Service Water Bldg. Elev. 600 and 581 11/06/2023

SW 581

FZ SW-620 Service Water Bldg. 620 Elev. 11/06/2023

TP-647 Turbine Power 647 Elev. 10/18/2023

Inspection Type Designation Description or Title Revision or

Procedure Date

Procedures FPI-A-C01 Fire Protection Program Control Processes (Hot Work 16

Permits, Transient Combustible Permits, Impairment

Permits, and Fire Watches)

PAP-1910 Fire Protection Program 45

71111.06 Engineering ECP 22-0026-000 Dewatering Pumps for Electrical Manholes 11/07/2023

Changes ECP 22-0026-001 NEW Drawing Update Notice (NDUN) 11/07/2023

Work Orders 200897625 Sump Pump Installation for EMH 1 per ECP 11/07/2023

71111.07A Calculations E12-106 RHR System Heat Exchanger 'A' Loop Performance Test 6

Evaluation

71111.11A Miscellaneous Email from Perry 2023 Annual Operating Exam Results Worksheet 12/15/2023

LORT B.U. dated

2/15/2023

71111.13 Corrective Action 2023-08638 Division 1 Diesel Generator Shutdown Based on Abnormal 11/20/2023

Documents Noises from Left Bank Turbo

71111.15 Corrective Action 2022-08760 Div 1 Diesel Low Starting Air Alarm 11/16/2023

Documents 2023-03205 Div 1 DG Bearing Temp High Trip Alarm 04/18/2023

23-08454 Div 1 DG Panel Spurious Alarms 11/12/2023

23-08906 Div 1 DG Multiple Unexpected Alarms 12/03/2023

CR 2023-08289 Div 3 Fuel Oil Record Gallons Used Vs Gallons Consumed 11/07/2023

Not within 400 Gallons

CR 2023-08559 Div 1 Diesel LB Turbo to be Installed Appears to Have 11/14/2023

Damage to the Mating Surface Area

CR 2023-08637 Division 1 Diesel Generator Shutdown Based on Abnormal 11/20/2023

Noises from Left Bank Turbo

CR 2023-08725 Loud Buzzing Coming from 42 Relay EFD09-G 11/25/2023

CR 2023-08739 EF1D09 3-Phase, 200Amp MCC Disconnect Switch Failed 11/26/2023

to Make Contact on One Phase

Work Orders 200745065 Dissasemble / Inspect LP turbo 11/14/2023

71111.24 Calibration CR 2023-08875 Rod Control and Information System Lockup 12/01/2023

Records

Corrective Action 2023-06059 Div 3 D/G AC Soakback Pump Threads Found Galled on 08/03/2023

Documents Swagelok Fitting

CR 2023-07670 Unable to Adjust Test 2 RPS Instrumentation Potentiometer 10/11/2023

during SVI-C51-T0027F

Inspection Type Designation Description or Title Revision or

Procedure Date

Work Orders 200807476 Replace AC Soakback Pump REPLACE AC SOAKBACK 08/09/2023

PUMP

200925091 No work description 10/19/2023

200929545 Rod Control & Information System LU /CR 12/01/2023

71114.04 Miscellaneous EPL-10 CFR 50.54 (q) Evaluation Lesson Plan 6

5054Q_FEN-01

PY-2022-028-00 10 CFR 50.54(q)2 Analysis - PSI-0019, Revision 22 and 10/18/2022

Q2 Emergency Action Level (EAL) Bases Document Changes

PY-2022-028-00 10 CFR 50.54(q)3 Screen/Evaluation - PSI-0019, Revision 10/27/2022

Q3 22 and Emergency Action Level (EAL) Bases Document

Changes

PY-2022-036-00 10 CFR 50.54(q)2 Analysis - PSI-0019, Revision 23 and 11/06/2022

Q2 Emergency Action Level (EAL) Bases Document Changes

PY-2022-036-00 10 CFR 50.54(q)3 Screen/Evaluation - PSI-0019, Revision 12/05/2022

Q3 23 and Emergency Action Level (EAL) Bases Document

Changes

PY-2023-001-00 10 CFR 50.54(q)2 Analysis - EP-0000, Emergency Plan, 01/19/2023

Q2 Revision 61

PY-2023-001-00 10 CFR 50.54(q)3 Screen/Evaluation - EP-0000, Emergency 02/01/2023

Q3 Plan, Revision 61

Procedures EP-0000 Emergency Plan for Perry Nuclear Power Plant 60

EP-0000 Emergency Plan for Perry Nuclear Power Plant 61

PSI-0019 Emergency Action Level (EAL) Bases Document 21

PSI-0019 Emergency Action Level (EAL) Bases Document 22

PSI-0019 Emergency Action Level (EAL) Bases Document 23

71152A Corrective Action 2022-06579 RPS MG Set A Voltage Drifting up 08/26/2023

Documents 2023-01264 Work Order 200502650 Removed from 1R19 02/23/2023

23-03525 System Monitoring: Reactor Protection System B Motor 04/26/2023

Generator Set Voltage Above Trend Plan Action Level

23-05040 RPS Bus B voltage rising 06/24/2023

23-05919 RPS Bus A Voltage Erratic 07/31/2022

23-06215 Automatic Reactor SCRAM and MSIV Closure Following 08/10/2023

RPS Bus Shift from ALT to NORM B

23-06283 RPS A Voltage Swinging While Unloaded 08/12/2023

Inspection Type Designation Description or Title Revision or

Procedure Date

23-06298 RPS A Voltage Swinging While loaded 08/14/2023

23-06312 As-Found Results for Removed RPS Transfer Switch Not 08/14/2023

Within Acceptable Range

23-06489 RPS MG Set "A" Output AC Voltage Is High Out Of Band 08/20/2023

23-06490 RPS MG Set "B" Output AC Voltage Is High Out Of Band 08/20/2023

23-06794 Voltage Spikes Observed RPS A on ICS 08/31/2023

23-08297 System Monitoring: Reactor Protection System Bus 'B' 11/06/2023

Voltage Drift

CR-2023-08591 Reactor Water Clean-Up Regenerative Heat Exchanger A 11/16/2023

Flange Leakage

Corrective Action CR-2023-03720 Reactor Water Clean-Up Roll-Up CR 05/02/2023

Documents

Resulting from

Inspection

13