IR 05000498/2020090
| ML20188A214 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/06/2020 |
| From: | Hay M NRC/RGN-IV/DRP |
| To: | Gerry Powell South Texas |
| References | |
| 4-2017-034, EA-19-054, EPID I-2020-090-0005, IR 2020090 IR 2020090 | |
| Preceding documents: |
|
| Download: ML20188A214 (15) | |
Text
July 6, 2020
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1 AND 2 - NRC INSPECTION REPORT 05000498/2020090; 05000499/2020090 AND NRC INVESTIGATION REPORT 4-2017-034
Dear Mr. Powell:
This letter refers to the investigation completed on March 4, 2020, by the U.S. Nuclear Regulatory Commission (NRC) Office of Investigations at the South Texas Project Electric Generating Station. The investigation was conducted, in part, to determine if a contract employee willfully provided incomplete or inaccurate information to STP Nuclear Operating Company regarding a fuel handling incident that resulted in damaged fuel bundles. Enclosure 1 provides a factual summary of the basis for the NRCs concern that willfulness was associated with an apparent violation in this case. The issue was discussed with you and other members of your staff during a telephone conversation on May 28, 2020.
Based on the information acquired during the investigation, one apparent violation was identified and is being considered for escalated enforcement action in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The apparent violation is of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.9(a), which requires, in part, that information required by the Commissions regulations, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects. Specifically, in a written statement collected on March 31, 2017, and incorporated into the licensees root cause evaluation of the incident, the contract refueling spotter/supervisor failed to provide complete and accurate information by omitting the material fact that an unqualified trainee operated the refueling machine during the incident. Further details regarding this apparent violation are documented in Enclosure 2 to this letter.
The circumstances surrounding the apparent violation, the significance of the issue, and the need for lasting and effective corrective action were discussed with you at the inspection exit meeting on May 28, 2020. Additionally, Enclosure 2 documents one finding of very low safety significance (Green), which involved a violation of NRC requirements. The NRC is treating this as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy. Before the NRC makes its enforcement decision, we are providing you an opportunity to:
(1) respond in writing to the apparent violation addressed in this inspection report within 30 days of the date of this letter; (2) request a predecisional enforcement conference (PEC); or (3) request alternative dispute resolution (ADR) mediation. If a PEC is held, the PEC will be closed to public observation since information related to an Office of Investigations report will be discussed and the report has not been made public. If you decide to participate in a PEC or pursue ADR, please contact Mr. Jeffrey Josey, Chief, Projects Branch A, at 817-200-1148 within 10 days of the date of this letter. A PEC should be held within 30 days and an ADR session within 45 days of the date of this letter.
If you choose to provide a written response, it should be clearly marked as a Response to Apparent Violation in NRC Inspection Report 05000498/2020090; 05000499/2020090; EA-19-054 and should include for the apparent violation: (1) the reason for the apparent violation or, if contested, the basis for disputing the apparent violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken, and (4) the date when full compliance will be achieved. Your response may reference or include previously docketed correspondence if the correspondence adequately addresses the required response.
Additionally, your written response should be sent to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Director, Division of Reactor Projects, U.S. Nuclear Regulatory Commission, Region IV, 1600 E. Lamar Blvd., Arlington, TX 76011-4511 and emailed to R4Enforcement@nrc.gov within 30 days of the date of this letter. If an adequate response is not received within the time specified or an extension of time has not been granted by the NRC, the NRC will proceed with its enforcement decision or schedule a PEC.
If you choose to request a PEC, the conference will afford you the opportunity to provide your perspective on these matters and any other information that you believe the NRC should take into consideration before making an enforcement decision. The decision to hold a PEC does not mean that the NRC has determined that a violation has occurred or that enforcement action will be taken. This conference would be conducted to obtain information to assist the NRC in making an enforcement decision. The topics discussed during the conference may include information to determine whether a violation occurred, information to determine the significance of a violation, information related to the identification of a violation, and information related to any corrective actions taken or planned.
In lieu of a PEC, you may also request ADR with the NRC in an attempt to resolve this issue.
Alternate Dispute Resolution is a general term encompassing various techniques for resolving conflicts using a neutral third party. The technique that the NRC has decided to employ is mediation. Mediation is a voluntary, informal process in which a trained neutral mediator works with parties to help them reach resolution. If the parties agree to use ADR, they select a mutually agreeable neutral mediator who has no stake in the outcome and no power to make decisions. Mediation gives parties an opportunity to discuss issues, clear up misunderstandings, be creative, find areas of agreement, and reach a final resolution of the issues.
Additional information concerning the NRCs ADR program can be obtained at http://www.nrc.gov/about-nrc/regulatory/enforcement/adr.html. The Institute on Conflict Resolution (ICR) at Cornell University has agreed to facilitate the NRC's program as a neutral third party. Please contact ICR at 877-733-9415 within 10 days of the date of this letter if you are interested in pursuing resolution of this issue through ADR.
In addition, please be advised that the number and characterization of the apparent violation described in Enclosure 2 may change as a result of further NRC review. You will be advised by separate correspondence of the results of our deliberations on this matter.
For administrative purposes, this letter and its enclosures are issued as NRC Inspection Report 05000498/2020090; 05000499/2020090. The apparent violation will be issued as AV 05000498/2020090-01 and the finding and associated NCV will be issued as NCV 05000498/2020090-02, both as described in Enclosure 2.
If you contest the violation or significance of the NCV, 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 205550001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the South Texas Project Electric Generating Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; to the Regional Administrator, Region IV; and the NRC resident inspector at the South Texas Project Electric Generating Station.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter, its enclosures, and your responses, if you choose to provide them, will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs ADAMS, accessible from the NRC Web site 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.
However, you should be aware that all final NRC documents, including the final Office of Investigations report, are official agency records and may be made available to the public under the Freedom of Information Act, subject to redaction of certain information in accordance with the Freedom of Information Act. If you have any questions concerning this matter, please contact Mr. Jeffrey Josey of my staff at 817-200-1148.
Sincerely, Michael Hay, Director (Acting)
Division of Reactor Projects
Docket Nos. 05000498 and 05000499 License Nos. NPF-76 and NPF-80
Enclosures:
1. Factual Summary 2. Inspection Report 05000498/2020090; 05000499/2020090
Inspection Report
Docket Numbers:
05000498, 05000499
License Numbers:
Report Numbers:
05000498; 05000499/2020090
Enterprise Identifier: I-2020-090-0005
Licensee:
STP Nuclear Operating Company
Facility:
South Texas Project Electric Generating Station, Units 1 and 2
Location:
Wadsworth, TX 77483
Inspection Dates:
June 30, 2017, to March 4, 2020
Inspectors:
R. Alexander, Senior Project Engineer
A. Athar, Project Engineer
A. Sanchez, Senior Resident Inspector
Approved By:
Jeffrey E. Josey, Chief
Reactor Project Branch A
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an inspection at South Texas Project Electric Generating Station,
Units 1 and 2, 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.
NRC identified and self-revealed findings, violations, and additional items are summarized in the
table below.
List of Findings and Violations
Failure to Maintain a Quality Record Complete and Accurate in All Material Respects
Cornerstone
Significance
Cross-cutting
Aspect
Inspection
Procedure
Not
Applicable
Apparent Violation
Open
Not
Applicable
The inspectors identified an apparent violation of 10 CFR 50.9(a), for the licensees failure to
maintain information required by the Commissions regulations as complete and accurate in all
material respects. Specifically, following a fuel handling event during the South Texas Project
Electric Generating Station (STP) Unit 1 refueling outage, on March 31, 2017, the licensee
failed to maintain complete and accurate information in the form of written statements collected
for the root cause evaluation Condition Report CR 17-13662 relative to the cause of the
damage to the fuel assemblies.
Failure to Follow Procedures Relative to Required Training and Prescribed Movements for
Fuel Handling Activities
Cornerstone
Significance
Cross-cutting
Aspect
Inspection
Procedure
Barrier
Integrity
Green
Closed
[H.2] - Field
Presence
The inspectors identified a Green, non-cited violation (NCV) of 10 CFR 50, Appendix B,
Criterion V, for the licensees failure to perform activities affecting quality in accordance with
documented instructions, procedures, or drawings, of a type appropriate to the circumstances.
Specifically, during the spring 2017, Unit 1 refueling outage, personnel failed to follow licensee
Procedure 0POP08-FH-0001 Refueling Machine Operating Instruction, Revision 46, an
Appendix B quality-related procedure, relative to fuel handling and operation of the refueling
machine, and the requisite training for the use of the equipment. The failure to follow the
procedure resulted in the damage of two fuel bundles, rendering them unusable for future
power operations, though there was no measurable release of radionuclides from the
damaged bundles.
Additional Tracking Items
None.
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 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
71153 - Follow-up of Events and Notices of Enforcement Discretion
Personnel Performance (IP Section 03.03) (1 Sample)
The inspectors evaluated the circumstances surrounding the licensees performance in
response to damage to two fuel assemblies during core offload operations at the South Texas
Project Electric Generating Station (STP), Unit 1 on March 30, 2017.
INSPECTION RESULTS
Failure to Maintain a Quality Record Complete and Accurate in All Material Respects
Cornerstone
Significance/Severity
Cross-cutting
Aspect
Inspection
Procedure
Not Applicable
Apparent Violation
Open
Not
Applicable
The inspectors identified an apparent violation of 10 CFR 50.9(a), for the licensees failure to
maintain information required by the Commissions regulations as complete and accurate in
all material respects. Specifically, following a fuel handling event during the STP Unit 1
refueling outage, on March 31, 2017, the licensee failed to maintain complete and accurate
information in the form of written statements collected for the root cause evaluation Condition
Report CR 17-13662 relative to the cause of the damage to the fuel assemblies.
Description: On the morning of March 30, 2017, during a refueling outage at STP Unit 1,
three contract personnel and one STP licensed senior reactor operator/core load
supervisor (SRO/CLS) conducted core offload operations. Procedural noncompliances and a
series of human performance errors resulted in two damaged fuel bundles that were rendered
unusable for future power operations. The damage occurred during fuel bundle movement
from core location G-3 which was conducted contrary to site procedures, and was conducted
by a non-certified trainee operating the refueling machine.
Over the subsequent days, the licensee initiated a root cause evaluation team to review the
circumstances that led to the damaged fuel bundles. Consistent with site procedures, on
March 31, 2017, the licensees evaluation team collected written statements from three of the
four individuals involved in the event. The evaluation team initially only collected statements
from the refuel machine operator, the refueling spotter/supervisor, and the STP SRO/CLS. At
that time, the evaluation team was not aware that a fourth individual (a trainee) was on the
bridge and involved in the event. The refuel machine operators statement identified by name
those individuals involved in the event, but made no mention of the additional member
(trainee) on the bridge nor his actions during the incident. The refueling spotter/supervisors
written statement focused on the technical aspects of the fuel bundle move from location G-3
and, except for mentioning the titles of two other crew members, the STP refuel machine
operator and STPs SRO/CLS, he did not mention the trainee or any crew members by name.
The SRO/CLSs written statement also relayed the technical aspects of the fuel bundles
movement and referred to the refuel machine operator and refueling spotter/supervisor by
titles only, remaining silent regarding the fourth individual. The written statements were
material to and incorporated into the licensees root cause evaluation. These statements
were cited as reference 17 of the evaluation.
Approximately three weeks later, the licensees evaluation team reviewed video of refuel
bridge activities on the day of the event and identified an unknown person operating the
refueling controls at the time of the incident. The unknown individual was later determined to
be a trainee. The licensees evaluation team contacted the SRO/CLS who confirmed the
fourth individual was an under instruction trainee. Due to the lack of discussion in the three
written statements of the trainees involvement during the incident, the licensee conducted
additional investigations to understand the inconsistencies and to assess whether the
omission of the trainee in the written statements was intentional. When contacted by the
licensee evaluation team, the trainee confirmed that he was at the controls of the refueling
machine when the incident occurred. Although the trainee believed his supervisor (refueling
spotter/supervisor) had obtained the appropriate authorization, the licensees investigation
determined that the trainee did not meet the sites requirements to be under instruction.
Corrective Actions: The licensee removed site access for the three contract personnel
suspected of providing incomplete/inaccurate information with appropriate entries into the
personnel access database system entries for each individual.
As a result of the incomplete and inaccurate information included in the licensees corrective
action program, relative to the written statements provided by the involved individuals, the
NRC has identified an apparent violation of 10 CFR 50.9(a), Completeness and Accuracy of
Information.
Corrective Action Reference: CR 17-13662
Enforcement:
Severity: The ROPs significance determination process does not specifically consider
willfulness in its assessment of licensee performance. Therefore, it is necessary to address
this violation which involves willfulness using the traditional enforcement process. The
severity of this apparent violation will be determined in accordance with the Enforcement
Policy pending a final enforcement determination.
Apparent Violation: 10 CFR 50.9(a) requires, in part, that information required by the
Commissions regulations, orders, or license conditions to be maintained by the licensee shall
be complete and accurate in all material respects.
10 CFR Part 50, Appendix B, Criterion XVII, requires, in part, that sufficient records shall be
maintained to furnish evidence of activities affecting quality. The licensee established quality
related Procedure 0PGP03-ZX-0002B, Station Cause Analysis Program, Revision 7, in part,
to implement the stations problem identification and resolution process, which includes the
evaluation, identification and resolution of significant conditions adverse to quality through
root cause analyses. Procedure 0PGP03-ZX-0002B, step 11.2.1, requires, in part, to collect
personal statements as part of the data collection to support the evaluation process.
Contrary to the above, on March 31, 2017, the licensee failed to maintain information required
by the Commissions regulations that was complete and accurate in all material respects.
Specifically, following core offload activities that resulted in damage to two fuel assemblies,
the licensee failed to maintain complete and accurate information in the form of written
statements collected for the root cause evaluation condition report CR 17-13662 relative to
the cause of the damage to the fuel assemblies. As part of the corrective action program, the
information supporting the root cause evaluation in the condition report CR 17-13662 was
material to the NRC because it is subject to NRC inspection and informs the NRCs review of
and response to incidents such as the underlying procedure violation.
Enforcement Actions: This violation is being treated as an apparent violation (AV) pending a
final significance enforcement determination.
Failure to Follow Procedures Relative to Required Training and Prescribed Movements for
Fuel Handling Activities
Cornerstone
Significance
Cross-cutting
Aspect
Inspection
Procedure
Initiating
Events
Green
Closed
H.2 - Field
Presence
The inspectors identified a Green, non-cited violation (NCV) of 10 CFR 50, Appendix B,
Criterion V, for the licensees failure to perform activities affecting quality in accordance with
documented instructions, procedures, or drawings, of a type appropriate to the
circumstances. Specifically, during the Spring 2017 Unit 1 refueling outage, licensee and
contract personnel failed to follow licensee Procedure 0POP08-FH-0001 Refueling Machine
Operating Instruction, Revision 46, an Appendix B quality-related procedure, relative to fuel
handling and operation of the refueling machine, and the requisite training for the use of the
equipment. The failure to follow the procedure resulted in the damage of two fuel bundles,
rendering them unusable for future power operations, though there was no measurable
release of radionuclides from the damaged bundles.
Description: On the morning of March 30, 2017, during a refueling outage at STP Unit 1,
three contract personnel and one STP SRO/CLS were conducting core offload operations. At
the time, the refuel machine operator, the refueling spotter/supervisor, and the STP SRO/CLS
were authorized to be on the bridge conducting movement of fuel bundles in accordance with
Procedure 0POP08-FH-0001, Refueling Machine Operating Instruction, Revision 46.
However, a fourth individual, a trainee, was also on the bridge observing fuel movement
activities under the instruction of the refuel machine operator.
As the work progressed, the refueling spotter/supervisor allowed the trainee to take control of
the machine "under instruction" and move 19 fuel bundles. During the movement of the 20th
bundle (from core location G-3), the trainee was supposed to be taking direction from the
refuel machine operator; however, the refuel machine operator became distracted viewing the
activities of the refueling spotter/supervisor and was not directly overseeing the actions of the
trainee. A combination of inadequate direct oversight and a failure to adhere to
Procedure 0POP08-FH-0001 for close-contact fuel movements resulted in the trainee taking
actions that caused the fuel bundle to contact an adjacent fuel bundle. This resulted in
damage to both fuel bundles and rendered them unusable for future power operations.
Subsequently, the licensee determined that by allowing the trainee to operate the fuel
handling machine, the refueling spotter/supervisor and STP SRO/CLS had not followed the
requirements of Procedure 0POP08-FH-0001, step 4.53. This procedure step requires, in
part, that each individual assigned to move fuel with the refueling machine shall have
completed: (1) on-the-job training activity (OJT-FH-8303, Refueling Machine Operator) or
Westinghouse Qualification 50004444, Refueling Machine; and (2) have previous experience
moving fuel at STP, moved a dummy fuel assembly at STP, or equivalent experience with
similar equipment at other sites with instruction on operating refueling equipment at STP.
The trainee had not completed either of the requirements of the STP procedure to be allowed
to operate the fuel handling machine (independently or under instruction).
Corrective Actions: The licensee's Root Cause Evaluation (CR 17-13662) directed corrective
actions to address: (1) the underlying technical violation (e.g., additions to procedures
relative to close contact fuel movements and strict compliance with those fuel handling
guidelines), (2) enhanced oversight of vendor activities and conformance with station
standards relative to fuel handling vendors, (3) specific requirements for the vendor trainee
authorization process, and (4) additional training for SRO/CLS on their roles/responsibilities
and specifics regarding the fuel handling guidelines.
Corrective Action References: CR 17-13662
Performance Assessment:
Performance Deficiency: Licensee and contract personnel failure to follow licensee
Procedure 0POP08-FH-0001, Refueling Machine Operating Instruction, Revision 46, an
Appendix B quality-related procedure, relative to fuel handling and operation of the refueling
machine, and the requisite training for use of the equipment, was determined to be a
performance deficiency. The failure to follow the procedure resulted in the damage of
two fuel bundles, rendering them unusable for future power operations, though there was no
measurable release of radionuclides from the damaged bundles.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Human Performance attribute of the Barrier Integrity
Cornerstone and adversely affected the cornerstone objective to provide reasonable
assurance that physical design barriers protect the public from radionuclide releases caused
by accidents or events. Specifically, the failure of the contract personnel and STP SRO/CLS
to follow training requirements and fuel movement guidelines in the licensee's fuel handling
activities procedure directly resulted in damage to two fuel bundle.
Significance: The inspectors assessed the significance of the finding using Appendix A, The
Significance Determination Process (SDP) for Findings At-Power. Specifically, using
Exhibit 3 to Appendix A, the inspectors determined that the finding did not (1) adversely affect
decay heat removal capabilities from the spent fuel pool, (2) result in a loss of fuel pool
inventory, nor (3) adversely affected the spent fuel pool neutron absorber, fuel bundle
misplacement, or soluble boron concentration levels. While the finding did result from fuel
handling errors that caused mechanical damage to two fuel bundles, it did not result in a
detectable release of radionuclides. Therefore, the finding was determined to be of very low
safety significance (Green).
Cross-Cutting Aspect: H.2 - Field Presence: Leaders are commonly seen in the work areas
of the plant observing, coaching, and reinforcing standards and expectations. Deviations from
standards and expectations are corrected promptly. Senior managers ensure supervisory and
management oversight of work activities, including contractors and supplemental
personnel. Specifically, the STP SRO/CLS (a licensee leader) failed to directly supervise all
core alterations, ensure compliance with procedures, and maintain overall responsibility for
direction of fuel handling activities, resulting in damage to the two fuel bundles.
Enforcement:
Violation: 10 CFR 50, Appendix B, Criterion V, requires, in part, that activities affecting
quality shall be accomplished in accordance with documented instructions, procedures, or
drawings, of a type appropriate to the circumstances.
Licensee Procedure 0POP08-FH-0001 Refueling Machine Operating Instruction,
Revision 46, an Appendix B quality-related procedure, provides instructions to station
personnel relative to the fuel handling and operation of the refueling machine and associated
equipment, and the training required to operate the fuel handling equipment. Specifically,
Procedure 0POP08-FH-0001:
- Step 4.53 requires, in part, that each individual assigned to move fuel with the
refueling machine shall have completed on-the-job training activity (OJT-FH-8303,
Refueling Machine Operator) or Westinghouse Qualification 50004444, Refueling
Machine. In addition, previous experience moving fuel at STP, movement of a dummy
fuel assembly at STP, or equivalent experience with similar equipment at other sites
with instruction on operating refueling equipment at STP, is also required of the
individual.
- Steps 4.42 and 4.43, and Addendums 4 and 5, provide specific fuel movement
guidelines relative to speed and direction of movement of a fuel assembly depending
on its location and orientation to other fuel assemblies in the core (i.e., close contact
and open water fuel assembly movements).
Contrary to the above, on March 30, 2017, licensee personnel failed to accomplish an activity
affecting quality in accordance with a documented procedure of a type appropriate to the
circumstances. Specifically, licensee personnel allowed a contract employee (i.e., trainee),
who had not completed the requisite training attributes described in step 4.53 of
Procedure 0POP08-FH-0001, to operate the STP Unit 1 refueling machine and move 20 fuel
assemblies from the Unit 1 core. Additionally, during the movement of the fuel by the trainee,
the licensee failed to follow the fuel assembly movement guidelines as described in
Procedure 0POP08-FH-0001 (steps 4.42 and 4.43, and Addendums 4 and 5) resulting in
damage to two fuel bundles.
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 confirmed that proprietary information was controlled to protect from public
disclosure.
On May 28, 2020, the NRC staff presented the inspection results to G.T. Powell, President and
CEO, and other members of the licensee staff in a telephonic exit meeting. The NRC staff
verified no proprietary information was retained or documented in this report.
SUNSI Review:
ADAMS:
Non-Publicly Available Non-Sensitive
Keyword:
By: JGK
Yes No
Publicly Available
Sensitive
OFFICE
SPE:DRS/RCB
SPE:DRP/A
BC:DRP/A
TL:ACES
RC
NAME
RAlexander
HFreeman
JJosey
JGroom
DCylkowski
TSteinfeldt
SIGNATURE
/RA/ E
/RA/ E
/RA/ E
/RA/ E
/RA/ E
/NOA/
DATE
05/31/20
06/01/20
06/03/20
06/02/20
06/03/20
07/02/2020
OFFICE
D:DRP
NAME
THipschman
MHay
SIGNATURE
/RA/E
/RA/
DATE
06/25/2020
07/06/2020