ML17208A090

From kanterella
Jump to navigation Jump to search

Relief Request I4R-17 Associated with the Alternate Repair of a 2-Inch Instrument Line Nozzle at Penetration N-16D on the Reactor Pressure Vessel
ML17208A090
Person / Time
Site: Limerick Constellation icon.png
Issue date: 08/14/2017
From: James Danna
Plant Licensing Branch 1
To: Bryan Hanson
Exelon Nuclear
Sreenivas V, NRR/DORL/LPLI, 415-2597
References
CAC MF9702
Download: ML17208A090 (12)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 14,2017 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LIMERICK GENERATING STATION, UNIT 2 - RELIEF REQUEST 14R-17, ASSOCIATED WITH THE ALTERNATE REPAIR OF A 2-INCH INSTRUMENT LINE NOZZLE AT PENETRATION N-16D ON THE REACTOR PRESSURE VESSEL (CAC NO. MF9702)

Dear Mr. Hanson:

By letter dated May 15, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17135A423), as supplemented by letter dated May 16, 2017 (ADAMS Accession No. ML17137A068), Exelon Generation Company, LLC (the licensee) requested relief from certain requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, at the Limerick Generating Station (Limerick), Unit 2. Specifically, the licensee requested approval for Relief Request 14R-17, associated with the alternate repair of a 2-inch instrument line nozzle at penetration N-16D on the reactor pressure vessel. Pursuant to Title 1O of the Code of Federal Regulations (10 CFR) 50.55a(z)(1 ), the licensee requested to use the proposed alternative on the basis that complying with the specified requirement would provide an acceptable level of quality and safety.

On May 17, 2017 (ADAMS Accession No. ML17137A307), the U.S. Nuclear Regulatory Commission (NRC) verbally authorized the use of Relief Request 14R-17 at Limerick, Unit 2, for the repair of the 2-inch instrument line nozzle at penetration N-16D on the RPV for one fuel cycle following the Spring 2017 refueling outage. Subsequently, by letter dated June 1, 2017 (ADAMS Accession No. ML17152A305), the licensee submitted an analyzed flaw evaluation, design analysis, and updated corrosion evaluation.

The NRC staff has determined the licensee demonstrated that the proposed alternative provides an acceptable level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(1 ).

Therefore, the NRC staff authorizes the use of Relief Request 14R-17 at Limerick, Unit 2, for one operating cycle following the Spring 2017 refueling outage of the fourth 10-year inservice inspection interval, which began on February 1, 2017, and will conclude on January 31, 2027.

All other requirements of ASME Code,Section XI, for which relief has not been specifically requested and approved in this relief request remain applicable, including third party review by the Authorized Nuclear lnservice Inspector.

B. Hanson If you have any questions, please contact the Limerick Project Manager, Dr. V. Sreenivas, at 301-415-2597 or V.Sreenivas@nrc.gov.

Sincerely, James G. Danna, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-353

Enclosure:

Safety Evaluation cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST 14R-17 ALTERNATE REPAIR OF INSTRUMENT LINE NOZZLE AT REACTOR VESSEL EXELON GENERATION COMPANY, LLC LIMERICK GENERATING STATION. UNIT 2 DOCKET NO. 50-353

1.0 INTRODUCTION

By letter dated May 15, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17135A423), as supplemented by letter dated May 16, 2017 (ADAMS Accession No. ML17137A068), Exelon Generation Company, LLC (Exelon, the licensee), submitted Relief Request 14R-17 to request relief from the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code)

Section XI, 2007 Edition through 2008 Addenda, regarding repair of a 2-inch instrument line nozzle at penetration N-16D on the reactor pressure vessel (RPV) at Limerick Generating Station (Limerick), Unit 2.

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z)(1 ),

Exelon requested to use the proposed alternative on the basis that the alternative provides an acceptable level of quality and safety.

On May 17, 2017 (ADAMS Accession No. ML17137A307), the U.S. Nuclear Regulatory Commission (NRG) verbally authorized the use of Relief Request 14R-17 at Limerick, Unit 2, for the repair of the 2-inch instrument line nozzle at penetration N-16D on the RPV for one fuel cycle following the Spring 2017 refueling outage. Subsequently, by letter dated June 1, 2017 (ADAMS Accession No. ML17152A305), the licensee submitted an analyzed flaw evaluation, design analysis, and updated corrosion evaluation.

2.0 REGULATORY EVALUATION

Adherence to Section XI of the ASME Code is mandated by 10 CFR 50.55a(g)(4), which states that ASME Code Class 1, 2, and 3 components will meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in Section XI of the ASME Code.

The regulation in 10 CFR 50.55a(z) states that alternatives to the requirements of paragraphs (b) through (h) of 10 CFR 50.55a, or portions thereof, may be used when authorized by the Director, Office of Nuclear Reactor Regulation. A proposed alternative must be

submitted and authorized prior to implementation. The licensee must demonstrate that: (1) the proposed alternatives provide an acceptable level of quality and safety, or (2) compliance with the specified requirements would result in hardship or unusual difficulty, without a compensating increase in the level of quality and safety.

Based on the above, and subject to the following technical evaluation, the NRC staff finds that regulatory authority exists for Exelon to request the use of an alternative and the NRC to authorize the proposed alternative.

3.0 TECHNICAL EVALUATION

3.1 ASME Code Component Affected Code Class:

Reference:

IWB-2500, Table IWB-2500-1 Exam Category: B-P Item Number: B15.10

Description:

RPV Instrument Penetration inch Nominal Pipe Size Component Number: N-16D 3.2 Applicable Code Edition and Addenda The current edition for the inservice inspection interval is the ASME Code,Section XI, 2007 Edition with the 2008 Addenda. The code of construction for the RPV is the ASME Code Section Ill, 1968 Edition up to, and including, Summer 1969 Addenda, except that Article 4 of the Winter 1969 Addenda applies.

3.3 Applicable Code Requirements Subarticles of the ASME Code,Section XI, contain the following provisions regarding flaw removal and flaw evaluation.

Flaw Removal

  • IWA-5250(a)(3) states, "Components requiring corrective action shall have repair/replacement activities performed in accordance with IWA-4000 or corrective measures performed where the relevant condition can be corrected without a repair/replacement activity."
  • IWA-4412 states, "Defect removal shall be accomplished in accordance with the requirements of IWA-4420."
  • IWA-4611.1 (a) states, "Defects shall be removed in accordance with IWA-4422.1. A defect is considered removed when it has been reduced to an acceptable size."
  • Subsection N-528 of the ASME Code, Section Ill, 1968 Edition up to, and including, Summer 1969 Addenda, except that Article 4 of the Winter 1969 Addenda applies, requires repair of weld defects including removal of defects detected by leakage tests.

Flaw Evaluation

  • IWB-3522.1 states, in part, "A component whose visual examination (IWA-5240) detects any of the following relevant conditions shall meet IWB-3142 and IWA-5250 prior to continued service ... "
  • IWB-3142.1 (b) states, "A component whose visual examination detects the relevant conditions described in the standards of Table IWB-3410-1 shall be unacceptable for continued service, unless such components meet the requirements of IWB-3142.2, IWB-3142.3, or IWB-3142.4."
  • IWA-3300(a) states, in part, "Flaws detected by the preservice and inservice examinations shall be sized ... "
  • IWA-3300(b) states, in part, "Flaws shall be characterized in accordance with IWA-3310 through IWA-3390, as applicable ... "
  • IWB-361 O(b) states, in part, "For purposes of evaluation by analysis, the depth of flaws in clad components shall be defined in accordance with Fig. IWB-3610-1 ... "
  • The implementing reply of ASME Code Case N-749 states, "It is the opinion of the Committee that, in lieu of IWB-3610 and IWB-3620, flaws in ferritic steel components operating in the upper shelf temperature range may be evaluated using the following acceptance criteria." The methods and criteria of N-749 are based on the methods of elastic-plastic fracture mechanics.
  • IWB-3420 states, "Each detected flaw or group of flaws shall be characterized by the rules of IWA-3300 to establish the dimensions of the flaws. These dimensions shall be used in conjunction with the acceptance standards of IWB-3500."

Peening NB-4422 of the ASME Code, Section Ill, states, "Controlled peening may be performed to minimize distortion. Peening shall not be used on the initial layer, root of the weld metal, or on the final layer unless the weld is postweld heat treated."

3.4 Reason for Alternative On May 8, 2017, during the Limerick, Unit 2, refueling outage (Li2R14), Exelon conducted pre-startup leakage testing of the RPV. During the testing, Exelon personnel discovered a leak of approximately one pint per minute between the RPV wall and a 2-inch instrument line nozzle at penetration N-16D. Exelon proposed to partially replace the existing nozzle assembly with a nozzle penetration that is resistant to intergranular stress corrosion cracking (IGSCC).

Exelon proposed to apply a welded pad to a preexisting weld pad on the outer diameter (OD) of the RPV using IGSCC-resistant nickel-based Alloy 52M (ERNiCrFe-7 A) filler metal. The

preexisting weld pad was installed as part of the RPV initial design. The new weld pad was to be welded using the machine gas tungsten arc welding (GTAW) ambient temperature temper bead (ATTB) welding technique. Exelon proposed to attach an IGSCC resistant nozzle to the new weld pad with a partial penetration weld using a non-temper bead manual welding technique using IGSCC-resistant, nickel-based Alloy 52M filler metal.

Exelon stated that the original partial penetration attachment weld and a remnant of the original nozzle will remain in place as part of the proposed alternative. After repair, Exelon proposed a flaw evaluation 14 days after the startup of Li2R14. The flaw evaluation will demonstrate the acceptability of leaving the original partial penetration attachment weld with a maximum postulated flaw in place. The defect on N-16D will not be removed in accordance with ASME Code paragraphs IWA-441 O and IWA-4611; therefore, relief was sought from these requirements.

In support of the flaw evaluation to applicable acceptance criteria, the ASME Code paragraphs IWB-3420 and IWB-361 O(b) require characterization of the flaw in the leaking penetration. Although demonstrated, there is not a qualified technique to perform non-destructive examination of the existing partial penetration J-groove weld in this configuration that can be used to accurately characterize the location, orientation, or size of a flaw in the weld. If any leakage is observed prior to performing the J-groove weld, peening would be required to stop the leakage.

This contingent activity would be used to seal the unacceptable indication, and peening is not allowed on the initial layer, unless the weld is post-heat treated per NB-4422 of the ASME Code, Section Ill; therefore, relief is requested. Exelon requested relief to install a welded pad using the ATTB welding technique in accordance with ASME Code Case N-638-4, "Similar and Dissimilar Metal Welding Using Ambient Temperature Machine (GTAW) Temper Bead Technique,Section XI, Division 1." The NRC has conditionally approved ASME Code Case N-638-4 to allow the use of the ATTB welding technique of dissimilar materials in Regulatory Guide 1.147, Revision 17, "lnservice Inspection Code Case Acceptability, ASME Section XI, Division 1" (ADAMS Accession No. ML13339A689).

3.5 Licensee's Proposed Alternative Exelon proposes the following alternatives to the requirements specified above on the basis that they provide an acceptable level of quality and safety:

  • As an alternative to flaw removal or reduction in size to meet the applicable acceptance standards paragraph IWA-5250(a)(3) of the ASME Code,Section XI, Exelon proposes to implement an OD repair of the RPV instrument nozzle N-16D utilizing an OD weld pad as described in the repair of nozzle penetration section below.
  • As an alternative to performing the non-destructive examination required to characterize the flaw under paragraphs IWB-3420 and IWB-361 O(b) of the ASME Code,Section XI, in penetration N-16D, Exelon proposes analyzing a maximum postulated flaw that bounds the range of flaw sizes that could exist in the original J-groove weld and nozzle.
  • As an alternative to performing post-weld heat treatment of the weld under NB-4422 of the ASME Code, Section Ill, Exelon proposes to allow peening on the initial layer of the weld material, if necessary, to seal the unacceptable indication. The thickness

of this layer will not be used in meeting the weld reinforcement design thickness requirements.

  • As an alternative to NB-4620 of the ASME Code, Section Ill, relief is requested to install a welded pad using ATTB welding in accordance with ASME Code Case N-638-4. The NRC has conditionally approved ASME Code Case N-638-4 to allow ATTB welding of dissimilar materials.

3.6 Basis for Use Pre-Installation Inspection During Li2R 14, Exelon discovered a leak at the instrument penetration nozzle N-16D located on the RPV. Visual examination detected active leakage at the nozzle interface (annular gap) with the RPV OD during the Class 1 system leakage test.

Design The Limerick, Unit 2, RPV is manufactured from SA-533, Grade B, quenched and tempered low alloy steel that has an inner diameter clad with stainless steel. There is an existing 2-inch thick nozzle reinforcement weld buildup at nozzle N-16D on the outside of the RPV shell that was installed using E8018-NM weld material. The RPV instrument penetrations are fabricated with Alloy 600 components. Enclosure 1 of the licensee's submittal included a sketch of nozzle N-16D.

Extent of Condition As a result of the leak identified on nozzle N-16D, Exelon performed a bare metal visual examination (VT-2) on all nozzles with the same design as nozzle N-16D, at a minimum pressure of 1,045 pounds per square inch gauge. This examination looked for evidence of through-wall leakage, degradation due to corrosion of a pressure retaining boundary, and evidence of pressure/flow loss or flow impairment. Exelon visually examined nine nozzles (N-16A, N-16B, N-16C, N-11 A, N-11 B, N-12A, N-12B, N-12C, and N-12D), and there was no evidence of leakage identified on any of the nozzles during the examination.

Installation The pre-planned steps of the repair are described below. Any changes to the plan detailed below remain in compliance with applicable ASME Code requirements. Exelon performed the repair as discussed below in accordance with ASME Code,Section XI, 2007 Edition with the 2008 Addenda.

1. Cut the existing nozzle outboard of the RPV.
2. Install/attach studs on the RPV shell for boring tool.
3. Bore to partially remove the existing N-16D nozzle.
4. Measure the bore.
5. Perform surface and volumetric examinations on the preexisting weld pad in preparation for the new weld pad.
6. Bore for weld dam.
7. Measure bore.
8. Machine, inspect, and perform a surface examination of the weld dam.
9. Install the weld dam. The weld dam will have an 0-ring to keep any leaking water from the nozzle from affecting deposition of the new weld pad.
10. Deposit the new weld pad in accordance with ASME Code Case N-638-4.
11. Perform post-weld grinding of the weld pad.
12. Inspect the weld pad's dimension.
13. Start the 48-hour hold after completing the third layer of the new weld pad in accordance with ASME Code Case N-638-4.
14. Perform a surface examination of weld pad and radial band around weld pad.
15. Perform ultrasonic testing of weld pad and radial band around weld pad.
16. Bore the weld pad to the final replacement nozzle size and remove the weld dam.
17. Measure and perform a surface examination of the final bore.
18. Machine, inspect, and perform a surface examination of the replacement nozzle.
19. Weld new reducing insert to nozzle.
20. Inspect and perform a surface examination of the nozzle-reducing insert weld.
21. Machine J-prep in the weld pad.
22. Inspect and perform a surface examination of the J-groove weld.
23. Install/weld replacement nozzle. Surface conditioning may be completed on the root pass to keep the area dry the remainder of the welding. The root pass will not be credited for the structural strength of the weld.
24. Inspect and perform a surface examination of the nozzle weld.
25. Install the piping and perform a surface examination.
26. Remove studs attached to RPV shell for boring tool.
27. Perform surface examination of RPV at stud attachment locations in accordance with the ASME Code, Section Ill.
28. Remove sealing plug.

Acceptance Examination After the repair, Exelon performed a visual examination from the RPV inner diameter using a black and white camera at nozzle N-16D location. The examination volume encompassed the Alloy 82 weld overlay and the outer portions of the Alloy 600 nozzle bore. No surface cleaning was performed prior to examination. Although there was a suspect area, there were no apparent crack-like indications observed on either the weld overlay or the nozzle bore.

Exelon also performed an ultrasonic testing examination on the N-16D J-groove weld from the RPV OD in accordance with topical report BWRVIP-03, Revision 19, "BWR Vessel and Internals Project, Reactor Pressure Vessel and Internals Examination Guidelines." The examination volume included the J-groove weld, weld butter, and RPV low alloy steel interface. Exelon stated that the weld overlay and nozzle could not be distinguished with this volumetric technique. Exelon did not identify crack-like indications in the RPV low alloy steel or the Alloy 182 weld butter. Several aligned fabrication-like flaws were detected along the nozzle to J-groove weld fusion line, although IGSCC could not be ruled out. Exelon stated that as the lnconel 82 weld overlay at the RPV inner diameter surface could not be distinguished by this examination, no determination of whether the fabrication defects were open to the surface could be made. No definitive crack or leak path was observed; however, this examination provides reasonable confidence that the flaw has not propagated into the RPV low alloy steel.

3.7 Duration of Alternative The licensee stated that the alternative is applicable to one operating cycle of the fourth 10-year inservice inspection interval, which began on February 1, 2017, and will conclude on January 31, 2027.

4.0 NRC STAFF EVALUATION Exelon identified a leak of approximately one pint per minute between the RPV wall and a 2-inch instrument line nozzle at penetration N-16D during the pre-startup testing for Li2R14.

The NRC staff evaluated the licensee's proposed alternative, weld design, flaw evaluations, welding, and examinations in accordance with ASME Code, Sections Ill and XI, and Code Case N-638-4. The NRC staff also evaluated any deviations from the applicable ASME Code requirements included in the proposed alternative. Exelon identified these deviations as "relief,"

and the staff used the same designation for consistency.

4.1 Repair and Non-Destruction Examination of N-16D Nozzle The N RC staff notes that Exelon replaced the N-16D nozzle with a nozzle penetration that is made of nickel-based Alloy 690, which is less susceptible to IGSCC and meets ASME Code, Sections Ill and XI, and Code Case N-638-4. To repair it, the licensee completed a partial replacement technique where a portion of the existing nozzle remains in place, and a welded pad was applied to the existing weld buildup pad at the OD of the RPV, using nickel-based Alloy 52M filler metal, which is less susceptible to IGSCC. The replacement nozzle is attached to the new weld pad with a partial penetration weld.

The NRC staff notes that the reinforcement pad was welded using the machine GTAW ATTB welding technique, the requirements established by ASME Code Case N-638-4. The requirements for performing the ATTB welding technique as an alternative to preheat and post-weld heat treatment requirements of the construction code is in ASME Code Case N-638-4. ASME Code Case N-638-4 requires that the final weld surface shall be examined using a surface and volumetric method when the completed weld has been at ambient temperature for at least 48 hours2 days <br />0.286 weeks <br />0.0658 months <br />. However, the NRC staff finds acceptable that Exelon will perform these examinations based on a 48-hour hold time after completing the third layer of the new weld pad. ASME Code Case N-638-4 has been conditionally approved for use by the NRC with the conditions that: (1) the ultrasonic examinations shall be demonstrated for the repaired volume using representative samples, which contain construction type flaws, and that (2) the provisions of 3(e)(2) of ASME Code Case N-638-4 only be used when 3(e)(1) is found to be impractical. The NRC staff notes that the proposed alternative satisfies these two conditions.

The NRC staff has determined that Exelon welded the replacement nozzle to the new weld pad, which is welded on the RPV, using a non-temper bead manual welding technique in accordance with the ASME Code Section XI, 2007 Edition with the 2008 Addenda. The NRC staff finds this acceptable because Exelon followed the welding requirements of the ASME Code,Section XI, for the similar metal welds.

Exelon further noted that following the completion of the repair, the weld, the heat affected zone, and the E8018-NM weld buildup beneath the Alloy 52M pad were examined by ultrasonic testing examination, in accordance with ASME Code, Section Ill, Division 1, 2007 Edition through 2008 Addenda, NB-5300. Section Ill NB-2530 was used for the remaining applicable portion of the vessel shell base material. The liquid dye penetrant examination was chosen to

verify that no unacceptable defects were found on the weld pad within the bore area or the original base metal material. The liquid penetrant test was performed in accordance with ASME Code, Section Ill, Division 1, 2007 Edition through 2008 Addenda, NB-5111 (a) and NB-5350.

4.2 Loose Parts Evaluation This repair only replaced a portion of the existing nozzle; therefore, Exelon performed a loose parts evaluation to assess any potential for remnant nozzle segments or existing J-groove weld to enter the RPV during normal power operations. The NRC staff finds that the remnant nozzle and existing J-groove welds will not likely result in loose parts falling into the RPV. The NRC staff concluded that Exelon's loose parts evaluation is acceptable and that loose parts are not likely to pose any safety concerns.

4.3 Corrosion Evaluation Regarding the corrosion evaluation that was mentioned in the original submittal, the licensee submitted its synopsis of all corrosion testing performed and operating experiences reviewed from the industry. The corrosion evaluation addressed general corrosion, galvanic corrosion, crevice corrosion, and stress corrosion cracking in exposed low alloy steel, nickel-based Alloys 690 and 52M. The licensee provided data on each type of corrosion listed above and concluded that the repairs are acceptable with respect to corrosion.

The licensee stated that its corrosion evaluation references NEDC-21120, "Monticello Feedwater Nozzle Cladding Crack Repair Report," as the basis for low general corrosion rates and the absence of galvanic corrosion. The water chemistry in its reactor currently is considered to meet or exceed the requirements listed BWRVIP-190, "BWR [Boiling Water Reactor] Vessel and Internals Project, BWR Water Chemistry Guidelines," which are more stringent than NEDC-21120 but the water chemistry is less aggressive at Limerick, Unit 2.

Therefore, the corrosion rates given are very conservative.

The NRC staff finds the licensee's evaluation of the potential for general corrosion, galvanic corrosion, and crevice corrosion is based on laboratory testing and operating experience in BWRs under conditions that conservatively bound those at Limerick, Unit 2, and Exelon's corrosion evaluation is, therefore, acceptable.

The corrosion evaluation also included an evaluation of the potential for stress corrosion cracking of the exposed alloy steel, Alloys 690 and 52M. The NRC staff finds the licensee's evaluation is based on operating experience in BWRs and pressurized water reactors, where both indicate that these materials have a low susceptibility to stress corrosion cracking; Exelon's corrosion evaluation is, therefore, acceptable.

5.0 CONCLUSION

As set forth above, the NRC staff has determined that the licensee has demonstrated that the proposed alternative provides an acceptable level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(1 ). Therefore, the NRC staff authorizes the use of Relief Request 14R-17 at Limerick, Unit 2, for one operating cycle following the Spring 2017 refueling outage of the fourth 10-year inservice inspection interval, which began on February 1, 2017, and will conclude on January 31, 2027.

All other requirements of ASME Code,Section XI, for which relief has not been specifically requested and approved in this relief request remain applicable, including third party review by the Authorized Nuclear lnservice Inspector.

Principal Contributors: D. Render J. Tsao Date: August 14, 2017

B. Hanson

SUBJECT:

LIMERICK GENERATING STATION, UNIT 2 - RELIEF REQUEST 14R-17, ASSOCIATED WITH THE ALTERNATE REPAIR OF A 2-INCH INSTRUMENT LINE NOZZLE AT PENETRATION N-16D ON THE REACTOR PRESSURE VESSEL (CAC NO. MF9702) DATED AUGUST 14, 2017 DISTRIBUTION:

PUBLIC RidsNrrLALRonewicz Resource RidsNrrDorlLpl1 Resource RidsNrrPMLimerick Resource RidsACRS_MailCTR Resource RidsRgn1 MailCenter Resource RidsNrrDeEpnb Resource DRender, NRR JTsao, NRR ADAMS Access1on No.: ML17208A090 *b1v memoran d um OFFICE DORULPL 1/PM DORULPL 1/LA DE/EPNB/BC* DORULPL 1/BC DORULPL 1/PM NAME VSreenivas LRonewicz DAiiey JDanna VSreenivas DATE 07/31/2017 07/28/2017 07/19/2017 08/14/2017 08/14/2017 OFFICIAL RECORD COPY

Retrieved from "https://kanterella.com/w/index.php?title=ML17208A090&oldid=2082444"