ML17244A102
| ML17244A102 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, McGuire  |
| Issue date: | 09/25/2017 |
| From: | Michael Mahoney Plant Licensing Branch II |
| To: | Capps S Duke Energy Carolinas |
| Mahoney M, NRR/DORL/LPL2-1, 415-3867 | |
| References | |
| CAC MF9108, CAC MF9109 | |
| Download: ML17244A102 (17) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 25, 2017 Mr. Steven D. Capps Vice President McGuire Nuclear Station Duke Energy Carolinas, LLC 12700 Hagers Ferry Road Huntersville, NC 28078-8985
SUBJECT:
MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS ADOPTING TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-285-A, REVISION 1 (CAC NOS. MF9108 AND MF9109)
Dear Mr. Capps:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 299 to Renewed Facility Operating License No. NPF-9 and Amendment No. 278 to Renewed Facility Operating License No. NPF-17 for the McGuire Nuclear Station, Units 1 and 2, respectively. The amendments are in response to your application dated January 11, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17025A069).
The amendments modify Technical Specification (TS) 3.4.12, "Low Temperature Overpressure Protection (LTOP) System," to increase the time allowed for swapping charging pumps to one hour and deletion of existing Note in Required Action A.1. Additionally, an existing note in the Applicability section of TS 3.4.12 is reworded and relocated to the Limiting Condition for Operation section of TS 3.4.12 as Note 2. The proposed changes are consistent with NRC-approved Technical Specifications Task Force (TSTF) Traveler TSTF-285-A, Revision 1, "Charging Pump Swap LTOP Allowance."
S. Capps A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
s/h Michael Mahoney, Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-369 and 50-370
Enclosures:
- 1. Amendment No. 299 to NPF-9
- 2. Amendment No. 278 to NPF-17
- 3. Safety Evaluation cc w/enclosures: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY CAROLINAS, LLC DOCKET NO. 50-369 MCGUIRE NUCLEAR STATION. UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 299 Renewed License No. NPF-9
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment to the McGuire Nuclear Station, Unit 1 (the facility), Renewed Facility Operating License No. NPF-9, filed by Duke Energy Carolinas, LLC (the licensee), dated January 11, 2017, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
Enclosure 1
- 2. Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-9 is hereby amended to read as follows:
(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 299, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.
- 3. This license amendment is effective as of its date of issuance and shall be implemented within 120 days of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to Renewed License No. NPF-9 and Technical Specifications Date of Issuance: September 2 5, 2O1 7
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY CAROLINAS. LLC DOCKET NO. 50-370 MCGUIRE NUCLEAR STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 278 Renewed License No. NPF-17
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment to the McGuire Nuclear Station, Unit 2 (the facility), Renewed Facility Operating License No. NPF-17, filed by the Duke Energy Carolinas, LLC (the licensee), dated January 11, 2017, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- Enclosure 2
- 2. Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-17 is hereby amended to read as follows:
(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 278, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.
- 3. This license amendment is effective as of its date of issuance and shall be implemented within 120 days of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to Renewed License No. NPF-17 and Technical Specifications Date of Issuance: September 2 5, 2o1 7
ATTACHMENT MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 LICENSE AMENDMENT NO. 299 RENEWED FACILITY OPERATING LICENSE NO. NPF-9 DOCKET NO. 50-369 AND LICENSE AMENDMENT NO. 278 RENEWED FACILITY OPERATING LICENSE NO. NPF-17 DOCKET NO. 50-370 Replace the following pages of the Renewed Facility Operating Licenses with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Insert NPF-9, page 3 NPF-9, page 3 NPF-17, page 3 NPF-17, page 3 Replace the following pages of the Appendix A Technical Specifications (TS) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Insert 3.4.12-1 3.4.12-1 3.4.12-2 3.4.12-2
(4) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproducts and special nuclear materials as may be produced by the operation of McGuire Nuclear Station, Units 1 and 2, and; (6) Pursuant to the Act and 10 CFR Parts 30 and 40, to receive, possess and process for release or transfer such byproduct material as may be produced by the Duke Training and Technology Center.
C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1) Maximum Power Level The licensee is authorized to operate the facility at a reactor core full steady state power level of 3469 megawatts thermal (100%).
(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 299, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.
(3) Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21(d}, as revised on December 16, 2002, describes certain future activities to be completed before the period of extended operation. Duke shall complete these activities no later than June 12, 2021, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.
The Updated Final Safety Analysis Report supplement as revised on December 16, 2002, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71(e)(4), following issuance of this renewed operating license.
Until that update is complete, Duke may make changes to the programs described in such supplement without prior Commission approval, provided that Duke evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.
Renewed License No. NPF-9 Amendment No. 299
(4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts, 30, 40 and 70, to possess, but not separate, such byproducts and special nuclear materials as my be produced by the operation of McGuire Nuclear Station, Units 1 and 2; and, (6) Pursuant to the Act and 10 CFR Parts 30 and 40, to receive, possess and process for release or transfer such by product material as may be produced by the Duke Training and Technology Center.
C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or thereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1) Maximum Power Level The licensee is authorized to operate the facility at a reactor core full steady state power level of 3469 megawatts thermal (100%).
(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 278, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.
(3) Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21(d), as revised on December 16, 2002, describes certain future activities to be completed before the period of extended operation.
Duke shall complete these activities no later than March 3, 2023, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.
The Updated Final Safety Analysis Report supplement as revised on December 16, 2002, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71(e)(4), following issuance of this renewed operating license.
Until that update is complete, Duke may make changes to the programs described in such supplement without prior Commission approval, provided that Duke evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59, and otherwise complies with the requirements in that section.
Renewed License No. NPF-17 Amendment No. 278
LTOP System 3.4.12 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.12 Low Temperature Overpressure Protection (LTOP) System LCO 3.4.12 An LTOP System shall be OPERABLE with a maximum of one centrifugal charging pump or one safety injection pump capable of injecting into the RCS and the accumulators isolated and either a or b below:
N 0 TES---------------------------------------------
- 1. Two charging pumps may be made capable of injecting for s 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for pump swap operations.
- 2. Accumulators may be unisolated when accumulator pressure is less than the maximum RCS pressure for the existing RCS cold leg temperature allowed by the P!T limit curves provided in Specification 3.4.3.
- a. Two power operated relief valves (PORVs) with lift setting ~ 385 psig or
NOTE----------------------------------------------
A PORV secured in the open position may be used to meet the RCS vent requirement provided that its associated block valve is open and power removed.
APPLICABILITY: MODE 4 when any RCS cold leg temperature is~ 300°F, MODE 5, MODE 6 when the reactor vessel head is on.
McGuire Units 1 and 2 3.4.12-1 Amendment Nos. 299/278
LTOP System 3.4.12 ACTIONS
N 0TE------------------------------------------------------------
LCO 3.0.4.b is not applicable when entering MODE 4.
McGuire Units 1 and 2 3.4.12-2 Amendment Nos. 299/278
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 299 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-9 AND AMENDMENT NO. 278 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-17 DUKE ENERGY CAROLINAS. LLC MCGUIRE NUCLEAR STATION. UNITS 1 AND 2 DOCKET NOS. 50-369 AND 50-370
1.0 INTRODUCTION
By letter to the U. S. Nuclear Regulatory Commision (NRC, the Commission) dated January 11, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17025A069), Duke Energy Carolinas, LLC (Duke Energy) submitted an application to seek approval to change the Technical Specification (TSs) for McGuire Nuclear Station, Units 1 and 2 (McGuire).
The amendments modify Technical Specification (TS) 3.4.12, "Low Temperature Overpressure Protection (LTOP) System," to increase the time allowed for swapping charging pumps to one hour and deletion of existing Note in Required Action A.1. Additionally, an existing note in the Applicability section of TS 3.4.12 is reworded and relocated to the Limiting Condition for Operation section of TS 3.4.12 as Note 2. The licensee stated that the proposed changes are consistent with NRG-approved Technical Specifications Task Force (TSTF) Traveler TSTF-285-A, Revision 1, "Charging Pump Swap LTOP Allowance," (ADAMS Accession No. ML040620093)
TSTF Travelers are generic changes to the Improved Standard Technical Specifications (STS).
A list of the Travelers proposed for adoption is included in Enclosure 1 of the LAR. The licensee states that the proposed amendments will bring the McGuire TSs into closer alignment with NUREG-1431, "Standard Technical Specifications - Westinghouse Plants." The NRC documented their approval of TSTF-285-A, Revision 1, in a letter from William Beckner (NRC) to James Davis, Nuclear Energy Institute, dated May 12, 1999 (ADAMS Accession No. ML090750111 ).
2.0 REGULATORY EVALUATION
In Title 1O of the Code of Federal Regulations (1 O CFR) Section 50.36, "Technical Specifications, the NRC established its regulatory requirements related to the content of TSs.
Pursuant to 10 CFR 50.36(c), TSs are required to include items in the following five specific Enclosure 3
categories related to plant operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) LCOs; (3) surveillance requirements; (4) design features; and (5) administrative controls. However, the regulation does not specify the particular requirements to be included in a plant's TSs. The LCOs are the lowest functional capability, or performance levels, of equipment required for safe operation of the facility. When an LCO of a nuclear reactor is not met, the licensee shall follow any remedial actions permitted by the TS until the condition can be met or shall shut down the reactor.
The LTOP system controls reactor coolant system (RCS) pressure at low temperatures so the integrity of the coolant pressure boundary (RCPB) is not compromised by violating the pressure and temperature (PfT) limits required by 10 CFR Part 50, Appendix G, "Fracture Toughness Requirements."
3.0 TECHNICAL EVALUATION
3.1 Licensee's Proposed Changes McGuire TS LCO 3.4.12 currently states:
TS LCO 3.4.12 An LTOP System shall be OPERABLE with a maximum of one centrifugal charging pump or one safety injection pump capable of injecting into the RCS and the accumulators isolated and either a or b below:
- a. Two power operated relief valves (PORVs) with lift settings s 385 psig or
NOTE----------------------------------
A PORV [power operated relief valve] secured in the open position may be used meet the RCS vent requirement provided that its associated block valve is open and power removed.
APPLICABILITY: MODE 4 when any RCS cold leg temperature is s 300°F MODE 5, MODE 6 when the reactor vessel head is on.
NOTE------------------------------------
Accumulator isolation is only required when accumulator pressure is greater than or equal to the maximum RCS pressure for the existing RCS cold leg temperature allowed by the PfT
[pressure/temperature] limit curves provided in Specification 3.4.3
A NOTE in the TS LCO 3.4.12, ACTIONS, CONDITION A, REQUIRED ACTION A.1 currently states:
NOTE----------------------------------
Two centrifugal charging pumps may be capable of injecting in to the RCS during pump swap operation for s 15 minutes.
The licensee proposes to revise the above TS LCO 3.4.12 CONDITION A, REQUIRED ACTION A.1 NOTE and move to TS LCO 3.4.12 as NOTE 1.
Additionally, the licensee proposes to revise the 'APPLICABILITY,' NOTE and move it to TS LCO 3.4. 12 as NOTE 2.
Proposed TS LCO 3.4.12 will read as follows:
LCO TS 3.4.12 An LTOP System shall be OPERABLE with a maximum of one centrifugal charging pump or one safety injection pump capable of injecting into the RCS and the accumulators isolated and either a or b below:
NOTES-------------------------------------------------
- 1. Two charging pumps may be made capable of injecting for s 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for pump swap operations.
- 2. Accumulators may be unisolated when accumulator pressure is less than the maximum RCS pressure for the existing RCS cold leg temperature allowed by the PIT limit curves provided in Specification 3.4.3.
- a. Two power operated relief valves (PORVs) with lift settings s 385 psig or
NOTE----------------------------------
A PORV [power operated relief valve] secured in the open position may be used meet the RCS vent requirement provided that its associated block valve is open and power removed.
APPLICABILITY: MODE 4 when any RCS cold leg temperature is s 300°F MODE 5, MODE 6 when the reactor vessel head is on.
3.2 NRC Staff's Technical Evaluation of Licensee's Proposed Changes The LTOP system controls the RCS pressure at low temperatures so the integrity of the RCPB is maintained by satisfying the PIT limits of 10 CFR 50, Appendix G.
McGuire TS LCO 3.4.12 REQUIRED ACTION (RA) A.1 (corresponding NUREG-1431 TS LCO 3.4.12 (LTOP system) RA B.1), has a Note allowing two charging pumps to be capable of injecting in the RCS system for up to 15 minutes during pump swap operations. This is
undesirable since it requires entry into TS LCO Actions; specifically, an action with an "immediately fix the condition" requirement. The relation between the "15 minutes" allowance in the Note and the "Immediately" could be confusing. Furthermore, 15 minutes is insufficient time to prudently complete the operation of making the charging pump incapable of injection.
Closing and racking out valves, or racking out the pump breaker requires appropriate administrative controls to be followed by plant operations personnel. Even with proper diligence, these actions may not be safely accomplished in 15 minutes in all cases.
The proposed TS changes increase the pump swap time of 15 minutes to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is a more reasonable timeframe to accomplish these actions considering the small likelihood of an event during this brief period and the other administrative controls available (e.g., operator action to stop any pump that inadvertently starts).
The proposed TS changes also relocate the Note in RA A.1 (corresponding RA B.1 for Westinghouse Owners Group STS) to become NOTE 1 in TS LCO 3.4.12. In addition, the "APPLICABILITY" Note of McGuire TS LCO 3.4.12 (same as NUREG-1431) is moved to become TS LCO 3.4.12 NOTE 2. Both proposed TS LCO 3.4.12 NOTE 1 and NOTE 2 give exceptions to the LCO requirements as opposed to the REQUIRED ACTIONS and APPLICABILITY requirements, respectively, and, therefore, should be placed with the LCO since moving the Notes to the LCO provides clarification.
TSTF-285, Revision 1, Note 2 states, in part, " ..... allowed by PIT limit curves provided in the PTLR [Pressure Temperature Limits Report]." TS 3.4.3, titled "RCS Pressure and Temperature (PIT) Limits" is equivalent to information which would be contained in the PTLR, therefore this minor deviation from the TSTF is acceptable.
McGuire TS LCO 3.4.12 requires that an LTOP system be OPERABLE with a maximum of one centrifugal charging pump or one safety injection pump. NUREG-1431 TS LCO 3.4.12 requires that an LTOP system be OPERABLE with a maximum of one high pressure injection pump and one charging pump. McGuire TS LCO 3.4.12 deviates from NUREG-1341 TS LCO 3.4.12, however since McGuire TS LCO 3.4.12 is more restrictive as it requires a maximum of one pump. Therefore, this deviation from the TSTF an NUREG-1431 is acceptable.
The NRC staff has previously reviewed and approved TSTF-285-A because, as stated above, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is a reasonable time considering the actions that must be accomplished, and moving the Notes to the LCO section provides appropriate clarification. The NRC staff finds that the proposed TS note changes are consistent with that in the previously approved TSTF-285-A, Revision 1, and, therefore, concludes that they are acceptable.
3.3 NRC Staff's Conclusion The NRC staff concludes that the TS changes, consistent with TSTF 285-A, Revision 1, are acceptable because the proposed changes provide reasonable assurance of plant safety, and the requirements of 10 CFR 50.36 continue to be met.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the NRC staff notified the North Carolina State official of the proposed issuance of the amendments on July 12, 2017. The State official confirmed on September 8, 2017 that the State of North Carolina had no comments.
5.0 PUBLIC COMMENTS On May 23, 2017, the NRC staff published a "Notice of Consideration of Issuance of Amendments to Facility Operating Licenses, Proposed No Significant Hazards Consideration Determination, and Opportunity for a Hearing," in the Federal Register associated with the proposed amendment request (82 FR 23620). In accordance with the requirements in 10 CFR 50.91, the notice provided a 30-day period for public comment on the proposed no significant hazards consideration determination. One comment from a member of the public was received, however it was not related to the no significant hazards consideration determination nor the LAR. The comment can be found at www.regulations.gov, reference NRC-2017-0120-0002.
6.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on this finding (82 FR 23620: May 23, 2017). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
7.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: D. Woodyatt, NRR R. Grover, NRR Date of issuance: September 25, 2017
ML17244A102 *b memorandum OFFICE DORL/LPL2-1/PM DORL/LPL2-1/LA DE/SRXB/BC DSS/STSB/BC NAME MMahoney KGoldstein (SRohrer for) EOesterle* JWhitman*
DATE 09/06/17 09/05/17 6/15/17 5/30/17 OFFICE OGC-NLO DORL/LPL2-1 /BC DORL/LPL2-1/PM NAME JGillespie MMarkley MMahoney DATE 09/14/17 09/22/17 09/25/17