ML17270A030
| ML17270A030 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/16/2017 |
| From: | David Wrona Plant Licensing Branch III |
| To: | Hamilton D FirstEnergy Nuclear Operating Co |
| Green K, 415-1627 | |
| References | |
| CAC MG0130, EPID L-2017-LLR-0080 | |
| Download: ML17270A030 (11) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 16, 2017 Mr. David B. Hamilton Site Vice President FirstEnergy Nuclear Operating Company Mail Stop A-PY-A290 P.O. Box 97, 10 Center Road Perry, OH 44081-0097
SUBJECT:
PERRY NUCLEAR POWER PLANT, UNIT NO. 1 -APPROVAL OF ALTERNATIVE TO USE ASME CODE CASE N-513-4 FOR REPAIR OF EMERGENCY SERVICE WATER SYSTEM PIPING (CAC NO. MG0130; EPID L-2017-LLR-0080) (L-17-278)
Dear Mr. Hamilton:
By letter dated August 20, 2017, as supplemented by letter dated August 21, 2017, FirstEnergy Nuclear Operating Company (FENOC, the licensee) submitted a request in accordance with paragraph 50.55a(z)(2) of Title 10 of the Code of Federal Regulations (10 CFR) for a proposed alternative to the requirements of Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) for Perry Nuclear Power Plant, Unit 1 (PNPP).
Specifically, pursuant to 10 CFR 50.55a(z)(2), FENOC requested to use the proposed alternative on the basis that the basis that complying with the specified requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the subject request and concludes, as set forth in the enclosed safety evaluation, that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(2).
The NRC authorizes the use of proposed alternative for PNPP either until the end of the next refueling outage, which is scheduled to occur in March 2019, or the allowable leak rate or allowable flaw size is exceeded, whichever occurs earlier.
The NRC staff notes that the authorization of this alternative does not constitute the NRC generic approval of ASME Code Case N-513-4.
All other requirements of ASME Code,Section XI, for which relief was not specifically requested and authorized by the NRC staff remain applicable, including the third-party review by the Authorized Nuclear In-service Inspector.
D. Hamilton If you have any questions, please contact Kimberly Green at (301) 415-1627.
Sincerely, 009_v__
David J. Wrona, Branch Chief Plant Licensing Branch 111 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-440
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 RELATED TO 10 CFR 50.55a ALTERNATIVE USING ASME CODE CASE N-513-4 ALTERNATE REPAIR OF EMERGENCY SERVICE WATER PIPING FIRSTENERGY NUCLEAR OPERATING COMPANY FIRSTENERGY NUCLEAR GENERATION, LLC PERRY NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-440
1.0 INTRODUCTION
By letter dated August 20, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 17232AOOO), as supplemented by letter dated August 21, 2017 (ADAMS Accession No. ML17233A292), FirstEnergy Nuclear Operating Company (FENOC, the licensee) requested relief from the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," IWD-3120, "lnservice Volumetric and Surface Examinations," to disposition a leaking 14-inch elbow on the outlet of the B emergency closed cooling (ECC) heat exchanger, immediately downstream of valve 1P45F0541 B at Perry Nuclear Power Plant (PPNP), Unit 1.
Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z)(2), the licensee requested the temporary use of ASME Code Case (hereafter referred to as Code Case) N-513-4, "Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping,Section XI, Division 1," to disposition the leaking elbow on the basis that complying with the specified ASME Code requirement to repair the degraded elbow would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
On August 21, 2017, the U.S. Nuclear Regulatory Commission (NRC) staff verbally authorized the use of proposed alternative at PNPP, Unit 1 (ADAMS Accession No. ML17234A554), either until the end of the next refueling outage, which is scheduled to begin March 2019, or the allowable leak rate or allowable flaw size is exceeded whichever occurs earlier. This safety evaluation documents the NRC staff's technical basis for the verbal authorization.
2.0 REGULATORY EVALUATION
ASME Code,Section XI, IWD-3120(b), requires that unacceptable flaws in ASME Code Class 3 components be corrected by repair or replacement activity or be accepted by supplemental examination and flaw evaluation, to the extent necessary to meet the acceptance standards in ASME Code,Section XI, Article IWD-3000, which refers to the requirements of IWC-3000.
Adherence to Section XI of the ASME Code is mandated by 10 CFR 50.55a(g)(4), which states, Enclosure
Adherence to Section XI of the ASME Code is mandated by 10 CFR 50.55a(g)(4), which states, in part, that ASME Code Class 1, 2, and 3 components (including supports) will meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code,Section XI.
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, or Director, Office of New Reactors, as appropriate. A proposed alternative must be submitted and authorized prior to implementation. The applicant or licensee must demonstrate that: (1) Acceptable level of quality and safety. The proposed alternative would provide an acceptable level of quality and safety; or (2) Hardship without a compensating increase in quality and safety. Compliance with the specified requirements of this section 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 the licensee to request the use of an alternative and the NRC to authorize the proposed alternative.
3.0 TECHNICAL EVALUATION
3.1 Licensee's 10 CFR 50.55a Request to Use ASME Code Case N-513-4 3.1.1 ASME Code Component Affected The licensee identified a pinhole leak on a 14-inch elbow on B emergency service water (ESW) piping. The elbow is on the outlet of the B ECC heat exchanger (ESW tube side), immediately downstream of valve 1P45F0541 B, "ECC HX B ESW OUTLET."
3.1.2 Applicable Code Edition and Addenda The applicable code of record for the fourth inservice inspection interval is the 2013 Edition of the ASME Code,Section XI.
3.1.3 Applicable Code Requirement For ASME Code Class 3 components such as the subject pipe, IWD-3120 of the ASME Code,Section XI, 2013 Edition states that the requirements of IWC-3120 may be used.
3.1.4 Reason for Request On August 19, 2017, the licensee declared the ESW B system inoperable. As a result, a number of limiting conditions for operation (LCOs) of the plant technical specifications were not met, including, but not limited to, LCO 3.7.1, "Emergency Service Water (ESW) System -
Divisions 1 and 2," and LCO 3.8.1, "AC [alternating current] Sources - Operating."
The licensee stated that Code Case N-513-3, "Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping,Section XI, Division 1," provides criteria to allow temporary acceptance of flaws, including through-wall flaws in moderate energy Class 2 or 3 piping without performing repair or replacement in accordance with the ASME Code. The NRC has approved Code Case N-513-3 in Regulatory Guide 1.147, "lnservice Inspection Code Case
Acceptability, ASME Section XI, Division 1," Revision 17 (ADAMS Accession No. ML13339A689), with the condition that the repair or replacement activity temporarily deferred under the provisions of this Code Case shall be performed during the next scheduled outage.
The licensee also stated that Code Case N-513-3 does not address the evaluation of flaws in pipe elbows. Code Case N-513-4, "Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping,Section XI, Division 1," (Revision 4, May 7, 2014),
contains several revisions to Code Case N-513-3 including expanding the applicability of the code case to pipe elbows. Code Case N-513-4 has not been approved by the NRC for generic use. The licensee proposed to use Code Case N-513-4 to allow temporary acceptance of the leaking elbow without performing repair or replacement activities, and thereby avoid a plant shutdown. Use of this alternative evaluation method in lieu of immediate action for such a degraded condition would allow the licensee to perform additional extent of condition examinations while allowing time for safe and orderly long-term repair actions.
The licensee stated that plant shutdown activities result in additional plant risk requiring use of a system that is in standby during normal operation. Such a shutdown would be inappropriate when an affected ASME Code component in a degraded condition is demonstrated to retain adequate margin to fulfill the component's function. The licensee further stated that compliance with the current code requirements results in a hardship without a compensating increase in the level of quality and safety.
3.1.5 Proposed Alternative In lieu of performing the required repair or replacement in accordance with the ASME Code,Section XI, the licensee proposed to temporarily accept the leaking piping in service for the remaining fuel cycle based on the requirements of Code Case N-513-4. The licensee stated that it will repair or replace the subject pipe in accordance with the ASME Code,Section XI, during the next scheduled refueling outage or prior to exceeding the allowable flaw size, whichever occurs first.
3.1.6 Basis for Use The licensee has followed the requirements of Code Case N-513-4 as discussed below. In addition, the licensee performed a flooding analysis with associated consequence of leakage and evaluated the operability of the leaking pipe.
Flaw Characterization Consistent with the flaw characterization described in ASME Code,Section XI, IWA-3300, and using straight beam and angled beam of ultrasonic testing (UT), the licensee characterized the flaw in the subject piping as a nonplanar flaw (i.e., pinhole leak indicative of pitting corrosion).
The licensee stated that this flaw is not crack-like, and thus, it is not expected to be subject to rapid propagation. The licensee measured the wall thickness of the piping directly surrounding the leak and found no pitting. Additionally, the licensee took circumferential readings in three axial planes 0.5 inches apart, with readings taken every 1 inch around the entire circumference of the pipe. The minimum wall thickness reading was 0.280 inches near the origin of the pinhole leak.
Structural Integrity Analysis The licensee performed a flaw evaluation to demonstrate that the 14-inch diameter pipe elbow with a pinhole leak meets the structural integrity requirements of Code Case N-513-4 and ASME Code,Section XI, Appendix C. Code Case N-513-4 can be applied to the subject pipe (i.e.,
elbow) because the maximum operating temperature is not above 200 degrees Fahrenheit (°F) and the operating pressure does not exceed 275 pounds per square inch gauge (psig). The design pressure and temperature of this portion of ESW is 150 psig and 150 °F, respectively.
The licensee stated that the minimum required piping thickness can be determined based on the larger of the wall thickness required to maintain internal pressure loads, the wall thickness required for imposed mechanical loading, and the Electric Power Research Institute guideline of 20 percent of the nominal pipe wall thickness.
The licensee calculated the minimum required wall thickness to be 0.139 inches. The licensee noted that the actual thickness was measured to exceed the minimum required wall thickness in all locations other than the flaw location. This also shows that the area of metal loss is highly localized at the point of the pinhole leak.
The licensee stated that its structural analysis envelopes all the UT measured pipe wall thickness values. Specifically, the licensee assumed a pipe wall thickness of 0.25 inches as the overall pipe wall thickness of the piping in the analysis even though based on the UT measurement the minimum wall thickness was 0.280 inches. The licensee assumed a bounding flaw with a diameter of 0.125 inches in its flaw evaluation. This structural evaluation bounds the effects of any other areas of erosion/corrosion within the 14-inch diameter piping.
The licensee calculated a maximum allowable flaw size of 0.58 inches in the axial direction and 1.35 inches in the circumferential direction that would still maintain structural integrity. The analysis assumed the flaw as a circle with a diameter of 0.125 inches. The licensee's analysis demonstrated that the assumed flaw size meets the acceptance criteria for structural integrity using Code Case N-513-4, as it is bounded by the allowable flaw size.
The licensee determined that based on the structural analysis and the characterization of the flaw as a pinhole leak and not subject to further rapid propagation, operability can be demonstrated for ESW B with the existing pinhole on the 14-inch elbow. The licensee concluded that because the pinhole leak is not subject to rapid growth and increased leakage, the ESW system will continue to perform its intended design function of delivering cooling water to plant components.
Flooding Analysis For a leaking flaw, the licensee determined the allowable leakage rate by dividing the critical leakage rate by a safety factor of four. The licensee defined the critical leakage rate as the highest leakage rate that can be tolerated from the ESW system cooling requirement and will be based on the allowable loss of inventory or the maximum leakage that can be tolerated relative to room flooding.
The design basis is considered for each leak and evaluated using the operability determination and functionality assessment process. The licensee considered requirements established for the system, continued degradation and potential consequences, operating experience, and engineering judgment. As required by the code case, the licensee considered system make-up
capacity, containment integrity with the leak not isolated, effects on adjacent equipment, and the potential for room flooding.
For the flooding analysis, the licensee combined the pinhole leak in the 14-inch elbow with a pinhole leak in a 3-inch ESW pipe containing 1P45F5466B, "ECG HX B ESW OUTLET BYPASS," downstream of the ECG B Heat Exchanger. The licensee stated that the pinhole leak in the 3-inch pipe was temporarily accepted in accordance with the requirements of Code Case N-513-3. The NRG staff notes that the proposed alternative covers only the 14-inch elbow leak, not the 3-inch ESW pipe leak, even though the licensee combined the leakage from the 3-inch pipe and the 14-inch elbow in its flooding assessment.
Effect on ESW 8 Loop System Flow The licensee stated that the location of the leak at the 14-inch elbow cannot be isolated from the return side of the ESW B Loop. The licensee further stated that currently the leakage has no impact on ESW Loop B system flow because the leak is insignificant, approximately 0.02 gallon per minute (gpm). While in operation, the flow at this point in the ESW system is approximately 2425 gpm going through the ECG B Heat Exchanger, and flow can range between 2400-2730 gpm. However, this flow can be increased by throttling open valve 1P45F0541 B. The majority of the coolant flows through 14-inch valve 1P45F0541 B, with a small percentage going through the 3-inch bypass line (estimated at 50 gpm).
According to the licensee, should leakage become greater than the current 0.02 gpm leak, there would be no effect on the cooling capability of ESW Loop B to cool the B ECG Heat Exchanger (or any other heat load on the B Loop). The reason is the location of the leak is on the downstream side of the ECG B Heat Exchanger. ESW water has already cooled its designated heat loads prior to reaching to the leaking location of the pipe. The net effect of increased leak rate, if occurs, would be water leaking onto the floor which would flow to the 4-inch floor drains.
The licensee calculated a permissible leakage rate of 5.625 gpm while the loop is in operation, and a permissible leakage rate of 3 gpm while the loop is in standby/keepfill. The licensee determined these leak rate limits by assigning the maximum allowable standby/keepfill leakage rate from plant water inventory calculation to system operating conditions, determining the corresponding leakage at standby/keepfill conditions, and applying a safety factor of four. The licensee noted that during system operation, any increase in leakage beyond 5.625 gpm would not affect the cooling capacity of ESW, as the leak location is downstream of all heat loads.
However, leakage of this magnitude could challenge the system standby/keepfill capacity, potentially introducing conditions in which the system would be susceptible to water hammer upon future pump start.
The licensee stated that the existing cumulative area of the pinholes identified in the ESW B Loop is less than the permissible total area of the pinholes. The existing cumulative area of the pinhole is approximately 0.00011 square inches, where the permissible pinhole area is approximately 0.0165 square inches. This permissible area equates to the both permissible leakage rates identified above, depending on the operating conditions.
The licensee stated that the evaluation of acceptable leakage, though performed considering two existing pinholes in the ESW B Loop piping, would remain applicable if additional pinholes were to occur prior to the restoration of the degraded piping. The licensee stated that the leakage limitations of 3 gpm and 5.625 gpm are applicable regardless of the number of pinholes. The licensee recognized that any additional pinhole would require individual evaluation for structural integrity, and a cumulative review for structural integrity if the new
pinhole were in the vicinity of an existing pinhole.
Effect of Flooding and Water Spray The licensee reported that the leak is located on the 574-feet-10-inch elevation of the control complex (east side), lowest elevation of the building. This level of the control complex has numerous floor drains, which are routed to the floor drain sump. The leak location on the 14-inch ESW line is on the south side of the pipe, and 50 inches off the floor. A 4-inch floor drain is located approximately 3 feet from where water would leak off the 14-inch pipe, if leakage were to increase. This floor drain will route water to the control complex floor drain sump where two-50 gpm pumps are located, which auto start. The licensee noted that based on the flaw evaluation there is reasonable assurance that the leakage will not significantly increase such that flooding would be a concern. This leak is bounded by a flooding analysis calculation, which postulates a pipe rupture in a 14-inch pipe.
The licensee stated that water spray from the subject pinhole leak on safety-related equipment is not a concern because leakage is approximately 0.02 gpm, and is oriented in the downward direction (approximately in the 4 o'clock position of the piping when viewed axially). If leakage were to increase (i.e., when the ESW Bloop is in operation) water would exit the piping and spray downward and to the south. An 8-inch thick drywall from the floor to the ceiling is located 6.5 feet to the west of the leak location.
The licensee observed that the nearest safety-related equipment that could possibly be affected by water spray is the three-way valve 1P42F6658, "ECC B HX OUT TEMP CONT," which has an electrically powered hydramotor actuator. However, the valve is located to the south of the leak and is approximately 10-feet away. The licensee noted that the internal pressure at this pipe location is approximately 80 psig with the system operating and the water spray would be directed toward the floor. Temperature at this pipe location is approximately 39 °F. There is no other equipment in a 20-foot radius around the leaking pipe that would be affected by potential water spray.
The licensee noted that manual valve 1P45F54668, "ECC HX B ESW OUTLET BYPASS," is currently being wetted by the identified leak but this has no effect on its operation because it is a manual valve.
Monitoring Paragraph 2( e) of Code Case N-513-4 requires periodic UT inspection of the flaw not to exceed 30 days. The licensee will track the periodic UT inspection of the flaw (every 30 days) through a corrective action or similar tracking mechanism.
Paragraph 2(f) of Code Case N-513-4 requires daily walkdown to confirm the analysis conditions used in the flaw evaluation remain valid. Significant change in the leakage rate is reason to question that the analysis conditions remain valid and would require reinspection per paragraph 2(f) of the Code Case. Any re-inspection must be performed in accordance with paragraph 2(a) of the Code Case. The licensee stated that twice daily plant rounds will be used to meet the daily walkdowns of the flaw action. The licensee stated that anti-sweat insulation on the elbow will be removed to facilitate monitoring of the leak until the pipe is repaired.
Section 5 of Code Case N-513-4 requires augmented inspections of at least five similar susceptible locations to that of the flaw. The licensee stated that a corrective action or similar mechanism will track completion of the augmented inspection activity.
3.1. 7 Duration of Proposed Alternative The proposed alternative is requested for the duration up to and including the 171h refueling outage that is scheduled to commence in March 2019.
3.2 NRC Staff Evaluation The NRC staff has not approved Code Case N-513-4 but has approved Code Case N-513-3.
Therefore, the staff has evaluated the proposed alternative based on the provisions of Code Case N-513-3.
3.2.1 Flaw Characterization Code Case N-513-3, paragraph 2(a), requires that the flaw geometry be characterized by volumetric inspection methods or by physical measurements. The full pipe circumference at the flaw location shall be inspected to characterize the length and depth of all flaws in the pipe section. The NRC staff notes that the licensee has measured the area of the pinhole as well as the wall thickness in the vicinity of the pinhole by UT. The NRC staff finds that measured wall thickness in the vicinity of the pinhole is sufficient to support applied loading. The staff finds that the licensee satisfied the flaw characterization of paragraph 2(a) of Code Case N-513-3.
3.2.2 Structural Integrity Analysis The NRC staff performed an independent calculation of the minimum required wall thickness based on equations in Code Case N-513-3. The NRC staff finds that the field measured wall thickness, 0.280 inches, in the vicinity of the leak has sufficient margin as compared to the calculated minimum required wall thickness of 0.139 inches.
The NRC staff notes that Code Case N-513-3 does not provide a method to calculate stresses for a pinhole at an elbow, but Code Case N-513-4 does. The licensee considered both pressure and design basis bending stress on the elbow and calculated acceptable flaw sizes in both the circumferential and axial directions. The staff does not have concern with the licensee performing the stress analysis of the degraded elbow in accordance with Code Case N-513-4.
The staff recognizes that the licensee will monitor the structural integrity of the subject piping periodically to verify its flaw evaluation of the elbow.
The NRC staff finds that the licensee's flaw evaluation has demonstrated the structural integrity of the subject piping until the next refueling outage. In addition, the staff notes that the licensee will monitor the leakage periodically as discussed below such that the structural integrity of the subject pipe will be verified against the allowable flaw size or leak rate.
3.2.3 Operability Code Case N-513-3, paragraph 1(d), requires the owner to demonstrate system operability considering effects of leakage. The NRC staff finds that the licensee has demonstrated that the current leakage of 0.02 gpm is much less than the allowable leak rate of 5.625 gpm when the ESW B loop is operating or approximately 3 gpm when the ESW B loop is in standby/keepfill.
There is a sufficient margin between the current leak rate and the allowable leak rates. The leak rate may or may not increase until the next refueling outage which is scheduled for March
2019. The licensee will monitor the leak rate twice a day. Should the leak rate exceed the allowable rate, the licensee will perform appropriate corrective actions.
3.2.4 Flooding Analysis The NRC staff finds that the licensee has demonstrated that flooding from the leakage is not a concern at present because there is a drain in the room where the subject pipe is located. The licensee has also demonstrated that water spray will not affect safety-related equipment except Manual valve 1P45F5466B. However, water spray on this manual valve will not affect its operation. Should the future leakage exceed the allowable leak rate, the licensee will take corrective actions. Therefore, the NRC staff finds that the licensee's flooding analysis is acceptable.
3.2.5 Monitoring The NRC staff notes that the licensee will perform walkdowns twice daily and UT every 30 days of the leaking 14-inch elbow. The staff finds that the proposed monitoring regiment satisfies the requirements of Code Case N-513-3 and is acceptable.
3.2.6 Hardship Justification The NRC staff finds that shutdown of the plant to perform the ASME Code required repair or replacement will result in additional plant risk, requiring use of a system that is in standby during normal operation. In addition, plant shutdown increases transients to the plant safety systems, thereby imposing additional loadings to the components. The staff further finds that the affected ESW piping is of low pressure and temperature and the leakage is small with respect to the normal flow capacity. Performing the ASME Code required repair or replacement at present would not result in a compensating increase in the level of quality and safety.
4.0 CONCLUSION
As set forth above, the NRC staff determines that the proposed alternative provides reasonable assurance of structural integrity of the subject piping. The NRC staff determines that complying with the ASME Code requirement would result in hardship or unusual difficulty without a compensating increase in the 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)(2). The NRC authorizes the use of proposed alternative for PNPP, Unit 1, either until the end of the next refueling outage which is scheduled to commence in March 2019, or the allowable leak rate or allowable flaw size is exceeded, whichever occurs earlier.
The NRC staff notes that the authorization of this alternative does not constitute the generic approval of Code Case N-513-4.
All other requirements of ASME Code,Section XI, for which relief was not specifically requested and authorized by the NRC staff remain applicable, including the third party review by the Authorized Nuclear In-Service Inspector. The staff notes that this authorization does not imply or infer NRC approval of Code Case N-513-4 for generic application.
Principal Contributor: J. Tsao, NRR/DE/EPNB Date of issuance: October 16, 2017
ML17270A030 *via email OFFICE N RR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DE/EPNB/BC* NRR/DORL/LPL3/BC NAME KGreen SRohrer DAiiey DWrona DATE 10/16/17 10/2/17 9/24/17 10/16/17