ML18365A373

From kanterella
Jump to navigation Jump to search

Issuance of Amendment Nos. 328 and 306 to Extend Completion Time of Required Action D.3 of Technical Specification 3.8.1 to 14 Days
ML18365A373
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 01/22/2019
From: Marshall M
Plant Licensing Branch 1
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
Marshall M, NRR/DORL/LPLI, 415-2871
References
EPID L-2018-LLA-0229
Download: ML18365A373 (23)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 22, 2019 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

CALVERT CUFFS NUCLEAR POWER PLANT, UNITS 1 AND 2- ISSUANCE OF AMENDMENT NOS. 328 AND 306 TO EXTEND COMPLETION TIME OF REQUIRED ACTION 0.3 OF TECHNICAL SPECIFICATION 3.8.1 TO 14 DAYS (EPID L-2018-LLA-0229)

Dear Mr. Hanson:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 328 to Renewed Facility Operating License No. DPR-53 and Amendment No. 326 to Renewed Facility Operating License No. DPR-69 for the Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (Calvert Cliffs), respectively. These amendments consist of changes to the Calvert Cliffs Technical Specifications (TSs) in response to your application dated August 23, 2018, as supplemented by letters dated November 12, 2018, and November 30, 2018.

Publicly-available versions are in the Agencywide Documents Access and Management System under Accession Nos. ML18235A199, ML18316A034, and ML18334A073, respectively.

These amendments revise the Calvert Cliffs TSs to permit two temporary one-time extensions (i.e., one for each unit) to the completion times for Required Action 0.3 in TS 3.8.1, "AC

[Alternating Current] Sources-Operating."

A copy of our related safety evaluation is enclosed. A notice of issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

(!II.ala/~

Michael L. Marshall, Jr., Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318

Enclosures:

1. Amendment No. 328 to DPR-53
2. Amendment No. 306 to DPR-69
3. Safety Evaluation cc: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. 50-317 CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 328 Renewed License No. DPR-53

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Exelon Generation Company, LLC (Exelon, the licensee) dated August 23, 2018, as supplemented by letters dated November 12, 2018, and November 30, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations 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; 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 amended by 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. DPR-53 is hereby amended to read as follows:
2. Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 328, are hereby incorporated into this license. Exelon Generation shall operate the facility in accordance with the Technical Specifications.
3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION James G. Danna, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Dateoflssuance:January 22, 2019

ATTACHMENT TO LICENSE AMENDMENT NO. 328 CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-53 DOCKET NO. 50-317 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Page Insert Page 3 3 Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Page Insert Page 3.8.1-5 3.8.1-5

(4) Exelon Generation pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use, in amounts as required, any byproduct, source, and special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) Exelon Generation pursuant to the Act and 10 CFR Parts 30 and 70 to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This license is deemed to contain and is subject to the conditions set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act, and the rules, regulations, and orders of the Commission, now or hereafter applicable; and is subject to the additional conditions specified and incorporated below:

( 1) Maximum Power Level Exelon Generation is authorized to operate the facility at steady-state reactor core power levels not in excess of 2737 megawatts-thermal in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 328, are hereby incorporated into this license. Exelon Generation shall operate the facility in accordance with the Technical Specifications.

(a) For Surveillance Requirements (SRs) that are new, in Amendment 227 to Facility Operating License No. DPR-53, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 227. For SRs that existed prior to Amendment 227, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the Surveillance was last performed prior to implementation of Amendment 227.

(3) Additional Conditions The Additional Conditions contained in Appendix C as revised through Amendment No. 318 are hereby incorporated into this license. Exelon Generation shall operate the facility in accordance with the Additional Conditions.

(4) Secondary Water Chemistry Monitoring Program Exelon Generation shall implement a secondary water chemistry monitoring program to inhibit steam generator tube degradation. This program shall include:

Amendment No. 328

AC Sources-Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. LCO 3.8.1.c offsite ---------- NOTE-----------

circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems-Operating," when Condition Dis entered with no AC power source to a train.

D.l Perform SR 3.8.1.1 or 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> SR 3.8.1.2 for required OPERABLE AND offsite circuit(s).

Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AND D.2 Declare, CREVS or 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from CRETS with no offsite discovery of no power available offsite power to inoperable when the one train redundant CREVS or concurrent with CRETS is inoperable. inoperability of redundant required feature(s)

AND D.3 Declare CREVS and 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />s*

CRETS supported by the inoperable offsite circuit inoperable.

  • Or 14 days, once during each applicable 2019 and 2020 Refuel Outage, for the connection of the new P-13000 Service Transformer.

Prior to entry into the 14-day Completion Time, the OC DG and the SMECO 69 kV Line shall be verified available. During the 14-day Completion Time, the OC DG and SMECO 69 kV Line shall be verified available once per shift.

If both the OC DG and SMECO 69 kV Line become un-available during the 14-day Completion Time, either the OC DG or the SMECO 69 kV Line shall be restored to available status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or the Unit shall be brought to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

CALVERT CLIFFS - UNIT 1 3.8.1-5 Amendment No. 328 CALVERT CLIFFS - UNIT 2 Amendment No. 306

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. 50-318 CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 306 Renewed License No. DPR-69

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Exelon Generation Company, LLC (Exelon, the licensee) dated August 23, 2018, as supplemented by letters dated November 12, 2018, and November 30, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations 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; 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 amended by 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. DPR-69 is hereby amended to read as follows:
2. Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 306, are hereby incorporated into this license. The licensee shall operate the facility in accordance with the Technical Specifications.
3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION C)~~

James G. Danna, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance: January 22, 2019

ATTACHMENT TO LICENSE AMENDMENT NO. 306 CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT 2 RENEWED FACILITY OPERATING LICENSE NO. DPR-69 DOCKET NO. 50-318 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Page Insert Page 3 3 Calvert Cliffs Nuclear Power Plant, Unit 2, uses the same Appendix A as Calvert Cliffs Nuclear Power Plant, Unit 1. Accordingly, the Unit 1 Renewed Facility Operating License has been updated with the following page, which is applicable to both Units 1 and 2:

Remove Page Insert Page 3.8.1-5 3.8.1-5

(4) Exelon Generation pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use, in amounts as required, any byproduct, source, and special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) Exelon Generation pursuant to the Act and 10 CFR Parts 30 and 70 to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This license is deemed to contain and is subject to the conditions set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act, and the rules, regulations, and orders of the Commission, now or hereafter applicable; and is subject to the additional conditions specified and incorporated below:

(1) Maximum Power Level Exelon Generation is authorized to operate the facility at steady-state reactor core power levels not in excess of 2737 megawatts-thermal in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 306, are hereby incorporated into this license. The licensee shall operate the facility in accordance with the Technical Specifications.

(a) For Surveillance Requirements (SRs) that are new, in Amendment 201 to Facility Operating License No. DPR-69, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 201. For SRs that existed prior to Amendment 201, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the Surveillance was last performed prior to implementation of Amendment 201.

(3) Less Than Four Pump Operation The licensee shall not operate the reactor at power levels in excess of five (5) percent of rated thermal power with less than four (4) reactor coolant pumps in operation. This condition shall remain in effect until the licensee has submitted safety analyses for less than four pump operation, and approval for such operation has been granted by the Commission by amendment of this license.

(4) Environmental Monitoring Program If harmful effects or evidence of irreversible damage are detected by the biological monitoring program, hydrological monitoring program, and the Amendment No. 306

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 328 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-53 AMENDMENT NO. 306 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-69 EXELON GENERATION COMPANY, LLC CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-317 AND 50-318

1.0 INTRODUCTION

By letter dated August 23, 2018 (Agencywide Documents Access Management System (ADAMS) Accession No. ML18235A199), as supplemented by letters dated November 12, 2018, and November 30, 2018 (ADAMS Accession Nos. ML18316A034 and ML18334A073, respectively), Exelon Generation Company, LLC (the licensee) requested an amendment to Renewed Facility Operating License Nos. DPR-53 and DPR-69 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (Calvert Cliffs), respectively. The license amendment request (LAR) would revise Technical Specification {TS) 3.8.1, "AC [Alternating Current]

Sources-Operating," by allowing two temporary, one-time extensions (i.e., one for each unit) for the Required Action D.3 completion time during the 2019 and 2020 refueling outages (RFOs).

The supplemental letters dated November 12, 2018, and November 30, 2018, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC or the Commission) staff's original proposed no significant hazards consideration determination as published in the Federal Register on October 23, 2018 (83 FR 53513). The letter dated November 30, 2018, reduced the scope of the application.

The licensee is requesting the proposed change to allow for the future installation and tie-in of a new 13,000-volt service transformer during the Unit 2 2019 RFO and Unit 1 2020 RFO. The tie-in of the service transformer cannot be accomplished within the current TS 3.8.1 completion time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The proposed change would revise the Calvert Cliffs TSs to permit one-time extensions to the completion times for a required action in TS 3.8.1.

The plant configuration during the requested 14-day completion time will be such that one unit will be in Mode 1 at 100 percent power and the other unit will be shut down in either Mode 5 or Mode 6. However, because Calvert Cliffs has a shared control room with a shared control room emergency ventilation system (CREVS) and control room emergency temperature control system (CRETS), two trains of CREVS and CRETS are required to be operable.

Enclosure 3

2.0 REGULATORY EVALUATION

2.1 Description of Systems 2.1.1 CREVS and CRETS The control room and the cable spreading room at Calvert Cliffs are incorporated into a single year-round air-conditioning system serving both Units 1 and 2. Therefore, the ambient temperature in the control room is expected to be the same as the ambient temperature in the cable spreading room. Air handling (AH) and refrigeration equipment are redundant. The safety-related refrigeration equipment associated with each AH unit consists of a direct expansion type cooling coil in the AH unit and an air cooled condensing unit and a compressor located outdoors, with interconnecting refrigerant pipes between the AH units and the associated condensing units. The control room and cable spreading room areas have a third source of cooling, which is not safety-related, in the form of a water chiller supplying a second set of coils in the safety-related air handling systems.

The CREVS is a shared system providing protection to the common control room for both Units 1 and 2. The CREVS consists of two redundant subsystems (trains 11 and 12), each capable of maintaining the habitability of the control room envelope. Each CREVS train is considered operable when the individual components necessary to limit operator exposure are operable within the given train.

A CREVS train is considered operable when the associated equipment is operable, as follows:

  • control room heating, ventilation, and air conditioning supply and return fans;
  • post loss-of-coolant incident fan;
  • post loss-of-coolant incident filter train;
  • high efficiency particulate air filters and charcoal adsorbers are not excessively restricting flow, and can perform their filtration functions;
  • ductwork, valves, and dampers are operable, and air circulation can be maintained; and

The CRETS is a subsystem that provides temperature control for the control room following isolation of the control room. The CRETS is a shared system that is supported by the CREVS, since the CREVS must be operating for CRETS to perform its safety function. The CRETS consists of two independent, redundant trains ( 11 and 12) that provide cooling of recirculated control room air.

The CREVS has its inlet fresh air supplies, one for each train, and the common air exhaust isolated by leaktight hatches; therefore, the CREVS is operated in full recirculation mode during normal and accident conditions.

The 11 train CREVS and CRET 1ZA 480 volt (V) load is powered from engineered safety feature (ESF) 11 bus, and the 12 train CREVS and CRETS 2ZB load is powered from the ESF bus 24. The CREVS and CRETS loads for each train are approximately 200 kilowatts (kW)

(211.8 kW for bus 11 and 203.6 kW for bus 24).

2.1.2 Electrical Systems The Calvert Cliffs electrical offsite power from the 500 kilovolts (kV) network to the switchyard is supplied by three physically independent transmission lines. Two physically independent circuits supply offsite power from the 500 kV switchyard to the onsite electrical distribution system via the 13 kV system. The two independent offsite circuits from the switchyard to the ESF electrical system include two 500 kV lines and buses, two 500 kV/14kV plant service transformers, two 13 kV service buses 11 and 21, and 13. 8 kV/4.16 kV unit service transformers. The two 500 kV lines and buses, two 500 kV/14kV plant service transformers, and two 13 kV service buses 11 and 21 are shared between the two units. Each 500 kV/14 kV plant service transformer can supply the total (two units) plant auxiliary load. Offsite power can also be supplied from the 13 kV from the Southern Maryland Electric Cooperative (SMECO) line. The 13 kV SMECO offsite circuit includes the 13 kV line, 13 kV service bus 23, 13 kV service bus 11 or 21, and 13.8 kV/4.16 kV unit service transformers. The 13 kV SMECO line can supply the power required to maintain both units in a safe shutdown condition. It may be substituted for one of the 500 kV/13 kV circuits as one of the two required, physically independent, offsite circuits. Upon loss of the switchyard power source, the SMECO line can be used to supply any two 4.16 kV ESF buses (one from each unit) through the 13 kV service bus 23 and either 13 kV service bus 11 or 21.

Four safety-related EDGs are provided for the plant, two for each unit. Any combination of two of the EDGs (one from each unit) can supply sufficient power ( 1) for the operation of necessary ESF loads during accident conditions in one unit and shutdown loads of the alternate unit, concurrent with a loss-of-offsite power (LOOP), and (2) for the safe and orderly shutdown of both units under LOOP conditions. The diesel generators (DGs) start automatically on safety injection actuation signal or an undervoltage condition on the 4.16 kV ESF buses that supply vital loads and are ready to accept loads within 10 seconds. A station blackout (SBO) diesel generator (SBO DG or OC DG) can also be aligned to any of the four ESF buses.

The safety-related AC electrical distribution systems (4.16 kV, 480 V, and vital 120 VAC) supply power to the ESF systems during normal operation and under accident conditions. The 4.16 kV and 480 VAC distribution systems for each unit include two 4.16 kV buses, four 480 V buses and load centers, and two motor control centers. Each of the two 4.16 kV ESF buses is supplied from either an offsite power source or a DG. The 480 VAC ESF buses are supplied from the DGs through the 4.16 kV/480 V service transformers in case offailure of the preferred source of power to the 4.16 kV ESF buses. Each of the two motor control center buses is supplied from separate EDGs via the 480 V unit load centers.

2.2 Description of Proposed Change In the LAR and its supplement, the licensee requested two temporary, one-time extensions for TS 3.8.1 Required Action D.3 completion time from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days. Required Action D.3 requires a declaration of the CREVS and CRETS inoperable upon the supported offsite circuit inoperable. The amendments would revise TS 3.8.1 by adding the following footnote to Required Action D.3 completion time:

Or 14 days, once during each applicable 2019 and 2020 Refueling Outage, for the connection of the new P-13000-3 Service Transformer.

Prior to entry into the 14-day Completion Time, the OC DG and the SMECO 69 kV Line shall be verified available . During the 14-day Completion Time, the OC DG and SMECO 69 kV Line shall be verified available once per shift.

If both the OC DG and SMECO 69 kV Line become un-available during the 14-day Completion Time, either the OC DG or the SMECO 69 kV Line shall be restored to available status within 24. hours, or the Unit shall be brought to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

In the LAR, the licensee stated that the proposed change will support the specific one-time conditions to tie in the new 13.8 kV service transformer during the Unit 2 2019 and Unit 1 2020 RFOs. When operational, the new service transformer will improve the reliability of the 13.8 kV offsite circuits. The modifications to the offsite circuits are being implemented under another process. The licensee further stated that the proposed change is in accordance with the guidance of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition," Branch Technical Position (BTP) 8-8, "Onsite (Emergency Diesel Generators) and Offsite Power Sources Allowed Outage Time Extensions."

The NRC staff notes that no physical changes are being proposed to the CREVS and CRETS.

The CREVS and CRETS were designed to meet single failure criteria of Institute of Electrical and Electronics Engineers (IEEE) 279, "Proposed IEEE Criteria for Nuclear Power Plant Protection Systems," dated August 30, 1968.

2.3 Description of Regulatory Requirements and Guidance The NRC staff applied the following requirements to the evaluation of the LAR:

  • Title 1O of the Code of Federal Regulations (10 CFR) Section 50.36, "Technical specifications," requires, in part, that the operating license of a nuclear production facility include TSs. Paragraph 56.36(c)(2) of 10 CFR requires that the TSs include limiting conditions for operation (LCOs), which 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 shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met.
  • 10 CFR 50.63, "Loss of all alternating current power," requires, in part, that a nuclear power plant shall be able to withstand for a specified duration and recover from a complete loss of offsite and onsite AC sources (i.e., an SBO).

Calvert Cliffs was designed and constructed to meet the intent of the draft (proposed) General Design Criteria (GDC) for Nuclear Power Plants, which was published by the Atomic Energy Commission in July 1967. Modifications to the facility are evaluated in accordance with 10 CFR 50.59 to assess consistency with the current licensing basis (including the draft GDC, as applicable).

The following draft GDC 24 and 39 are applicable to the Calvert Cliffs electrical power systems.

o Draft GDC 24, "Emergency Power for Protection Systems," states:

[l]n the event of loss of all offsite power, sufficient alternate sources of power shall be provided to permit the required functioning of the protection systems.

o Draft GDC 39, "Emergency Power for Engineered Safety Features," states:

[A]n alternate power system shall be provided and designed with adequate independency, redundancy, capacity, and testability to permit the functioning required of the engineered safety features. As a minimum, the onsite power system and the offsite power system shall each, independently, provide this capacity assuming a failure of a single active component in each power system.

  • Additionally, Calvert Cliffs UFSAR, Appendix 1C, states that a new safety-related DG (Emergency Diesel Generator (EOG) 1A) was installed at Calvert Cliffs in 1996. The new EOG 1A, its support systems, and the building which houses it, were designed to the final GDC in Appendix A to 10 CFR Part 50.

o 10 CFR, Appendix A to Part 50, GDC 17, "Electric Power Systems," requires that an onsite electric power system and an offsite electric power system be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that ( 1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences, and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents. The onsite electric power supplies, including the batteries and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure.

The NRC staff applied the following regulatory guidance to the evaluation the LAR:

  • Regulatory Guide (RG) 1.93, "Availability of Electric Power Sources," provides guidance with respect to operating restrictions or completion time if the number of available AC sources is less than that required by the TS LCO. This guide recommends a maximum completion time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for an inoperable onsite or offsite AC source.
  • RG 1.155, "Station Blackout," provides guidance for complying with the requirement in 10 CFR 50.63 that nuclear power plants be capable of coping with an SBO event for a specified duration.
  • RG 1.9, "Application and Testing of Safety-Related Diesel Generators in Nuclear Power Plants," in describing the reliability of the EDGs, states that the design of the EDGs should also incorporate high operational reliability, and this high reliability should be maintained throughout their lifetime by initiating a reliability program that is designed to monitor, improve, and maintain reliability. Increased operational reliability can be achieved through

appropriate testing and maintenance, as well as an effective root cause analysis of all EOG failures.

  • NUREG-0800, BTP 8-8, provides guidance to the NRC staff in reviewing LARs for licensees proposing a one-time or permanent TS change to extend an EOG allowed outage time beyond 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
  • Generic Letter 80-30, "Clarification of the Term 'Operable' as it Applies to Single Failure Criterion for Safety Systems Required by TS," states that when a plant condition does not meet the LCO requirement and is relying on the provisions of the actions table, the single failure criterion consideration is suspended.

3.0 TECHNICAL EVALUATION

The NRC staff's evaluation of the proposed change considered several potential plant conditions that could be encountered while exercising the temporary CT extensions. The NRC staff also considered the available redundant or diverse means to respond to various plant conditions. The NRC staff reviewed information pertaining to the electrical power systems in the application, the UFSAR, and applicable TS LCO to verify the capability of the affected electrical power systems to perform their safety functions (assuming no additional failures of electrical components) is maintained. The NRC staff reviewed the capacity of the remaining and alternate power sources to verify whether these power sources are capable of providing power to the CREVS and CRETS. In conjunction with reviewing the remaining and alternate power sources, the NRC staff considered supplemental electrical power sources (either safety or non-safety related) that are available at Calvert Cliffs and are capable of performing the same function of the inoperable electrical power source.

3.1 Consideration of Risk Insights In its LAR, the licensee stated that the proposed changes are based on a deterministic evaluation centered on "NUREG-0800, BTP 8-8. Therefore, the LAR was not a risk-informed request, and a risk evaluation was not required for making a regulatory decision.

The NRC staff determined that "special circumstances," as discussed in NUREG-0800, Section 19.2, "Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis; General Guidance," which would have necessitated additional risk information to be provided, did not exist. As such, the NRC staff did not request any additional risk information associated with the review of this LAR.

The licensee provided risk insights related to the proposed change in Section 4.4 of to the LAR. Because this is not a risk-informed LAR, the staff neither reviewed the licensee's PRA models to determine their technical acceptability to support this LAR nor relied on the numerical results provided by the licensee. The staff performed an independent assessment using the Calvert Cliffs Standardized Plant Analysis Risk (SPAR) model. The review of the Calvert Cliffs SPAR model and the licensee-provided risk insights supported the traditional engineering conclusions associated with the licensee's proposed compensatory actions. The risk insights did not challenge the engineering conclusions that the proposed changes maintain defense-in-depth.

3.2 Evaluation of CREVS and CRETS Power Sources With respect to the power sources for the CREVS and CRETS, TS 3.8.1, LCO 3.8.1 requires:

a. One qualified circuit between the offsite transmission network and the other unit's onsite Class 1E AC electrical power distribution subsystems, and
b. One DG from the other unit capable of supplying power to the CREVS and CRETS.

As stated in the LAR, the required TS offsite power circuits are 13.8 kV service buses 11 and 21, which can be powered by:

a. Two 500 kV lines, two 500 kV buses, and two P-13000 (500 kV/13.8 kV) transformers; or
b. One 500 kV line, one 500 kV bus, one associated P-13000 (500 kV/13.8 kV) transformer, and the 69 kV/ 13.8 kV SMECO line.

In the LAR, the licensee stated that during normal plant operation, train 11 of the CREVS and CRETS is powered from Unit 1 4.16 kV ESF bus 11, which is powered from the 13.8 kV service bus 11 offsite circuit and backed up by 1A EOG. Train 12 of CREVS and CRETS is powered from Unit 2 4.16 kV ESF bus 24, which is powered from the 13.8 kV service bus 21 offsite circuit and backed up by 28 EOG. During the Unit 2 2019 RFO 14-day completion time period, both trains of CREVS and CRETS will be powered from 13.8 kV service bus 11 offsite circuit. The SMECO line will be aligned to the 13.8 kV service bus 11 in a standby mode. During the Unit 1 2020 RFO 14-day completion time, both trains of CREVS and CRETS will be powered from the 13.8 kV service bus 21 offsite circuit. The SMECO line will be aligned to the 13.8 kV service bus 21 in a standby mode.

The NRC staff further evaluated the power sources for the CREVS and CRETS during the RFO 14-day CT periods in the event of the LOOP. As stated in the LAR, for a normal LOOP and a failure of one EOG, Train-11 of CREVS and CRETS will be powered by 1A EOG and Train-12 of CREVS and CRETS will be powered by 28 EOG. The NRC staff evaluated the most limiting failure case, where there is a LOOP concurrent with the failure of one EOG during the saltwater system outage, which renders another EOG inoperable. For the evaluation with this most limiting failure case, the NRC staff focused in the failure of the EDGs that power the CREVS and CRETS ( 1A and 28 EDGs ).

The NRC staff notes that during the Unit 2 2019 RFO 14-day completion time, both trains of the CREVS and CRETS will be powered from the Unit 1 offsite circuit and backed up by the EDGs.

Therefore, the staff finds that during the Unit 2 2019 RFO 14-day completion time, the capability of the electrical power system to provide power to the CREVS and CRETS is maintained (assuming no additional failures nor inoperability of electrical components).

Similarly, during the Unit 1 2020 RFO 14-day completion time, both trains of the CREVS and CRETS will be powered from the Unit 2 offsite circuit with associated electrical power distribution subsystems and backed up by the EDGs. Therefore, the NRC staff finds that the capability of the electrical power system to provide power to the CREVS and CRETS is maintained (assuming no additional failures or inoperability of electrical components). This is further discussed in Section 3.3 of this safety evaluation.

3.3 Evaluation of Alternate Power Sources for the CREVS and CRETS In the LAR, the licensee stated that during each RFO, the CREVS and CRETS alternate power can be provided by either the SBO DG or the SM ECO line. The NRC staff's evaluation of the alternate power sources for the CREVS and CRETS during the above 14-day completion times is provided below.

SMECO Line As stated in Chapter 8 of the UFSAR, the 13 kV SMECO line can supply the power required to maintain both units in a safe shutdown condition. The SMECO line can be substituted for one of the 500 kV/13 kV offsite circuits as one of the two required offsite circuits. The SMECO system can energize 13 kV service bus 23, which can be used to supply either 13 kV bus 11 or 21, as required. Upon loss of the switchyard power source, the SMECO system could then be used to supply any two 4.16 kV ESF buses, one for each unit, through either 13 kV service bus 11 or

21. A manual engineered safety feature actuation system loss-of-coolant incident and shutdown sequencer actuation is provided in the control room to ensure that the SMECO system is loaded in an orderly manner to minimize system transients. The SMECO system has a capability always of 5,000 kW. Electrical indication is provided in the control room for bus voltage, bus current, and power usage.

The LCO requires operability of two out of three qualified circuits between the transmission network and the onsite Class 1E AC electrical power distribution system circuits. These circuits consist of two 500 kV circuits and the 69 kV SM ECO dedicated source. The engineered safety feature actuation system loss-of-coolant incident and shutdown sequencer for the 4.16 kV bus will sequence loads on the bus after the 69 kV/13.8 kV SMECO line has been manually placed in service.

As stated in the LAR, the SMECO line power source has the capability to supply the power necessary to maintain Units 1 and 2 in a safe shutdown condition. The SMECO system has a capability of 5,000 kW. The system's bus voltage, bus current, and power usage indications are provided in the control room. Upon loss of the switchyard power source, the SMECO system could be used to supply any two 4.16 kV ESF buses, one for each unit through either 13 kV service bus 11 or 21.

In the LAR, the licensee further stated that during the Unit 2 2019 RFO 14-day completion time, with the 13.8 kV 21 service bus out of service, all four 4.16 kV ESF buses will be powered from the remaining qualified offsite circuit, the 13.8 kV service bus 11, which is powered from the P-13000-1 service transformer. The third delayed qualified offsite circuit 13.8 kV SMECO line will be available and aligned to the 13.8 kV service bus 11 in a standby mode. Thus, if the normal 500 kV offsite switchyard supply or the Unit 1 500/13.8 kV service transformer is lost, the SMECO line can be manually closed (using existing operation procedures in approximately 1O minutes) onto 13.8kV service bus 11 and provide power for accident mitigation on Unit 1 and shutdown loads for Unit 2. The 1A and 1B EDGs will be operable and protected equipment on Unit 1.

Similarly, during the Unit 1 2020 RFO 14-day completion time, with the 13.8 kV service bus 11 out of service, all four 4.16 kV ESF buses will be powered from the 13.8 kV service bus 21, which is powered from the P-13000-2 service transformer. The third delayed qualified offsite circuit 13.8 kV SMECO line will be available and aligned to the 13.8 kV service bus 21 in a

standby mode. Additionally, the 2A and 2B EDGs will be operable and protected equipment on Unit 2.

The NRC staff notes that during the Unit 2 2019 RFO 14-day completion time, the SMECO line will be aligned to the 13.8 kV service bus 11 in a standby mode. Similarly, during the Unit 1 2020 RFO 14-day completion time, the SMECO line will be aligned to the 13.8 kV service bus 21 in a standby mode. As stated in the November 12, 2018, supplement, the SMECO line shall be verified available prior to entry into the 14-day completion time and once per shift during the 14-day completion time. The NRC staff notes that the SMECO line has the capacity to supply the power required to maintain both units in a safe shutdown condition.

Based on these considerations, the NRC staff finds, with reasonable assurance, that the SMECO line is an adequate alternate power source for the CREVS and CRETS during the above RFO 14-day completion times because:

a. This alternate power source has the capacity to supply the power required to maintain both units in a safe shutdown condition; thus, this power source is sufficient to provide alternate power to the CREVS and CRETS;
b. The SMECO system will be aligned to the remaining offsite circuit and can be connected to the service bus, using the existing procedures, within 10 minutes, which is less than the BTP 8-8 time critical action (60 minutes);
c. The SMECO system will be verified available prior to and during the 14-day completion times; and
d. The proposal is consistent with BTP 8-8.

SBODG In the LAR, the licensee stated that during the 2019 Unit 2 RFO, the 1A and 1B EDGs will be operable and protected equipment on Unit 1. Both 2A EDG and 2B EDG will be operable and protected equipment on Unit 2, except for two periods where the saltwater system maintenance outages are scheduled. During the 14-day completion time, the 2B EDG will be inoperable for approximately 4 days during the scheduled saltwater system B train maintenance outage.

Following the B train maintenance, a saltwater system A train maintenance outage will be conducted for approximately 4 days, which will make the 2A EDG inoperable. Train 12 of the CREVS will be maintained operable and the EDG backed throughout the saltwater system maintenance outages. The most limiting failure case for the CREVS and CRETS during the 2019 RFO is when there is a LOOP, concurrent with the failure of 1A EDG during the saltwater system outage that renders 2B EDG inoperable. In this case, the SBO DG can be aligned to power the 11 ESF bus, thus providing power to the CREVS and CRETS train 11 and satisfying the requirement of having one train of CREVS and CRETS operable to perform its safety function.

Similarly, during the 2020 Unit 1 RFO, the 2A and 28 EDGs will be operable and protected equipment on Unit 2. Both 1A EDG and 1B EDG will be operable and protected equipment on Unit 1, except for a period where the saltwater system maintenance outages are scheduled.

During 14-day completion time, the 1B EDG will be inoperable for approximately 4 days during the scheduled saltwater system B train maintenance outage. The 1A EDG is air cooled and will not be impacted by the saltwater system maintenance outage, and therefore, will remain

operable. Train 11 of CREVS will be maintained operable and EOG backed throughout the saltwater system maintenance outages. The most limiting failure case for the CREVS and CRETS during the 2020 RFO is when there is a LOOP, concurrent with the failure of 28 EOG.

In this case, the S80 DG can be aligned to power the 24 ESF bus, thus providing power to the CREVS and CRETS train 12. Train 11 is not affected by the saltwater system maintenance outage.

As described in the UFSAR, the S80 DG is designed to provide a power source capable of starting and supplying the essential loads necessary to safely shut down one unit and maintain it in a safe shutdown condition during an S80 event. The S80 DG can supply any of the four ESF buses. The S80 DG is started manually and is loaded onto a bus when it is determined that the EOG dedicated to that bus is not available to supply the plant loads. Furthermore, the S80 DG can supply the same emergency plant loads as the EDGs.

The S80 DG is available to power the inoperable DG bus loads in the event of an S80 or loss of offsite power. The TS requires the licensee to administratively verify both opposite-unit DGs operable and the S80 DG available within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and to continue this action once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter until restoration of the required DG is accomplished. This verification provides assurance that both opposite-unit DGs and the S80 DG can supply the onsite Class 1E AC electrical power distribution system.

As stated in the LAR, the S80 DG is not Class 1E equipment; however, it was purchased to the same equipment specifications as the safety-related 1A EOG. The S80 DG has a design continuous rating of 5,400 kW and a design 2-hour peak rating of 5,940 kW. Per EOG loading calculation E-88-015, "Diesel Generator Accident Loading," for Unit 1, the highest EOG peak loading during a LOOP is 3,512.7 kW for ESF bus 11, and 2,341.0 kW for ESF bus 14.

Similarly, for Unit 2, the highest EOG peak loading during a LOOP is 2,406.2 kW for ESF bus 21, and 2,734.9 kW for ESF bus 24. Therefore, the loads are within the capacity of the S80 DG. and the S80 DG's capacity meets the electrical load requirements for 4.16 kV ESF bus 11 or 14 during a Unit 1 LOOP, concurrent with a loss of 1A or 18 EOG, and for the 4.16 kV ESF bus 21 or 24 during a Unit 2 LOOP, concurrent with a loss of 2A or 28 EOG to safely shut down the plant.

In the LAR, the licensee further stated that to calculate a realistic essential load profile for the S80 DG, the SMECO summary table was used, and ESF buses 11 and 24 were selected, since they are the two most heavily loaded buses of the four buses. The normal shutdown highest load of 4,168.9 kW was conservatively selected over a 2-hour period ( 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is required, per 8TP 8-8, to restore the battery chargers and control reactor coolant system inventory). The SMECO tables do not include the auxiliary feedwater pumps and the S80 diesel building loads.

The S80 diesel building loads are conservatively estimated to be 597.4 kW and the highest auxiliary feedwater pump load for the unit in Mode 1 is 427.3 kW for Unit 1 and 368.2 kW for Unit 2. Since the auxiliary feedwater pumps are not in use at the time of maximum loading that occurs after shutdown cooling conditions are established, their contribution is not additive to the total maximum loading condition. Therefore, the highest total load is 4,766.3 kW, which is within the S80 DG capacity The NRC staff notes that the S80 DG's capacity is sufficient to provide power to bring the operating unit to a cold shutdown and to maintain the shutdown cooling loads on the unit that is in the shutdown or refueling mode. In the LAR, the licensee stated that the S80 DG currently has an equipment issue with its OC2 turbocharger. The licensee further stated that a technical evaluation with the performance of a special test run concluded that the S80 DG will maintain

greater than continuous 4,766.3 kW load with engine room temperatures averaging 75.4 degrees Fahrenheit (°F), as would be expected during the months of January through March (the RFOs time period). An additional limit of 92 °F ambient air temperature restriction will be placed on the SBO DG to ensure adequate room temperature and SBO DG capacity.

The NRC staff notes that the OC2 turbocharger issue may impact the SBO DG reliability as described in RG 1.9. In the November 12, 2018, supplement, the licensee stated that the SBO DG is monitored and maintained in accordance with ER-AA-440, "Emergency Diesel Generator (EOG) Reliability Program." Based on a review of the corrective action review program from year 2014 to present, the reliability of the SBO DG is 100 percent. There was no start demand failures for scheduled periodic testing recorded. The licensee further stated that the equipment issue has had no impact on the SBO DG reliability based upon not having any start demand failures per RG 1.155. The equipment issue could impact the SBO DG design capacity of 5,400 kW. The SBO OC2 turbocharger and cylinder exhaust temperature condition have been evaluated. The evaluation has identified a long-term degradation occurring in the OC2 exhaust gas temperatures. This degradation is resulting in lowered margin to alarm setpoints during fully loaded runs. The evaluation substantiated that despite this degradation, the SBO DG can meet the expected 4,766.3kw load, with the additional establishment of the compensatory action limit of 92 °F ambient (outside) air temperature during the expected February 2019 and 2020 14-day completion times. The SBO DG expected 4,766.3 kW maximum load is conservatively based on the highest loaded emergency safety-related bus from each unit.

As stated in the LAR, the total time to power any of the four ESF 4.16 kV buses by the SBO DG for either unit is less than 60 minutes. Aligning the SBO DG within 60 minutes is considered a time-critical action, and the licensee-expected performance time to realign the SBO DG is 40 minutes. With respect to testing, in the LAR, the licensee stated that the SBO DG will be tested within 30 days prior to entering the extended completion time by bringing the power source to its rated voltage and frequency for more than 5 minutes and ensuring all its auxiliary support systems are available or operational to be consistent with BTP 8-8 guidance. With respect to the existing procedure, in the LAR, the licensee stated that EOP-0, "Post-Trip Immediate Actions," and EOP-7, "Station Blackout," provide instructions for starting and loading the SBO DG onto the appropriate ESF bus as determined by the control room staff. Emergency Response Plan Implementing Procedure 611 allows for connecting more than one 4.16 kV ESF bus to the SBO DG, if required.

The NRC staff notes that although the SBO DG in its normal operating condition cannot be started within 10 seconds upon receiving a start signal to support the assumptions of the design-basis loss-of-coolant accident analysis in the UFSAR, this DG has been credited in the Calvert Cliffs TSs as an emergency power source. The NRC staff notes that TS 3.8.1, Conditions B, E, and F, require the SBO DG to be in an available status (aligned with the safety buses) when one required DG is inoperable. While in the above TS conditions, operator action (closing a breaker) from the control room will start and load this DG.

The NRC staff finds, with reasonable assurance, that upon an EOG becoming inoperable due to the saltwater system maintenance outage, the SBO DG is an adequate alternate power source for the CREVS and CRETS during the 2019 and 2020 RFO 14-day completion times because (a) this alternate power source has the capacity to supply the power required to maintain both units in a safe shutdown condition; thus, this power source is sufficient to provide alternate power to the CREVS and CRETS; (b) the DG can be connected to the service bus, using the existing procedures, within 60 minutes, which is consistent the BTP 8-8 time critical action

(60 minutes); (c) the DG will be verified available prior to and during the 14-day completion times; and d) the proposal is consistent with BTP 8-8.

The NRC staff determined that the proposed change continues to meet the intent of the design-criteria described, applicable GDCs concerning availability, capacity, and capability of the electrical power systems. The proposed change meets the requirements of 10 CFR 50.36(c)(2) because the lowest functional capability or performance levels of equipment required for safety is maintained. Therefore, the NRC staff concludes that the proposed change is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Maryland State official was notified of the proposed issuance of the amendments on November 27, 2018. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component 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 such finding (October 23, 2018; 83 FR 53513). 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.

6.0 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: Larry Wheeler Khoi Nguyen Keith Tetter Date: January 22, 2019

SUBJECT:

CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2- ISSUANCE OF AMENDMENT NOS. 328 AND 306 TO EXTEND COMPLETION TIME OF REQUIRED ACTION 0.3 OF TECHNICAL SPECIFICATION 3.8.1 TO 14 DAYS (EPID L-2018-LLA-0229) DATED JANUARY 22, 2019 DISTRIBUTION:

Public PM File Copy RidsNrrDorlLpl1 Resource RidsNrrLALRonewicz Resource RidsNrrDssStsb Resource RidsRgn1 MailCenter Resource RidsACRS_MailCTR Resource RidsNrrPMCalvertCliffs Resource RidsNrrDeEeob Resource RidsNrrDirslrab Resource RidsNrrDraAplb Resource RidsNrrDssStsb Resource RidsNrrDssScpb Resource GDentel, R-1 LWheeler, NRR PSnyder, NRR KNguyen, NRR MKichline, NRR KTetter, NRR MReisiFard, NRR ADAMS Access1on No.: ML18365A373 *b1y memoran d um **b,y e-ma1 OFFICE DORL/LPL 1/PM DORL/LPL 1/LA DRA/APLB/TL ** DSS/STSB/BC** DE/EEOB/BC(A)*

NAME MMarshall LRonewicz MReisiFard VCusumano EMiller DATE 01/03/2019 01/02/2019 01/07/2019 01/09/2019 12/07/2018 OFFICE DSS/SCPB/BC* OGC- NLO** DORL/LPL 1/BC DORL/LPL 1/PM NAME SAnderson BHarris JDanna MMarshall DATE 12/11/2018 01/15/2019 01/18/2019 01/22/2019 OFFICIAL RECORD COPY