ML20232A171

Request to Use Alternative Code Case OMN-26

ML20232A171
Person / Time
Site:	Calvert Cliffs, Peach Bottom, Nine Mile Point, Braidwood, Limerick, Ginna, Clinton
Issue date:	09/01/2020
From:	Nancy Salgado Plant Licensing Branch III
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Wiebe J
References
EPID L-2020-LLR-0012
Download: ML20232A171 (12)

Text

September 1, 2020 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO)

Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

BRAIDWOOD STATION, UNITS 1 AND 2; CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2; CLINTON POWER STATION, UNIT 1; R. E. GINNA NUCLEAR POWER PLANT; LIMERICK GENERATING STATION, UNITS 1 AND 2; NINE MILE POINT, UNITS 1 AND 2; AND PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 - REQUEST TO USE ALTERNATIVE CODE CASE OMN-26 (EPID L-2020-LLR-0012)

Dear Mr. Hanson:

By letter dated January 31, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20034C819), as supplemented by letter dated July 6, 2020 (ADAMS Accession No. ML20188A264), Exelon Generation Company, LLC (Exelon) submitted a request in accordance with paragraph 50.55a(z)(1) of Title 10 of the Code of Federal Regulations (10 CFR) to implement the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel Code Case OMN-26, Alternate Risk-Informed and Margin Based Rules for lnservice Testing of Motor Operated Valves," at Braidwood Station, Units 1 and 2; Calvert Cliffs Nuclear Power Plant, Units 1 and 2; Clinton Power Station, Unit 1; R. E. Ginna Nuclear Power Plant; Limerick Generating Station, Units 1 and 2; Nine Mile Point, Units 1 and 2; and Peach Bottom Atomic Power Station, Units 2 and 3.

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 proposed alternative to implement ASME OM Code Case OMN-26, as described in Exelons letters dated January 31, 2020, and July 6, 2020, provides an acceptable level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(1).

Therefore, the NRC staff authorizes the proposed alternative for the implementation of ASME OM Code Case OMN-26, for the specified 10-year inservice testing program intervals.

All other ASME OM Code requirements for which relief or an alternative was not specifically requested and approved in the subject requests remain applicable.

B. Hanson If you have any questions, please contact Joel Wiebe at 301-415-6606 or via e-mail at Joel.Wiebe@nrc.gov.

Sincerely, Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-456, STN 50-457, 50-317, 50-318, 50-461, 50-244, 50-352, 50-353, 50-220, 50-410, 50-277, and 50-278

Enclosure:

Safety Evaluation cc: Listserv Nancy L.

Salgado Digitally signed by Nancy L. Salgado Date: 2020.09.01 09:15:49 -04'00'

Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ALTERNATIVE REQUEST TO USE ASME OM CODE CASE OMN-26 RELATED TO THE INSERVICE TESTING PROGRAMS FOR BRAIDWOOD, UNITS 1 AND 2, CALVERT CLIFFS, UNITS 1 AND 2, CLINTON, UNIT 1, R.E. GINNA, LIMERICK, UNITS 1 AND 2, NINE MILE POINT, UNITS 1 AND 2, AND PEACH BOTTOM, UNITS 2 AND 3 DOCKET NOS. STN 50-456, STN 50-457, 50-317, 50-318, 50-461, 50-244 50-352, 50-353, 50-220, 50-410, 50-277, AND 50-278

1.0 INTRODUCTION

By a letter dated January 31, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20034C819), as supplemented by letter dated July 6, 2020 (ADAMS Accession No. ML20188A264), Exelon Generation Company, LLC (Exelon, the licensee), submitted to the U.S. Nuclear Regulatory Commission (NRC) an alternative test plan in lieu of certain inservice testing (IST) requirements of the American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code:

Section IST [inservice testing] (OM Code) for the IST programs at the following plants:

Table 1 Plant Docket ASME Test Interval ASME OM Code Edition Interval Start Date Interval End Date Braidwood Station Unit 1 50-456 4th 2012 7/29/2018 7/28/2028 Braidwood Station Unit 2 50-457 4th 2012 7/29/2018 7/28/2029 Calvert Cliffs Nuclear Power Plant Unit 1 50-317 5th 2012 7/1/2018 6/30/2028 Calvert Cliffs Nuclear Power Plant Unit 2 50-318 5th 2012 7/1/2018 6/30/2028 Table 1 Plant Docket ASME Test Interval ASME OM Code Edition Interval Start Date Interval End Date Clinton Power Station Unit 1 50-461 3rd 2012 7/1/2020 6/30/2030 R.E. Ginna Nuclear Power Plant 50-244 6th 2012 1/1/2020 12/31/2029 Limerick Generating Station Unit 1 50-352 4th 2012 1/8/2020 1/7/2030 Limerick Generation Station Unit 2 50-353 4th 2012 1/8/2020 1/7/2030 Nine Mile Point Nuclear Station Unit 1 50-220 5th 2012 1/1/2019 12/31/2028 Nine Mile Point Nuclear Station Unit 2 50-410 4th 2012 1/1/2019 12/31/2028 Peach Bottom Atomic Power Station Unit 2 50-277 5th 2012 11/16/2018 8/14/2028 Peach Bottom Atomic Power Station Unit 3 50-278 5th 2012 11/16/2018 8/14/2028 Specifically, pursuant to Title 10, of the Code of Federal Regulations (CFR), Part 50, Section 55a, paragraph (z), subparagraph (1) (10 CFR 50.55a(z)(1)), the licensee requested to implement ASME OM Code Case OMN-26 related to the testing of certain active motor-operated valves (MOVs) on the basis that the alternative provides an acceptable level of quality and safety.

2.0 REGULATORY EVALUATION

The NRC regulations in 10 CFR 50.55a(f), "Inservice Testing Requirements," require, in part, that IST of certain ASME Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda, except where alternatives have been authorized pursuant to paragraph 10 CFR 50.55a(z)(1) or 10 CFR 50.55a(z)(2).

In proposing alternatives, a licensee must demonstrate that the proposed alternatives provide an acceptable level of quality and safety (10 CFR 50.55a(z)(1)) or compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety (10 CFR 50.55a(z)(2)).

3.0.1 Applicable ASME OM Code The following request is an alternative test plan in lieu of certain IST requirements of the 2012 Edition of the ASME OM Code for the IST programs at the plants listed in Table 1 of this safety evaluation (SE) for the duration of their current 10-year IST program interval.

3.1.1 Licensees Alternative Request ASME OM Code Requirements:

Mandatory Appendix III, Preservice and Inservice Testing of Active Electric Motor Operated Valve Assemblies in Light-Water Reactor Power Plants, paragraph III-3310, Inservice Test Interval, subparagraph (c) states, in part, that The maximum inservice test interval shall not exceed 10 yr.

Mandatory Appendix III, paragraph III-3700, Risk-Informed MOV Inservice Testing, states that Risk-informed MOV inservice testing that incorporates risk insights in conjunction with performance margin to establish MOV grouping, acceptance criteria, exercising requirements and testing interval may be implemented.

Mandatory Appendix III, paragraph III-3721, [High Safety Significant Component] HSSC MOVs, states that HSSC MOVs shall be tested in accordance with para. III-3300 and exercised in accordance with para. III-3600. HSSC MOVs that can be operated during plant operation shall be exercised quarterly, unless the potential increase in core damage frequency (CDF) and large early release (LER) associated with a longer exercise interval is small.

Mandatory Appendix III, paragraph III-3722, [Low Safety Significant Component] LSSC MOVs, subparagraph (d), states that LSSC MOVs shall be inservice tested at least every 10 yr in accordance with para. III-3310.

Alternative testing is requested for safety-related MOVs that are currently required to meet these ASME OM Code requirements.

The licensee states, in part:

=

Reason for Request===

Code Case OMN-26 better aligns OM Code Mandatory Appendix Ill to the Risk and Margin Based Licensee Motor Operated Valve (MOV) Programs developed in response to NRC Generic Letter 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves, that have been in effect since 1998. The Appendix Ill ten-year maximum inservice test interval was originally established to align with the maximum test interval allowed under the Generic Letter 96-05 MOV Programs that, for most Licensees, was established by the Joint Owners Group (JOG) MOV Periodic Verification Program.

There is no formal technical basis for the current Appendix Ill ten-year maximum interval that applies to all MOVs regardless of Risk and Margin. Over the past twenty years, Exelon MOV Programs have demonstrated many margin stable MOVs that can be readily justified to extend from their current MOV Program maximum inservice test intervals of six years (for High Risk) and ten years (for Low Risk).

Proposed Alternative Exelon proposes to implement the ASME OM Code Case OMN-26 alternative risk and margin informed rules for inservice testing of MOVs in its entirety.

HSSC MOVs shall be tested in accordance with para. III-3300 and exercised in accordance with para. III-3600 while applying the following HSSC MOV risk insights and limitations:

(a) HSSC MOVs that can be operated during plant operation shall be exercised quarterly, unless the potential increase in core damage frequency (CDF) and large early release (LER) associated with a longer exercise interval is small.

(b) For HSSC MOVs, the maximum inservice test interval shall be established in accordance with Table 1 of OMN-26 OMN Table 1 HSSC MOV - Margin Based Maximum Inservice Test Intervals HSSC MOV Functional Margin(D)

Maximum Inservice Test Interval (Years)

If MOV is routinely(A) operated at Design Basis Pressure Conditions

- Max Inservice Test Interval (Years)(B)

Low (< 5%)

2 4

Medium ( 5% and < 10%)

4 9

High ( 10% and < 20%)

9 9

Very High ( 20%)

9 12 OMN-26 Table 1 - Notes (A) Occurs at a periodicity no less frequent than once a refueling outage.

(B) To utilize these intervals, test strokes at or exceeding design basis system conditions must be in the applicable safety function direction(s) and have no applicable operating experience, degradation or diagnostic test anomaly with the potential for adverse impact on MOV functional margin or the capability of the MOV to perform its design basis function.

(D) For the purpose of this code case, the MOV functional margin limits apply to the As-Left MOV conditions at the start of the inservice test interval and include applicable test uncertainties and allowance for service-related degradation.

For LSSC MOVs, the maximum inservice test interval shall be established in accordance with Table 2 of OMN-26 OMN Table 2 LSSC MOV - Margin Based Maximum Inservice Test Intervals LSSC MOV Functional Margin(D)

Maximum Inservice Test Interval (Years)

If MOV is routinely(A) operated at Design Basis Pressure Conditions

- Max Inservice Test Interval (Years)(B)

Low (< 5%)

4 9

Medium ( 5% and < 10%)

9 12 High ( 10% and < 20%)

12 12 Very High ( 20%)

12 16(C)

OMN-26 Table 2 - Notes (A) Occurs at a periodicity no less frequent than once a refueling outage.

(B) To utilize these intervals, test strokes at or exceeding design basis system conditions must be in the applicable safety function direction(s) and have no applicable operating experience, degradation or diagnostic test anomaly with the potential for adverse impact on MOV functional margin or the capability of the MOV to perform its design basis function.

(C) Operating plants that have acquired the requisite test data to satisfy Appendix Ill, paragraphs III-3310(b) or III-3722(c) must complete one cycle of collecting diagnostic test data at an extended test interval, minimum 9 and maximum 12 years, before extending the test interval by engineering evaluation to the maximum 16-year test interval.

(D) For the purpose of this code case, the MOV functional margin limits apply to the As-Left MOV conditions at the start of the inservice test interval and include applicable test uncertainties and allowance for service-related degradation.

Basis for Use In its letters dated January 31 and July 6, 2020, the licensee describes the basis for its proposed alternative to implement ASME OM Code Case OMN-26 for the nuclear power plants listed in Table 1 of this SE. In summary, the licensee considers the requested alternative to adopt OMN-26 to be in line with the current JOG MOV periodic verification test program that Exelon has implemented since the late 1990's in response to Generic Letter(GL) 96-05. Both the JOG MOV periodic verification program and Code Case OMN-26 provide a risk-margin based methodology that establishes limitations for maximum IST intervals for MOVs. The licensee considers Code Case OMN-26 to provide a reasonable extension of this risk-Informed philosophy based on the lessons learned and accumulated MOV performance data gathered over more than 25 years of MOV performance verification testing. The licensee states that Appendix Ill alone, in isolation from Code Case OMN-26, provides no such methodology other than a maximum limit for the IST interval regardless of risk or margin.

In its letter dated July 6, 2020, the licensee clarifies the implementation of Code Case OMN-26 to be consistent with its plant operations. For example, the licensee states that to implement to extended intervals with MOV design-basis differential pressure testing, test strokes at or exceeding design basis system conditions must occur at a periodicity no less frequent than once a refueling cycle in the applicable safety function direction(s), and the MOV must have no applicable operating experience, degradation or diagnostic test anomaly with the potential for adverse impact on MOV functional margin or the capability of the MOV to perform its design basis function. The licensee notes that these routine strokes during the IST interval are not required to be diagnostically monitored. The licensee also states that the MOV functional margin limits apply to the As-Left MOV condition at the start of the IST interval and includes applicable test uncertainties and allowance for service-related degradation. The licensee notes that the IST interval is uniquely established for each MOV based on margin and risk classification of the MOV.

3.1.2 NRC Staff Evaluation The NRC regulations in 10 CFR 50.55a(b)(3)(ii) require nuclear power plant licensees to comply with the provisions of the ASME OM Code incorporated by reference in 10 CFR 50.55a, and must establish a program to ensure that MOVs continue to be capable of performing their design-basis safety function. The NRC staff considers ASME OM Code testing specified in Mandatory Appendix III with the conditions in 10 CFR 50.55a(b)(3)(ii), and the MOV diagnostic test programs developed in response to NRC GL 89-10, Safety-Related Motor-Operated Valve Testing and Surveillance (ADAMS Accession No. ML031150300) and GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves ADAMS Accession No. ML031110010), together will satisfy the regulatory requirements of 10 CFR 50.55a(b)(3)(ii).

In GL 89-10, the NRC staff requested that each nuclear power plant licensee establish a program to demonstrate that safety-related MOVs are capable of performing their design basis functions. During the implementation of GL 89-10, the NRC staff provided four acceptable methods a licensee could use to demonstrate the design basis capability of safety-related MOVs. The four methods for demonstrating capability in descending order of acceptability are:

1) Dynamic testing at or near design basis conditions with diagnostics of each MOV where practicable. Valves dynamically tested at less than design basis conditions may be extrapolated with proper justification.

2) Electric Power Research Institute (EPRI) MOV Performance Prediction Methodology (PPM). This method was developed for those valves that could not be dynamically tested. The PPM required internal valve measurements to provide assurance that the valve performance was predictable. The NRC staff began accepting the use of the PPM even where dynamic testing for an MOV was practicable.

3) MOV valve grouping. Where valve-specific dynamic testing was not performed and the PPM was not used, the staff accepted grouping of MOVs that were dynamic tested at the plant to apply the plant-specific test information to an MOV in the group.

4) The use of valve test data from other plants or research programs. The NRC ranks this as the least-preferred approach (with the most margin required) because the licensee would have minimal information regarding the tested valve and its history.

In superseding GL 89-10, GL 96-05 requested that each licensee establish a program, or ensure the effectiveness of its current program, to verify on a periodic basis that safety-related MOVs continue to be capable of performing their safety functions within the current licensing basis of the facility. The program should ensure that changes in required performance resulting from degradation (such as those caused by age) can be properly identified and addressed.

In response to GL 96-05, the nuclear industry joined together to form the JOG MOV periodic verification program. The JOG program consisted of three elements: (1) an interim MOV periodic verification program for licensees to use in response to GL 96-05 during development of a long-term program; (2) a 5-year MOV dynamic diagnostic test program; and (3) a long-term MOV periodic diagnostic test program to be based on the information from the dynamic testing program. The JOG effort was intended to answer the valve degradation question as it pertained to valve configuration, design, and system application. The JOG test program was not intended to provide data to the industry for the purpose of justifying valve performance. The final JOG program plan consisted of periodic diagnostic test program that is based on risk and margin.

The NRC staff approved the JOG final program plan, with conditions, in an SE dated September 25, 2006 (ADAMS Accession No. ML061280315).

The ASME OM Code establishes the requirements for preservice and inservice testing and examination of certain components to assess their operational readiness in light-water reactor nuclear power plants. These requirements apply to pumps and valves that are required to perform a specific function in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident. The ASME OM Code also applies to pressure relief devices and dynamic restraints.

Prior to the development of Mandatory Appendix III, the ASME OM Code testing for MOVs consisted of:

1) Valve exercising to include quarterly stroke time testing

2) Valve obturator movement verification during the exercise test

3) Valve leakage testing (only if the valve has a leakage limit requirement)

4) Remote position indication verification In the past, these required tests were considered to be adequate to assess MOV operational readiness. However over the course of several years of operating experience and testing, it was determined that quarterly stroke time testing of MOVs was not an adequate indicator of valve degradation. As an alternative to MOV stroke-time testing, ASME developed Code Case OMN-1 to allow periodic exercising and diagnostic testing in assessing operational readiness of active MOVs in lieu of quarterly stroke-time testing. ASME provided additional guidance by developing Code Case OMN-11, Risk-Informed Testing for Motor-Operated Valves, for MOVs in the IST program that are determined to have a high safety significance. The NRC staff has reviewed and accepted these Code Cases with certain conditions as noted in Regulatory Guide (RG) 1.192, Operation and Maintenance Code Case Acceptability ASME OM Code (ADAMS Accession No. ML19128A261), which is incorporated by reference in 10 CFR 50.55a. ASME merged these two Code Cases into an updated version of Code Case OMN-1 published in the 2006 Addenda of the ASME OM Code. This updated OMN-1 Code Case was later adopted into the 2009 Edition of ASME OM Code as Mandatory Appendix III. The NRC conditions for use of Mandatory Appendix III are specified in 10 CFR 50.55a(b)(3)(ii).

Most licensees of operating nuclear power plants committed to follow the JOG MOV periodic verification program as part of their response to GL 96-05. The NRC staff reviewed each licensees GL 96-05 program and risk methodology (including implementation of the JOG program) and prepared an SE describing its review of each of those programs with conditions. Many licensees committed to the Boiling Water Reactor Owners Group (BWROG) risk methodology NEDC-32264A (Revision 2) approved by NRC staff on February 27, 1996, Westinghouse Owners Group (WOG) risk method V-EC-1658-A (Revision 2) approved by NRC staff on August 13, 1998, or a plant-specific risk methodology. The nuclear power plants listed in Table 1 of this SE committed to the following risk ranking method:

1) Limerick - committed to follow the BWROG risk method - SE dated November 17, 2000 (ADAMS Accession No. ML003755447)

2) Braidwood - committed to follow the WOG risk method - Response to Request for Additional Information (RAI) dated April 12, 1999 (ADAMS Accession No. ML17191B310)

3) Calvert Cliffs - committed to follow the WOG risk method - SE dated December 15, 1999 (ADAMS Accession No. ML993550374)

4) Clinton - committed to follow a plant-specific risk method - SE dated February 8, 2000 (ADAMS Accession No. ML003681570)

5) Ginna - committed to follow the WOG risk method - SE dated December 27, 1999 (ADAMS Accession No. ML003672670)

6) Nine Mile - committed to follow a plant-specific risk method - SE dated July 18, 2000 (ADAMS Accession No. ML003729304)

7) Peach Bottom - committed to follow the BWROG risk method - SE dated November 16, 2000 (ADAMS Accession No. ML003752691)

Licensees of operating nuclear power plants must meet the requirements of 10 CFR 50.55a(b)(3)(ii) to follow the ASME OM Code requirements, and have an MOV program that periodically verifies that MOVs will continue to perform their safety functions. The NRC staff considers the JOG program plan and Mandatory Appendix III to meet 10 CFR 50.55a(b)(3)(ii) with conditions. Both programs are similar but have differences such as:

1) The JOG program incorporates risk into its MOV diagnostic testing schedule, but Mandatory Appendix III does not require the implementation of a risk-informed program. Applying risk in Mandatory Appendix III relaxes valve grouping requirements which allows for more flexible testing.

2) The JOG program has specific test intervals based on risk and margin. High risk MOVs have shorter test intervals dependent on margin with a maximum test interval of 6 years for high margin MOVs and 2 years for low margin MOVs. Mandatory Appendix III relies on the plant MOV engineer to set the correct test interval not to exceed 10 years based on specific MOV diagnostic test data. High risk valves can be justified to extend the test interval to 10 years.

3) The licensees implementation of the JOG program is a commitment, whereas the implementation of Mandatory Appendix III is a regulatory requirement.

4) The JOG program applies to valve performance, and the licensee is responsible for justifying the periodic verification of the actuator performance.

ASME developed Code Case OMN-26 to reduce the amount of programmatic changes for licensees incorporating Mandatory Appendix III for the first time when the licensees update their IST program plans. Code Case OMN-26 aligns those portions of Mandatory Appendix III to follow the JOG approach of the test interval being based on both margin and risk that has been successfully implemented for the last 20 years. In some instances, Code Case OMN-26 is more restrictive in that certain valves (without periodic design-basis testing) are not allowed to have test intervals up to the 10-year interval allowed in Mandatory Appendix III. On the other hand, Code Case OMN-26 will allow certain valves to have test intervals based on their risk and margin that are beyond the 10-year interval in Appendix III. The NRC staff considers the extensions of the test intervals in Code Case OMN-26 to be reasonable based on many years of successful test data in implementing the JOG program by nuclear power plant licensees.

Another improvement in Code Case OMN-26 is that for high-risk valves with very high margins that are successfully stroked at least once per operating cycle under full design pressure and flow, the test interval may be extended to 12 years. Similarly, the diagnostic test interval for low-risk valves with very high margins and that are successfully stroked at least once per operating cycle under full design pressure and flow, the test interval may be extended to 16 years. Essentially, each successful stroke under full design pressure and flow is a reasonable demonstration of a very high margin MOV being operationally ready to perform its safety function without diagnostic test equipment.

In its letter dated July 6, 2020, the licensee states that the provisions of Code Case OMN-26 will be implemented in their entirety, including all tables and associated notes. The licensee specifies minor clarifications of the notes in the tables in Code Case OMN-26 to be consistent with its normal plant operations. The NRC staff has determined that the licensees proposed alternative to implement Code Case OMN-26, as described in the licensees letters dated January 31, 2020, and July 6, 2020, at the nuclear power plants listed in Table 1 of this SE, provides an acceptable level of quality and safety for their current 10-year IST program intervals.

4.0 CONCLUSION

As described above, the NRC staff concludes that the proposed alternative to implement ASME OM Code Case OMN-26, as described in the licensees letters dated January 31, 2020, and July 6, 2020, provides an acceptable level of quality and safety for the nuclear power plants listed in Table 1 of this SE. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(1).

Therefore, the NRC staff authorizes the proposed alternative for the implementation of ASME OM Code Case OMN-26, for the specified 10-year IST program intervals for the nuclear power plants listed in Table 1 of this SE.

All other ASME OM Code requirements for which relief or an alternative was not specifically requested and approved in the subject requests remain applicable.

Principal Contributor: Michael Farnan, NRR Date of issuance: September 1, 2020

ML20232A171

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NAME JWiebe SRohrer TScarbrough DATE 8/19/2020 8/19/2020 7/22/2020 OFFICE NRR/DORL/LPL3/BC*

NAME NSalgado DATE 9/1/2020