ML21139A022
| ML21139A022 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 06/09/2021 |
| From: | Mahesh Chawla Plant Licensing Branch IV |
| To: | Diya F Union Electric Co |
| Chawla M | |
| References | |
| EPID L-2020-LLA-0235 | |
| Download: ML21139A022 (17) | |
Text
June 9, 2021 Mr. Fadi Diya Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Energy Center 8315 County Road 459 Steedman, MO 65077
SUBJECT:
CALLAWAY PLANT, UNIT NO. 1 - AUDIT
SUMMARY
FOR LICENSE AMENDMENT REQUEST TO ADOPT 10 CFR 50.69, RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS AND COMPONENTS FOR NUCLEAR POWER REACTORS (EPID L-2020-LLA-0235)
Dear Mr. Diya:
By application dated October 30, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20304A454), Union Electric Company, dba Ameren Missouri (the licensee), submitted a license amendment request for Callaway Plant, Unit No. 1 (Callaway). The proposed amendment would modify the Callaway licensing basis by the addition of a license condition (i.e., License Condition 2.(C).(19)), to allow for the implementation of the provisions of Title 10 of the Code of Federal Regulations (10 CFR),
Section 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors.
To support its review, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a virtual regulatory audit on May 11-13, 2021. The NRC staff reviewed documents and held discussions with members of Ameren Missouri and its contractors. The regulatory audit summary is enclosed with this letter.
If you have any questions, please contact me by telephone at (301) 415-8371 or by e-mail at Mahesh.Chawla@nrc.gov.
Sincerely,
/RA/
Mahesh L. Chawla, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483
Enclosure:
Audit Summary
Enclosure OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY AUDIT
SUMMARY
FOR MAY 11-13, 2021, AUDIT IN SUPPORT OF LICENSE AMENDMENT REQUEST TO ADOPT 10 CFR-50.69, RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS AND COMPONENTS FOR NUCLEAR POWER REACTORS UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT NO. 1 DOCKET NO. 50-483
1.0 BACKGROUND
By application dated October 30, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20304A454), Union Electric Company, dba Ameren Missouri (the licensee), submitted a license amendment request (LAR) for Callaway Plant, Unit No. 1 (Callaway). The proposed amendment would modify the Callaway licensing basis by the addition of a license condition (i.e., License Condition 2.C.(19)), to allow for the implementation of the provisions of Title 10 of the Code of Federal Regulations (10 CFR), Section 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors.
On February 18, 2021 (ADAMS Accession No. ML21039A222), NRC issued an audit plan, which provided the list of requested documents and other details pertaining to the audit. An audit team, consisting of U.S. Nuclear Regulatory Commission (NRC) staff and one contractor from the Pacific Northwest National Laboratory (PNNL), conducted a remote regulatory audit to support the review of the LAR from May 11-13, 2021. The purpose of the audit was to gain an understanding of the information needed to support the NRC staffs licensing decision regarding the LAR and to develop requests for additional information (RAIs). The information submitted in support of the LAR is under final review, and any additional information needed to support the LAR review will be formally requested by the NRC staff using the RAI process in accordance with Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-101, Revision 6, License Amendment Review Procedures (ADAMS Accession No. ML19248C539).
The regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. The regulatory audit is conducted with the intent to gain understanding, to verify information, and/or to identify information that will require docketing to support the basis of a licensing or regulatory decision.
Performing a regulatory audit of the licensees information is expected to assist the NRC staff in efficiently conducting its review or gain insights on the licensees processes or procedures.
Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. However, the NRC staff may review supporting information retained as records under Title 10 of the Code of Federal Regulations (10 CFR) Section 50.71, Maintenance of records, making of reports, and/or 10 CFR 54.37, Additional records and recordkeeping requirements, which, although not required to be submitted as part of the licensing action, would help the NRC staff better understand the licensees submitted information.
2.0 AUDIT ACTIVITIES The NRC audit team consisted of four NRC staff from NRR, Division of Risk Assessment (DRA),
Probabilistic Risk Assessment (PRA) Licensing Branches (APLA and APLC); two NRC staff from NRR, Division of Engineering and External Hazards (DEX), External Hazards Branch (EXHB); and one PNNL contractor. In addition, one NRC observer from DRA was in attendance for the audit. Attachment 1 of this enclosure provides the list of participants from NRC, PNNL, the licensee, and other attendees.
The NRC audit team held an entrance meeting on Tuesday, May 11, 2021, with the licensees staff and contractors. During the remainder of the audit, the NRC audit team participated in technical discussions with the licensee based on discipline according to the audit agenda (ADAMS Accession No. ML21110A123). Attachment 2 of the enclosure includes a list of documents reviewed during the audit.
3.0 RESULTS OF THE AUDIT Technical discussions were focused on the following major areas: PRA model changes since the LAR submittal, internal events, fire, seismic, and external hazards topics. The NRC audit team participated in an audit exit meeting with the licensee on Thursday, May 13, 2021, where the NRC staff provided a brief summary of the teams goals, objectives, and technical discussion conclusions.
The NRC staff provided a brief conclusion of the audit objectives that were met and details on the path forward. There were no open items in the discussion and no deviation from the audit plan. The licensee agreed to provide a supplement to the application to address audit discussion points and potential RAIs. During the audit, the licensee requested that new questions posed during the audit and a summary of the audit question discussions be provided by the NRC staff to facilitate the preparation of the supplement. This information is included as Attachments 3 and 4 of this enclosure.
The information submitted in support of the Callaway LAR is under review, and additional information needed to support the LAR review will be formally communicated by the NRC staff using the RAI process in accordance with NRR Office Instruction LIC-101.
Attachments:
- 1. List of Participants
- 2. List of Documents Reviewed During Audit
- 3. Status of Audit Questions
- 4. Revised Audit Question APLA 02
LIST OF PARTICIPANTS U.S. Nuclear Regulatory Commission (NRC) Audit Team Mahesh Chawla Project Manager, NRR1/DORL2/LPL43 Jeff Circle PRA Licensing Reviewer, NRR/DRA4/APLA5 Garill Coles Contractor, PNNL6 Joshua Havertape Team Lead, PRA Licensing Reviewer, NRR/DRA/APLA David Heeszel Geophysicist, NRR/DEX7/EXHB8 Sunwoo Park Observer, NRR/DRA/APLC9 Kevin Quinlan Physical Scientist (Meteorologist), NRR/DEX/EXHB Keith Tetter PRA Licensing Reviewer, NRR/DRA/APLC De (Wesley) Wu PRA Licensing Reviewer, NRR/DRA/APLC Union Electric Company dba Ameren Missouri, Callaway, Team Andrew Burgess Lead Callaway Contact Justin Hiller Lead PRA Contact Bruce Huhmann 50.69 Project Supervisor Jake Heithold 50.69 Project Engineer Jim Kovar Licensing Ben Hryciw High Winds PRA Contractor Garrett Snedeker 50.69 Categorization Contractor Rick Grantom 50.69 PRA Contractor Ricky Summit Contractor - Seismic PRA Russell Sharpe Contractor - PRA Brian Krystek Contractor - PRA Matt Degonish Contractor - PRA Jeff Sciaudone High Winds PRA Contractor Tom Elwood Supervisor, Regulatory Affairs Stephanie Banker VP, Nuclear Engineering Steve Meyer Manager, Regulatory Affairs 1 Office of Nuclear Reactor Regulation 2 Division of Operating Reactor Licensing 3 Plant Licensing Branch IV 4 Division of Risk Assessment 5 Probabilistic Risk Assessment Licensing Branch A 6 Pacific Northwest National Laboratory 7 Division of Engineering and External Hazards 8 External Hazards Branch 9 Probabilistic Risk Assessment Licensing Branch C
LIST OF DOCUMENTS REVIEWED DURING THE AUDIT Callaway Plant, Unit No. 1 (Callaway), Documents Available for Review on the Portal Union Electric Company, dba Ameren Missouri (the licensee) provided an extensive list of supporting documents (e.g., analyses, calculations, reports, drawings, and procedures) on the Callaway document portal for review in support of the audit, as follows:
Callaway Fire Protection Change Logs (file loaded during the audit meeting to support discussions).
Flex Sensitivity Study Results (file loaded during the audit meeting to support discussions).
Nuclear Energy Institute (NEI) 16-09, Risk-Informed Engineering Programs (10 CFR-[Title 10 of the Code of Federal Regulations Section] 50.69) Implementation Guidance, dated August 2020.
Callaway Energy Center (CEC) Report, PRA-CRM-Analysis, Revision 001, Configuration Risk Management Modeling & Analysis Notebook, dated May 2021.
Callaway Energy Center Report, PRA-HW, Revision 001, High Wind Probabilistic Risk Assessment [PRA] Summary Report, dated May 2021.
Callaway Energy Center Report, PRA-HW-MISSILE_FRAGILITY, Revision 000, Missile Fragility Analysis, dated October 2019.
Callaway Energy Center Report, PRA-HW-PRESS_FRAGILITY, Revision 001, Wall Pressure Fragility Analysis, dated October 2019.
Callaway Energy Center Report, PRA-SEISMIC-PLANT_RESPONSE, Revision 001, Seismic Probabilistic Risk Assessment Modeling Notebook, dated May 2021.
Callaway Energy Center Report, PRA-SEISMIC-QUANT, Revision 001, Seismic Probabilistic Risk Assessment, Quantification Analysis Notebook, dated May 2021.
Callaway Energy Center Report, PRA-SEISMIC-FRAGILITY APP, Revision 000, Civil Structure Evaluation for CEC Seismic PRA, dated January 2019.
Callaway Energy Center Report, PRA-FIRE-17671_015, Revision 001, NFPA [National Fire Protection Association] 805 Fire Quality Summary, dated May 2021.
Callaway Energy Center Report, PRA-FIRE-17671_013, Revision 001, Callaway NFPA 805 Fire PRA Integrated Fire Risk Report, dated May 2021.
Callaway Energy Center Report PRA-OEH-ANALYSIS, Other External Hazards:
Screening Assessment Notebook, Update 8.
Pressurized Water Reactor Owners Group (PWROG)-19012-P, Peer Review of the Callaway Internal Events and Internal Flood Probabilistic Risk Assessment, dated April 2019.
Pressurized Water Reactor Owners Group, PWROG-19022-P, Peer Review of the Callaway External Hazard Screening Assessment and High Winds Probabilistic Risk Assessment, dated April 2019.
Pressurized Water Reactor Owners Group, PWROG-19034-P, Independent Assessment of Facts & Observations Closure and Focused Scope Peer Review of the Callaway Probabilistic Risk Assessments, dated November 2019.
Pressurized Water Reactor Owners Group, PWROG-18044-P, Peer Review of the Callaway Seismic Probabilistic Risk Assessment, dated June 2018.
Pressurized Water Reactor Owners Group, PWROG-19011-P, Independent Assessment of Facts & Observations Closure and Focused Scope Peer Review of the Callaway Seismic Probabilistic Risk Assessment, dated March 2019.
Westinghouse LTR-RAM-II-10-019, Fire PRA Peer Review Against the Fire PRA Standard Supporting Requirements from Section 4 of the ASME/ANS [American Society of Mechanical Engineers/American Nuclear Society] Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessments for Nuclear Power Plant Applications for the Callaway Nuclear Plant Fire Probabilistic Risk Assessment, dated October 2009.
AMN#PES00021-REPT-001, Callaway Energy Center Fire Probabilistic Risk Assessment Peer Review F&Os [Facts and Observations] Closure, dated June 2019.
AMN#PES00031-REPT-001, Callaway Energy Center Probabilistic Risk Assessment Focused Scope Peer Review, dated July 2020.
AMN#PES00031-REPT-002, Callaway Energy Center Probabilistic Risk Assessment Peer Review F&Os Closure, dated July 2020.
Pressurized Water Reactor Owners Group, PWROG-19020-NP Revision 1, Newly Developed Method Peer Review Pilot - General Screening Criteria for Loss of Room Cooling in PRA Modeling, dated April 2020.
Pressurized Water Reactor Owners Group, PWROG-18027-NP Revision 0, Loss of Room Cooling in PRA Modeling, dated April 2020.
Callaway Energy Center Report PRA-IE-UNCERT, Probabilistic Risk Assessment (PRA), Uncertainty Analysis Notebook, Revision 000.
Callaway Energy Center Report PRA-IE-UNCERT Appendix 6, Disposition of Key Uncertainties: Risk-Informed Engineering Programs (10CFR50.69), Revision 000.
STATUS OF AUDIT QUESTIONS QUESTION NUMBER QUESTION TOPIC STATUS KEY ITEMS FROM AUDIT QUESTION
RESPONSE
New Question Probabilistic Risk Assessment (PRA) Update 9 Potential Request for Additional Information (RAI)
Document and justify the basis for the large change in seismic large early release frequency (SLERF) from the PRA model update 8 to 9.
APLA - 01 PRA Upgrades Potential RAI Part a. Potential RAI Positive statement to document the closure of open fact and observations (F&O) associated with PRA update 9.
Positive statement there were no PRA upgrades that have not been peer-reviewed.
Part b. Potential RAI -
Positive statement that that there were no unreviewed upgrades to the fire PRA since 2009.
Table summarizing major updates to fire PRA and justification that they were updates opposed to upgrades.
Include guidance used to make the determination of maintenance update/upgrade.
Part c. Potential RAI -
Positive statement there are no unreviewed upgrades.
QUESTION NUMBER QUESTION TOPIC STATUS KEY ITEMS FROM AUDIT QUESTION
RESPONSE
APLA - 02 Use of Newly Developed Method from Pressurized-Water Reactor Owners Group (PWROG)-18027-NP Part a. Potential RAI Part b. Potential RAI Part c. Potential RAI - New question Part a. Potential RAI -
Positive statement that the necessary supporting requirements (SRs), including the hazard-specific back reference to these SRs, have been peer reviewed.
Part b. Potential RAI -
If cited SRs were not included in the peer review, then perform a focused-scope peer review or justify exclusion (e.g., using a sensitivity study)
Part c. Potential RAI -
How was room cooling screening from full power internal event mode revisited for other hazards (e.g., fire PRA)?
APLA - 03 Overlap of Functions and Components Potential RAI Potential RAI Restate audit response on the docket.
APLA - 04 Key Assumptions and Sources of Uncertainties Identification Process Potential RAI Part a. Potential RAI Provide description of the updated uncertainty analysis performed for the application.
Part b. Potential RAI Provide an explicit statement that generic industry sources of uncertainty in Electric Power Research Institute (EPRI) report 1026511 were reviewed for QUESTION NUMBER QUESTION TOPIC STATUS KEY ITEMS FROM AUDIT QUESTION
RESPONSE
seismic, fire and high winds hazards.
Part c. Potential RAI Provide summary bullet list of the half dozen or so criteria used to justify why each uncertainty issue was determined not to be key as described verbally during the audit.
Part d. Potential RAI No questions based on the response.
APLA/APLC
- 05 PRA Model Uncertainty Dispositions Potential RAI Part a. Potential RAI Identify the studies that form the basis of the electrical grid fragility in the high winds analysis.
Summarize the results of the sensitivity studies on the impact of component fragility on component categorization.
Elaborate on what pessimistic estimate means.
Part b. Potential RAI Positive statement on docket that the Nuclear Energy Institute (NEI) 00-04 sensitivity studies for human failure events (HFEs) will include adjustment to the four seismic human reliability analysis (HRA) bins.
QUESTION NUMBER QUESTION TOPIC STATUS KEY ITEMS FROM AUDIT QUESTION
RESPONSE
Part c. Potential RAI Describe PRA update 9 results and margin to Regulatory Guide 1.174 guidelines.
Part d. Potential RAI Statement that truncation convergence criteria met in PRA update 9 Basis for seismic core damage frequency (CDF) and SLERF decrease from PRA update 8 to PRA update 9.
APLA - 06 Total risk consideration Potential RAI Part a. Potential RAI Provide a summary of the parametric uncertainty analysis performed for each hazard that addresses the state of knowledge correlation (SOKC) and identify the hazard-specific parameters that were correlated.
Part b. Potential RAI Provide a quantitative assessment of the level of impact that using point estimate means has on the application.
APLA/APLC
- 07 PRA credit for Diverse and Flexible Coping (FLEX) strategies Potential RAI Describe how FLEX was treated in PRA update 9, as opposed to update 8 (i.e., FLEX is set to true in PRA update 9 for all hazards).
QUESTION NUMBER QUESTION TOPIC STATUS KEY ITEMS FROM AUDIT QUESTION
RESPONSE
APLB - 01 Focused-scope peer review of Fire PRA HRA for main control room (MCR) abandonment Potential RAI Positive statement regarding F&O closure in Feb 2021, that there are no longer any outstanding commitments or implementation items.
Reference to May 3rd Appendix X memo.
APLB - 02 Fire PRA methods Potential RAI Include listing of the guidance documents (NUREGs and frequently asked questions (FAQs)) that were used to update the fire PRA since the full-scope peer review - that were identified in the audit.
Include positive statement that licensee does not credit incipient detection.
Include positive statement regarding implementation of FAQ 13-0004 for sensitive equipment in fire PRA that includes a discussion of the caveats.
APLC - 01 Integrated PRA hazards model Potential RAI Provide description presented during audit showing that integration of PRA importance factors will be in alignment with NEI 00-04 guidance.
QUESTION NUMBER QUESTION TOPIC STATUS KEY ITEMS FROM AUDIT QUESTION
RESPONSE
APLC - 02 Overall use of NEI 00-04 Figure 5-6 and use for external floods Potential RAI LAR not consistent with licensee response regarding use of NEI 00-04, Figure 5-6. Provide positive statement that NEI 00-04, Figure 5-6 will be applied at the time of categorizing an SSC.
APLC - 03 Seismic PRA Modeling Potential RAI Extension of discussion from APLA/APLC-05. Describe truncation convergence in PRA update 9.
Explain how there are two separate quantifications for CDF and LERF and, thus, the seismic hazard intervals for CDF and LERF can be defined differently.
APLC - 04 Seismic site-specific inputs Potential RAI Provide updated list of dominant fragilities in seismic PRA and justify not using more refined fragility analyses.
Explain what is meant by a generic and conservative estimate with respect to site specific analysis.
APLC - 05 Seismic PRA model uncertainties Potential RAI Explain drivers for the difference in the mean and base SLERF values if the difference remains high (a factor of 3) for update 9.
APLC - 06 High winds and their generated missiles hazards development Potential RAI Summarize the PRA notebook references in the audit response QUESTION NUMBER QUESTION TOPIC STATUS KEY ITEMS FROM AUDIT QUESTION
RESPONSE
such that it can be referenced in the safety evaluation (brief summary of method and data used).
APLC - 07 High winds PRA modeling Potential RAI Summarize the PRA notebook reference provided in audit response.
REVISED AUDIT QUESTION APLA 021 APLA Question 02 - Use of Newly Developed Method from PWROG-18027-NP Note: Changes to the audit question are underlined Section B of Regulatory Guide (RG) 1.200, Revision 3, Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities, dated December 2020 (ADAMS Accession No. ML20238B871), endorses Nuclear Energy Institute (NEI) 17-07, Revision 2, Performance of PRA Peer Reviews Using the ASME/ANS PRA Standard, dated August 2019 (ADAMS Accession No. ML19241A615). The guidance in NEI 17-07, Revision 2, establishes a newly developed method (NDM) peer review process. Section B of RG 1.200, Revision 3 also endorses the following portions from the Pressurized Water Reactor Owners Group (PWROG)-19027-NP, Revision 2, Newly Developed Method Requirements and Peer Review, dated July 2020 (part of ADAMS Accession No. ML20213C660):
Requirements for the peer review of NDMs (see Regulatory Positions C.2.2.2 through C.2.2.4).
Process for determining whether a change to a PRA is classified as PRA maintenance or a PRA upgrade (see Appendix C).
Definitions related to NDMs, PRA maintenance, and PRA upgrade.
Sections 3.2.1, Internal Events and Internal Flooding, and 3.3 of Enclosure 1 to the LAR, state that Callaway incorporated the NDM described in PWROG-18027-NP, Revision 0, Loss of Room Cooling in PRA Modeling, dated April 2020, into its internal events PRA. The licensee explains that in November 2019 an independent assessment was performed to close open F&Os, but that an F&O related to implementation of the PWROG-18027-NP methodology remained open. In Section 3.3 of the LAR, the licensee explains that in June 2020 an independent assessment to close open F&Os and a concurrent focused-scope peer review was performed to complete review of the use of the PWROG-18027-NP methodology. In the LAR, the licensee states that the PRA standard supporting requirements (SRs) associated with implementation of the guidance in PWROG-18027-NP, Revision 0, were found to meet Capability Category II. The licensee also explains, that as part of an effort unrelated to the Callaway reviews, a peer review was performed in February and March of 2020 on the PWROG-18027-NP methodology following the guidance in NEI 17-07, Revision 2, and PWROG-19027-NP, Revision 2, which contains the SRs for new methods. This NDM pilot review is documented in a letter to the NRC titled For Information Only - PWROG-19020-NP Revision 1 Appendices B, C and E Newly Developed Method Peer Review Pilot - General Screening Criteria for Loss of Room Cooling in PRA Modeling per PA-RMSC-1647, dated August 6, 2020 (ADAMS Accession Nos. ML20230A125 and ML20230A126). The NDM pilot review document states that the PWROG-18027-NP methodology was found to meet all SRs associated with the NDM without any open F&Os.
However, Section E.4.2 of PWROG-19020-NP states that a peer review of this method is needed when it is implemented at a plant that includes evaluation of the following SRs: SY-A3, SY-A6, SY-A11, SY-A18, SY-A21, SY-A22, SY-B6, SY-B9, SY-B11, and SYB12 and hazard-specific SRs that reference back to these SRs. It is not clear to NRC staff whether these SRs were included in the focused-scope peer review of the methodology.
1 Probabilistic Risk Assessment Licensing Branch A in the Office of Nuclear Reactor Regulation, Division of Risk Assessment Also, the LAR states that the loss of room cooling evaluation methodology documented in PWROG-18027-NP, Revision 0, was incorporated into and peer reviewed for the internal events PRA. The NRC staff notes that because the internals events PRA is the foundation for the fire, seismic and high winds PRAs, the approach could be implemented in the other PRAs. For the fire PRA, it is not clear whether the screening and application of the method based on interference theory was re-applied or if the evaluation for the internal events PRA was assumed to apply without further assessment. It is also not clear how the consideration of internal fires impacts the application of the PWROG-18027-NP approach on fire PRA scenarios, given that fire can increase the temperature within a room with PRA components or that a fire outside of the room can impact the interfacing instrument and control systems associated with a room cooling system.
In light of the observations above, address the following:
- a. Confirm that the SRs cited above were included in the June 2020 Callaway internal events focused-scope peer review of the implementation of the PWROG-18027-NP methodology.
- b. If in response to Part a. above, it cannot be confirmed that the cited SRs were included in the June 2020 focused-scope peer review of the implementation of the PWROG-18027-NP methodology, then justify any exclusions. Alternatively, perform a focused-scope peer review of the method against the cited SRs and close any resulting F&Os using an NRC-approved process.
- c. Explain whether and how the PWROG-18027-NP methodology for evaluating room cooling systems from the PRA was applied in the fire PRA. If the approach is applied to the fire PRA, include a discussion and justification of how fire impacts were considered (i.e., room heat-up due to fire or fire damage of the instrument and control system associated with a room cooling system, which may exist outside the room).
- via e-mail OFFICE NRR/DORL/LPL4/PM*
NRR/DORL/LPL4/LA*
NRR/DEX/EXHB/BC*
NRR/DRA/APLA/BC*
NAME MChawla (DGalvin for)
PBlechman w/comment BHayes RPascarelli DATE 5/21/2021 5/21/2021 5/21/2021 5/19/2021 OFFICE NRR/DRA/APLC/BC*
NRR/DORL/LPL4/BC*
NRR/DORL/LPL4/PM*
NAME SRosenberg JDixon-Herrity (SLee for) MChawla DATE 6/1/2021 6/9/2021 6/9/2021