ML21326A099
| ML21326A099 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 01/07/2022 |
| From: | Richard Guzman NRC/NRR/DORL/LPL1 |
| To: | Stoddard D Dominion Energy Nuclear Connecticut |
| Guzman R | |
| References | |
| EPID L-2020-LLA-0266, WCAP-17642-P-A, Rev. 1 | |
| Download: ML21326A099 (1) | |
Text
January 7, 2022 Mr. Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Dominion Energy Nuclear Connecticut, Inc.
Millstone Power Station Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711
SUBJECT:
MILLSTONE POWER STATION, UNIT NO. 3 ISSUANCE OF AMENDMENT NO. 281 RE: REVISED REACTOR CORE SAFETY LIMIT TO REFLECT TOPICAL REPORT WCAP-17642-P-A, REVISION 1 (EPID L-2020-LLA-0266)
Dear Mr. Stoddard:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 281 to Renewed Facility Operating License No. NPF-49 for the Millstone Power Station, Unit No. 3 (Millstone 3), in response to your application dated December 8, 2020, as supplemented by letter dated December 21, 2021.
The amendment modifies the technical specifications by revising the Reactor Core Safety Limit 2.1.1.2 peak fuel centerline temperature to reflect the fuel centerline temperature specified in Topical Report WCAP-17642-P-A, Revision 1, Westinghouse Performance Analysis and Design Model (PAD5).
A copy of the related safety evaluation is also enclosed. The Commissions monthly Federal Register notice will include the Notice of Issuance.
Sincerely,
/RA/
Richard V. Guzman, Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-423
Enclosures:
- 1. Amendment No. 281 to NPF-49
- 2. Safety Evaluation cc: Listserv DOMINION ENERGY NUCLEAR CONNECTICUT, INC., ET AL DOCKET NO. 50-423 MILLSTONE POWER STATION, UNIT NO. 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 281 Renewed License No. NPF-49
- 1.
The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Dominion Energy Nuclear Connecticut, Inc.
(DENC, the licensee), dated December 8, 2020, as supplemented by letter dated December 21, 2021, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions 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 Commissions 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 Commissions regulations, and all applicable requirements have been satisfied.
- 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. NPF-49 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A, revised through Amendment No. 281 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto are hereby incorporated into the license. DENC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3.
This license amendment is effective as of the date of issuance and shall be implemented within 90 days of issuance.
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 Renewed Facility Operating License and Technical Specifications Date of Issuance: January 7, 2022 James G.
Danna Digitally signed by James G. Danna Date: 2022.01.07 10:28:58 -05'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 281 MILLSTONE POWER STATION, UNIT NO. 3 RENEWED FACILITY OPERATING LICENSE NO. NPF-49 DOCKET NO. 50-423 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 Insert 4
4 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 a marginal line indicating the area of change.
Remove Insert 2-1 2-1 (2)
Technical Specifications The Technical Specifications contained in Appendix A, revised through Amendment No. 281 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto are hereby incorporated into the license. DENC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(3)
DENC shall not take any action that would cause Dominion Energy, Inc.
or its parent companies to void, cancel, or diminish DENC's Commitment to have sufficient funds available to fund an extended plant shutdown as represented in the application for approval of the transfer of the licenses for MPS Unit No. 3.
(4)
Immediately after the transfer of interests in MPS Unit No. 3 to DNC*, the amount in the decommissioning trust fund for MPS Unit No. 3 must, with respect to the interest in MPS Unit No. 3, that DNC* would then hold, be at a level no less than the formula amount under 10 CFR 50.75.
(5)
The decommissioning trust agreement for MPS Unit No. 3 at the time the transfer of the unit to DNC* is effected and thereafter is subject to the following:
(a)
The decommissioning trust agreement must be in a form acceptable to the NRC.
(b)
With respect to the decommissioning trust fund, investments in the securities or other obligations of Dominion Energy, Inc. or its affiliates or subsidiaries, successors, or assigns are prohibited.
Except for investments tied to market indexes or other non-nuclear-sector mutual funds, investments in any entity owning one or more nuclear power plants are prohibited.
(c)
The decommissioning trust agreement for MPS Unit No. 3 must provide that no disbursements or payments from the trust, other than for ordinary administrative expenses, shall be made by the trustee until the trustee has first given the Director of the Office of Nuclear Reactor Regulation 30 days prior written notice of payment. The decommissioning trust agreement shall further contain a provision that no disbursements or payments from the trust shall be made if the trustee receives prior written notice of objection from the NRC.
(d)
The decommissioning trust agreement must provide that the agreement cannot be amended in any material respect without 30 days prior written notification to the Director of the Office of Nuclear Reactor Regulation.
- On May 12, 2017, the name Dominion Nuclear Connecticut, Inc. changed to Dominion Energy Nuclear Connecticut, Inc.
Renewed License No. NPF-49 Amendment No. 270-280, 281
MILLSTONE - UNIT 3 2.0 SAFETY LIMITS AND LIMITING SAFETY SYSTEM SETTINGS 2.1 SAFETY LIMITS REACTOR CORE 2.1.1 The combination of THERMAL POWER, Reactor Coolant System highest loop average temperature, and pressurizer pressure shall not exceed the limits specified in the CORE OPERATING LIMITS REPORT; and the following Safety Limits shall not be exceeded:
2.1.1.1 The departure from nucleate boiling ratio (DNBR) shall be maintained greater than or equal to 1.14 for the WRB-2M DNB correlation.
2.1.1.2 The peak fuel centerline temperature shall be maintained less than 5080F, decreasing by 9F per 10,000 MWD/MTU of burnup.
APPLICABILITY:
MODES 1 and 2.
ACTION:
Whenever the Reactor Core Safety Limit is violated, restore compliance and be in HOT STANDBY within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
REACTOR COOLANT SYSTEM PRESSURE 2.1.2 The Reactor Coolant System pressure shall not exceed 2750 psia.
APPLICABILITY:
MODES 1, 2, 3, 4, and 5.
ACTION:
MODES 1 and 2:
Whenever the Reactor Coolant System pressure has exceeded 2750 psia be in HOT STANDBY with the Reactor Coolant System pressure within its limit within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
MODES 3, 4 and 5:
Whenever the Reactor Coolant System pressure has exceeded 2750 psia, reduce the Reactor Coolant System pressure to within its limit within 5 minutes.
Amendment No. 173, 217, 236, 242, 280 2-1 281 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 281 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-49 DOMINION ENERGY NUCLEAR CONNECTICUT, INC., ET AL MILLSTONE POWER STATION, UNIT NO. 3 DOCKET NO. 50-423
1.0 INTRODUCTION
By application dated December 8, 2020, as supplemented by letter dated December 21, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20343A243 and ML21355A247, respectively), Dominion Energy Nuclear Connecticut, Inc.
(DENC or the licensee) submitted a license amendment request (LAR) for Millstone Power Station Unit No. 3 (Millstone 3). The proposed amendment would revise the Millstone 3 Technical Specification (TS) reactor core safety limit (SL) 2.1.1.2 peak fuel centerline temperature to reflect the peak fuel centerline melt temperature specified in Topical Report (TR)
WCAP-17642-P-A, Revision 1, "Westinghouse Performance Analysis and Design Model (PAD5)," dated November 30, 2017, (ADAMS Accession No. ML17338A396 (non-proprietary version)).
The supplemental letter dated December 21, 2021, 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, Commission) staffs original proposed no significant hazards consideration determination as published in the Federal Register on February 23, 2021 (86 FR 11012).
2.0 REGULATORY EVALUATION
2.1 System Description
The proposed amendment is related to the Millstone 3 nuclear fuel. Millstone 3 TS SL 2.1.1.2 protects against overheating of the nuclear fuel and fuel cladding, which would lead to the fuel centerline temperature rising above the fuel melting point. Millstone 3 TS 2.1.1.2, "Safety Limit, Reactor Core," ensures Departure from Nucleate Boiling (DNB) does not occur and the fuel centerline temperature remains below the fuel melting temperature, thereby ensuring acceptable fuel design limits are not exceeded during steady state operation, normal operational transients, and anticipated operational occurrences, consistent with the Millstone 3 licensing bases. The LAR states that the, [f]uel centerline melting occurs when the local linear heat rate (LHR), or power peaking, in a region of the fuel is high enough to cause the fuel centerline temperature to reach the melting point of the fuel.
2.2 Applicable Regulatory Requirements and Guidance The NRC staff considered the following regulations during its review of the proposed changes:
x Section 182.a of the Atomic Energy Act of 1954, as amended, requires applicants for nuclear power plant operating licenses to include TSs as part of the license application to enable the Commission to find that the utilization of special nuclear material will be in accord with the common defense and security and will provide adequate protection to the health and safety of the public.
x Section 50.36 (Title 10 of the Code of Federal Regulations (10 CFR) 50.36), Technical specifications,paragraph (a)(1) requires that an application for an operating license include proposed TSs and paragraph (c) requires that TSs include items such as:
(1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; (5) administrative controls; (6) decommissioning; (7) initial notification; and (8) written reports.
x Section 50.36(b) (10 CFR 50.36(b)) also requires that technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto.
x Section 50.90 (10 CFR 50.90), Application for amendment of license, construction permit, or early site permit, requires, in part, that whenever a holder of a license wishes to amend the license, including TSs in the license, an application for amendment must be filed, fully describing the changes desired.
x 10 CFR 50, Appendix A, GDC 10, Reactor design, requires that the reactor core and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that specified fuel design limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences.
2.3 Licensees Proposed Changes The licensee proposes to revise the TS reactor core SL 2.1.1.2 peak fuel centerline temperature to reflect the fuel centerline melt temperature specified in TR WCAP-17642-P-A, Revision 1.
The proposed amendment revises the peak fuel centerline melting temperature specified in SL 2.1.1.2 but does not alter the SL associated with the DNB ratio.
The current Millstone 3 TS SL 2.1.1.2 states:
The peak fuel centerline temperature shall be maintained less than 5080°F, decreasing by 58°F per 10,000 MWD/MTU of burnup.
The licensee requests that Millstone 3 TS SL 2.1.1.2 be revised to state:
The peak fuel centerline temperature shall be maintained less than 5080°F, decreasing by 9°F per 10,000 MWD/MTU of burnup.
The licensee stated that plant-specific safety analyses are performed to ensure compliance with the SL. The TR WCAP-17642-P-A methodology defined the fuel pellet melting limit that is included in the PAD5 methodology based on available fuel pellet material properties. The NRC staff previously reviewed and concluded the melting limits defined in the Westinghouse PAD5 methodology are acceptable (see NRC staffs safety evaluation (SE) dated September 28, 2017, ADAMS Accession No. ML17090A443).
In its LAR, the licensee stated that the proposed amendment will be implemented to maintain consistency between the value in SL 2.1.1.2 and the criteria used when performing safety analyses that rely on the NRC approved methodology in TR WCAP-17642-P-A, Revision 1.
3.0 TECHNICAL EVALUATION
The scope of the NRC staff's review is limited to the proposed change to the TS SL for peak fuel centerline temperature. The proposed limit reflects the limit in TR WCAP-17642-PA, Revision 1 (WCAP-17642-P-A). NRC review and approval of the PAD5 methodology for use at Millstone 3 was not part of the scope of the staffs review of this LAR.
The empirically derived fuel centerline melt temperature described in WCAP-17642-P-A is based on fuel properties described in open literature. The description of the fuel properties can be found in (1) S.G. Popov; J.J. Carbajo; V.K. Ivanov; and G.L. Yoder, 'Thermophysical Properties of MOX and UO2 Fuels Including the Effects of Irradiation," ORNL/TM-2000/3S1 (2000) and (2) J.J. Carbajo; G.L. Yoder; S.G. Popov; and V.K. Ivanov, "A Review of the Thermophysical Properties of MOX and UO2 Fuels," Journal of Nuclear Materials, 299, 181 (2001). As noted beneath the caption for Figure 59, on page 92 of the NRC staff SE on WCAP-17642-P-A (ADAMS Accession No. ML17257A338), in its approval of WCAP-17642-P-A, the NRC staff determined that this melting limit is acceptable. The burnup dependent fuel centerline melt temperature is based on inherent fuel properties and does not depend on any specific calculational methodology. Therefore, the NRC staff considers it acceptable as a standalone limit.1 3.1 TS SL 2.1.1.2 Change Evaluation In the LAR, the licensee requests to change Millstone 3 TS SL 2.1.1.2 to reflect the peak fuel centerline melt temperature found in WCAP-17642-P-A. Millstone 3 TS SL 2.1.1.2 limits the peak fuel centerline temperature. For normal operation and anticipated operational occurrences, the reactor protection system is designed to ensure that the peak fuel centerline 1 The two identified references provide the data describing the fuel properties. The specific burnup dependence is provided in Section 6.1.5 of TR WCAP-17642-P-A based on an assessment of these data.
The NRC staff determined that this burnup dependence was acceptable as described in Section 3.7.12, Pellet Overheating Melting, of the staffs SE approving TR WCAP-17642-P-A (ADAMS Accession No. ML17090A443).
temperature does not exceed the fuel melt temperature criterion. The intent of this criterion is to avoid gross fuel melting.
The NRC staff previously determined that the peak fuel centerline temperature is not dependent on the PAD5 methodology, as discussed in Section 3.0. The staff evaluated the peak fuel centerline temperature and determined that it is applicable to Millstone 3 since, as discussed below, the properties of the fuel design in use at Millstone 3 are consistent with the property data used to generate the proposed SL.
The proposed SL was empirically derived and covers the lower bound of the fuel property data, which is conservative because the lower bound assures that the SL does not underestimate the applicable data. Additionally, as documented in the staffs SE on WCAP-17642-P-A, the NRC staff compared the fuel centerline melting temperatures in the TR WCAP-17642-P-A to the fuel centerline melting temperature in the NRC's confirmatory calculation code, "FRAPCON" (now known as FAST). The WCAP-17642-P-A fuel centerline melting temperature is less than that in FRAPCON, which is conservative.
The NRC staff determined that its analysis and technical justification for the fuel centerline melting temperature in the SE on WCAP-17642-P-A is applicable to Millstone 3 because the properties of the fuel design in use at Millstone 3 are consistent with the fuel property data used to generate the fuel centerline melting temperature. Therefore, the NRC staff determined that the proposed SL is conservative for Millstone 3.
As stated by the licensee in its LAR:
The peak fuel centerline temperature SL is independent of the PAD5 methodology The current licensing basis safety analyses use the existing SL 2.1.1.2 for fuel melt, as an acceptance criterion, as required by the current methodology. Thus, DENC will continue to meet the existing SL when using its current licensing basis safety analyses even with the implementation of the proposed SL. Since the existing SL for peak fuel centerline temperature is more restrictive than the proposed limit, the current licensing basis safety analyses remain conservative with respect to the proposed SL.
In the licensees Final Safety Analysis Report (FSAR) Sections 4.2.1.2, Fuel Material, and 4.4.1.2, Fuel Temperature Design Basis, (ADAMS Accession No. ML20209A400), the licensee discusses the basis for the existing Millstone 3 SL. Specifically, Sections 4.2.1.2 and 4.4.1.2 cite the melting temperature of the UO2 melting point as 5,080 °F, unirradiated and decreasing by 58 °F per 10,000 MWD/MTU. These sections also state that a calculated fuel centerline temperature of 4,700 °F has been selected as an overpower limit to ensure no fuel melting.
This conservative limit assures that the applicable safety analyses demonstrates that the proposed TS SL is not exceeded. Additionally, the licensee stated in its supplement dated December 21, 2021, that the Millstone 3 FSAR Sections 4.2.1.2 and 4.4.1.2 will be revised as part of the implementation plan for the license amendments following their issuance, to include the revised fuel melt safety limit and its technical basis. The licensee further stated in its supplement that, the FSAR will be reviewed in its entirety and additional FSAR changes will be implemented, if required, to reflect the revised peak fuel centerline melt temperature limit.
Based on the above, including the LAR information that supports the use of the empirically derived and less restrictive temperature, the NRC staff concludes that the proposed increase in the peak fuel centerline temperature TS SL is consistent with the 10 CFR 50.36(b) requirement that TSs be derived from licensee safety analyses, as amended.
The licensee's proposed TS change meets the requirements of GDC 10 and Section 182.a of the Atomic Energy Act, because (1) the peak fuel centerline temperature is based on a conservative evaluation of test data that is applicable to the fuel design used at Millstone 3, and (2) the proposed limit will ensure that fuel melt is precluded during conditions of normal operations and under anticipated operational occurrences. The proposed TS change also meets 10 CFR 50.36(c)(1)(i)(A) because the revised TS limits an important variable that is necessary to reasonably protect the integrity of a physical barrier that guards against the uncontrolled release of radioactivity. Therefore, the NRC staff concludes that the proposed change is acceptable.
3.2 Consideration of WCAP-17642-P-A Limitations and Conditions The licensee described how applicable limitations and conditions in the NRC staffs safety evaluation of WCAP-17642-P-A would be addressed. The NRC staff notes that there are other limitations and conditions in the WCAP-17642-P-A SE that are not addressed in the LAR. Since the licensee is not requesting in the LAR to implement the portions of the WCAP-17642-P-A methodology that would necessitate those limitations and conditions, the NRC staff determined that the LAR need not address the limitations and conditions.
The LAR addressed limitations and conditions (a) and (b), as described in Section 4.1 of the NRC staffs SE on WCAP-17642-P-A. Adherence to the limitation and condition (a) ensures that the proposed SL applies to Millstone 3. If limitation and condition (a) is not satisfied, then a different SL for fuel melting would be needed. In addition, limitation and condition (b) requires that, should WCAP-17642-P-A be implemented at any point, the Millstone 3 specific analyses are not to be used to predict fuel conditions beyond the melting point.
Limitation and condition (a) in the SE on WCAP-17642-P-A states, in part:
The NRC staff limits the applicability of the PAD5 code and methodology for cladding, fuel types and reactor for the ranges that are listed.
The NRC staff confirmed that Millstone 3 uses Westinghouse fuel that meets the constraints identified in limitation and condition (a). The licensee stated in its LAR that it will apply PAD5 within the limits specified in Section 4.1 of [the TR WCAP-17642-P-A] for cladding, fuel, and reactor parameters to be used at [Millstone 3]. Because these PAD5 inputs depend on the reload design, these parameters are validated on a cycle-specific basis. As such, the staff is assured that the proposed SL is applicable to Millstone 3 in that it reflects an acceptable limit on the peak fuel centerline temperature that would preclude fuel melting. Based on the confirmation provided by the licensee, the staff determined that this approach to address limitation and condition (a) is acceptable to change TS SL 2.1.1.2 for Millstone 3.
Limitation and condition (b) in the SE on WCAP-17642-P-A states:
The application of PAD5 should at no time exceed the fuel melting temperature as calculated by PAD5 due to the lack of properties for molten fuel in PAD5 and other properties such as thermal conductivity and FGR [fission gas release].
In the LAR, the licensee stated that it will limit the [Millstone 3] peak fuel centerline temperature per this amendment request. The NRC staff determined that the licensees statement is acceptable because the LAR specifically proposes to change the peak fuel centerline temperature SL to ensure that fuel melt is precluded during conditions for normal operation and anticipated operational occurrences, consistent with the requirements of GDC 10. The staff also notes that the LAR only proposed to implement the empirically derived TS SL and therefore, this SE does not approve the use of PAD5 to calculate any associated parameters.
3.3 NRC Staff Conclusion
The proposed change has been evaluated by the NRC staff to determine compliance with applicable regulatory requirements as specified in Section 2.2 of this SE.
Based on the evaluation discussed in Section 3 of this SE, the staff has determined that the proposed change for Millstone 3 meets the requirement of 10 CFR 50.36, 10 CFR 50.90, and 10 CFR 50, Appendix A, GDC 10. Therefore, the NRC staff concludes that the proposed change to modify TS 2.1.1.2 is acceptable.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the NRC staff notified the Connecticut State official on November 7, 2021, of the proposed issuance of the amendment. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20, Standards for protection against radiation. The NRC staff has determined that the amendment involves 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 NRC has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on this finding published in the Federal Register (86 FR 11012; February 23, 2021).
Accordingly, the amendment meets 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 amendment.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that public health and safety 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 Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to public health and safety.
Principal Contributor: F. Forsaty Date of Issuance: January 7, 2022
ML21326A099 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DSS/SNSB/BC NAME RGuzman KEntz SKrepel DATE 11/22/2021 11/29/2021 07/3/2021 OFFICE NRR/DSS/STSB/BC (A)
OGC - NLO NRR/DORL/LPL1/BC NAME NJordan MWoods JDanna DATE 11/29/2021 1/5/2022 1/6/2022 OFFICE NRR/DORL/LPL1/PM NAME RGuzman DATE 1/7/2022