ML23012A015

Issuance of Amendment No. 224 to Change Nozzle Blockage Testing Requirement for Reactor Building Spray System

ML23012A015
Person / Time
Site:	Summer  (NPF-012)
Issue date:	02/21/2023
From:	Geoffrey Miller Plant Licensing Branch II
To:	Stoddard D Dominion Energy South Carolina
Williams S, NRR/DORL/LPLLPL
References
EPID L-2022-LLA-0060
Download: ML23012A015 (1)

Text

February 21, 2023 Mr. Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Dominion Energy South Carolina Innsbrook Technical Center 5000 Dominion Blvd.

Glen Allen, VA 23060-6711

SUBJECT:

VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 ISSUANCE OF AMENDMENT NO. 224 TO CHANGE NOZZLE BLOCKAGE TESTING REQUIREMENT FOR REACTOR BUILDING SPRAY SYSTEM (EPID L-2022-LLA-0060)

Dear Mr. Stoddard:

The U.S. Nuclear Regulatory Commission (NRC, or the Commission) has issued the enclosed Amendment No. 224 to Renewed Facility Operating License No. NPF-12 for the Virgil C.

Summer Nuclear Station, Unit 1. The amendment revises the Technical Specifications (TSs) in response to your application dated April 22, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22115A104), as supplemented by letter dated June 27, 2022 (ML22179A368).

The amendment revises TS 4.6.2.1.d to change the frequency at which each reactor building spray nozzle must be verified to be unobstructed.

D. Stoddard A copy of the related safety evaluation and notice and environmental findings are also enclosed.

The Commissions monthly Federal Register notice will include the notice of issuance.

Sincerely,

/RA/

G. Edward Miller, Project Manager Plant Licensing Branch II-I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395

Enclosures:

1. Amendment No. 224 to NPF-12

2. Safety Evaluation cc: Listserv DOMINION ENERGY SOUTH CAROLINA, INC.

SOUTH CAROLINA PUBLIC SERVICE AUTHORITY DOCKET NO. 50-395 VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 224 Renewed License No. NPF-12

1.

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

A.

The application for amendment to the Virgil C. Summer Nuclear Station, Unit No. 1 (the facility), Renewed Facility Operating License No. NPF-12, filed by the Dominion Energy South Carolina, Inc. (the licensee), dated April 22, 2022, as supplemented by letter dated June 27, 2022, 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 public health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations as set forth in 10 CFR Chapter I; 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 hereby amended by a page change 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-12 is hereby amended to read as follows:

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 224, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. Dominion Energy South Carolina, Inc. shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 60 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License and Technical Specifications Date of Issuance: February 21, 2023 Michael T.

Markley Digitally signed by Michael T. Markley Date: 2023.02.21 11:16:34 -05'00'

VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 ATTACHMENT TO LICENSE AMENDMENT NO. 224 RENEWED FACILITY OPERATING LICENSE NO. NPF-12 DOCKET NO. 50-395 Replace the following pages of the renewed facility operating license with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Page Insert Page License License Page 3 Page 3 Technical Specifications Technical Specifications 3/4 6-12 3/4 6-12

Renewed Facility Operating License No. NPF-12 Amendment No. 224 (3)

DESC, pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage amounts required for reactor operation, as described in the Final Safety Analysis Report, as amended through Amendment No. 33; (4)

DESC, pursuant to the Act and 10 CFR Part 30, 40 and 70 to receive, possess and use at any time byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed neutron sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5)

DESC, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus of components; and (6)

DESC, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as m[a]y be produced by the operation of the facility.

C.

This renewed license shall be deemed to contain, and is subject to, the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1)

Maximum Power Level DESC is authorized to operate the facility at reactor core power levels not in excess of 2900 megawatts thermal in accordance with the conditions specified herein and in Attachment 1 to this renewed license.

The preoccupation tests, startup tests and other items identified in to this renewed license shall be completed as specified. is hereby incorporated into this renewed license.

(2)

Technical Specifications and Environmental Protection Plant The Technical Specifications contained in Appendix A, as revised through Amendment No. 224, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. Dominion Energy South Carolina, Inc. shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

CONTAINMENT SYSTEMS SUMMER - UNIT 1 3/4 6-12 Amendment No. 127, 204, 222, 224 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS REACTOR BUILDING SPRAY SYSTEM LIMITING CONDITION FOR OPERATION 3.6.2.1 Two independent reactor building spray systems shall be OPERABLE with each spray system capable of taking suction from the RWST and automatically transferring suction to the spray sump.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTION:

With one reactor building spray system inoperable, restore the inoperable spray system to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; restore the inoperable spray system to OPERABLE status within the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.6.2.1 Each reactor building spray system shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by:

1. Verifying that each valve (manual, power operated, or automatic) in the flow path that is not locked, sealed or otherwise secured in position is in its correct position*, and

2. Verifying Containment Spray locations susceptible to gas accumulation are sufficiently filled with water.

b.

By verifying, that on recirculation flow, each pump develops a discharge pressure of greater than or equal to 195 psig when tested pursuant to Specification 4.0.5.

c.

In accordance with the Surveillance Frequency Control Program during shutdown, by:

1. Verifying that each automatic valve in the flow path actuates to its correct position on each of the following test signals a Phase 'A', Reactor Building Spray Actuation, and Containment Sump Recirculation.

2. Verifying that each spray pump starts automatically on a Reactor Building Spray Actuation test signal.

d.

By verifying each spray nozzle is unobstructed following activities that could cause nozzle blockage.

Not required to be met for system vent flow paths opened under administrative control.

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 224 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-12 DOMINION ENERGY SOUTH CAROLINA, INC.

VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 DOCKET NO. 50-395

1.0 INTRODUCTION

By letter dated April 22, 2022, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22115A104), as supplemented by letter dated June 27, 2022 (ML22179A368), Dominion Energy South Carolina, Inc. (DSEC or the licensee), submitted a request for changes to the Technical Specifications (TSs) for Virgil C. Summer Nuclear Station (VCSNS) Unit 1. The proposed amendment would modify Technical Specification 4.6.2.1.d to change the frequency at which each reactor building spray nozzle must be verified to be unobstructed. Specifically, the proposed change would replace the current testing frequency, as specified by the Surveillance Frequency Control Program, with an event-based frequency to verify the spray nozzles are unobstructed following activities that could cause nozzle blockage.

The supplemental letter dated June 27, 2022, 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) staffs original proposed no significant hazards consideration determination as published in the Federal Register on June 14, 2022 (87 FR 36007).

2.0 REGULATORY EVALUATION

2.1

System Description

Section 2.1 of the LAR provides a brief description of system design and operation of the VCSNS Reactor Building (RB) spray system:

The VCSNS RB spray system includes a total of 330 spray nozzles. These nozzles are ramp type, hollow cone nozzles. The spray nozzles are located on 6 rings. The arrangement of the spray rings within the RB is such that essentially all of the free volume above the operating floor, elevation 463', is exposed to the spray. Below the operating floor elevation, areas outside the secondary shield walls are shielded from the spray. However, the atmosphere in these areas is mixed with the rest of the volume inside the secondary shield walls. The volume inside the secondary shield walls, with the exception of the pressurizer compartment, is open to the spray.

During normal plant operation, the RB spray system is in standby condition with spray pump suction aligned to receive water from the Refueling Water Storage Tank (RWST). Operation of the system is initiated automatically following a Loss of Coolant Accident (LOCA) or Main Steam Line Break (MSLB) by signals from the Engineered Safety Features (ESF) Actuation System when Reactor Building pressure increases to the actuation setpoint. The RB spray system can also be started manually from the control room.

During the injection phase following a LOCA, the spray pumps receive fluid from the RWST and sodium hydroxide storage tank. The solutions are carried through the spray pump discharge lines to the spray headers and are then sprayed into the Reactor Building atmosphere through the spray nozzles. The spray is collected in the bottom of the RB with water from the Emergency Core Cooling System (ECCS) and the Reactor Coolant System (RCS) in the RB recirculation sumps. During the recirculation phase, the spray pumps may take suction from the sumps in the RB.

The spray droplets absorb heat as they fall through the steam-air atmosphere in the RB, thereby reducing RB atmosphere temperature. Additionally, the spray is credited for iodine removal following a design basis accident to reduce post-accident dose consequences.

Debris which washes down to the sumps and passes through the sump strainer has been evaluated for the potential to block and erode downstream systems and components. The size of the debris is limited by the 1/16-inch round holes in the perforated plate strainer. The inner diameter of the spray nozzles is 3/8 inch.

2.2 Description of Proposed Changes The VCSNS TS Limiting Condition of Operation (LCO) 3.6.2.1 specifies conditions of operability for the RB spray system. Associated SR 4.6.2.1.d requires performance of an air or smoke flow test through each spray header and verifying that each spray nozzle is unobstructed at a frequency of at least once in 10 years. DESC proposes to replace the fixed 10-year frequency in the current SR with an event-based frequency, and the test method will be deleted from SR 4.6.2.1.

The current SR 4.6.2.1.d states:

At least once per 10 years by performing an air or smoke or equivalent flow test through each spray header and verifying each spray nozzle is unobstructed.

Revised SR 4.6.2.1.d would state:

By verifying each spray nozzle is unobstructed following activities that could cause nozzle blockage.

2.3 Reason for the Proposed Change The current surveillance requires workers to verify flow of air or other medium (smoke or other) at each nozzle. Since the nozzles are located at a high elevation in the RB and in a potentially high temperature environment, the licensee states that limiting the exposure to such conditions will reduce the risk to personal safety. VCSNS also states that the proposed change will eliminate unnecessary testing of the spray nozzles by providing other options to verify that each nozzle is unobstructed following activities or conditions that could potentially cause nozzle blockage.

2.4 Regulatory Requirements and Guidance Under 10 CFR 50.90, whenever a holder of a license wishes to amend the license, including technical specifications in the license, an application for amendment must be filed, fully describing the changes desired. Under 10 CFR 50.92(a), determinations on whether to grant an applied-for license amendment are to be guided by the considerations that govern the issuance of initial licenses or construction permits to the extent applicable and appropriate. Both the common standards in 10 CFR 50.40(a), and those specifically for issuance of operating licenses in 10 CFR 50.57(a)(3), provide that there must be reasonable assurance that the activities at issue will not endanger the health and safety of the public.

The NRC's regulatory requirements related to the content of the TS are set forth in 10 CFR Section 50.36, "Technical specifications." This regulation requires that the TSs include items in, among other things, the following five specific categories: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) SRs; (4) design features; and (5) administrative controls. The regulation does not specify the particular requirements to be included in a plant's TSs.

10 CFR 50.36(c)(3) states:

Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be met.

Per 10 CFR 50.36(a)(1), (as made applicable by 10 CFR 50.90) each applicant for an operating license includes in its application proposed technical specifications, and a "summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications."

Appendix A to Title 10 of the Code of Federal Regulations (10 CFR) Part 50 provides General Design Criteria (GDC) for nuclear power plants. Plant-specific design criteria are described in the plants Updated Final Safety Analysis Report (UFSAR). Specifically, Section 3.1.2.4 of the VCSNS UFSAR discusses conformance with the following GDC:

GDC 38: Criterion 38, "Containment heat removal," states:

A system to remove heat from the reactor containment shall be provided. The system safety function shall be to reduce rapidly, consistent with the functioning of other associated systems, the containment pressure and temperature following any loss-of-coolant accident and maintain them at acceptably low levels.

GDC 39, Criterion 39, "Inspection of containment heat removal system," states:

The containment heat removal system shall be designed to permit appropriate periodic inspection of important components, such as the torus, sumps, spray nozzles, and piping to assure the integrity and capability of the system.

GDC 40, Criterion 40, "Testing of containment heat removal system," states:

The containment heat removal system shall be designed to permit appropriate periodic pressure and functional testing to assure (1) the structural and leak tight integrity of its components, (2) the operability and performance of the active components of the system, and (3) the operability of the system as a whole, and under conditions as close to the design as practical the performance of the full operational sequence that brings the system into operation, including operation of applicable portions of the protection system, the transfer between normal and emergency power sources, and the operation of the associated cooling water system.

The NRC staff also considered in its review the guidance in the following documents:

NUREG-1366, Improvements to Technical Specifications Surveillance Requirements, (ML20127H094) reported the results of the NRC staff review of industry experience related to problems with RB spray systems.

Generic Letter (GL) 93-05, Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation, (ML031070342) provides the basis for the current 10-year surveillance frequency and discusses operating experience for spray headers and coating degradation.

3.0 TECHNICAL EVALUATION

The NRC staff evaluated the operating and performance history of spray nozzle testing at VCSNS, guidance provided in GL 93-05 and NUREG-1366, and the VCSNS Foreign Materials Exclusion (FME) program in its evaluation of the proposed changes.

Evaluation of VCSNS Operating and Performance History The application provided the following history of spray flow tests: Spray flow tests were performed at VCSNS to verify that the orifices were properly sized to provide the correct mixture of sodium hydroxide solution and RWST water during operation of the RB spray system.

Periodic surveillance tests of the spray nozzles were conducted in 1987 and 1991, on a 5-year frequency since original plant construction and startup. The surveillance tests in 2002 and 2012 were conducted on the current 10-year frequency in SR 4.6.2.1.d. All the periodic surveillance tests were conducted by injecting low pressure air or smoke into the spray headers and using visual observation of smoke or other telltales to verify that the nozzles are unobstructed. The application concluded that all tests demonstrated unobstructed flow through each nozzle.

Based on the licensees description of the history of testing results (i.e., 4 successful tests over multiple decades), the NRC staff finds that the VCSNS-specific operating history supports that the system has a low likelihood of becoming obstructed while in a standby configuration.

Evaluation of the Foreign Material Exclusion (FME) Program The application stated that FME program at VCSNS is governed by a nuclear fleet procedure.

The application stated that the FME fleet procedure encompasses the following:

Precautions to minimize inadvertent and uncontrolled introduction of foreign materials into plant systems and components; Document, as found, inspection when a system, component, or process is opened or breached; Practices for maintaining cleanliness of systems and components during activities that create debris, such as welding and grinding; Inspections to verify the system, component or process is free of foreign material before final closure; and Corrective action program in the event of loss of FME integrity, including directions to stop work, notify the Supervisor, and develop a foreign material recovery plan, including documentation of event description, consequences, retrieval plan and results.

The licensee stated that a review of maintenance activities performed on the RB spray system, since the last spray nozzle test in November 2012, identified one issue involving FME that impacted the spray system. A 6-inch wrench was accidentally dropped through the B RHR sump grating while gathering tools. The wrench was leaning against the outer FME screen. The wrench was retrieved, and the issue was documented in the corrective action program. At no time did the wrench enter the RB spray piping.

The application stated that cleanliness of the RB spray system was maintained during maintenance activities since the last RB spray nozzle test in 2012. The application stated that no work activities were needed on the RB spray nozzles or headers since the last RB spray nozzle surveillance in 2012.

The application stated that due to the spray headers location at the top of the reactor building, introduction of foreign material into the spray header via the open nozzles is unlikely during unrelated maintenance activities. Foreign material introduced, because of maintenance of this system, is the most likely cause for obstruction. Given the post-maintenance FME verification, the potential for unidentified nozzle obstruction is very low. Therefore, verification that no foreign material has entered the system following such maintenance is sufficient to confirm that the nozzles are free from blockage.

Based on the licensees description of the FME program, and its appropriate control under the quality assurance and TS programs, the NRC staff finds that the FME program provides adequate control to preclude the introduction of potentially clogging material following the last verification that the system was unobstructed. The location of the system spray rings (and associated openings) are at a high elevation in containment, further minimizing opportunities for foreign material to drop into the system.

NUREG-1366 Section 8.1 Containment Spray System (PWR) of NUREG-1366 (December 1992) states that the NRC staff searched for problems involving the containment spray system that had been uncovered by means of air or smoke flow tests. Only three cases were found and in all three cases the problem involved a construction error.

In its letter dated April 22, 2022, the licensee stated they searched a database of Licensee Event Reports (LERs) for relevant events that occurred after the publication of NUREG-1366 and found two LERs about spray nozzle blockage. Both LERs concerned the same facility and both were caused by boric acid solution left unremoved from system low points during previous spray header overfill events. The licensee stated that a similar event at VCSNS would require an evaluation be performed to determine if a surveillance needs to be performed. The license further noted that the number of blocked nozzles were small in number, and, in both instances, the remaining unobstructed nozzles would have provided required spray flow.

The operational history described in NUREG-1366 supports the conclusion that there is a low likelihood of becoming obstructed while in a standby configuration and that the only reported problems with this test have been construction related. The licensees review of LERs did identify two additional instances of system blockage experienced by another facility. The NRC staff finds reasonable assurance that the situations described would be evaluated by the licensee. The licensee would verify the system and that the blockage from that scenario was sufficiently small to allow the system to continue to provide the required flow. Based on the above, the NRC finds the operating experience and licensee actions support the proposed modification to the SR frequency.

Method of Surveillance The proposed change would no longer require using of an air or smoke or equivalent flow test, instead allowing the licensee to determine the appropriate method to verify the system is free of obstructions.

The NRC staff finds that the procedures used by the licensee to implement the SR will continue to be controlled adequately by the existing quality assurance and TS programs. Further, the NRC staff finds there to be reasonable assurance to allow the licensee to determine the appropriate method of verification based on activity-specific factors (e.g., system maintenance, plant configuration, etc.). The NRC, therefore, concludes that removal of the specified method of surveillance from the TSs is acceptable.

System Design

The licensee has proposed no changes involved to any of the structures, systems and components (SSCs) at VCSNS. The applicable GDC do not specify the frequency or method of inspection. Based on the above, compliance with GDC 38 (containment heat removal) and GDC 40 (testing of containment heat removal) are not impacted by the proposed change. The licensee stated that it would make conforming changes to the VCSNS UFSAR which currently states, regarding Criterion 39, that the functional operability of each spray nozzle is verified by an air or smoke test, and specify determination of methods based on activity-specific conditions and applicable QA and TS programs.

Summary Based on the above, the NRC staff concludes that there is reasonable assurance that the potential for nozzle obstruction occurring simply based on the passage of time is sufficiently low.

The NRC staff concludes that most realistic causes for obstruction are associated with maintenance activities or system operation and during such activities the FME controls described in the application provide reasonable protection from the introduction of foreign materials into open piping during maintenance or testing and require post-maintenance verification of system cleanliness and freedom from foreign materials.

Based on the above, the NRC staff finds that performing the SR on an event-based schedule and performing the verification in a manner appropriate to the activity-specific situation provides reasonable assurance the system is capable of performing its intended safety function.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the NRC staff notified the South Carolina State official of the proposed issuance of the amendment on January 10, 2023. On January 18, 2023, the State official confirmed the State of South Carolina had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. 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 published in the Federal Register on June 14, 2022 (87 FR 36007).

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 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 Contributors: D. Scully, NRR N. Karipineni, NRR C. Tran, NRR Date of issuance: February 21, 2023

ML23012A015

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BWittick DATE 1/26/2023 01/27/2023 1/25/2023 1/27/2023 OFFICE OGC (NLO)

NRR/DORL/LPL2-1/BC NRR/DORL/LPL2-1/PM NAME DRoth MMarkley GEMiller DATE 2/2/2023 2/21/2023 2/21/2023