ML23178A074
| ML23178A074 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 08/07/2023 |
| From: | Robert Kuntz Plant Licensing Branch III |
| To: | Rhoades D Constellation Energy Generation |
| Kuntz R | |
| References | |
| EPID L-2023-LLA-0017 | |
| Download: ML23178A074 (18) | |
Text
August 7, 2023 Mr. David P. Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 296 AND 292 RE: ADOPTION OF TSTF-416, LOW PRESSURE COOLANT INJECTION (LPCI) VALVE ALIGNMENT VERIFICATION NOTE LOCATION (EPID L-2023-LLA-0017)
Dear Mr. Rhoades:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 296 to Renewed Facility Operating License No. DPR-29 and Amendment No. 292 to Renewed Facility Operating License No. DPR-30 for the Quad Cities Nuclear Power Station, Units 1 and 2, respectively. The amendments consist of changes to the technical specifications (TSs) in response to your application dated February 3, 2023.
The amendments adopt Technical Specifications Task Force (TSTF) Traveler 416 (TSTF-416),
Revision 0, Low Pressure Coolant Injection (LPCI) Valve Alignment Verification Note Location.
The adoption of TSTF-416 revises TS 3.5.1, ECCS [Emergency Core Cooling Systems]-
Operating, by moving the LPCI valve alignment note from Surveillance Requirement 3.5.1.2 to Limiting Condition for Operation 3.5.1.
D. Rhoades A copy of the related safety evaluation is also enclosed. The Notice of Issuance will be included in the Commissions monthly Federal Register notice.
Sincerely,
/RA/
Robert Kuntz, Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-254 and 50-265
Enclosures:
- 1. Amendment No. 296 to DPR-29
- 2. Amendment No. 292 to DPR-30
- 3. Safety Evaluation cc: Listserv
CONSTELLATION ENERGY GENERATION, LLC AND MIDAMERICAN ENERGY COMPANY DOCKET NO. 50-254 QUAD CITIES NUCLEAR POWER STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 296 Renewed License No. DPR-29
- 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by Constellation Energy Generation, LLC (the licensee) dated February 3, 2023, 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.
Enclosure 1
- 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 3.B. of Renewed Facility Operating License No. DPR-29 is hereby amended to read as follows:
B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 296, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.
- 3. This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Jeffrey A. Jeffrey A. Whited Date: 2023.08.07 Whited 09:19:28 -04'00' Jeffrey Whited, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: August 7, 2023
CONSTELLATION ENERGY GENERATION, LLC AND MIDAMERICAN ENERGY COMPANY DOCKET NO. 50-265 QUAD CITIES NUCLEAR POWER STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 292 Renewed License No. DPR-30
- 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by the Constellation Energy Generation, LLC (the licensee) dated February 3, 2023, 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.
Enclosure 2
- 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 3.B. of Renewed Facility Operating License No. DPR-30 is hereby amended to read as follows:
B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 292, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.
- 3. This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Jeffrey A. Jeffrey A. Whited Date: 2023.08.07 Whited 09:19:51 -04'00' Jeffery Whited, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: August 7, 2023
ATTACHMENT TO LICENSE AMENDMENT NOS. 296 AND 292 RENEWED FACILITY OPERATING LICENSE NOS. DPR-29 AND DPR-30 QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-254 AND 50-265 Replace the following pages of the Renewed Facility Operating Licenses and Appendix A, Technical Specifications, with the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Insert License No. DPR-29 License No. DPR-29 Page 4 Page 4 License No. DPR-30 License No. DPR-30 Page 4 Page 4 TSs TSs 3.5.1-1 3.5.1-1 3.5.1-2 3.5.1-2 3.5.1-3 3.5.1-3 3.5.1-4 3.5.1-4
B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 296, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.
C. The licensee shall maintain the commitments made in response to the March 14, 1983, NUREG-0737 Order, subject to the following provision:
The licensee may make changes to commitments made in response to the March 14, 1983, NUREG-0737 Order without prior approval of the Commission as long as the change would be permitted without NRC approval, pursuant to the requirements of 10 CFR 50.59. Consistent with this regulation, if the change results in an Unreviewed Safety Question, a license amendment shall be submitted to the NRC staff for review and approval prior to implementation of the change.
D. Equalizer Valve Restriction Three of the four valves in the equalizer piping between the recirculation loops shall be closed at all times during reactor operation with one bypass valve open to allow for thermal expansion of water.
E. The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822), and the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined sets of plans1, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: Quad Cities Nuclear Power Station Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 2, submitted by letter dated May 17, 2006.
Constellation Energy Generation, LLC shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).
The CSP was approved by License Amendment No. 249 as modified by License Amendment No. 259.
1 The Training and Qualification Plan and Safeguards Contingency Plan are Appendices to the Security Plan.
Renewed License No. DPR-29 Amendment No. 296
B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 292, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.
C. The licensee shall maintain the commitments made in response to the March 14, 1983, NUREG-0737 Order, subject to the following provision:
The licensee may make changes to commitments made in response to the March 14, 1983, NUREG-0737 Order without prior approval of the Commission as long as the change would be permitted without NRC approval, pursuant to the requirements of 10 CFR 50.59. Consistent with this regulation, if the change results in an Unreviewed Safety Question, a license amendment shall be submitted to the NRC staff for review and approval prior to implementation of the change.
D. Equalizer Valve Restriction Three of the four valves in the equalizer piping between the recirculation loops shall be closed at all times during reactor operation with one bypass valve open to allow for thermal expansion of water.
E. The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822), and the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans1, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: Quad Cities Nuclear Power Station Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 2, submitted by letter dated May 17, 2006.
Constellation Energy Generation, LLC shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The CSP was approved by License Amendment No. 244 and modified by License Amendment No. 254.
1 The Training and Qualification Plan and Safeguards Contingency Plan are Appendices to the Security Plan.
Renewed License No. DPR-30 Amendment No. 292
ECCSOperating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV)
WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC)
SYSTEM 3.5.1 ECCSOperating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of five relief valves shall be OPERABLE.
NOTE---------------------------
Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the Residual Heat Removal (RHR) cut-in permissive pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable.
APPLICABILITY: MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure 150 psig.
ACTIONS
NOTE---------------------------------
LCO 3.0.4.b is not applicable to HPCI.
CONDITION REQUIRED ACTION COMPLETION TIME A. One Low Pressure A.1 Restore LPCI pump to 30 days Coolant Injection OPERABLE status.
(LPCI) pump inoperable.
B. One LPCI subsystem B.1 Restore low pressure 7 days inoperable for reasons ECCS injection/spray other than Condition subsystem to OPERABLE A. status.
OR One Core Spray subsystem inoperable.
C. One LPCI pump in each C.1 Restore one LPCI pump 7 days subsystem inoperable. to OPERABLE status.
(continued)
Quad Cities 1 and 2 3.5.1-1 Amendment No. 296/292273/268
ECCSOperating 3.5.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and --------------NOTE-----------
associated Completion LCO 3.0.4.a is not applicable Time of Condition A, when entering MODE 3.
B, or C not met. -----------------------------
D.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> E. Two LPCI subsystems E.1 Restore one LPCI 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable for reasons subsystem to OPERABLE other than Condition status.
C.
F. Required Action and F.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition E AND not met.
F.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> G. HPCI System G.1 Verify by Immediately inoperable. administrative means RCIC System is OPERABLE.
AND G.2 Restore HPCI System 14 days to OPERABLE status.
H. One ADS valve H.1 Restore ADS valve to 14 days inoperable. OPERABLE status.
I. Required Action and --------------NOTE-----------
associated Completion LCO 3.0.4.a is not applicable Time of Condition G or when entering MODE 3.
H not met. -----------------------------
I.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (continued)
Quad Cities 1 and 2 3.5.1-2 Amendment No. 296/292245/240
ECCSOperating 3.5.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME J. Two or more ADS valves J.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> inoperable.
AND J.2 Reduce reactor steam 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> dome pressure to
< 150 psig.
K. Two or more low K.1 Enter LCO 3.0.3 Immediately pressure ECCS injection/spray subsystems inoperable for reasons other than Condition C or E.
OR HPCI System and one or more ADS valves inoperable.
OR One or more low pressure ECCS injection/spray subsystems inoperable and one or more ADS valves inoperable.
OR HPCI System inoperable and either one low pressure ECCS injection/spray subsystem is inoperable or Condition C entered.
Quad Cities 1 and 2 3.5.1-3 Amendment No. 296/292245/240
ECCSOperating 3.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify, for each ECCS injection/spray In accordance subsystem, locations susceptible to gas with the accumulation are sufficiently filled with Surveillance water. Frequency Control Program SR 3.5.1.2 -------------------NOTE-------------------
Not required to be met for system vent flow paths opened under administrative control.
Verify each ECCS injection/spray subsystem In accordance manual, power operated, and automatic valve with the in the flow path, that is not locked, Surveillance sealed, or otherwise secured in position, Frequency is in the correct position. Control Program SR 3.5.1.3 Verify correct breaker alignment to the In accordance LPCI swing bus. with the Surveillance Frequency Control Program SR 3.5.1.4 Verify each recirculation pump discharge In accordance valve cycles through one complete cycle of with the full travel or is de-energized in the INSERVICE closed position. TESTING PROGRAM (continued)
Quad Cities 1 and 2 3.5.1-4 Amendment No. 296/292266/2615
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 296 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-29 AND AMENDMENT NO. 292 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-30 CONSTELLATION ENERGY GENERATION, LLC AND MIDAMERICAN ENERGY COMPANY QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-254 AND 50-265
1.0 INTRODUCTION
By letter to the U.S. Nuclear Regulatory Commission (NRC, the Commission) dated February 3, 2023 (Agencywide Documents Access and Management System Accession No. ML23034A219), Constellation Energy Generation, LLC (the licensee) submitted a license amendment request (LAR) to change the technical specifications (TSs) for the Quad Cities Nuclear Power Station, Units 1 and 2 (Quad Cities).
The proposed change would revise the emergency core cooling systems (ECCS) TSs based upon NRC-approved Technical Specifications Task Force (TSTF) Traveler TSTF-416, Revision 0, Low Pressure Coolant Injection (LPCI) Valve Alignment Verification Note Location (ML012390252), and the associated NRC staff safety evaluation (SE) (ML022240526).
2.0 REGULATORY EVALUATION
2.1 Description of Proposed Change The LAR proposed to revise Quad Cities TS 3.5.1, ECCS-Operating, by moving the LPCI valve alignment note located in Surveillance Requirement (SR) 3.5.1.2 to Limiting Condition for Operation (LCO) 3.5.1. The LPCI valve alignment note states:
Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the Residual Heat Removal (RHR) cut in permissive pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable.
Enclosure 3
2.2 Variations The LAR identified one variation from TSTF-416. Section 3.0 of this SE provides a description of the variation and the NRC staffs evaluation.
2.3 Applicable Regulatory Requirements Title 10 of the Code of Federal Regulations (10 CFR) section 50.36, Technical specifications, paragraph (c)(2), Limiting conditions for operation, requires that TSs include LCOs. According to 10 CFR 50.36(c)(2)(i), LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility. This regulation also requires that when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the LCO can be met.
The regulation at 10 CFR 50.36(c)(3), Surveillance requirements, requires that TSs include SRs and states that SRs 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 [LCOs] will be met.
2.4 Applicable Regulatory Guidance The NRC staffs guidance for the review of TSs is in chapter 16.0, Technical Specifications, of NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition (SRP), dated March 2010 (ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared standard technical specifications (STSs) for each of the LWR nuclear designs. Accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with the applicable STSs, NUREG-1433,1 as modified by NRC-approved travelers.
3.0 TECHNICAL EVALUATION
Traveler TSTF-416 revised STS 3.5.1, ECCS - Operating, by moving the LPCI valve alignment note for SR 3.5.1.2 to LCO 3.5.1.
The NRC staff compared the proposed TS change described in section 2.1 of this SE against the change in NRC-approved TSTF-416. In accordance with SRP chapter 16.0, the NRC staff determined that the change in NRC-approved TSTF-416 is applicable to the Quad Cities TSs because the Quad Cities units are boiling-water reactors (BWRs) and the NRC approved the TSTF-416 change for BWR designs. The NRC staff also determined that the proposed change to the Quad Cities TSs described in section 2.1 of this SE conforms to the change made to the STSs by NRC-approved TSTF-416.
In its SE for TSTF-416, the NRC staff concluded that the TSTF-416 change to STS 3.5.1 is acceptable because the SR 3.5.1.2 LPCI valve alignment note applies to all LPCI/RHR subsystem shared components; however, the note is located in the SRs that only address valve operability. The NRC staffs SE also stated that the preferred location for this note is in the LCO 1
U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General Electric BWR/4 Plants, NUREG-1433, Volume 1, Specifications, and Volume 2, Bases, Revision 5.0, dated September 2021 (ML21272A357 and ML21272A358, respectively).
because the LCO applies to the components of the shared portions of the LPCI/RHR subsystem. TSTF-416 did not change the design or function of any safety- or nonsafety-related systems or components previously reviewed by the NRC staff and found acceptable. The NRC staffs SE for TSTF-416 concluded that moving the note is an administrative change.
Based on the above discussion, the NRC staff concludes that the proposed change to Quad Cities TS 3.5.1 to move the LPCI valve alignment note from the SR to the LCO is consistent with NRC-approved TSTF-416 and conforms to the applicable STS. The NRC staff also concludes that the proposed change clarifies the lowest functional capability or performance levels of equipment required for safe operation of the facility and continues to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCO will be met. Therefore, the NRC staff finds that the proposed change continues to meet the requirements of 10 CFR 50.36(c)(2) and 10 CFR 50.36(c)(3).
The LAR identified one variation from the NRC-approved TSTF-416. Specifically, TSTF-416 includes moving LPCI valve alignment notes located in SRs 3.5.1.2 and 3.5.2.4 to LCOs 3.5.1 and 3.5.2, respectively. However, the licensee has already incorporated the relocation of the SR 3.5.2.4 LPCI valve alignment note into TS 3.5.2 as part of Amendment Nos. 273 and 268 for Quad Cities, Units 1 and 2, respectively, related to the adoption of TSTF-542, Reactor Pressure Vessel Water Inventory Control (ML18353A229). As a result, the LAR only requested relocation of the LPCI valve alignment note from SR 3.5.1.2 to LCO 3.5.1. Based on the above discussion, the NRC staff concludes that this variation is acceptable because the TSTF-416 proposed changes to SR 3.5.2.4 and LCO 3.5.2 have already been incorporated.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Illinois State official was notified of the proposed issuance of the amendments on June 27, 2023. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change requirements with respect to the installation or use of facility components 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 (88 FR 31282; dated May 16, 2023). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: Clint Ashley, NRR Date of Issuance: August 7, 2023
ML23178A074 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR//DSS/STSB/BC NAME RKuntz SRohrer VCusumano DATE 6/27/2023 6/28/23 4/26/2023 OFFICE OGC NLO NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME JWachuka JWhited RKuntz DATE 7/7/2023 8/7/2023 8/7/2023