ML25269A107
| ML25269A107 | |
| Person / Time | |
|---|---|
| Site: | Vogtle (NFP-091, NPF-092) |
| Issue date: | 11/25/2025 |
| From: | John Lamb NRC/NRR/DORL/LPL2-1 |
| To: | Coleman J Southern Nuclear Operating Co |
| References | |
| EPID L-2025-LLA-0064 TS 3.8.2 | |
| Download: ML25269A107 (0) | |
Text
November 25, 2025 Jamie M. Coleman Regulatory Affairs Director Southern Nuclear Operating Company, Inc.
3535 Colonnade Parkway, Bin N-274-EC Birmingham, AL 35243
SUBJECT:
VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 - ISSUANCE OF AMENDMENT TO REVISE TECHNICAL SPECIFICATION 3.8.2, DC [DIRECT CURRENT] SOURCES - SHUTDOWN, CONDITION B (EPID L-2025-LLA-0064)
Dear Ms. Coleman:
In response to your application dated March 31, 2025, the U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment Nos. 209 and 207 to Combined License (COL)
Nos. NPF-91 and NPF-92 for Vogtle Electric Generating Plant (Vogtle), Units 3 and 4, respectively. The amendment revises Technical Specification (TS) 3.8.2, DC [Direct Current]
Sources - Shutdown, Condition B. The amendments change the entry requirements for Condition B of TS 3.8.2.
A copy of the related safety evaluation is enclosed. The notice of issuance of the amendment documents included in this letter will be published in the Federal Register.
If you have questions, please contact me at 301-415-3100 or John.Lamb@nrc.gov.
Sincerely,
/RA/
John G. Lamb, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 52-025 and 52-026
Enclosures:
- 1. Amendment No. 209 to Vogtle, Unit 3, COL
- 2. Amendment No. 207 to Vogtle, Unit 4, COL
- 3. Safety Evaluation cc: Listserv
SOUTHERN NUCLEAR OPERATING COMPANY, INC.
GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MEAG POWER SPVM, LLC MEAG POWER SPVJ, LLC MEAG POWER SPVP, LLC CITY OF DALTON, GEORGIA VOGTLE ELECTRIC GENERATING PLANT, UNIT 3 DOCKET NO.52-025 AMENDMENT TO FACILITY COMBINED LICENSE Amendment No. 209 License No. NPF-91
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Southern Nuclear Operating Company (SNC),
dated March 31, 2025, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's regulations set forth in 10 CFR Chapter I; B.
The facility will be constructed and 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 Commission's regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations, and all applicable requirements have been satisfied.
- 2.
The license is also amended by changes to Appendix A, Technical Specifications, of the facility Combined License as indicated in the attachment to this license amendment.
Accordingly, the license is amended by changes to Appendix A, Technical Specifications, of the facility Combined License as indicated in the attachment to this license amendment. Paragraph 2.D(8) of facility Combined License No. NPF-91 is hereby amended to read as follows:
(8) Incorporation The Technical Specifications, Environmental Protection Plan, in Appendices A and B, respectively, of this license, as revised through Amendment No. 209, are hereby incorporated into this license.
- 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:
Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Page 4 of the facility Combined License and affected pages of Appendix A of the facility Combined License Date of Issuance: November 25, 2025 MICHAEL MARKLEY Digitally signed by MICHAEL MARKLEY Date: 2025.11.25 12:31:33 -05'00'
SOUTHERN NUCLEAR OPERATING COMPANY, INC.
GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MEAG POWER SPVM, LLC MEAG POWER SPVJ, LLC MEAG POWER SPVP, LLC CITY OF DALTON, GEORGIA VOGTLE ELECTRIC GENERATING PLANT, UNIT 4 DOCKET NO.52-026 AMENDMENT TO FACILITY COMBINED LICENSE Amendment No. 207 License No. NPF-92
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Southern Nuclear Operating Company (SNC),
dated March 31, 2025, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I; B.
The facility will be constructed and 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 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.
The license is also amended by changes to Appendix A, Technical Specifications, of the facility Combined License as indicated in the attachment to this license amendment.
Paragraph 2.D(8) of facility Combined License No. NPF-92 is hereby amended to read as follows:
(8) Incorporation The Technical Specifications and Environmental Protection Plan in Appendices A and B, respectively, of this license, as revised through Amendment No. 207, are hereby incorporated into this license.
- 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:
Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Page 4 of the facility Combined License and affected pages of Appendix C of the facility Combined License Date of Issuance: November 25, 2025 MICHAEL MARKLEY Digitally signed by MICHAEL MARKLEY Date: 2025.11.25 12:32:59 -05'00'
ATTACHMENT TO LICENSE AMENDMENT NOS. 209 AND 207 TO FACILITY COMBINED LICENSE NOS. NPF-91 AND NPF-92 DOCKET NOS.52-025 AND 52-026 Replace the following pages of the facility Combined License Nos. NPF-91 and NPF-92 with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Facility Combined License No. NPF-91 REMOVE INSERT 4
4 Facility Combined License No. NPF-92 REMOVE INSERT 4
4 Appendix A to facility Combined License Nos. NPF-91 and NPF-92 REMOVE INSERT 3.8.2-2 3.8.2-2
D.
The license is subject to, and SNC shall comply with, the conditions specified and incorporated below:
(1)
Changes during Construction - Removed by Amendment No. 202 (2)
Pre-operational Testing - Removed by Amendment Nos. 192 and 202 (3)
Nuclear Fuel Loading and Pre-critical Testing - Removed by Amendment Nos. 192 and 202 (4)
Initial Criticality and Low-Power Testing - Removed by Amendment No. 202 (5)
Power Ascension Testing - Removed by Amendment No. 202 (6)
Maximum Power Level (7)
(8)
SNC is authorized to operate the facility at steady state reactor core power levels not to exceed 3400 MW thermal (100-percent thermal power), as described in the UFSAR, in accordance with the conditions specified herein.
Reporting Requirements - Removed by Amendment No. 202 Incorporation The Technical Specifications and Environmental Protection Plan in Appendices A and B, respectively, of this license, as revised through Amendment No. 209, are hereby incorporated into this license.
(9)
Technical Specifications - Removed by Amendment No. 202 (10)
Operational Program Implementation - Removed by Amendment No. 202 (11)
Operational Program Implementation Schedule - Removed by Amendment No.202 (12)
Site-and Unit-specific Conditions - Removed by Amendment No. 202
[Blank Pages 5 through 14 removed by Amendment No. 202.]
4 Amendment No. 209
D.
The license is subject to, and SNC shall comply with, the conditions specified and incorporated below:
(1)
Changes during Construction - Removed by Amendment No. 199 (2)
Pre-operational Testing - Removed by Amendment Nos. 194 and 199 (3)
Nuclear Fuel Loading and Pre-critical Testing - Removed by Amendment Nos. 194 and 199 (4)
Initial Criticality and Low-Power Testing - Removed by Amendment No. 199 (5)
Power Ascension Testing - Removed by Amendment No. 199 (6)
Maximum Power Level (7)
(8)
SNC is authorized to operate the facility at steady state reactor core power levels not to exceed 3400 MW thermal (100-percent thermal power), as described in the UFSAR, in accordance with the conditions specified herein.
Reporting Requirements - Removed by Amendment No. 199 Incorporation The Technical Specifications and Environmental Protection Plan in Appendices A and B, respectively, of this license, as revised through Amendment No. 207, are hereby incorporated into this license.
(9)
Technical Specifications - Removed by Amendment No. 199 (10)
Operational Program Implementation - Removed by Amendment No. 199 (11)
Operational Program Implementation Schedule - Removed by Amendment No. 199 (12)
Site-and Unit-specific Conditions - Removed by Amendment No. 199
[Blank Pages 5 through 14 removed by Amendment No. 199.]
4 Amendment No. 207
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 209 AND 207 TO COMBINED LICENSE NOS. NPF-91 AND NPF-92 SOUTHERN NUCLEAR OPERATING COMPANY, INC.
GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MEAG POWER SPVM, LLC MEAG POWER SPVJ, LLC MEAG POWER SPVP, LLC CITY OF DALTON, GEORGIA VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 DOCKET NOS.52-025 AND 52-026
1.0 INTRODUCTION
By letter dated March 31, 2025 (Agencywide Documents Access and Management System Accession No. ML25090A305), Southern Nuclear Operating Company (SNC, the licensee) requested that the U.S. Nuclear Regulatory Commission (NRC, the Commission) amend Vogtle Electric Generating Plant (Vogtle), Units 3 and 4, Combined License (COL) Nos. NPF-91 and NPF-92, respectively. The license amendment request (LAR) proposed to revise Technical Specifications (TS) 3.8.2, DC [Direct Current] Sources - Shutdown, Condition B. The amendments revise the entry requirements to Condition B of TS 3.8.2.
2.0 REGULATORY EVALUATION
2.1
System Description
The Vogtle, Units 3 and 4, Updated Final Safety Analysis Report (UFSAR), Revision 12, Section 8.3.2.1.1.1, Class 1E DC Distribution, (ML23165A215) states, in part, that:
There are four independent, Class 1E 250 Vdc divisions, A, B, C, and D.
Divisions A and D are each comprising one battery bank, one switchboard, and one battery charger. The battery bank is connected to Class 1E dc switchboard through a set of fuses and a disconnect switch. Divisions B and C are each composed of two battery banks, two switchboards, and two battery chargers. The first battery bank in the four divisions, designated as 24-hour battery bank, provides power to the loads required for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following an event of loss of all ac power sources concurrent with a design basis accident (DBA). The battery charger for each 24-hour division battery bank provides two Class 1E battery charger input voltage status signals to the protection and safety monitoring system for actuation of engineered safety features. The second battery bank in divisions B and C, designated as 72-hour battery bank, is used for those loads requiring power for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following the same event. Each switchboard connected with a 24-hour battery bank supplies power to an inverter, a 250 Vdc distribution panel, and a 250 Vdc motor control center. Each switchboard connected with a 72-hour battery bank supplies power to an inverter. No load shedding or load management program is needed to maintain power during the required 24-hour safety actuation period.
A single spare battery bank with a spare battery charger is provided for the Class 1E dc and UPS [uninterrupted power supply] system. In the case of a failure or unavailability of the normal battery bank and the battery charger, permanently installed cable connections allow the spare to be connected to the affected bus by plugin locking type disconnect along with kirk-key interlock switches. The plug-in locking type disconnect and kirk-key interlock switches permit connection of only one battery bank and battery charger at a time so that the independence of each battery division is preserved. The spare battery and the battery charger can also be utilized as a substitute when offline testing, maintenance, and equalization of an operational battery bank are desired. If the spare battery charger is substituted for a 24-hour division battery charger and the 24-hour division battery charger is disconnected from its normal power supply, the two undervoltage relays on the 24-hour division battery charger each provide a low input voltage signal to the protection and safety monitoring system for the division.
2.2 Regulations and Guidance The regulation 10 CFR 50.36(c)(2)(i) requires that TSs include limiting conditions for operation (LCO) that are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Further, per 10 CFR 50.36(c)(2)(i), when an LCO is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TS until the LCO can be met. Per 10 CFR 50.36(c)(3), TS will include surveillance requirements that 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 LCO will be met. Per 10 CFR 52.97(c), a COL shall contain the terms and conditions, including TSs, as the Commission deems necessary and appropriate.
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 to the extent applicable and appropriate. Both the common standards for licenses in 10 CFR 50.40(a)
(regarding, among other things, consideration of the operating procedures, the facility and equipment, the use of the facility, and other TSs, or the proposals) and those specifically for
issuance of combined licenses in 10 CFR 52.97(a)(3), provide that there must be reasonable assurance that the activities at issue will not endanger the health and safety of the public, and that the applicant will comply with the Commission's regulations.
Vogtle, Units 3 and 4, UFSAR, Revision 12, Section 3.1, Conformance with Nuclear Regulatory Commission General Design Criteria, provides the plant-specific design criteria. UFSAR Section 8.1.4.2.1, Safety Design Basis, states, in part, that the Class 1E dc and UPS power system meets the single failure criterion of General Design Criteria (GDC) 17. UFSAR Section 3.1.2, Protection by Multiple Fission Product Barriers, states that a reliable DC power source supplied by batteries provides power for the safety-related valves and instrumentation during transient and accident conditions; and the Class 1E DC and UPS system is the only safety-related power source required to monitor and actuate the safety-related passive systems provided for core cooling and containment integrity.
Vogtle plant-specific Criterion 17 in UFSAR Section 3.1.2 and Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix A, General Design Criterion (GDC) 17, Electric Power Systems, states, in part:
An onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents.
The onsite electric power supplies, including the batteries, and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure.
NRC staff guidance for the review of proposed TS changes is provided in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants:
LWR [Light-Water Reactor] Edition (SRP), Chapter 16, Section 16.0, Technical Specifications, Revision 3, March 2010 (ML100351425). The NRC staffs review includes consideration of whether the proposed changes are consistent with the NUREG-2194, Revision 1, Standard Technical Specifications, Westinghouse Advanced Passive 1000 (AP1000) Plants (ML16110A277).
3.0 TECHNICAL EVALUATION
3.1 Current TSs Current TS 3.8.2, Condition B are as follows:
CONDITION REQUIRED ACTION COMPLETION TIME B. One or more required DC electrical power subsystems inoperable.
B.1 Declare affected required features inoperable.
OR B.2.1 Suspend movement of irradiated fuel assemblies.
AND B.2.2 Suspend operations with a potential for draining the reactor vessel.
AND B.2.3 Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.
AND B.2.4 Initiate action to restore required DC electrical power subsystems to OPERABLE status.
Immediately Immediately Immediately Immediately Immediately
3.2 Proposed TSs Revised TS 3.8.2, Condition B would state:
CONDITION REQUIRED ACTION COMPLETION TIME B.
One or more required DC electrical power subsystems inoperable for reasons other than Condition A.
OR Required Action and associated Completion Time of Condition A not met.
B.1 Declare affected required features inoperable.
OR B.2.1 Suspend movement of irradiated fuel assemblies.
AND B.2.2 Suspend operations with a potential for draining the reactor vessel.
AND B.2.3 Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.
AND B.2.4 Initiate action to restore required DC electrical power subsystems to OPERABLE status.
Immediately Immediately Immediately Immediately Immediately 3.3 Technical Evaluation and Technical Conclusion of the Proposed Changes 3.3.1 Technical Evaluation Vogtle, Units 3 and 4, TS Limiting Condition for Operation (LCO) 3.8.2 requires the operability of the DC electrical power subsystems to support the DC electrical power distribution subsystem(s) required by LCO 3.8.6, Distribution Systems - Shutdown, in MODES 5 and 6, and during movement of irradiated fuel assemblies. The operability of the DC electrical power subsystems is described in Vogtle, Units 3 and 4, TS Bases 3.8.1, Revision 73, (ML23165A219) which states: An OPERABLE Class 1E DC electrical power subsystem requires all required batteries and respective chargers to be operating and connected to the associated DC bus(es).
The spare battery and/or charger may be used by one subsystem for OPERABILITY.
TS Bases 3.8.1 also indicates that the four independent Class 1E 250 VDC divisions, A, B, C, and D are the DC electrical power subsystems.
The LAR proposes to add for reasons other than Condition A, to Vogtle, Units 3 and 4, TS 3.8.2 Condition B. Existing Condition B is entered when one or more required DC electrical power subsystem(s) is (are) inoperable. Required Action B.2.4 initiates action to restore required DC electrical power subsystems to OPERABLE status Immediately. Vogtle, Units 3 and 4, TS 3.8.2 Condition A is entered when one or more required battery charger(s) in one division is (are) inoperable. Completion Time for Required Action A.3 restores battery charger(s) to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In Condition A, the division (subsystem) containing the inoperable battery charger(s) is also inoperable. As currently written, both Conditions A and B with different Required Actions would be entered if a required battery charger were inoperable. The LAR states that the addition of the phrase for reasons other than Condition A, to Condition B should prevent entering both Condition A and Condition B when the subsystem is inoperable due to the required battery charger being inoperable.
The NRC staff reviewed the proposed addition of for reasons other than Condition A, to Condition B and finds it acceptable, because the additional phrase excludes Condition A that provides remedial actions for an inoperable DC subsystem, which is caused by an inoperable battery charger. The NRC staff notes this is also consistent with the AP1000 standard TS (STS) 3.8.2 in NUREG-2194 Revision 1.
The LAR proposes to add a new entry condition, which states Required Action and associated Completion Time of Condition A not met, to Condition B with a connector OR. The existing TS 3.8.2 states in the Note for Actions that LCO 3.0.3 is not applicable, but it does not provide a default condition when the Required Action and associated Completion Time of Condition A are not met. The LAR states that Condition B is proposed to provide the default condition when the Required Action and associated Completion Time of Condition A are not met, because it includes appropriate Required Actions for an inoperable DC subsystem. The existing Required Actions for Condition B provide (1) Required Action B.1 to declare affected required features inoperable immediately, or (2) Required Actions B.2.1 and B.2.2 and B.2.3 to suspend movement of irradiated fuel assemblies, operation with a potential for draining the reactor vessel, and operations involving positive reactivity additions that could result in loss of required shutdown margin or boron concentration immediately, respectively, and Required Action B.2.4 to restore required DC electrical power subsystems to OPERABLE status immediately.
TS Bases 3.8.2 states that the suspension of these activities in Required Actions B.2.1 and B.2.2 and B.2.3 minimizes the probability of occurrence of postulated events while the action to restore the required DC electrical power subsystem in Required Action B.2.4 is continued until restoration is accomplished to provide the necessary Class 1E DC electrical power to the unit safety systems, as required by TS LCO 3.8.2.
The NRC staff reviewed the proposed new alternate entry condition to Condition B and finds would continue to meet 10 CFR 50.35 and is, therefore, acceptable, because the proposed revised Condition B will exclude Condition A, as evaluated above. The proposed new alternate entry condition is also consistent with the AP1000 STS 3.8.2 in NUREG-2194 Revision 1, the existing Required Actions for Condition B provide appropriate remedial actions for an inoperable DC electrical power subsystem to meet the TS LCO 3.8.2 in accordance with 10 CFR 50.36(c)(2)(i).
3.3.2 Technical Conclusion The NRC staff reviewed the licensees proposed changes to the Vogtle, Units 3 and 4, TS 3.8.2 Condition B. Based on the above, the NRC staff finds that the proposed TS changes are acceptable, because the proposed exclusion of Condition A from Condition B and the new alternate entry condition to Condition B are reasonable and consistent with AP1000 STS 3.8.2, Revision 1; and the revised Condition B provides acceptable remedial actions for an inoperable DC subsystem to meet the TS LCO 3.8.2. Therefore, the NRC staff concludes that the proposed TS change would continue to meet regulatory requirements in 10 CFR 50.36(c)(2)(i) and 10 CFR 50 Appendix A, GDC 17 for availability of the Class 1E DC electrical power systems.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Georgia State official was notified of the proposed issuance of the amendments on September 18, 2025. On September 18, 2025, the State official indicated the State of Georgia 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. The NRC staff has determined that the amendments 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 Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (90 FR 20519) on May 14, 2025.
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 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 Contributors: Adakou Foli, NRR Kayleh James, NRR Mark Schwieg, NRR Date: November 25, 2025
ML25269A107 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DSS/STSB/BC NRR/DEX/EEEB/BC NAME JLamb KZelenock SMehta WMorton (SRay for)
DATE 09/22/2025 09/30/2025 11/14/2025 09/22/2025 OFFICE NRR/DORL/LPL2-1/BC NRR/DORL/LPL2-1/PM NAME MMarkley JLamb DATE 11/24/2025 11/25/2025