ML17123A228

Issuance of Amendment Regarding One-Time Extension of 10 CFR Part 50, Appendix J, Type C Local Leakage Rate Tests

ML17123A228
Person / Time
Site:	Watts Bar
Issue date:	05/18/2017
From:	Robert Schaaf Plant Licensing Branch II
To:	James Shea Tennessee Valley Authority
Schaaf R, NRR/DORL/LPLII-2, 415-6020
References
CAC MF9297
Download: ML17123A228 (14)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 18, 2017 Mr. J. W. Shea Vice President, Nuclear Licensing Tennessee Valley Authority 1101 Market Street, LP 3R-C Chattanooga, TN 37 402-2801

SUBJECT:

WATTS BAR NUCLEAR PLANT, UNIT 2 - ISSUANCE OF AMENDMENT REGARDING ONE-TIME EXTENSION OF 10 CFR PART 50, APPENDIX J, TYPE C LOCAL LEAKAGE RATE TESTS (CAC NO. MF9297)

Dear Mr. Shea:

The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment No. 11 to Facility Operating License No. NPF-96 for the Watts Bar Nuclear Plant, Unit 2. This amendment is in response to your application dated February 16, 2017.

This amendment revises Technical Specification 5.7.2.19 to extend, on a one-time basis, the Type C local leak rate test for certain containment isolation valves.

A copy of the safety evaluation is also enclosed. Notice of issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, Robert G. Schaaf, Senior Project ~anager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-391

Enclosures:

1. Amendment No. 11 to NPF-96

2. Safety Evaluation cc w/enclosures: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-391 WATTS BAR NUCLEAR PLANT, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 11 License No. NPF-96

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

A. The application for amendment by Tennessee Valley Authority (TVA, the licensee) dated February 16, 2017, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's 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 Commission's 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 Commission's 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 2.C.(2) of Facility Operating License No. NPF-96 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. 11 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. TVA 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 its issuance, and shall be implemented no later than 30 days from the date of its issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Benjamin G. Beasley, Chief Plant Licensing Branch 11-2 Division of operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Operating License and Technical Specifications Date of Issuance: May 1 8 , 2o1 7

ATTACHMENT TO AMENDMENT NO. 11 WATTS BAR NUCLEAR PLANT, UNIT 2 FACILITY OPERATING LICENSE NO. NPF-96 DOCKET NO. 50-391 Replace Page 3 of Operating License NPF-96 with the attached Page 3. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Replace the following page of the Appendix A Technical Specifications with the attached pages.

The revised page and the new page are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 5.0-25 5.0-25 5.0-25a

C. The license shall be deemed to contain and is subject to the conditions specified in the Commission's 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 TVA is authorized to operate the facility at reactor core power levels not in excess of 3411 megawatts thermal.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A as revised through Amendment No. 11 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. TVA shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) TVA shall implement permanent modifications to prevent overtopping of the embankments of the Fort Loudon Dam due to the Probable Maximum Flood by June 30, 2018.

(4) PAD4TCD may be used to establish core operating limits for Cycles 1 and 2 only. PAD4TCD may not be used to establish core operating limits for subsequent reload cycles.

(5) By December 31, 2017, the licensee shall report to the NRC that the actions to resolve the issues identified in Bulletin 2012-01, "Design Vulnerability in Electrical Power System," have been implemented.

(6) The licensee shall maintain in effect the provisions of the physical security plan, security personnel training and qualification plan, and safeguards contingency plan, and all amendments made pursuant to the authority of 10 CFR 50.90 and 50.54(p).

(7) TVA 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 TVA approved CSP was discussed in NUREG-0847, Supplement 28, as amended by changes approved by License Amendment No. 7.

(8) TVA shall implement and maintain in effect all provisions of the approved fire protection program as described in the Fire Protection Report for the facility, as described in NUREG-0847, Supplement 29, subject to the following provision:

Unit 2 Facility Operating License No. NPF-96 Amendment No. 11

Procedures, Programs, and Manuals 5.7 5.7 Procedures, Programs, and Manuals

5. 7 .2.18 Safety Function Determination Program (SFDP) (continued)

A loss of safety function exists when, assuming no concurrent single failure, a safety function assumed in the accident analysis cannot be performed. For the purpose of this program, a loss of safety function may exist when a support system is inoperable, and:

a. A required system redundant to the system(s) supported by the inoperable support system is also inoperable; or

b. A required system redundant to the system(s) in turn supported by the inoperable supported system is also inoperable; or

c. A required system redundant to the support system(s) for the supported systems (a) and (b) above is also inoperable.

The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

5. 7 .2.19 Containment Leakage Rate Testing Program A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(0) and 10 CFR 50 Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide (RG) 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995, with the exception that for the containment isolation valves listed in Table 5. 7.2-1, an extension of their Type C local leak rate test is permitted on a one-time basis and expires prior to WBN Unit 2 entering Mode 4, following the Cycle 1 refueling outage, but no later than December 31, 2017.

For containment leakage rate testing purposes, a value of 15.0 psig, which is equivalent to the maximum allowable internal containment pressure, is utilized for Pa to bound the peak calculated containment internal pressure for the design basis loss of coolant accident.

The maximum allowable containment leakage rate, La, at Pa, is 0.25%

of the primary containment air weight per day.

(continued)

Watts Bar - Unit 2 5.0-25 Amendment 11

Procedures, Programs, and Manuals 5.7 Table-5. 7 .2-1 I Containment Description Valve number Penetration X-29 RCP oil cooler CCS Return Outboard FCV-70-92 X-44 RCP Seal Water Return Outboard FCV-62-63 FCV-61-192 Glycol Supply Inboard X-47A CKV-61-533 Glycol Suoolv Outboard FCV-61-191 I FCV-61-194 Glycol Return Inboard X-47B CKV-61-680 Glycol Return Outboard FCV-61-193 FCV-67-113 Lower Containment ERCW Supply X-56A CKV-67-10540 Lower Containment ERCW Supply FCV-67-107 FCV-67-111 X-57A Lower Containment ERCW Return CKV-67-5750 FCV-67-112 FCV-67-89 X-58A Lower Containment ERCW Supply CKV-67-1054A FCV-67-83 FCV-67-87 X-59A Lower Containment ERCW Return CKV-67-575A FCV-67-88 FCV-67-105 X-60A Lower Containment ERCW Supply CKV-67-10548 FCV-67-99 FCV-67-103 X-61A Lower Containment ERCW Return CKV-67-5758 FCV-67-104 I FCV-67-97 X-62A Lower Containment ERCW Supply CKV-67-1054C FCV-67-91 FCV-67-95 X-63A Lower Containment ERCW Return CKV-67-575C FCV-67-96 I (continued)

Watts Bar - Unit 2 5.0-25a Amendment 11

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 11 TO FACILITY OPERATING LICENSE NO. NPF-90 TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT. UNIT 1 DOCKET NO. 50-391

1.0 INTRODUCTION

By letter dated February 16, 2017 (Agencywide Documents Access and Management System Accession No. ML17048A514) Tennessee Valley Authority (TVA, the licensee) submitted a license amendment request (LAR) for Watts Bar Nuclear Plant (Watts Bar) Unit 2. The LAR would revise Technical Specification (TS) 5.7.2.19, "Containment Leakage Rate Testing Program," to allow a one-time interval extension for the local leak rate tests (LLRTs) of a select group of containment isolation valves (CIVs). This one-time extension would be an exception to, or deviation from, the provisions of Nuclear Energy Institute (NEI) 94-01, Revision 0, July 26, 1995, "Industry Guideline for Implementing Performance-Based Option of Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix J," as endorsed by Regulatory Guide (RG) 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995. RG 1.163 is identified in TS 5.7.2.19 as the implementation document used to develop the licensee's performance-based leakage-testing program. NEI 94-01 Section 10.2.3.1 states that Type C (CIV) tests shall be performed prior to initial reactor operation and that subsequent periodic Type C tests be performed at a frequency of at least once per 30 months until adequate performance has been established to justify an extended test interval greater than 30 months. A CIV demonstrates adequate performance by not exceeding the administrative leakage limit established by the licensee during two consecutive periodic LLRTs.

After the Watts Bar Unit 2 Operating License was issued on October 22, 2015, TVA began the process of starting up the unit, which included completion of required TS equipment surveillances prior to entry into their associated operating mode of applicability. In addition to completing the surveillance requirements (SRs) required to enter each reactor operating mode, TVA performed power accession testing to confirm that the unit operated as designed. Initial plans for Watts Bar Unit 2 were to declare Unit 2 ready for commercial operation by the end of 2015. With commercial operation originally projected in 2015, TVA planned the first refueling outage to occur in September 2016. Due to delays in the startup of Unit 2, commercial operation was delayed until October 19, 2016.

TVA initially planned to perform Type C LLRTs for the CIVs that are the subject of this amendment during the September 2016 Refueling Outage. When commercial operation was delayed to October 19, 2016, TVA revised the planned date for the first refueling outage to October 2017. To Enclosure 2

support continuous plant operation until the October 2017 Refueling Outage date, the LAR proposed a one-time change to extend the LLRT intervals for the CIVs that are the subject of this amendment. The licensee indicated in the proposed amendment that these LLRTs cannot be conducted during power operations. The proposed extended date for LLRTs will allow these tests to be performed during the Watts Bar Unit 2 Cycle 1 Refueling Outage, which is scheduled to commence in October 2017. Specifically, the LLRTs for these CIVs will be completed prior to Watts Bar Unit 2 entering Mode 4 following the Cycle 1 Refueling Outage, but no later than December 31, 2017.

With the proposed one-time LLRT interval extensions, a plant shutdown solely to perform these tests would be avoided. If such a mid-cycle outage were to occur, these tests would likely need to be repeated during the first refueling outage to synchronize their performance with the schedule for subsequent refueling outages. The extra cold shutdown (Mode 5) mid-cycle outage would involve an unnecessary transient on the plant and associated risks and additional personnel radiological dose.

2.0 REGULA TORY EVALUATION Section 50.54(0) of 10 CFR requires primary reactor containments for water cooled power reactors be subject to the requirements set forth in Appendix J to 10 CFR Part 50, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors." Appendix J to 10 CFR Part 50 includes two options: "Option A - Prescriptive Requirements," and "Option B -

Performance-Based Requirements," either of which may be chosen by a licensee for meeting the requirements of the Appendix. TVA adopted 10 CFR Part 50, Appendix J, Option B for Type A (integrated leak rate tests), and Type B and Type C LLRTs for Watts Bar Unit 2 prior to receiving the operating license for the unit.

The testing requirements in 10 CFR Part 50, Appendix J ensure that (a) leakage through containments or systems and components penetrating containments does not exceed allowable leakage rates specified in the TS, and (b) integrity of the containment structure is maintained during the service life of the containment.

Option B of 10 CFR Part 50, Appendix J, specifies performance-based requirements and criteria for preoperational and subsequent leakage rate testing. These requirements are met by performing Type A tests to measure the containment system overall integrated leakage rate; Type B pneumatic tests to detect and measure local leakage rates across pressure-retaining leakage-limiting boundaries such as penetrations; and Type C pneumatic tests to measure containment isolation valve leakage rates. After the preoperational tests, these tests are required to be conducted at periodic intervals based on the historical performance of the overall containment system (for Type A tests), and based on the safety significance and historical performance of each penetration boundary and isolation valve (for Type Band C tests) to ensure integrity of the overall containment system as a barrier to fission product release.

The leakage rate test results must not exceed the allowable leakage rate (La) with margin, as specified in the TS. Option B also requires that a general visual inspection of the accessible interior and exterior surfaces of the containment system, for structural deterioration which may affect the containment leak-tight integrity, must be conducted prior to each Type A test and at a periodic interval between tests.

Section V.B.3of10 CFR Part 50, Appendix J, Option B, requires that the RG or other implementation document used by a licensee to develop a performance-based leakage-testing

program must be included, by general reference, in the plant TSs. Furthermore, the submittal for TS revisions must contain justification, including supporting analyses, if the licensee chooses to deviate from methods approved by the Commission and endorsed in an RG.

NEI 94-01, Revision O, was reviewed by the U.S. Nuclear Regulatory Commission (NRC) and approved for use through endorsement in RG 1.163, September 1995.

The regulations in 10 CFR 50.55a "Codes and standards," contain the containment inservice inspection program requirements that, in conjunction with the requirements of Appendix J, ensure the continued leak-tight and structural integrity of the containment during its service life.

The regulations in 10 CFR 50.65(a), "Requirements for monitoring the effectiveness of maintenance at nuclear power plants," state, in part, that the licensee" ... shall monitor the performance or condition of structures, systems, or components, against licensee-established goals, in a manner sufficient to provide reasonable assurance that these structures, systems, and components, as defined in paragraph (b) of this section, are capable of fulfilling their intended functions. These goals shall be established commensurate with safety and, where practical, take into account industrywide operating experience."

The regulations in 10 CFR 50.36, "Technical specifications" state, in part, that the TSs include items in five specific categories. These categories include: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) SRs; (4) design features; and (5) administrative controls.

NUREG-1431, "Standard Technical Specifications - Westinghouse Plants," Revision 4.0, incorporated the Standard Technical Specification Task Force Traveler TSTF-52, Revision 3 (ML040400371) that provided guidance for specific changes to TSs for implementation of 10 CFR Part 50 Appendix J Option B.

3.0 TECHNICAL EVALUATION

Watts Bar Unit 2 is a Westinghouse design 4-loop pressurized-water reactor within an ice-condenser pressure suppression design containment. The primary containment consists of a cylindrical domed steel vessel enclosed within a concrete shield building that provides environmental and missile protection in addition to radiation shielding and also allows for collection and treatment of primary containment leakage into the annulus volume between the primary containment vessel and the shield building.

The primary containment provides the leak-tight barrier against the potential uncontrolled release of fission products during a design basis loss of coolant accident. The CIVs form part of the containment pressure boundary and provide a means for fluid penetrations not serving accident consequence limiting systems to be provided with two isolation barriers. Two barriers in series are provided for each penetration so that no single credible failure or malfunction of an active component can result in a loss of isolation or leakage that exceeds limits assumed in the safety analyses.

3.1 Licensee's Proposed Changes Watts Bar Unit 2 TS 5. 7.2.19 currently states, in part:

A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(0) and 10 CFR 50 Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide (RG) 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995.

With the proposed changes this part of Watts Bar Unit 2 TS 5. 7 .2.19 would state:

A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(0) and 10 CFR 50 Appendix J, Option B, as modified by approved exemptions.

This program shall be in accordance with the guidelines contained in Regulatory Guide (RG) 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995, with the exception that for the containment isolation valves listed in Table 5.7.2-1, an extension of their Type C local leak rate test is permitted on a one-time basis and expires prior to Watts Bar Unit 2 entering Mode 4, following the Cycle 1 Refueling Outage, but no later than December 31, 2017.

The proposed changes to Watts Bar Unit 2 TS 5.7.2.19 would also add Table-5.7.2-1, as shown on the next page.

The licensee stated in the LAR that the CIVs listed in the proposed Table-5.7.2-1 had been replaced or refurbished prior to their preoperational LLRTs. This would mean that they were in like-new condition with minimal or no wear at the time of initial Watts Bar Unit 2 startup. The license also indicated that the CIVs listed in the table were similar or the same in design and service conditions to the corresponding CIVs in Watts Bar Unit 1, which have a substantial leakage testing history. The LAR indicated that the corresponding CIVs in Unit 1 had not contributed significantly to the historical combined as-found minimum pathway totals for that Unit.

The LAR also provided the preoperational LLRT results for these Unit 2 CIVs. All the preoperational LLRT results showed no detectable or very minimal leakage. The licensee stated in the LAR that the total preoperational LLRT demonstrated leakage of these CIVs was 0.24 standard cubic feet per hour (scfh) which is approximately 0.16 percent(%) of the combined total allowable leakage (60% La, 147.6 scfh) for the Watts Bar Unit 2 Type Band C LLRTs.

The licensee stated in the LAR that the Watts Bar Unit 2 preoperational total leak rate for all penetrations on a minimum path basis was approximately 4.5% of the Type B and C LLRT combined total allowable leakage. The LAR also indicated that the total leakage of the CIVs listed in proposed Table-5.7.2-1 was approximately 0.39% of the total allowable bypass leakage for the Watts Bar Unit 2 Type Band C bypass tests (61.5 scfh, which is the TS 25% La limit). For comparison purposes, the Watts Bar Unit 2 total leakage for all bypass leakage penetrations on a minimum path basis is approximately 4.4% of the total allowable bypass leakage.

Table-5.7.2-1 Containment Description Valve Number Penetration X-29 RCP oil cooler CCS Return Outboard FCV-70-92 X-44 RCP Seal Water Return Outboard FCV-62-63 Glycol Supply Inboard FCV-61-192 X-47A CKV-61-533 Glycol Supply Outboard FCV-61-191 FCV-61-194 Glycol Return Inboard X-47B CKV-61-680 Glycol Return Outboard FCV-61-193 FCV-67-113 Lower Containment ERCW Supply X-56A CKV-67-10540 Lower Containment ERCW Supply FCV-67-107 FCV-67-111 X-57A Lower Containment ERCW Return CKV-67-5750 FCV-67-112 FCV-67-89 X-58A Lower Containment ERCW Supply CKV-67-1054A FCV-67-83 FCV-67-87 X-59A Lower Containment ERCW Return CKV-67-575A FCV-67-88 FCV-67-105 X-60A Lower Containment ERCW Supply CKV-67-1054B FCV-67-99 FCV-67-103 X-61A Lower Containment ERCW Return CKV-67-575B FCV-67-104 FCV-67-97 X-62A Lower Containment ERCW Supply CKV-67-1054C FCV-67-91 FCV-67-95 X-63A Lower Containment ERCW Return CKV-67-575C FCV-67-96 The proposed LLRT interval extensions range from 73 to 211 days (approximately 2-1/2 to 7 months) which represents about an 8 to 23% extension of the 30-month baseline interval normally required for valves without a specific demonstrated acceptable leakage test results performance history. The leakage testing program implementation guidance will allow these CIVs, when they have demonstrated acceptable performance history, to have their test intervals extended up to a maximum of 60 months.

The Watts Bar Unit 2 CIVs for which a one-time extension of required LLRT interval is proposed have entered their initial plant operating cycle in excellent condition regarding leakage potential.

The corresponding CIVs in Unit 1 have in the aggregate demonstrated acceptable performance over many operating cycles from which to draw inference of the Unit 2 CIVs likely also having similarly acceptable leakage performance. Watts Bar Unit 2 entered its initial operating cycle with a large margin to the acceptance criteria for combined LLRT totals available to accommodate

development of some additional leakage potential over the relatively short interval extensions proposed. Based on these three considerations, there is reasonable assurance that the TS LLRT leakage limits would not be exceeded when LLRTs are performed and the totals calculated during Watts Bar Unit 2's first refueling outage.

Based on the preceding regulatory and technical evaluations, the staff finds that there is reasonable assurance that the proposed one-time LLRT interval extensions, a deviation from the RG 1.163, Revision 0, endorsed leakage rate testing program implementation document NEI 94-01, Revision 0, will not result in the Watts Bar Unit 2 TS LLRT combined leakage limits being exceeded. The proposed change to Watts Bar Unit 2 TS 5. 7.2.19 is thus acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Tennessee State official was notified of the proposed issuance of the amendment on May 8, 2017. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRG 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 Commission 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 on March 14, 2017 (82 FR 13671 ). 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 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 Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: Jerome Bettle Date: May 18, 2017

ML17123A228 *via memo **via email OFFICE DORL/LPL2-2/PM DORL/LPL2-2/LA DSS/SBPB/BC* DSS/STSB/BC(A)**

NAME RSchaaf BClayton RDennig JWhitman DATE 5/4/2017 5/4/2017 5/2/2017 5/8/2017 OFFICE OGC- NLO** DORL/LPL2-2/BC DORL/LPL2-2/PM NAME BMizuno BBeaslev RSchaaf DATE 5/16/2017 5/18/2017 5/18/2017