ML15205A313: Difference between revisions

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| issue date = 09/28/2015
| issue date = 09/28/2015
| title = OEDO-15-00026 - St. Lucie Plant, Unit 2, Sace 2.206 Petition Partial Acknowledgement Letter
| title = OEDO-15-00026 - St. Lucie Plant, Unit 2, Sace 2.206 Petition Partial Acknowledgement Letter
| author name = Dean W M
| author name = Dean W
| author affiliation = NRC/NRR
| author affiliation = NRC/NRR
| addressee name = Curran D
| addressee name = Curran D
Line 17: Line 17:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 28, 2015 Ms. Diane Curran Harmon, Curran, Spielberg, and Eisenberg, LLP 1726 M Street NW, Suite 600 Washington, DC 20036 dcurran@harmoncurran.com  
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 28, 2015 Ms. Diane Curran Harmon, Curran, Spielberg, and Eisenberg, LLP 1726 M Street NW, Suite 600 Washington, DC 20036 dcurran@harmoncurran.com


==Dear Ms. Curran:==
==Dear Ms. Curran:==
This letter is in reference to the petition you submitted on behalf of the Southern Alliance for Clean Energy (SAGE) on March 10, 2014. You initially filed the petition as a request for a hearing. However, by a memorandum and order (CLl-14-11) dated December 19, 2014, the Commission referred your request to the Executive Director for Operations for disposition under Title 10 of the Code of Federal Regulations (10 CFR) Section 2.206, "Requests for Action Under this Subpart." In your petition, you requested that the U.S. Nuclear Regulatory Commission (NRG) take action regarding the replacement steam generators at the St. Lucie Plant, Unit 2. Specifically, you requested that the NRG take enforcement action against the plant licensee Florida Power and Light Company (FPL) to revoke the NRG staff's de facto amendment of the St. Lucie, Unit 2 license regarding the replacement steam generators.
 
The basis for your request was your assertion that the licensee incorrectly applied the 10 CFR 50.59, "Changes, Tests, and Experiments," process to replace the steam generators at St. Lucie, Unit 2. I would like to express my appreciation to the Southern Alliance for Clean Energy for bringing these concerns to the NRG. I assigned Ms. Farideh Saba, a Senior Project Mananger in the Office of Nuclear Reactor Regulation (NRR), as your petition manager. You may direct any questions you have concerning the petition process or the status of your petition to Ms. Saba by phone at 301-415-1447 or by e-mail to Farideh.Saba@nrc.gov.
This letter is in reference to the petition you submitted on behalf of the Southern Alliance for Clean Energy (SAGE) on March 10, 2014. You initially filed the petition as a request for a hearing. However, by a memorandum and order (CLl-14-11) dated December 19, 2014, the Commission referred your request to the Executive Director for Operations for disposition under Title 10 of the Code of Federal Regulations (10 CFR) Section 2.206, "Requests for Action Under this Subpart."
A Petition Review Board (PRB) was established to review your petition.
In your petition, you requested that the U.S. Nuclear Regulatory Commission (NRG) take action regarding the replacement steam generators at the St. Lucie Plant, Unit 2. Specifically, you requested that the NRG take enforcement action against the plant licensee Florida Power and Light Company (FPL) to revoke the NRG staff's de facto amendment of the St. Lucie, Unit 2 license regarding the replacement steam generators. The basis for your request was your assertion that the licensee incorrectly applied the 10 CFR 50.59, "Changes, Tests, and Experiments," process to replace the steam generators at St. Lucie, Unit 2.
The PRB is comprised of representatives from the following organizations within the NRG: a Chair (who is a Division Director from NRR);
I would like to express my appreciation to the Southern Alliance for Clean Energy for bringing these concerns to the NRG. I assigned Ms. Farideh Saba, a Senior Project Mananger in the Office of Nuclear Reactor Regulation (NRR), as your petition manager. You may direct any questions you have concerning the petition process or the status of your petition to Ms. Saba by phone at 301-415-1447 or by e-mail to Farideh.Saba@nrc.gov.
NRR staff from the Division of Engineering, Division of Operating Reactor Licensing, and Division of Policy and Rulemaking; Region II staff; and advisors from the Office of Enforcement and the Office of the General Counsel. In accordance with NRG Management Directive (MD) 8.11, "Review Process for 10 CFR 2.206 Petitions," you had the opportunity to address the petition review board, either in person at NRG headquarters in Rockville, MD or by telephone conference.
A Petition Review Board (PRB) was established to review your petition. The PRB is comprised of representatives from the following organizations within the NRG: a Chair (who is a Division Director from NRR); NRR staff from the Division of Engineering, Division of Operating Reactor Licensing, and Division of Policy and Rulemaking; Region II staff; and advisors from the Office of Enforcement and the Office of the General Counsel.
Ms. Farideh Saba, the petition manager, initially contacted you on January 16, 2015, and asked if you wished to address the petition review board. On February 24, 2015, you informed Ms. Saba that SAGE had decided not to request a meeting with the petition review board with regard to its 10 CFR 2.206 proceeding on St. Lucie, Unit 2.
In accordance with NRG Management Directive (MD) 8.11, "Review Process for 10 CFR 2.206 Petitions," you had the opportunity to address the petition review board, either in person at NRG headquarters in Rockville, MD or by telephone conference. Ms. Farideh Saba, the petition manager, initially contacted you on January 16, 2015, and asked if you wished to address the petition review board. On February 24, 2015, you informed Ms. Saba that SAGE had decided not to request a meeting with the petition review board with regard to its 10 CFR 2.206 proceeding on St. Lucie, Unit 2.
D. Curran The petition review board met internally on March 25, April 29, and May 20, 2015, to discuss your petition with respect to the criteria for review described in MD 8.11, "Review Process for
 
* 10 CFR 2.206 Petitions." Based upon that review, the board determined that your request partially meets the criteria for review under 10 CFR 2.206 and partially*
D. Curran                                           The petition review board met internally on March 25, April 29, and May 20, 2015, to discuss your petition with respect to the criteria for review described in MD 8.11, "Review Process for
meets the criteria for rejection under Management Directive 8.11. The parts of the petition that met the criteria for rejection under MD 8.11, Criterion 2, are ( 1) concerns related to the inspection of the replacement steam generators and (2) concerns regarding the effects of the extended power uprate (EPU) on steam generator tube inservice inspection and flow-induced effects on the steam generator internals.
* 10 CFR 2.206 Petitions." Based upon that review, the board determined that your request partially meets the criteria for review under 10 CFR 2.206 and partially* meets the criteria for rejection under Management Directive 8.11.
Because these issues have already been reviewed, evaluated, and resolved by the NRC staff, they meet the criteria for rejection under MD 8.11. In the below paragraphs, we detail the NRC staff's prior resolutions of these issues. Regarding your first concern about the inspection of replacement steam generators, NRC Region II inspectors had already reviewed several aspects ofthe replacement steam generators at St. Lucie, Unit 2 under Inspection Procedure 50001, "Steam Generator Replacement Inspection" (ADAMS Accession No. ML080350408), dated February 1, 2008. The design and planning of the replacement steam generators, removal and replacement of the original steam generators, and replacement steam generator preservice and baseline inspections, were included in the Region II inspection.
The parts of the petition that met the criteria for rejection under MD 8.11, Criterion 2, are
This inspection also covered a review of the plant change modification packages and licensee procedures to design and replace the steam generators.
( 1) concerns related to the inspection of the replacement steam generators and (2) concerns regarding the effects of the extended power uprate (EPU) on steam generator tube inservice inspection and flow-induced effects on the steam generator internals. Because these issues have already been reviewed, evaluated, and resolved by the NRC staff, they meet the criteria for rejection under MD 8.11. In the below paragraphs, we detail the NRC staff's prior resolutions of these issues.
Regarding your first concern about the inspection of replacement steam generators, NRC Region II inspectors had already reviewed several aspects ofthe replacement steam generators at St. Lucie, Unit 2 under Inspection Procedure 50001, "Steam Generator Replacement Inspection" (ADAMS Accession No. ML080350408), dated February 1, 2008. The design and planning of the replacement steam generators, removal and replacement of the original steam generators, and replacement steam generator preservice and baseline inspections, were included in the Region II inspection. This inspection also covered a review of the plant change modification packages and licensee procedures to design and replace the steam generators.
During their inspection, NRC Region II inspectors did not identify any findings of significance.
During their inspection, NRC Region II inspectors did not identify any findings of significance.
Regarding your second concern about extended power uprates and steam generator inspections, NRC staff reviewed and approved the St. LuCie,-Unit 2 extended power uprate amendment dated September 24, 2012 (ADAMS Accession No. ML 12268A167).
Regarding your second concern about extended power uprates and steam generator inspections, NRC staff reviewed and approved the St. LuCie,-Unit 2 extended power uprate amendment dated September 24, 2012 (ADAMS Accession No. ML12268A167). The licensee's application for the extended power uprate included evaluations of replacement steam generators and replacement steam generator supports. In its review, the NRC staff determined that the effects of the proposed extended power uprate at St. Lucie, Unit 2 do not adversely affect the structural integrity of the steam generators and their supports.
The licensee's application for the extended power uprate included evaluations of replacement steam generators and replacement steam generator supports.
The Advisory Committee on Reactor Safeguards (ACRS) also reviewed the St. Lucie, Unit 2 extended power uprate application with respect to steam generator performance. By letter dated July 23, 2012 (ADAMS Accession No. ML12198A202), ACRS evaluated th~ licensee's root cause of steam generator tube wear indications and the licensee's action plan to address steam generator tube integrity. ACRS determined that the licensee's action plan adequately addressed the concerns about steam generator tube integrity.
In its review, the NRC staff determined that the effects of the proposed extended power uprate at St. Lucie, Unit 2 do not adversely affect the structural integrity of the steam generators and their supports.
The Advisory Committee on Reactor Safeguards (ACRS) also reviewed the St. Lucie, Unit 2 extended power uprate application with respect to steam generator performance.
By letter dated July 23, 2012 (ADAMS Accession No. ML 12198A202), ACRS evaluated licensee's root cause of steam generator tube wear indications and the licensee's action plan to address steam generator tube integrity.
ACRS determined that the licensee's action plan adequately addressed the concerns about steam generator tube integrity.
The NRC staff is currently evaluating the application of the 10 CFR 50.59 process in conjunction with St. Lucie, Unit 2 steam generator replacement that appears related to SACE's petition.
The NRC staff is currently evaluating the application of the 10 CFR 50.59 process in conjunction with St. Lucie, Unit 2 steam generator replacement that appears related to SACE's petition.
Specifically, the NRC staff is further investigating whether the licensee properly applied the 10 CFR 50.59 process to changes made in the structural analysis codes as described in the updated final safety analysis report (UFSAR). As such, the petition review board determined that the part of your petition that addresses the licensee's application of the 10 CFR 50.59 process, with respect to the change in a methodology as described in the UFSAR, meets the criteria for review of a petition under 10 CFR 2.206.
Specifically, the NRC staff is further investigating whether the licensee properly applied the 10 CFR 50.59 process to changes made in the structural analysis codes as described in the updated final safety analysis report (UFSAR). As such, the petition review board determined that the part of your petition that addresses the licensee's application of the 10 CFR 50.59 process, with respect to the change in a methodology as described in the UFSAR, meets the criteria for review of a petition under 10 CFR 2.206.
D. Curran '* On August 4, 2015, the petition manager informed you of the PRB's initial recommendation and, per MD 8.11, offered you another opportunity to address the PRB, if you had additional information in support of your petition for the PRB to consider.
 
You responded on August 5, 2015, that "SACE has no new information to add to the document already filed.* Therefore we do not seek an opportunity to address the PRB." Therefore, the PRB recommendation is final and as provided by 10 CFR 2.206, the NRC will take action on your request within a reasonable time. * * . I have enclosed a copy of the notice that the NRC will publish in the Federal Register.
D. Curran                         '*             On August 4, 2015, the petition manager informed you of the PRB's initial recommendation and, per MD 8.11, offered you another opportunity to address the PRB, if you had additional information in support of your petition for the PRB to consider. You responded on August 5, 2015, that "SACE has no new information to add to the document already filed.* Therefore we do not seek an opportunity to address the PRB." Therefore, the PRB recommendation is final and as provided by 10 CFR 2.206, the NRC will take action on your request within a reasonable time.           *                   *                 .
MD 8.11 and NUREG/BR 0200, "Public Petition Process," can be found in ADAMS under Accession Nos. ML041770328 and ML050900248, respectively.
I have enclosed a copy of the notice that the NRC will publish in the Federal Register. MD 8.11 and NUREG/BR 0200, "Public Petition Process," can be found in ADAMS under Accession Nos.
If you need hard copies of these documents, please contact Ms. Saba. * '-...  
ML041770328 and ML050900248, respectively. If you need hard copies of these documents, please contact Ms. Saba.
* William M. Dean, Director Office of Nuclear Reactor Regulation


==Enclosure:==
==Enclosure:==


Federal Register Notice cc w/encl: Mr. Mano Nazar President and Chief Nuclear Officer Nuclear Division NextEra Energy P.O. Box 14000 Juno Beach, FL 33408-0420 cc w/o encl: ListServ William M. Dean, Director Office of Nuclear Reactor Regulation D. Curran On August 4, 2015, the petition manager informed you of the PRB's initial recommendation and, per MD 8.11, offered you another opportunity to address the PRB, if you had additional information in support of your petition for the PRB to consider.
Federal Register Notice cc w/encl:
You responded on August 5, 2015, that "SAGE has no new information to add to the document already filed. Therefore we do not seek an opportunity to address the PRB." Therefore, the PRB recommendation is final and as provided by 10 CFR 2.206, the NRC will take action on your request within a reasonable time. I have enclosed a copy of the notice that the NRC will publish in the Federal Register.
Mr. Mano Nazar President and Chief Nuclear Officer Nuclear Division NextEra Energy P.O. Box 14000 Juno Beach, FL 33408-0420 cc w/o encl: ListServ
MD 8.11 and NUREG/BR 0200, "Public Petition Process," can be found in ADAMS under Accession Nos. ML041770328 and ML050900248, respectively.
 
If you need hard copies of these documents, please contact Ms. Saba.  
D. Curran                                                     On August 4, 2015, the petition manager informed you of the PRB's initial recommendation and, per MD 8.11, offered you another opportunity to address the PRB, if you had additional information in support of your petition for the PRB to consider. You responded on August 5, 2015, that "SAGE has no new information to add to the document already filed. Therefore we do not seek an opportunity to address the PRB." Therefore, the PRB recommendation is final and as provided by 10 CFR 2.206, the NRC will take action on your request within a reasonable time.
I have enclosed a copy of the notice that the NRC will publish in the Federal Register. MD 8.11 and NUREG/BR 0200, "Public Petition Process," can be found in ADAMS under Accession Nos. ML041770328 and ML050900248, respectively. If you need hard copies of these documents, please contact Ms. Saba.
Sincerely,
                                                                  /RAJ William M. Dean, Director Office of Nuclear Reactor Regulation


==Enclosure:==
==Enclosure:==


Federal Register Notice cc w/encl: Mr. Mano Nazar President and Chief Nuclear Officer Nuclear Division NextEra Energy P.O. Box 14000 Juno Beach, FL 33408-0420 cc w/o encl: ListServ Sincerely, /RAJ William M. Dean, Director Office of Nuclear Reactor Regulation DISTRIBUTION:
Federal Register Notice cc w/encl:
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Mr. Mano Nazar President and Chief Nuclear Officer Nuclear Division NextEra Energy P.O. Box 14000 Juno Beach, FL 33408-0420 cc w/o encl: ListServ DISTRIBUTION: OED0-15-00026 PUBLIC                     RidsOcaMailCenter       RidsNrrDorlLpl2-2            LRonewicz, NRR            LPL2-2 R/F RidsNrrLABClayton         RidsNrrPMStLucie       DGalvin, NRR                RidsNrrOd          RidsRgn2MailCenter RidsNrrMailCenter         RWilliams, Rll         RidsOpaMail                  TMensah, NRR              RidsNrrDorl RidsNrrDpr                 MBanic, NRR             AChereskin, NRR             JRivera-Ortiz, Rll        SWalker, Rll RCarpenter, OE            JDavis, NRR             LSuggs, Rll                 GKulesa, NRR               RidsEdoMailCenter ADAMS A ccess1on Nos.: PKG ML15013A103            LTR ML15205A313             FRN ML15205A296
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Latest revision as of 11:18, 5 February 2020

OEDO-15-00026 - St. Lucie Plant, Unit 2, Sace 2.206 Petition Partial Acknowledgement Letter
ML15205A313
Person / Time
Site: Saint Lucie NextEra Energy icon.png
Issue date: 09/28/2015
From: Bill Dean
Office of Nuclear Reactor Regulation
To: Curran D
Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP
Chereskin A
Shared Package
ML15013A103 List:
References
OEDO-15-00026
Download: ML15205A313 (4)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 28, 2015 Ms. Diane Curran Harmon, Curran, Spielberg, and Eisenberg, LLP 1726 M Street NW, Suite 600 Washington, DC 20036 dcurran@harmoncurran.com

Dear Ms. Curran:

This letter is in reference to the petition you submitted on behalf of the Southern Alliance for Clean Energy (SAGE) on March 10, 2014. You initially filed the petition as a request for a hearing. However, by a memorandum and order (CLl-14-11) dated December 19, 2014, the Commission referred your request to the Executive Director for Operations for disposition under Title 10 of the Code of Federal Regulations (10 CFR) Section 2.206, "Requests for Action Under this Subpart."

In your petition, you requested that the U.S. Nuclear Regulatory Commission (NRG) take action regarding the replacement steam generators at the St. Lucie Plant, Unit 2. Specifically, you requested that the NRG take enforcement action against the plant licensee Florida Power and Light Company (FPL) to revoke the NRG staff's de facto amendment of the St. Lucie, Unit 2 license regarding the replacement steam generators. The basis for your request was your assertion that the licensee incorrectly applied the 10 CFR 50.59, "Changes, Tests, and Experiments," process to replace the steam generators at St. Lucie, Unit 2.

I would like to express my appreciation to the Southern Alliance for Clean Energy for bringing these concerns to the NRG. I assigned Ms. Farideh Saba, a Senior Project Mananger in the Office of Nuclear Reactor Regulation (NRR), as your petition manager. You may direct any questions you have concerning the petition process or the status of your petition to Ms. Saba by phone at 301-415-1447 or by e-mail to Farideh.Saba@nrc.gov.

A Petition Review Board (PRB) was established to review your petition. The PRB is comprised of representatives from the following organizations within the NRG: a Chair (who is a Division Director from NRR); NRR staff from the Division of Engineering, Division of Operating Reactor Licensing, and Division of Policy and Rulemaking; Region II staff; and advisors from the Office of Enforcement and the Office of the General Counsel.

In accordance with NRG Management Directive (MD) 8.11, "Review Process for 10 CFR 2.206 Petitions," you had the opportunity to address the petition review board, either in person at NRG headquarters in Rockville, MD or by telephone conference. Ms. Farideh Saba, the petition manager, initially contacted you on January 16, 2015, and asked if you wished to address the petition review board. On February 24, 2015, you informed Ms. Saba that SAGE had decided not to request a meeting with the petition review board with regard to its 10 CFR 2.206 proceeding on St. Lucie, Unit 2.

D. Curran The petition review board met internally on March 25, April 29, and May 20, 2015, to discuss your petition with respect to the criteria for review described in MD 8.11, "Review Process for

The parts of the petition that met the criteria for rejection under MD 8.11, Criterion 2, are

( 1) concerns related to the inspection of the replacement steam generators and (2) concerns regarding the effects of the extended power uprate (EPU) on steam generator tube inservice inspection and flow-induced effects on the steam generator internals. Because these issues have already been reviewed, evaluated, and resolved by the NRC staff, they meet the criteria for rejection under MD 8.11. In the below paragraphs, we detail the NRC staff's prior resolutions of these issues.

Regarding your first concern about the inspection of replacement steam generators, NRC Region II inspectors had already reviewed several aspects ofthe replacement steam generators at St. Lucie, Unit 2 under Inspection Procedure 50001, "Steam Generator Replacement Inspection" (ADAMS Accession No. ML080350408), dated February 1, 2008. The design and planning of the replacement steam generators, removal and replacement of the original steam generators, and replacement steam generator preservice and baseline inspections, were included in the Region II inspection. This inspection also covered a review of the plant change modification packages and licensee procedures to design and replace the steam generators.

During their inspection, NRC Region II inspectors did not identify any findings of significance.

Regarding your second concern about extended power uprates and steam generator inspections, NRC staff reviewed and approved the St. LuCie,-Unit 2 extended power uprate amendment dated September 24, 2012 (ADAMS Accession No. ML12268A167). The licensee's application for the extended power uprate included evaluations of replacement steam generators and replacement steam generator supports. In its review, the NRC staff determined that the effects of the proposed extended power uprate at St. Lucie, Unit 2 do not adversely affect the structural integrity of the steam generators and their supports.

The Advisory Committee on Reactor Safeguards (ACRS) also reviewed the St. Lucie, Unit 2 extended power uprate application with respect to steam generator performance. By letter dated July 23, 2012 (ADAMS Accession No. ML12198A202), ACRS evaluated th~ licensee's root cause of steam generator tube wear indications and the licensee's action plan to address steam generator tube integrity. ACRS determined that the licensee's action plan adequately addressed the concerns about steam generator tube integrity.

The NRC staff is currently evaluating the application of the 10 CFR 50.59 process in conjunction with St. Lucie, Unit 2 steam generator replacement that appears related to SACE's petition.

Specifically, the NRC staff is further investigating whether the licensee properly applied the 10 CFR 50.59 process to changes made in the structural analysis codes as described in the updated final safety analysis report (UFSAR). As such, the petition review board determined that the part of your petition that addresses the licensee's application of the 10 CFR 50.59 process, with respect to the change in a methodology as described in the UFSAR, meets the criteria for review of a petition under 10 CFR 2.206.

D. Curran '* On August 4, 2015, the petition manager informed you of the PRB's initial recommendation and, per MD 8.11, offered you another opportunity to address the PRB, if you had additional information in support of your petition for the PRB to consider. You responded on August 5, 2015, that "SACE has no new information to add to the document already filed.* Therefore we do not seek an opportunity to address the PRB." Therefore, the PRB recommendation is final and as provided by 10 CFR 2.206, the NRC will take action on your request within a reasonable time. * * .

I have enclosed a copy of the notice that the NRC will publish in the Federal Register. MD 8.11 and NUREG/BR 0200, "Public Petition Process," can be found in ADAMS under Accession Nos.

ML041770328 and ML050900248, respectively. If you need hard copies of these documents, please contact Ms. Saba.

  • William M. Dean, Director Office of Nuclear Reactor Regulation

Enclosure:

Federal Register Notice cc w/encl:

Mr. Mano Nazar President and Chief Nuclear Officer Nuclear Division NextEra Energy P.O. Box 14000 Juno Beach, FL 33408-0420 cc w/o encl: ListServ

D. Curran On August 4, 2015, the petition manager informed you of the PRB's initial recommendation and, per MD 8.11, offered you another opportunity to address the PRB, if you had additional information in support of your petition for the PRB to consider. You responded on August 5, 2015, that "SAGE has no new information to add to the document already filed. Therefore we do not seek an opportunity to address the PRB." Therefore, the PRB recommendation is final and as provided by 10 CFR 2.206, the NRC will take action on your request within a reasonable time.

I have enclosed a copy of the notice that the NRC will publish in the Federal Register. MD 8.11 and NUREG/BR 0200, "Public Petition Process," can be found in ADAMS under Accession Nos. ML041770328 and ML050900248, respectively. If you need hard copies of these documents, please contact Ms. Saba.

Sincerely,

/RAJ William M. Dean, Director Office of Nuclear Reactor Regulation

Enclosure:

Federal Register Notice cc w/encl:

Mr. Mano Nazar President and Chief Nuclear Officer Nuclear Division NextEra Energy P.O. Box 14000 Juno Beach, FL 33408-0420 cc w/o encl: ListServ DISTRIBUTION: OED0-15-00026 PUBLIC RidsOcaMailCenter RidsNrrDorlLpl2-2 LRonewicz, NRR LPL2-2 R/F RidsNrrLABClayton RidsNrrPMStLucie DGalvin, NRR RidsNrrOd RidsRgn2MailCenter RidsNrrMailCenter RWilliams, Rll RidsOpaMail TMensah, NRR RidsNrrDorl RidsNrrDpr MBanic, NRR AChereskin, NRR JRivera-Ortiz, Rll SWalker, Rll RCarpenter, OE JDavis, NRR LSuggs, Rll GKulesa, NRR RidsEdoMailCenter ADAMS A ccess1on Nos.: PKG ML15013A103 LTR ML15205A313 FRN ML15205A296

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NAME AChereskin FSaba BClayton CHsu GKulesa LSuggs DATE 08/10/15 08/31/15 08/07/15 08/26/15 08/12/15 08/17/15 OFFICE Rll/DRP/RPB3/ Rll/DRS/EB3/IN* Rll/DRS/EB3/BC* NRR/DPRIPGCB/ NRR/DPR/PGCB/ NRRIDORL/

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NAME RWilliams JRivera-Ortiz SWalker MBanic SStuchell SHelton (TMensah for)

DATE 08/17/15 08/11/15 08/11/15 08/12/15 08/11/15 08/13/15 OFFICE NRR/DPR/PGCB/ OE* OGC* NRR/JLD/D NRR/DORL/ NRR/D PM* D NAME DBeaulieu RCarpenter EMonteith JDavis ABoland WDean DATE 08/31/15 08/14/15 08/26/15 09/11/15 09/15/15 09/28/15 OFFICIAL RECORD COPY