ML17261B218

Issuance of Amendments Adopting Technical Specifications Task Force Traveler TSTF-315-A Revision 0 (CAC Nos. MF9112 and MF9113; EPID L-2017-LLA-0171)

ML17261B218
Person / Time
Site:	McGuire, Mcguire
Issue date:	10/25/2017
From:	Michael Mahoney Plant Licensing Branch II
To:	Capps S Duke Energy Carolinas
Miller G, NRR/DORL/LPL2-1, 415-2481
References
CAC MF9112, CAC MF9113, EPID L-2017-LLA-0171
Download: ML17261B218 (16)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Steven D. Capps Vice President McGuire Nuclear Station Duke Energy Carolinas, LLC 12700 Hagers Ferry Road Huntersville, NC 28078-8985 October 25, 2017

SUBJECT:

MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 -ISSUANCE OF AMENDMENTS ADOPTING TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-315-A, REVISION 0 (CAC NOS. MF9112 AND MF9113; EPID L-2017-LLA-0171)

Dear Mr. Capps:

The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 301 to Renewed Facility Operating License No. NPF-9 and Amendment No. 280 to Renewed Facility Operating License No. NPF-17 for the McGuire Nuclear Station, Units 1 and 2, respectively.

The amendments are in response to your application dated January 11, 2017. The amendments modify Technical Specification (TS) 3.1.8, "PHYSICS TESTS Exceptions,

to allow the numbers of channels required by the Limiting Condition of Operation section of TS 3.3.1, "Reactor Trip System (ATS) Instrumentation,

to be reduced from "4" to "3" to allow one nuclear instrumentation channel to be used as an input to the reactivity computer for physics testing without placing the nuclear instrumentation channel in a tripped condition.

The changes are consistent with Technical Specifications Task Force (TSTF) Traveler TSTF-315-A, Revision 0, "Reduce plant trips due to spurious signals to the NIS [Nuclear Instrumentation System] during physics testing."

S. Capps A copy of the related Safety Evaluation is also enclosed.

Notice of Issuance will be included in the Commission's biweekly Federal Register notice. Docket Nos. 50-369 and 50-370

Enclosures:

1. Amendment No. 301 to NPF-9 2. Amendment No. 280 to NPF-17 3. Safety Evaluation cc w/enclosures:

Distribution via Listserv ?hlyJI /Jv Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY CAROLINAS.

LLC DOCKET NO. 50-369 MCGUIRE NUCLEAR STATION. UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 301 Renewed License No. NPF-9 1. The Nuclear Regulatory Commission (the Commission) has found that: A. The application for amendment to the McGuire Nuclear Station, Unit 1 (the facility), Renewed Facility Operating License No. NPF-9, filed by Duke Energy Carolinas, LLC (the licensee), dated January 11, 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 as set forth in 1 O 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 set forth in 1 O CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 1 O CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1 2. Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-9 is hereby amended to read as follows: (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 301, 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 its date of issuance and shall be implemented within 120 days of issuance.

Attachment:

Changes to Renewed License No. NPF-9 and Technical Specifications Date of Issuance:

October 25, 2017 FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY CAROLINAS.

LLC DOCKET NO. 50-370 MCGUIRE NUCLEAR STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 280 Renewed License No. NPF-17 1. The Nuclear Regulatory Commission (the Commission) has found that: A. The application for amendment to the McGuire Nuclear Station, Unit 2 (the facility), Renewed Facility Operating License No. NPF-17, filed by the Duke Energy Carolinas, LLC (the licensee), dated January 11, 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 as set forth in 1 O 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 set forth in 1 O CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 2 2. Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-17 is hereby amended to read as follows: (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 280, 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 its date of issuance and shall be implemented within 120 days of issuance.

FOR THE NUCLEAR REGULA TORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed License No. NPF-17 and Technical Specifications Date of Issuance:

October 25, 2017 ATTACHMENT MCGUIRE NUCLEAR STATION. UNITS 1 AND 2 LICENSE AMENDMENT NO. 301 RENEWED FACILITY OPERATING LICENSE NO. NPF-9 DOCKET NO. 50-369 AND LICENSE AMENDMENT NO. 280 RENEWED FACILITY OPERATING LICENSE NO. NPF-17 DOCKET NO. 50-370 Replace the following pages of the Renewed Facility Operating Licenses with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. Remove NPF-9, page 3 NPF-17, page 3 Insert NPF-9, page 3 NPF-17, page 3 Replace the following pages of the Appendix A Technical Specifications (TS) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. Remove TS 3.1.8-1 Insert TS 3.1.8-1 (4) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproducts and special nuclear materials as may be produced by the operation of McGuire Nuclear Station, Units 1 and 2, and; (6) Pursuant to the Act and 1 O CFR Parts 30 and 40, to receive, possess and process for release or transfer such byproduct material as may be produced by the Duke Training and Technology Center. C. This renewed operating 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 The licensee is authorized to operate the facility at a reactor core full steady state power level of 3469 megawatts thermal (100%). (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 301, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21(d), as revised on December 16, 2002, describes certain future activities to be completed before the period of extended operation.

Duke shall complete these activities no later than June 12, 2021, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

The Updated Final Safety Analysis Report supplement as revised on December 16, 2002, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71(e)(4), following issuance of this renewed operating license. Until that update is complete, Duke may make changes to the programs described in such supplement without prior Commission approval, provided that Duke evaluates each such change pursuant to the criteria set forth in 1 O CFR 50.59 and otherwise complies with the requirements in that section. Renewed License No. NPF-9 Amendment No. 301 (4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts, 30, 40 and 70, to possess, but not separate, such byproducts and special nuclear materials as my be produced by the operation of McGuire Nuclear Station, Units 1 and 2; and, (6) Pursuant to the Act and 10 CFR Parts 30 and 40, to receive, possess and process for release or transfer such by product material as may be produced by the Duke Training and Technology Center. C. This renewed operating 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 thereafter in effect; and is subject to the additional conditions specified or incorporated below: (1) Maximum Power Level The licensee is authorized to operate the facility at a reactor core full steady state power level of 3469 megawatts thermal (100%). (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 280, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21 (d), as revised on December 16, 2002, describes certain future activities to be completed before the period of extended operation.

Duke shall complete these activities no later than March 3, 2023, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

The Updated Final Safety Analysis Report supplement as revised on December 16, 2002, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71(e)(4), following issuance of this renewed operating license. Until that update is complete, Duke may make changes to the programs described in such supplement without prior Commission approval, provided that Duke evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59, and otherwise complies with the requirements in that section. Renewed License No. NPF-17 Amendment No. 280 PHYSICS TESTS Exceptions 3.1.8 3.1 REACTIVITY CONTROL SYSTEMS 3.1.8 PHYSICS TESTS Exceptions LCO 3.1.8 During the performance of PHYSICS TESTS, the requirements of LCO 3.1.3, "Moderator Temperature Coefficient (MTC)"; LCO 3.1.4, "Rod Group Alignment Limits"; LCO 3.1.5, "Shutdown Bank Insertion Limits"; LCO 3.1.6, "Control Bank Insertion Limits"; and LCO 3.4.2, "RCS Minimum Temperature for Criticality" may be suspended and the number of required channels for LCO 3.3.1, "RTS Instrumentation," Functions 2, 3, 6, and 16.d, may be reduced to "3" required channels, provided:

a. RCS lowest loop average temperature is 541°F; and b. SDM is within the limit specified in the COLR. APPLICABILITY:

MODE 2 during PHYSICS TESTS. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. SDM not within limit. A.1 Initiate boration to restore 15 minutes SDM to within limit. AND A.2 Suspend PHYSICS TESTS 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> exceptions.

B. THERMAL POWER not B.1 Open reactor trip breakers.

Immediately within limit. C. RCS lowest loop C. 1 Restore RCS lowest loop 15 minutes average temperature not average temperature to within limit. within limit. (continued)

McGuire Units 1 and 2 3.1.8-1 Amendment Nos. 301/280 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 301 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-9 AND AMENDMENT NO. 280 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-17 DUKE ENERGY CAROLINAS, LLC MCGUIRE NUCLEAR STATION. UNITS 1 AND 2 DOCKET NOS. 50-369 AND 50-370

1.0 INTRODUCTION

By letter to the U.S. Nuclear Regulatory Commission (NRC or Commission) dated January 11, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17025A069), Duke Energy Carolinas, LLC (Duke Energy) submitted an application to seek approval to change the technical specifications (TSs) for McGuire Nuclear Station, Units 1 and 2 (McGuire).

The amendments modify TS 3.1.8, "PHYSICS TESTS Exceptions," to allow the numbers of channels required to be operable by the limiting condition of operation (LCO) section of TS 3.3.1, "Reactor Trip System (RTS) Instrumentation,

to be reduced from "4" to "3" to allow one nuclear instrumentation channel to be used as an input to the reactivity computer for physics testing without placing the nuclear instrumentation channel in a tripped condition.

The changes are consistent with Technical Specifications Task Force (TSTF) Traveler TSTF-315-A, Revision 0, "Reduce plant trips due to spurious signals to the NIS [Nuclear Instrumentation System] during physics testing, (ADAMS Accession No. ML040620172).

The NRC approved TSTF-315-A, Revision 0, in a letter dated June 29, 1999 (ADAMS Legacy Accession No. 9907060395).

2.0 REGULATORY EVALUATION

2.1 RTS Instrumentation Description McGuire's Updated Final Safety Analysis Report, Section 7 .2.1.1.2, "Reactor Trips", states, in part: Enclosure 3 The various reactor trip circuits automatically open the reactor trip breakers whenever a condition monitored by the Reactor Protection System reaches a preset or calculated level. ... TS 3.3.1, Table 3.3.1-1 lists the RTS Instrumentation functions.

The RTS functions related to the subject license amendment request are the following:

Function 2 -Power Range Neutron Flux (Low and High) The Power Range Neutron Flux -High trip function ensures protection against a positive reactivity excursion leading to departure from nucleate boiling during power operation.

The Power Range Neutron Flux -Low trip function ensures protection against a positive reactivity excursion from low power or subcritical conditions.

Function 3 -Power Range Neutron Flux Rate (High Positive Rate) The Power Range Neutron Flux -High Positive Rate trip function ensures that protection is provided against rapid increases in neutron flux. Function 6 -Overtemperature Li T The Overtemperature Li T trip function is provided to ensure that the design departure from nucleate boiling rate is met. Function 16.d -RTS Interlocks (Power Range Neutron Flux, P-10) RTS interlocks ensure reactor trips are in the correct configuration for the given plant status. Power Range Neutron Flux, P-10 RTS interlock is actuated at approximately 10% power. 2.1 Licensee's Proposed Changes Current TS LCO 3. 1. 8, states: During the performance of PHYSICS TESTS, the requirements of LCO 3.1.3, "Moderator Temperature Coefficient (MTC)"; LCO 3.1.4, "Rod Group Alignment Limits"; LCO 3.1.5, "Shutdown Bank Insertion Limits"; LCO 3.1.6, "Control Bank Insertion Limits"; and LCO 3.4.2, "RCS [Reactor Coolant System] Minimum Temperature for Criticality" may be suspended, provided:

a. RCS lowest loop average temperature is ;;:: 541°F [degrees Fahrenheit];

and b. SOM [Shutdown Margin] is within the limits provided in the COLR [Core Operating Limits Report]. Revised TS LCO 3.1.8, would state: During the performance of PHYSICS TESTS, the requirements of LCO 3.1.3, "Moderator Temperature Coefficient (MTC)"; LCO 3.1.4, "Rod Group Alignment Limits"; LCO 3.1.5, "Shutdown Bank Insertion Limits"; LCO 3.1.6, "Control Bank Insertion Limits"; and LCO 3.4.2, "RCS Minimum Temperature for Criticality" may be suspended, and the number of required channels for LCO 3.3.1, RTS [Reactor Trip System] Instrumentation," Functions 2, 3, 6, and 16.d, may be reduced to "3" required channels, provided:

a. RCS lowest loop average temperature is 541°F; and b. SOM is within the limits provided in the COLR. 2.3 Applicable Regulations and Guidance As described in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(c)(2)(i), "Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility." The amendments adopt previously NRG-approved TSTF-315-A, Revision 0 to bring McGuire's TSs into alignment with NUREG-1431, Revision 4, "Standard Technical Specifications

-Westinghouse Plants: Specifications" (Volume 1 ), which contains the improved Standard Technical Specifications (STS) for Westinghouse plants. 3.0 TECHNICAL EVALUATION 3.1 NRC Staff's Technical Evaluation of Licensee's Proposed Changes The NRC staff compared the licensee's proposed changes against NRG-approved TSTF-315-A, Revision 0, and NUREG-1431, Revision 4, "Standard Technical Specifications

-Westinghouse Plants: Specifications" (Volume 1 ). TSTF-315-A, Revision 0, revised STS 3.1.10, "PHYSICS TESTS Exceptions

-MODE 2," to allow the number of channels to be operable of Functions 2, 3, 6, and 18.e required by LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation," to be reduced from "4" to "3" to allow one nuclear instrumentation channel to be used as an input to the reactivity computer for physics testing without placing the affected nuclear instrumentation channel in a tripped condition. The following provides a description for the associated functions:

STS LCO 3.3.1 RTS Equivalent McGuire STS RTS Function Title Function No. LCO 3.3.1 RTS Function No. 2 2 Power Range Neutron Flux -HiQh, and -Low 3 3 Power Range Neutron Flux Rate High Positive Rate 6 6 Overtemperature

/':.. T 18.e 16.d RTS Interlocks Power Range Neutron Flux, P-10 McGuire TS 3.1.8, "PHYSICS TESTS Exceptions," is equivalent to TS 3.1.10 from the STS markup included in TSTF-315-A, Revision 0. TSTF-315-A, Revision 0, which is based on NUREG-1431 Revision 1, identifies that a physics test exception is applicable to LCO 3.3.1 Functions 2, 3, 6, and 18.e. In NUREG-1431, Function 18.e of TS 3.3.1Table3.3.1-1, "Reactor Trip System Instrumentation," pertains to "Power Range Neutron Flux, P-1 O." Function 16.d is the corresponding function in TS Table 3.3.1-1 of the McGuire TSs. Therefore, the McGuire TSs are modified to apply to LCO 3.3.1 Functions 2, 3, 6, and 16.d. Reducing the required number of the operable channels from "4" channels to "3" channels creates a two-out-of-three logic (from an one-out-of-three) for trip Functions 2, 3, 6, and 16.d. The change in TS LCO 3.1.8 does not change the TS LCO 3.3.1 requirement for "4" operable channels for Functions 2, 3, 6, and 16.d in MODE 2 when not conducting physics tests. The NRC staff has reviewed the licensee's proposed changes to TS 3.1.8 and concludes that reducing the number of required channels to be operable for LCO 3.3.1 Functions 2, 3, 6, and 16.d from "4" to "3" is adequate because the "3" required channels of Functions 2, 3, 6, and 16.d will continue to provide adequate reactor protection should anticipated operational occurrences occur. The NRC staff concludes that the requirements of 10 CFR 50.36(c)(2) continue to be met because the minimum performance level of equipment needed for safe operation of the facility is contained in the LCO. Based on the above, the NRC staff concludes that this change, consistent with guidance in TSTF-315-A, Revision 0 and NUREG-1431, Revision 4, is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the NRC staff notified the North Carolina State official of the proposed issuance of the amendments on September 18, 2017. The State official confirmed on September 22, 2017, that the State of North Carolina had no comments.

5.0 PUBLIC COMMENTS On May 23, 2017, the NRC staff published a "Notice of Consideration of Issuance of Amendments to Facility Operating Licenses, Proposed No Significant Hazards Consideration Determination, and Opportunity for a Hearing," in the Federal Register associated with the proposed amendment request (82 FR 23619). In accordance with the requirements in 10 CFR 50.91, the notice provided a 30-day period for public comment on the proposed no significant hazards consideration determination.

One comment from a member of the public was received, however it was not related to the no significant hazards consideration determination nor the LAR. The comment can be found at www.regulations.gov, reference NRC-2017-0120-0002.

6.0 ENVIRONMENTAL CONSIDERATION The amendments change a requirement with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20. 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 this finding (82 FR 23621: May 23, 2017). 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.

7.0 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 amendments will not be inimical to the common defense and security or to the health and safety of the public. Principal Contributor:

A. Smith, NRR Date of issuance:

October 25, 2017 S. Capps

SUBJECT:

MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 -ISSUANCE OF AMENDMENTS ADOPTING TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-315-A, REVISION 0 (CAC NOS. MF9112 AND MF9113; EPID L-2017-LLA-0171)

DATED OCTOBER 25, 2017 DISTRIBUTION:

PUBLIC RidsACRS_MailCTR Resource RidsNrrLpl2-1 Resource LPL2-1 R/F RidsNrrDssStsb Resource RidsNrrDeEicb Resource RidsNrrPMMcGuire Resource RidsRgn2MailCenter Resource ASmith, NRR RidsNrrLALKGoldstein Resource ADAMS Accession No. ML172618218

• b memorandum OFFICE DORL/LPL2-1/PM DORL/LPL2-1/LA DSS/STSB/BC*

DE/EICB/BC NAME MMahoney DA TE 9/22/17 OFFICE OGC -NLO NAME DRoth DATE 10/19/17 KGoldstein (SRohrer for) 9/20/17 JWhitman 6/6/17 DORL/LPL2-1

/BC DORL/LPL2-1

/PM MMarkley MMahoney 10/25/17 10/25/17 OFFICIAL RECORD COPY MWaters 9/25/17