IR 05000454/2020002

Integrated Inspection Report 05000454/2020002 and 05000455/2020002

ML20209A595
Person / Time
Site:	Byron
Issue date:	07/27/2020
From:	Hironori Peterson Region 3 Branch 3
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2020002
Download: ML20209A595 (15)

Text

July 27, 2020

SUBJECT:

BYRON STATION - INTEGRATED INSPECTION REPORT 05000454/2020002 AND 05000455/2020002

Dear Mr. Hanson:

On June 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Byron Station. On July 15, 2020, the NRC inspectors discussed the results of this inspection with Mr. M. Kanavos and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Byron Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Byron Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Hironori Peterson, Chief Branch 3 Division of Reactor Projects Docket Nos. 05000454 and 05000455 License Nos. NPF-37 and NPF-66

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000454 and 05000455 License Numbers: NPF-37 and NPF-66 Report Numbers: 05000454/2020002 and 05000455/2020002 Enterprise Identifier: I-2020-002-0024 Licensee: Exelon Generation Company, LLC Facility: Byron Station Location: Byron, IL Inspection Dates: April 01, 2020 to June 30, 2020 Inspectors: D. Betancourt-Roldan, Senior Resident Inspector C. Hunt, Resident Inspector D. Szwarc, Senior Reactor Inspector C. Thompson, Illinois Emergency Management Agency Approved By: Hironori Peterson, Chief Branch 3 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Byron Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Incorrect Valve Manipulation During Component Cooling Pump ASME Surveillance Testing Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.2] - Field 71111.22 Systems NCV 05000455/2020002-01 Presence Open/Closed A finding of very low safety significance (Green) and associated non-cited violation of Title 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, Drawings," was self-revealed for the licensee's failure to perform activities affecting quality in accordance with an approved procedure appropriate for the circumstance. Specifically, while performing 1BOSR 5.5.8.CC.5-1C, "Unit One Comprehensive Inservice Testing (IST) Surveillance Requirements For Component Cooling Pump 1CC01PA," equipment operators incorrectly manipulated 2CC9507B, vice 1CC9507B, causing an unplanned 7-day limiting condition for operation (LCO) entry for one component cooling water flow path inoperable.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 began the inspection period operating at full power. With the exception of minor reductions in power to support scheduled testing activities, or load changes requested by the transmission dispatcher, the unit remained at or near full power for the entire inspection period.

Unit 2 began the inspection period operating at full power. With the exception of minor reductions in power to support scheduled testing activities or load changes requested by the transmission dispatcher, the unit remained at or near full power for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of extreme high temperatures on May 29, 2020

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on April 17, 2020

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) 1B essential service water (SX) train during a planned 1A essential service water pump work window on May, 5, 2020

(2) 2A emergency diesel generator (EDG) during a planned 2B SX work window on May, 13, 2020

(3) 2A EDG walkdown with during a planned 2B EDG work window on June 16, 2020

(4) 1A auxiliary feedwater (AFW) pump during planned 1B AFW pump work window on June 23, 2020

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Fire Zone 11.1B-0; auxiliary building 330'-0" elevation, Unit 2 SX pump room on April 16, 2020

(2) Removal of fire hoses per engineering change 626870 on April 16, 2020

71111.07A - Heat Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) 1B AFW pump oil cooler 1AF01AB on April 6, 2020

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the Control Room during dilution using the new Westinghouse Ovation' system on April 21; a briefing for manipulation of the reactor containment fan cooler on June 9; and the briefing and performance of multiple surveillance tests on June 25, 2020

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a licensed operator requalification training examination on May 5, 2020

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (3 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Fuel pool cooling and cleanup system on April 3, 2020

(2) Maintenance Rule a(3) assessment on April 17, 2020

(3) Unit 1 AFW system on April 24, 2020

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) Commercial grade dedication of Detroit Diesel Corp. valve bridge P/N 5104243 on April 3, 2020

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed;

(1) Protected equipment walkdown and review of risk management actions associated with the planned 2A EDG work window on April 27, 2020

(2) Protected equipment walkdown and review of risk management actions associated with the work week beginning May 11, 2020

(3) Protected equipment walkdown and risk review during the planned 2B EDG outage on June 15, 2020

(4) Inoperability of the 1B AFW pump due to a jacket water cooling hose leak on June 26, 2020

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) 1SXE5A-3" pipe ultrasonic testing (UT) below Tmin as documented in AR 04326499 on April 3, 2020

(2) Leak on AFW pump recirculation piping return to essential service water piping as documented in AR 04333276 on April 7, 2020

(3) Unit 2 TSLB-4 light 14.4 flashing as documented in AR 04337028 on April 29, 2020

(4) Gas void detected in 1SI06BA-24" near 1SI8811A as documented in AR 04342984 on May 19, 2020

(5) AOV 2A residual heat removal (RHR) heat exchanger 2RH02AA outlet valve (EOP VLV) as documented in AR 04347238 on May 31, 2020

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:

(1) Westinghouse Ovation' system following installation

(2) The 2A EDG post-maintenance testing following maintenance on May 1, 2020

(3) The 2A SX pump following maintenance on June 5, 2020

(4) 2B EDG post-maintenance testing following maintenance window on June 19, 2020

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) 0BOSR FC-1, Unit 0/1/2 Performance Evaluation of Fuel Pool Clean Up pumps surveillance on May 27, 2020

Inservice Testing (IP Section 03.01) (2 Samples)

(1) 2BOSR 5.5.8.SI.5-2a, Group A inservice testing (IST) requirements for safety injection pump 2SI01PB, Revision 3, on April 16, 2020

(2) 1BOSR 5.5.8.CC.5-1c, 1A component cooling pump comprehensive run on May 4,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) ===

(1) Unit 1 (April 1, 2019 - March 31, 2020)

(2) Unit 2 (April 1, 2019 - March 31, 2020)

MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)

(1) Unit 1 (April 1, 2019 - March 31, 2020)

(2) Unit 2 (April 1, 2019 - March 31, 2020)

MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)

(1) Unit 1 (April 1, 2019 - March 31, 2020)

(2) Unit 2 (April 1, 2019 - March 31, 2020)

71152 - Problem Identification and Resolution

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed the licensees corrective action program for incorrect wiring issues during electrical maintenance that might be indicative of a more significant safety issue during the week of June 26,

INSPECTION RESULTS

Incorrect Valve Manipulation During Component Cooling Pump ASME Surveillance Testing Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.2] - Field 71111.22 Systems NCV 05000455/2020002-01 Presence Open/Closed A finding of very low safety significance (Green) and associated non-cited violation of Title 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, Drawings," was self-revealed for the licensee's failure to perform activities affecting quality in accordance with an approved procedure appropriate for the circumstance. Specifically, while performing 1BOSR 5.5.8.CC.5-1C, "Unit One Comprehensive Inservice Testing (IST) Surveillance Requirements For Component Cooling Pump 1CC01PA," equipment operators incorrectly manipulated 2CC9507B, vice 1CC9507B, causing an unplanned 7-day limiting condition for operation (LCO) entry for one component cooling water flow path inoperable.

Description:

On May 4, 2020, during the performance of 1BOSR 5.5.8.CC.5-1C for the Unit 1 1A component cooling water pump, equipment operators incorrectly performed step F.2.d.5 which directs operators to verify or throttle close the 1B residual heat removal (RHR) heat exchanger outlet butterfly valve, 1CC9507B. Instead, equipment operators throttled close on 2CC9507B, which is the outlet butterfly valve on the opposite unit for the 2B RHR heat exchanger.

The purpose of throttling close on 1CC9507B, per 1BOSR 5.5.8.CC.5-1C, reduces the pressure and flow perturbations on the component cooling system when cooling flow is initiated to the 1B RHR heat exchanger. The procedure then has equipment operators reopen 1CC9507B to attain the desired flow rate for the surveillance test. The incorrect valve manipulation caused several unexpected main control room alarms while performing subsequent steps of the procedure and prompted control room operators to contact the equipment operators in the field. Once it was determined that the incorrect valve had been manipulated, equipment operators restored 2CC9507B to its correct position and positioned 1CC9507B to its required position, per procedure, and the alarms in the main control room cleared. The licensee determined that Unit 2 had an unplanned entry into technical specification LCO 3.7.7, Condition A, for the duration that 2CC9507B was out of normal position.

Corrective Actions: The licensee took immediate corrective action to restore the Unit 2 component cooling system to its normal lineup. The licensee captured this event under AR04340951 in their corrective action program. The licensee also performed a Corrective Action Program Evaluation under AR04341834 highlighting this event.

Corrective Action References:

AR04340951, 1BOSR 5.5.8.CC.5-1C Component Cooling Mispositioning Event AR04341834, Trend in HU Fundamental Usage in Operations

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensee's failure to perform surveillance testing in accordance with a quality procedure was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, equipment operators incorrectly throttled close on 2CC9507B, vice 1CC9507B, negatively impacting the availability and capability of the 2B RHR heat exchanger.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors screened the finding against the Mitigating Systems screening questions in Exhibit 2 and answered "NO" to all six screening questions. Therefore, the finding screened to very low safety significance (Green).

Cross-Cutting Aspect: H.2 - Field Presence: Leaders are commonly seen in the work areas of the plant observing, coaching, and reinforcing standards and expectations. Deviations from standards and expectations are corrected promptly. Senior managers ensure supervisory and management oversight of work activities, including contractors and supplemental personnel. Specifically, licensee supervision failed to ensure that equipment operators applied adequate peer checks and other human performance tools during the surveillance test designed to prevent operators from incorrectly manipulating a valve on the opposite unit that was not part of the test.

Enforcement:

Violation: Title 10 CFR 50 Appendix B, Part V, "Instructions, Procedures, Drawings," states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Contrary to the above, on May 4, 2020, while performing an activity affecting quality, equipment operators did not accomplished a surveillance in accordance with the procedure and incorrectly performed a step in surveillance procedure 1BOSR 5.5.8.CC.5-1C and operated the wrong valve. Specifically, equipment operators throttled close on 2CC9507B, vice 1CC9507B, resulting in an unplanned entry into technical specification LCO 3.7.7, Condition A, and adversely affecting the availability and capability of the 2B RHR heat exchanger.

Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Observation: Numerous Wiring Errors Occurring During Maintenance 71152 Inspectors performed a semiannual review to identify trends that might indicate the existence of a more significant safety issue. For their review, the inspectors focused on issues, particularly those entered in to the licensee Corrective Action Program (CAP), associated with incorrectly performed electrical wiring.

From January 2020 to June 2020, inspectors identified multiple instances of wiring errors discovered by the licensee during maintenance or post maintenance testing. Most notably:

• AR 04328475 documents a wiring error that caused the starter motor on the 1B auxiliary feedwater pump to inadvertently energize, which caused the auxiliary feedwater pump diesel engine to begin cranking unexpectedly.

• AR 04328368 documents the over thrusting of 1AF017A during as left diagnostic testing due to wires being terminated incorrectly.

• AR 04328203 documents the 1C turbine driven feedwater pump turbine trip button being wired incorrectly during work associated with the Westinghouse Ovation' modification installed during the B1R23 outage.

• AR 04328169 documents a field cable being landed at the wrong terminal for the 1C turbine driven feedwater pump speed control cabinet during work associated with the Westinghouse Ovation' modification installed during the B1R23 outage.

• AR 04329513 documents an event where a technician inadvertently landed the tip of a meter lead to a cabinet during troubleshooting which led to a fault to ground while performing voltage measurements.

• AR 04342063 documents the closing out of a work order without re-terminating the leads for the equipment.

The inspectors noted that four of the cases above involved site electrical or instrument maintenance technicians not using prescribed human performance tools or maintenance practices designed to prevent these types of errors. As such, the issues were avoidable, resulted in an unplanned expenditure of licensee resources, and placed an undue strain on the organization particularly as it worked to exit the B1R23 outage.

Through the CAP, the licensee documented a trend concerning numerous wiring errors in AR 04335360, in addition to those identified above, associated with the Westinghouse Ovation' modification work performed by the onsite contractor during the B1R23 outage.

The licensee also documented a Fleet Assessment identified Focus Area in AR 04341779 associated with site electrical and instrument maintenance technicians demonstrating lapses in technical maintenance fundamental behaviors. Additionally, the licensee developed a maintenance and work control human performance intervention plan under AR 04336130 to address the issues highlighted above.

The wiring errors identified by the inspectors during their review were discovered by the licensee during the maintenance process and prior to the equipment being fully returned to service. The inspectors determined that the licensee identified the adverse trend in electrical wiring at an appropriate threshold per their CAP and that the licensee took appropriate actions, commensurate with safety, for each of the issues documented.

The inspectors did not identify any findings or violations during their review.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On July 15, 2020, the inspectors presented the integrated inspection results to Mr. M. Kanavos, Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Procedures EN-AA-402-0005 Extreme Heat Implementation Revision 3

EN-BY-402-0005 Extreme Heat Implementation Revision 6

OP-AA-10-107- Interface Between COMED/PEPCO and Exelon for Revision 12

1002 Transmission Ops

OP-AA-108-111- Severe Weather and National Disaster Guidelines Revision 20

10001

71111.04 Procedures BOP AF-M1A Auxiliary Feedwater System Train A Valve Lineup Revision 7

BOP DG-E2A Unit 2 Diesel Generator Train A Electrical Lineup Revision 3

BOP DG-M2A Train A Diesel Generator System Valve Lineup Revision 10

BOP SX-M1B Train B Essential Service Water System Valve Lineup Revision 14

71111.05 Engineering 626870 GL 86-10 Evaluation - Removal of Occupant Use Fire Hose Revision 0

Changes at Interior Hose Stations

Fire Plans PFP #97 FZ 11.1B-0, Auxiliary Building 330'-0" Elevation, Unit 2 Revision 2

Essential Service Water Pump Room

71111.07A Procedures ER-AA-340-1002 Service Water Heat Exchanger Inspection Guide Revision 9

Work Orders 04618348-01 LR-1AF01AB-HX Inspection per Generic Letter 89-13 09/16/2018

04834792-01 LR-1AF01AB-HX Inspection per Generic Letter 89-13 01/15/2020

71111.12 Corrective Action 04243213 2BOA SEC-7 Entered for Elevated AF Piping 04/21/2020

Documents 04324184 1B AF Full Flow Test 03/05/2020

04332881 1B AF Pump Oil Cooler SX Leakage Increased 04/05/2020

04333091 1AF01PA - Small Oil Leak during Aux Lube Oil Pump Run 04/06/2020

043339840 During 0BOSR FC-1, 1FC01P dP Below Acceptance Criteria 04/07/2020

04339731 Need Engineering Evaluation for Unit 2 FC Pump Availability 04/30/2020

04343085 Revise 0BOSR FC-1 05/13/2020

04344116 ROB Guarding Switches on 1B AF Panel Broken 05/18/2020

Engineering EXL 00246282 Eval 246282 was Prepared to Provide the Safety Basis and 03/19/2020

Evaluations Commercial Grade Dedication Requirements for Detroit

Diesel Corp. Valve Bridge P/N 5104243

Miscellaneous Maintenance Rule a(3) Assessment Report July 2019 - Jan 03/31/2020

20

Procedures ER-AA-310-1004 Maintenance Rule Performance Monitoring Revision 14

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.13 Procedures 2BOL 8.1 LCOAR AC Sources - Operating Tech Spec LCO #3.8.1 Revision 25

OP-AA-108-112 Plant Status and Configuration Revision 11

WC-AA-101 Online Work Control Process Revision 29

71111.15 Corrective Action 04347238 2RH606 Failed Closed 06/01/2020

Documents 04349284 Gas Void Detected in 1SI06BA-24" Near 1SI8811A 05/13/2020

Drawings 6E-2-4031RC17 Loop S/D Reactor Coolant System Wide Range Pressure 06/17/1997

(2PT-0403) Prot. Cab. 4 (2PA04J)

Engineering 379408 Past Operability Evaluation of Gas Void at 1SI8811A Revision 0

Changes

71111.19 Work Orders 4817517 2A DG Load Rejection and Overspeed Test 05/02/2020

4817616 2A DG Relay Operation Verification 05/03/2020

5030791 2A DG Operability Surveillance 05/02/2020

71111.22 Corrective Action 04339840 During 0BOSRr FC-1, 1FC01 dP Below Acceptance Criteria 04/30/2020

Documents 04340951 1BOSR 5.5.8.CC.5-1C Component Cooling Mispositioning 05/04/2020

Event

Engineering BB-PRA-005.05 Byron and Braidwood Probabilistic Risk Assessment Revision 6

Evaluations

Procedures 0BOSR FC-1 Performance Evaluation of Fuel Pool Cooling and Cleanup Revision 2

(FC) Pumps

1BOSR Comprehensive Inservice Testing (IST) Surveillance Revision 8

5.5.8.CC.5-1c Requirements for Component Cooling Pump 1CC01PA

BY-MSPI-001 Reactor Oversight Program MSPI Basis Document Byron Revision 20

Nuclear Generating Station

Work Orders 5005995 Performance Evaluation of Fuel Pool Cooling 04/30/2020

71151 Miscellaneous Review of Logs for Unavailability Time from April 1, 2019 -

March 21, 2020

BY-MSPI-001 Reactor Oversight Program MSPI Basis Document 06/29/2017

2