IR 05000275/2017007
| ML18025A000 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 01/24/2018 |
| From: | Haire M S NRC/RGN-IV/DRP/RPB-A |
| To: | Welsch J M Pacific Gas & Electric Co |
| Haire M S | |
| References | |
| IR 2017007 | |
| Download: ML18025A000 (18) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 E. LAMAR BLVD
. ARLINGTON, TX 76011
-4511 January 24, 2018 Mr. James M. Welsch, Vice President, Nuclear Generation and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Power Plant P.O. Box 56, Mail Code 104/6 Avila Beach, CA 93424
SUBJECT: DIABLO CANYON POWER PLANT, UNITS 1 AND 2
- INSPECTION OF THE IMPLEMENTATION OF MITIGATION STRATEGIES AND SPENT FUEL POOL INSTRUMENTATION ORDERS AND EMERGENCY PREPAREDNESS COMMUNICATION/STAFFING/ MULTI
-UNIT DOSE ASSESSMENT PLANS
- INSPECTION REPORT (05000275/2017007 AND 05000323/2017007
)
Dear Mr. Welsch:
On December 27
, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Diablo Canyon Power Plant, Units 1 and 2.
On December 27, 2017 , t he NRC inspectors discussed the results of this inspection with Mr. C. Murry , Acting Station Director, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report. The inspection examined activities conducted under your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and Emergency Preparedness Communication, Staffing, and Multi-Unit Dose Assessment Plans, your compliance with the Commission's rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station personnel.
Based on the results of this inspection, no findings of significance were identified.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding,"
a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading
-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/ Mark S. Haire
, Chief, Project Branch A Division of Reactor Projects Docket Nos. 50-275 and 50
-323 License Nos. DPR-80 and DPR-82
Enclosure:
Inspection Report 05000 275/201700 7 and 5000323/2017007 w/
Attachment:
Supplemental Information cc w/encl: Electronic Distribution
Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 50-275 and 50
-82 Report: 05000275/2017007 and 05000323/2017007 Licensee: Pacific Gas and Electric Company Facility: Diablo Canyon Power Plant, Units 1 and 2 Location: P.O. Box 56, Mail Code 104/6 Avila Beach, CA 93424 Dates: November 13 through December 27, 2017 Inspectors:
J. Mateychick
, Senior Reactor Inspector (Team Leader) C. Newport, Senior Resident Inspector R. Alexander, Senior Project Engineer E. Uribe, Project Engineer Approved By: Mark S. Haire Chief, Project Branch A Division of Reactor Projects 2
SUMMARY
- 11/13/2017 - 12/27/2017
- Diablo Canyon Power Plant, Units 1 and 2
- Temporary Instruction 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans , issued December 23, 2015. The inspection covered a one week inspection onsite by three inspectors from the Region IV office and one of the assigned resident inspectors.
No findings of significance were identified.
The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 5.
A. NRC-Identified and Self-Revealing Findings
None
B. Licensee-Identified Violations
None 3
REPORT DETAILS
4. Other Activities
4OA5 Other Activities
(TI 2515/191) The objective of Temporary Instruction (TI) 2015/191 "Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi
-Unit Dose Assessment Plans" is to verify that licensees have adequately implemented the mitigation strategies as described in the licensee's Final Integrated Plan (ADAMS Accession No. ML16221A390
) and the NRC's plant safety evaluation (ADAMS Accession No. ML16349A386
) and to verify that the licensee installed reliable water-level measurement instrumentation in their spent fuel pools. The purpose of this TI is also to verify the licensees have implemented Emergency Preparedness (EP) enhancements as described in their site
-specific submittals and NRC safety assessments, including multi-unit dose assessment capability and enhancements t o ensure that staffing is sufficient and communications can be maintained during such an event. The inspection verifies that plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond- Design-Basis External Events (ADAMS Accession No. ML12229A174)and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation (ADAMS Accession No. ML12056A044)are in place and are being implemented by the licensee. Additionally, the inspection verifies implementation of staffing and communications information provided in response to the March 12, 2012 , request for information letter and multiunit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 (ADAMS Accession No. ML12339A262).
The team discussed the plans and strategies with plant staff, reviewed documentation, and where appropriate, performed plant walkdowns to verify that the strategies could be implemented as stated in the licensee's submittals and the NRC staff prepared safety evaluation.
For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged. Specific details of the team's inspection activities are described in the following sections. 1. Mitigation Strategies for Beyond-Design-Basis External Events
a. Inspection Scope
The team examined the licensee's established guidelines and implementing procedures for the beyond-design-basis mitigation strategies.
The team assessed how the licensee coordinated and documented the interface/transition between existing off-normal and Emergency Operating Procedures with the newly developed mitigation strategies.
The team selected a number of mitigation strategies , conducted plant walkdowns with licensed operators and responsible plant staff , to assess the adequacy and completeness of the procedures; familiarity of operators with the procedure objectives and specific guidance; staging and compatibility of equipment ,
and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios.
The team verified that a preventive maintenance program had been established for the FLEX portable equipment and that periodic equipment inventories were in place and being conducted.
Additionally, the team examined the introductory and planned periodic/refresher training provided to the Operations and Fire Protection staffs most likely to be tasked with implementation of the FLEX mitigation strategies.
The team also reviewed the introductory and planned periodic training provided to the Emergency Response Organization personnel.
Documents reviewed are listed in the attachment.
b. Assessment Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA-12-049. The inspectors verified that the licensee satisfactorily:
Developed and issued FLEX Support Guidelines (FSG s) to implement the FLEX strategies for postulated external events; Integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs are clear when using existing plant procedures; Protected FLEX equipment from site-specific hazards; Developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability; Trained their staff to assure personnel proficiency in the mitigation of beyond-design-basis events; and Developed means to ensure that the necessary off-site FLEX equipment will be available from off-site locations.
The inspectors verified that non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.
c. Findings
No findings identified.
2. Spent Fuel Pool (SFP) Instrumentation
a. Inspection Scope
The team examined the licensee's newly installed spent fuel pool instrumentation. Specifically, the inspectors verified the sensors were installed as described in the plant specific submittals and the associated safety evaluation and that the cabling for the power supplies and the indications for each channel are physically and electrically separated.
Additionally, environmental conditions and accessibility of the instruments were evaluated.
Documents reviewed are listed in the attachment.
b. Assessment Based on samples selected for review, the inspectors determined that the licensee satisfactorily installed and established control of the spent fuel pool instrumentation as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA-12-051. The inspectors verified that the licensee satisfactorily:
Installed the SFP instrumentation sensors, cabling , and power supplies to provide physical and electrical separation as described in the plant specific submittal and safety evaluation; Installed the SFP instrumentation display in the location, environmental conditions
, and accessibility as described in the plant specific submittals; and Trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation.
The inspectors verified that non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.
c. Findings
No findings identified.
3. Staffing and Communication Request for Information
a. Inspection Scope
Through discussions with plant staff, review of documentation
, and plant walkdowns the team verified that the licensee has implemented required changes to staffing, communications equipment , and facilities to support an Extended Loss of All AC Power (ELAP) scenario as described in the licensee's staffing assessment and the NRC safety assessment.
The team also verified that the licensee has implemented dose assessment (including releases from spent fuel pools) capability using the licensee's site-specific dose assessment software and approach as described in the licensee's dose assessment submittal.
Documents reviewed are listed in the attachment.
b. Assessment The inspectors reviewed information provided in the licensee's multi-unit dose submittal and in response to the NRC's March 12, 2012, request for information letter and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all ac power to the site and impedes access to the site. The inspectors verified the following:
Licensee satisfactorily implemented required staffing change(s)to support an ELAP scenario; Emergency preparedness communications equipment and facilities are sufficient for dealing with an ELAP scenario; and Implemented dose assessment capabilities (including releases from spent fuel pools) using the licensee's site-specific dose assessment software and approach. The inspectors verified that non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.
c. Findings
No findings identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On November 16
, 2017, the inspectors presented the on-site inspection results in a management debrief to Mr. H. Hamzehee, Manager Regulatory Services
, and other members of the site staff. The inspectors completed an exit meeting with Mr. C. Murry , Acting Station Director, and other members of the site staff, via telephone on December 27
, 201 7 , who acknowledged the final results of the inspection.
The inspectors confirmed that proprietary information was not provided or examined during the inspection.
=SUPPLEMENTAL
INFORMATION=
KEY POINTS OF CONTACT
Licensee Personnel
- B. Ashbrook, Security and Emergency Services Manager
- M. Baker, Engineering Supervisor
- T. Baldwin, Business Initiatives Chief
- R. B aradar an, Acting Manager, Regulatory Services
- J. Brancheau, Operations Shift Forman
- K. Bych, Manager, Engineering
- A. Chitwood, Operations
Shift Manager
- W. Conklin, FLEX Engineer
- D. Esminger, Chief, Fire Department
- M. Frauenheim, Process Improvement Manager
- S. Guess, Manager, Operations
- H. Hamzehee, Manager, Regulatory Services
- J. Harker, Manager, Maintenance and Technical Training
- S. Kirvin, Manager, Security
- S. Leke, Nuclear Operator
- D. Madson, Acting Compliance Supervisor
- S. Maze, Fukushima Program Supervisor
- M. McCoy, NRC Interface, Regulatory Services
- J. Morris, Regulatory Services Supervisor
- C. Murry, Acting Station Director
- A. Peck, Engineering Director
- D. Phillips, Security Operations Support
- G. Reed, Beyond Design Basis Project Manager
- B. Simpson, Manager, Operations Training
- A. Sorensen, Regulatory Services Engineer
- D. Spaulding, Strategic Projects Contractor
- D. Ven tr es ca, Security Operations supervisor
- R. Waltos, Assistant engineering Director
- A. Warwick, Supervisor, Emergency Planning
- T. Wernet, Assistant Chief, Fire Department
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Closed
- 2515/191 TI Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/ Multi-Unit Dose Assessment Plans
LIST OF DOCUMENTS REVIEWED
Calculations
- Number Title Revision
- STA-294 Fukushima Emergency Pump Sizing
Drawings
- Number Title Revision 8920 Model 500F Globe Valve Union Bonnet
- AA 347139 Emergency Operations Facility
- 900004146, Sheet
- FSG 99 Posting
- OP1.DC23 Control
- 6/29/2016
- 900004146, Sheet
- FSG 99 Posting
- OP1.DC23 Control
- 6/29/2016
Miscellaneous Documents
- Strategy S
-9, Communications Strategy
- DN 50813278
- FLEX PMCR: EAFW Pumps
- 10/21/2015
- EDT 4*1278
- 68038941) 7/24/2015 PG&E Letter
- DCL-15-117 Response to March 12, 2012,
- NRC 10 CFR
- 50.54(f) Request for Information Regarding Recommendation 9.3, Resubmittal of Phase 2 Staffing Assessment
- 10/28/2015
- PG&E Letter DCL
-16-003 Pacific Gas and Electric Company's Notification of Full Compliance with Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond
-Design-Basis External Events (Order Number
- EA-12-049) for Diablo Canyon Power Plant Unit 1
- 01/05/2016
- PG&E Letter DCL
-16-077 Pacific Gas and Electric Company's Notification of
- Full Compliance with Commission Order Modifying Licenses with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (Order Number
- EA-12-049) for Diablo Canyon Power Plant Units 1 and 2
- 7/28/2016
Miscellaneous Documents
- Number Title Revision
- Implementation Guide
- NRC Letter ML16349A386
- Diablo Canyon Power Plant, Unit Nos. 1 and 2
- Safety Evaluation Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA
-12-049 and EA
-12-051 (CAC Nos. MF0958, MF0959, MF0963, and
- MF0964) 12/28/2016
- Diablo Canyon Power Plant Beyond Design Basis Validation of the FLEX Time Sensitive Actions Units 1
and 2 4
- Diablo Canyon Power Plant Emergency Plan
- Section 5, Organizational Control of Emergencies
- 4.18
- FLEX Maintenance Plan Frequency Spreadsheet
{None}
- FLEX Equipment Status Board (per
- FS1.ID4), various dates 6/02/2016 10/05/2017
- 10/16/2017
- 10/19/2017
- 11/14/2017
- MIDAS Demonstration Report: Combined Accident Runs (DRILL)
- 11/16/2017
- SAFER Response Plan for Diablo Canyon Power Plant Operation and Maintenance Manual
- STARS Alliance PG&E Fukushima
- 150kW
- Operation and Maintenance Manual
- STARS Alliance PG&E Fukushima
- 275kW
- SIMPLEX Infinity 200kW Portable Load Bank
- EATON Doub le-Throw Safety Switch Spent Fuel Pool Instrumentation System Westinghouse Standard Product Technical Manual Spent Fuel Pool Instrumentation System Configuration
- Unit 1
- Installation Instructions for Westinghouse Spent Fuel Pool Instrumentation System Equipment Mounting & Termination Installation Instructions for Westinghouse Spent Fuel Pool Instrumentation System Power
-Up & Acceptance
Miscellaneous Documents
- Number Title Revision Testing
- Spent Fuel Pool Instrumentation System Westinghouse Torque Specification Spent Fuel Pool Instrumentation System Westinghouse Specialty Tools List Spent Fuel Pool Instrumentation System Westinghouse Standard Product Integrated Function Test Procedure Spent Fuel Pool Instrumentation System Westinghouse Calibration Procedure
Notifications
(Corrective Action Program Documents)
- 50950327*
- 50950367*
- 50950415*
- 50950417*
- 50950447*
- 50950592*
- 50950613*
- 50950615*
- 50950624*
- 50950628*
- 50950634*
- 50950673*
- 50950674*
- 50950536*
- 50950575*
- 50950576*
- 50950619*
- 50950675*
- 50950677*
- 50937019
- 50946852
- 50646319
- 50880784
- 50904294
- 50950628*
- Preventative Maintenance Activities Number Title Revision WO 64175685
-0010 Annual Inspection/Test of Emergency AFW Pump 1
- 10/13/2017
-0010 Annual Inspection/Test of Emergency AFW Pump 1 10/13/2017
-0020 Annual Inspection/Test of Emergency ASW Pump 1
- 10/13/2017
-0040 Annual Inspection/Test of Raw Water Pump 1
- 10/13/2017
- Preventative Maintenance Activities Number Title Revision WO 64175685
-0050 Annual Inspection/Test of FLEX 480V Safety Function Support (Distribution Panel) 1
- 10/12/2017
-0060 Annual Inspection/Test of FLEX 480V Safety Function Support (Distribution Panel) 4
- 10/12/2017
-0070 Annual Inspection/Test of 275KW FLEX 480V Diesel Generator 1
- 10/12/2017
-0080 Annual Inspection/Test of 20KW FLEX 120/240V Diesel Driven Generator FDEG5
- 10/12/2017
-0010 Quarterly Inspection/Test of 275KW FLEX 480V Diesel Generator 2
- 11/10/2017
-0020 Quarterly Inspection/Test of 150KW FLEX 480V Diesel Generator
- 11/10/2017
-0030 Quarterly Inspection/Test of 20KW FLEX 120/240V Diesel Driven Generator FDEG6
- 11/09/2017
-0050 Quarterly Inspection/Test of Emergency ASW Pump 2
- 11/10/2017
-0060 Quarterly Inspection/Test of Raw Water Reservoir Pump 0-2
- 11/09/2017
-0070 Quarterly Inspection/Test of Emergency AFW Pump
- 0-2
- 11/09/2017
-0090 Quarterly Inspection/Test of Portable Diesel Fuel Oil Caddy 0-2
- 11/06/2017
- WO 641810 91-0100 6 Month Inspection/Test of Emergency RCS Makeup Pump 0-1 4/20/2017 WO 64181091
-0200 6 Month Inspection/Test of Emergency RCS Makeup Pump 0-2 4/20/2017 WO 64181091
-0300 6 Month Inspection/Test of Emergency RCS Makeup Pump 0-3 3/13/2017
Procedures
- Number Title Revision
- AD4.ID4 Temporary Storage Process
- ECA-0.0 Loss of All Vital AC Power (Unit 1)
- ECA-0.0 Loss of All Vital AC Power (Unit 2)
- EP R-2 Release of Airborne Radioactive Materials Initial Assessment
- RB-16 Operating Instructions for the EARS Computer Program 14 FS1 FLEX and SFP Instrumentation Program
- FS1.ID1 FLEX Strategy Management
Procedures
- Number Title Revision
- FS1.ID2 Spent Fuel Pool Level Instrumentation Management
- FS1.ID4 FLEX Equipment Status and Availability
- FLEX Support Guideline 01
- Long Term RCS Inventory Control
- FLEX Support Guideline 02
- Alternate AFW Suction Source
- FLEX Support Guideline 03 (Unit 1)
- Alternate Low Pressure Feedwater
- FLEX Support Guideline 03 (Unit 2)
- Alternate Low Pressure Feedwater
- FLEX Support Guideline 04
(Unit 1) ELAP DC Bus Load Shed and Management
- FLEX Support Guideline 04
(Unit 2) ELAP DC Bus Load Shed and Management
- FLEX Support Guideline 05
- Initial Assessment and FLEX Equipment Staging
- 1A FLEX Support Guideline 08
- Alternate RCS Boration
- FLEX Support Guideline 09
- Low Decay Heat Temperature Control
- FLEX Support Guideline 10 (Unit 1)
- Accumulator Isolation
- FLEX Support Guideline 10 (Unit 2)
- Accumulator Isolation
- FLEX Support Guideline 11
- Alternate Containment Cooling
- FLEX Support Guideline 14 (Unit 1)
- Shutdown RCS Makeup
Procedures
- Number Title Revision FLEX Support Guideline 14 (Unit 2)
- Shutdown RCS Makeup
- FLEX Support Guideline 40
- Component Cooling Water Alignment for ELAP
- FLEX Support Guideline 41
- Refill Fire Water Storage Tank with FLEX Equipment
- FLEX Support Guideline 42
- FLEX Support Guideline 43
- Staging FLEX Equipment
- FLEX Support Guideline 44
- Site Debris Removal 1 FLEX Support Guideline 45 (Unit 1)
- Supplying Power to SI Accumulator and RHR Valves
- FLEX Support Guideline 45 (Unit 2)
- Supplying Power to SI Accumulator and RHR Valves
- FLEX Support Guideline 47
- Operation of FLEX Communications Equipment
- FLEX Support Guideline 49 (Unit1)
- Align RCS Injection for Inventory / Boration
- FLEX Support Guideline 49 (Unit2)
- Align RCS Injection for Inventory / Boration
- FLEX Support Guideline 50 (Unit 1)
- Align Injection to Normal Charging During Reflux
- FLEX Support Guideline 50 (Unit 2)
- Align Injection to Normal Charging During Reflux
- FLEX Support Guideline 51
- Pacing Emergency ASW Pumps in Service
- FLEX Support Guideline 54
(Unit 1) Placing 480V Loads in Service
- FLEX Support Guideline 54
(Unit 2) Placing 480V Loads in Service
Procedures
- Number Title Revision FLEX Support Guideline 56
- Fueling FLEX Equipment
- FLEX Support Guideline 58
(Unit 1) Preparing 4kV Bus for Service
- FLEX Support Guideline 58
(Unit 2) Preparing 4kV Bus for Service
- FLEX Support Guideline 59
(Unit 1) Placing 4kV Bus in Service
- FLEX Support Guideline 59
(Unit 2) Placing 4kV Bus in Service
- FLEX Support Guideline 60
- Local Manual Operation of 10% Steam Dumps
- FLEX Support Guideline 61
- Restarting Turbine Driven AFW Pump After Overspeed Trip 0 FLEX Support Guideline 62
- Local Closing of MSIVs
- FLEX Support Guideline 63
- Establishing Forced FLEX Guidelines
- FLEX Support Guideline 98
- FLEX Equipment Operating Guides
- MA1.ID27 Preventive Maintenance Program
- OP AP
- SD-1 Loss of AC Power
- TS3.ID2 Licensing Basis Impact Evaluations
- Training Documents Number Title Revision
- Enrollment and Completion Report for EQIP
-0022 November 13, 2017
- Fire Training FLEX Presentation
{None} ECTP 1702 ERO Requalification Training on FSGs for ERO
-TSC Engineers, and Emergency Response Unit
- 2017
- EDP 912 FLEX Support Guidelines
{None}
- EQIP-0022 Wheel Loader Participant's Guide
{None} ESP 4Q2012
- 2012 ESP Continuing Training
- Fukushima Project 0 JITTOP 1608
- FLEX Equipment Status
- 0A MDCT 1502E
- Electrical Maintenance Continuing Training 2015
- 2015 MSCT 1401 Fukushima Design Changes Overview
- 2014 R151C3 FLEX - The First 24 Hours
- 0A R156C6 Licensed Operator Continuing Training
- In-Plant Walkdown Package (FLEX)
- 2015 R161C11 Oasis FLEX Dynamic Learning Activity
- Introduction to FLEX Systems
- 2014
- SUNSI Review:
- ADAMS:
- Non-Publicly Available
- Non-Sensitive
- Keyword:
- NRC-002 By:
- JMM/rdr
- Yes
- No
- Publicly Available
- Sensitive
- OFFICE SRI:EB2 S PE: PBA PE:IPAT SRI: PBA BC: PBA
- NAME JMateychick
- RAlexander
- EUribe CNewport MHaire
- SIGNATURE /RA/ /RA-E/ /RA/ /RA-E/ /RA/
- DATE 1/22/18 1/17/2018 1/24/18 1/22/18 1/24/18