ML25022A098
| ML25022A098 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 03/03/2025 |
| From: | Markley M Plant Licensing Branch II |
| To: | Carr E Dominion Energy South Carolina |
| Miller, GE | |
| References | |
| EPID L-2024-LLR-0035 | |
| Download: ML25022A098 (1) | |
Text
March 3, 2025 Eric S. Carr Senior Vice President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Blvd.
Glen Allen, VA 23060-6711
SUBJECT:
VIRGIL C. SUMMER NUCLEAR STATION, UNIT NO. 1 - RE: RELIEF REQUEST RR-24-123 CONTAINMENT UNBONDED POST-TENSIONING SYSTEM INSERVICE INSPECTION REQUIREMENTS (EPID L-2024-LLR-0035)
Dear Eric Carr:
By letter dated May 31, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24155A204) Dominion Energy South Carolina (Dominion, the licensee), submitted a request for the Virgil C. Summer Nuclear Station, Unit No. 1 (Summer, VCSNS), to the U.S. Nuclear Regulatory Commission (NRC or the Commission) for authorization of a proposed alternative to certain American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code inservice inspection (ISI) requirements.
Specifically, Dominion requested approval of a proposed alternative from ASME BPV Code Tables IWL-2500-1 (L-A) and IWL-2500-1 (L-B) on the basis that the proposed alternative provides an acceptable level of quality and safety.
The NRC staff has reviewed the alternative request and concludes, as set forth in the enclosed safety evaluation, that Dominion has adequately addressed all the regulatory requirements set forth in Title 10 of the Code of Federal Regulations Section 50.55a(z)(1) and that the proposed alternative provides an acceptable level of quality and safety. Therefore, the NRC authorizes the proposed alternative for remainder of the Third IWL ISI Interval which ends December 31, 2026.
All other ASME Code requirements for which relief was not specifically requested and approved remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
If you have any questions, please contact the Project Manager, Ed Miller at 301-415-2481 or via e-mail at Ed.Miller@nrc.gov.
Sincerely, Michael Markley, Chief Plant Licensing Branch 2-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395
Enclosure:
Safety Evaluation cc: Listserv MICHAEL MARKLEY Digitally signed by MICHAEL MARKLEY Date: 2025.03.03 10:07:44 -05'00'
Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION CONTAINMENT UNBONDED POST-TENSIONING INSERVICE INSPECTION REQUIREMENTS RR-24-123 DOMINION ENERGY SOUTH CAROLINA VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 DOCKET NO. 50-395
1.0 INTRODUCTION
By letter dated May 31, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24155A204), Dominion Energy South Carolina (Dominion, the licensee), submitted a request for the Virgil C. Summer Nuclear Station, Unit No. 1 (VCSNS), to the U.S. Nuclear Regulatory Commission (NRC or Commission) for a proposed alternative to certain American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV)
Code inservice inspection (ISI) requirements.
Specifically, Dominion requested approval of a proposed alternative from ASME Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, Subsection IWL-2420, Unbonded Post-Tensioning Systems and Table IWL-2500-1, Examination Category L-B, Unbonded Post-Tensioning System, Item Nos. L2.10, L2.20, L2.30, L2.40, and L2.50.
2.0 REGULATORY EVALUATION
The NRC regulations in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(z),
Alternatives to codes and standards requirements, state that alternatives to the requirements of 10 CFR 50.55a(b) through (h) or portions thereof may be used when authorized by the Director, Office of Nuclear Reactor Regulation. A proposed alternative must be submitted and authorized prior to implementation. The applicant or licensee must demonstrate that:
(1)
Acceptable level of quality and safety. The proposed alternative would provide an acceptable level of quality and safety; or (2)
Hardship without a compensating increase in quality and safety. Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
3.0 TECHNICAL EVALUATION
The applicable code of record for this evaluation is The American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, Subsection IWL, 2007 Edition with 2008 Addenda for the interval beginning January 1, 2017, and ending December 31, 2026.
ASME Code Components Affected The following plant equipment within the scope of this request are:
Code Class:
Reference:
IWL-2420, IWL-2520, and Table IWL-2500-1 Examination Category:
Table IWL-2500-1, Category L-B Item Number:
L2.10, L2.20, L2.30, L2.40, and L2.50
==
Description:==
Examination of Unbonded Post-Tensioning System Component Number:
VCSNS Containment Building Applicable ASME OM Code Requirements In its letter dated May 31, 2024, the licensee specified the following five requirements of the ASME BPV Code as incorporated by reference in 10 CFR 50.55a as related to this request:
- 1.
Item No. L2.10 requires that selected tendon force and elongation be measured every 5 years in accordance with paragraph IWL 2522, Tendon Force and Elongation Measurements.
- 2.
Item No. L2.20 requires that tendon single wire samples be removed and examined for corrosion examinations and mechanical damage as well as tested to obtain yield strength, ultimate tensile strength, and elongation on each removed wire. This inspection must be performed every 5 years in accordance with paragraph IWL 2523, Tendon Wire and Strand Examination and Testing.
- 3.
Item No. L2.30 requires that a detailed visual examination on selected tendon anchorage hardware and adjacent concrete extending 2 feet from the edge of the bearing plate be performed every 5 years in accordance with paragraph IWL 2524, Examination of Tendon Anchorage Areas. In addition, the quantity of free water released from the anchorage end cap, as well as any free water that drains from the tendon during examination, must be documented.
- 4.
Item No. L2.40 requires that samples of selected tendon corrosion protection medium (CPM) be obtained and analyzed every 5 years in accordance with paragraph IWL 2525, Examination of Corrosion Protection Medium and Free Water.
- 5.
Item No. L2.50 requires that samples of free water be obtained and analyzed every 5 years in accordance with paragraph IWL 2525.
Proposed Alternative for Request RR-24-123 In its letter dated May 31, 2024, the licensee specified the following as the proposed alternative in RR-24-123:
This alternative request proposes to perform visual examination only of the concrete containment and accessible steel hardware visible without tendon cover removal. Physical testing would be performed only if visual examination results indicate a need for such testing, as determined by the Responsible Engineer (IWL-2330). Based on the dates of the Structural Integrity Test (January 2, 1981),
the 50th year examination/testing would be required to be completed no later than January 1, 2032.
Further, Section 2.1 of the Enclosure to the letter stated:
The following departures from current ISI requirements are proposed and evaluated in this report.
(Subsection IWL Table IWL-2500-1, Examination Category L-B, Items L2.10, L2.20, L2.30, L2.40 and L2.50) Extend the interval between post-tensioning system examinations and tests and detailed visual examination of concrete adjacent to tendon bearing plates from 5 years to 10 years with future examinations to be performed 50 years after the pre-operational structural integrity test (SIT) and every 10 years thereafter.
(Subsection IWL Table IWL-2500-1, Examination Category L-B, Item 2.20)
Eliminate de-tensioning / re-tensioning of tendons, sample wire removal and sample wire testing unless such testing is specified by the Responsible Engineer.
(Subsection IWL Table IWL-2500-1, Examination Category L-B, Item L2.40) Limit corrosion protection medium (CPM) chemical tests to the determination of sample absorbed water content unless measured water content exceeds the Table IWL-2525-1 acceptance limit and / or conditions at the anchorage where the sample was collected are judged by the Responsible Engineer to justify additional tests.
=
Reason for Request===
In its letter dated May 31, 2024, the licensee specified the following as the reason for RR-24-123:
Physical testing requires exposing plant personnel to industrial safety hazards.
Removing the tendon end caps and load testing or de-tensioning/re-tensioning the tendons also unnecessarily cycles the tendons. Below are specific hazards and undesirable conditions that would be reduced by this proposed alternative:
Most tendons are located well above ground level and require work to be performed at heights, with the inherent risks associated with such work.
This work is often performed from hanging platforms. The platform must be moved to a parked location to exit the platform safely.
Some work areas are in difficult-to-reach locations that have only one small access point.
The testing requires working with high pressure hydraulics.
The testing requires working in the vicinity of high energy plant systems.
The testing requires working with solvents and hot petroleum products and associated fumes.
The testing requires working with containers and pressurized lines filled with a heated CPM (grease).
The testing requires working in the vicinity of high levels of stored elastic energy in the tendons. Sudden rotation during force measurement has resulted in high-speed shim ejections.
The work includes the handling of heavy loads (i.e., test equipment) that expose test personnel and equipment to hazards.
While tendon testing is not often performed in radiation areas, there are occasionally some tendons tested in areas that involve radiation fields.
Performing examination/testing on a reduced frequency reduces the repetitive loading required for force measurement and/or de-tensioning/re-tensioning.
Reducing the frequency of tendon end cap removal will reduce environmental waste (e.g., solvents, used grease, [and] other consumables).
Duration of the Proposed Alternative In its letter dated May 31, 2024, the licensee stated:
The provisions of this alternative are applicable to the remainder of the VCSNS Third 10-year IWL ISI interval which ends on December 31, 2026. The next, and final IWL examination within this interval is scheduled to occur with completion of the 45th year examination on January 2, 2026, plus or minus one year. It is noted that the 45th year IWL examination is projected to occur in the spring of 2026, with completion prior to the end of the Third 10-year IWL ISI interval.
Licensees Assessment In its letter dated May 31, 2024, the licensee provided the following assessment of Request RR-24-123:
The reduced frequency of post-tensioning system physical testing will continue to provide an acceptable level of quality and safety based on projected system performance and a requirement for implementation of additional physical testing if visual examination results indicate a need for additional testing.
VCSNS proposes to perform a general visual examination and detailed visual examination (when required) of accessible concrete and exposed steel hardware as required by Section XI, Table IWL-2500-1, Item Numbers L 1.11, and L 1.12, as modified by 10 CFR 50.55a. The examination and physical testing requirements of Section XI, Table IWL-2500-1, Item Numbers L2.10, L2.20, L2.30 L2.40, and L2.50 will only be performed if the general visual examination and detailed visual examination identify conditions indicating potential degradation of tendon hardware, as documented by the Responsible Engineer in an engineering evaluation.
Example conditions that could require removal of a tendon end cap and further examination per Item Numbers L2.10, L2.20, L2.30, L2.40, and L2.50 are:
Evidence of possible damage to the enclosed post-tensioning hardware as indicated by conditions such as end cap deformation found during external visual examination. Conditions observed by removal of the end cap would determine the extent of additional examinations per L2.10, L2.20, L2.30, L2.40, and L2.50.
Active corrosion on a bearing plate or end cap that required further investigation as determined by the Responsible Engineer in an engineering evaluation.
Evidence of CPM leakage will be evaluated and a plan developed that requires further investigation and corrective actions as defined in an engineering evaluation documented by the Responsible Engineer.
In Enclosure 1 to its submittal, the licensee provided a detailed discussion of the historical basis for examination and testing of containment post-tensioning systems which included VCSNS-specific observations.
The licensee also described the following additional supporting actions:
[The] ASME B&PV Code Section XI, Subsection IWL program at VCSNS is credited for managing containment building degradation. The Examination Category L-A visual examinations (every 5 years) are expected to identify any conditions that would allow water intrusion into the tendons or leakage of CPM, which are precursors indicating an environment that could allow corrosion of the tendon wires of inaccessible tendon hardware covered be the tendon end cap.
Such conditions would be evaluated by the Responsible Engineer to determine what additional actions are necessary to assure no corrosive environmental conditions exist.
The mean pre-stresses for VCSNS are predicted to be acceptable will beyond the August 6, 2042 expiration date of the renewed facility operating license. The average tendon forces are predicted to remain above the lower limits for required mean force beyond T=100 years. Therefore, extending the examination/test frequency from 5 to 10 years will continue to provide an acceptable level of quality and safety.
NRC Staff Evaluation of RR-24-123 The NRC staff reviewed the information provided in the proposed alternative request and noted that the licensee will continue to conduct the general visual examinations and detailed visual examination of suspect areas on a 5-year frequency as required by Table IWL-2500-1 (L-A)
Examination Category L-A, Concrete. Any indications identified during these examinations are precursors that may lead to additional examinations in accordance with Table IWL-2500-1 (L-B)
Examination Category L-B, Unbonded Post-Tensioning System, as determined by the Responsible Engineer (RE). As required by IWL-2511, Accessible Areas, this would include examination of the concrete surfaces and tendon end anchorage areas on a 5-year frequency to identify evidence of damage, degradation, deformation of the end cap, water intrusion, corrosion, concrete cracking, or CPM leakage. Tendon end caps are required to be removed for this examination if there is evidence of tendon end cap deformation or damage.
The NRC staff also reviewed the plant-specific operating experience information and summary results of VCSNS, Unit 1 examinations provided in the enclosure to the request. These examinations and tests were conducted during 10 inspections for VCSNS, Unit 1, over an almost-40-year period (1982-2020) for each of the requirements of ASME Section XI, Subsection IWL, Table IWL-2500-1 (L-B), Item Nos. L2.10, L2.20, L2.30, L2.40, and L2.50. This information is specifically described in Section 4, V. C. Summer Nuclear Station Unit 1 Examination History and Results Evaluation, of Enclosure 1 to the proposed alternative. The NRC staffs evaluation of each code examination item number is provided below.
Item No. L2.10, Tendon Force Trends and Forecasts Section 4.1 of Enclosure 1 to the request states that forces in sample tendons were measured during each examination and projected (forecast) forces in each of the tendon groups (i.e., the hoop, vertical, and dome tendons) based on regression analysis of the measured forces as well as 95 percent lower confidence limit (LCL) trend were calculated. The NRC staff noted that the projected force for the vertical tendon group is based on only the 15-year through 40-year surveillance results because all of the vertical tendons were re-tensioned following the 10-year surveillance.
The NRC staff reviewed the tendon force data in Figures 1 through 8 of Enclosure 1 to the request, and verified that the projected forces remain above the minimum required tendon force (i.e., 1000 kilo-pound (kip), 1160 kip, and 1025 kip, respectively, for the hoop, vertical, and dome tendons) until beyond the January 2032 deadline for completion of the next surveillance if the interval is extended to 10 years and through the end of the current 60-year operating license. Based on the statistical analyses of past surveillance results, and the ample margin between the measured force trend (forecast) values and the minimum required force, the NRC staff finds it acceptable to extend the interval of the post-tensioning system examinations and tests (ASME Code,Section XI, Table IWL-2500-1 (L-B), Item No. L2.10) from 5 years to 10 years for the third 10-year containment inservice inspection (CISI) interval, for a one-time deferral for VCSNS, Unit 1. Accordingly, the next tendon force measurement will be conducted in 2031 (+/- 1 year) on VCSNS, Unit 1.
Item No. L2.20, Wire Examination and Test Results Section 4.2 of Enclosure 1 to the request states that during each surveillance sample wires (one wire from at least one tendon in each tendon group) were extracted, visually examined for damage and corrosion, and tested for ultimate tensile strength and elongation at failure.
The NRC staff reviewed the results of the wire test results/ultimate tensile strength - designated tendons, as summarized in Table 5a of Enclosure 1 to the request and noted that all the tensile strengths were above the minimum specified value of 240 kips per square inch (ksi), with the mean value computed for all tests performed during a given surveillance varying from 247 to 260 ksi. The NRC staff also reviewed the results of the elongation tests, as summarized in Table 5b of Enclosure 1 to the request and noted that, although a number of elongation values were below the four percent limit, most of the elongations exceeded the minimum of four (4) percent elongation specified for ASTM A421 wire. In addition, while there were variations, the data did not show any apparent trend of increasing or decreasing elongation over time. The NRC staff also noted that from visual examination of 33 extracted wires, none of the wires had signs of damage; and only six of the extracted wires exhibited light rust with no pitting. Since the examination and testing of extracted sample wires have shown no significant degradation of condition, strength, or elongation over a time period of approximately 40 years, and have not identified any significant active corrosion, the NRC staff finds it acceptable to waive the requirement for sample wire removal and testing (ASME Code,Section XI, Table IWL 2500-1 (L-B), Item No. L2.20) for the third 10-year CISI interval for VCSNS, Unit 1. Accordingly, the next sample wire removal and testing will be conducted in 2031 (+/- 1 year) on VCSNS, Unit 1.
Item Number L2.30, Anchorage Hardware and Surrounding Concrete Inspection Section 4.3 of Enclosure 1 to the request summarizes the examination results of end anchorage hardware/concrete condition examinations performed periodically at VCSNS, Unit 1, through the 40th year surveillance. During each of the surveillances, end anchorage areas were visually examined for evidence of corrosion, discontinuous wires, damage to or distortion of load bearing components, and cracks in concrete adjacent to bearing plates. The NRC staff reviewed the results of these examinations, summarized in Subsections 4.3.1 through 4.3.5 of Enclosure 1 to the request.
The NRC staff noted the following from review of tendon anchorage area examination results:
Corrosion documented through the 40th year surveillance identified no corrosion greater than severity Level 2 or B (light rust with no pitting), with exception of those identified through the 20th year surveillance. It was concluded that there is no evidence of significant active corrosion on anchor heads, shims, button heads, wires or areas of bearing plates that are enclosed by the end cap gasket and protected by CPM; and all corrosion observed on load bearing components and on protected areas of bearing plates occurred prior to or during construction and before installation of CPM; Only 17 wires were found to be broken or have missing button heads during the 10 surveillances completed to date; this represents a miniscule fraction of the total number of over 30,000 wires examined and this fraction is too small to be of structural significance. Additionally, the NRC staff noted that the maximum number of ineffective wires in any single surveillance was four. Even if all of those four wires were to be found in a single tendon, the reduction in the tendon force due to four missing wires out of 170 total wires for a single tendon would still be insignificant to tendon force trend values if the inspection interval is extended to 10 years. Therefore, the NRC staff finds it acceptable; No damaged, cracked or distorted load bearing components, such as bearing plates, anchor head, and shims, have been found; and Only two areas with cracks having widths over 0.010 inches were found through the 40th year surveillance and these cracks were either accepted by evaluation or considered to have no structural significance. It was therefore concluded that cracking of concrete adjacent to tendon end anchorage bearing plates is not an issue.
The NRC staff reviewed the information related to the anchorage hardware examinations and noted that no active or significant corrosion has been identified in the approximately 15 years between the 25th year surveillance and the most recent inspection in 2020. In addition, an insignificant number of broken wires (17 out of 30,000 examined) have been found and no significant concrete cracks or damage in load bearing components have been identified.
Therefore, the NRC staff finds it acceptable to extend the interval of the anchorage hardware examinations (ASME Code,Section XI, Table IWL-2500-1 (L-B), Item No. L2.30), from 5 years to 10 years for the third 10-year CISI interval for VCSNS, Unit 1. Accordingly, the next tendon anchorage hardware and adjacent concrete examination will be conducted in 2031 (+/- 1 year).
Item Number L2.40 and L2.50, CPM and Free Water Testing Section 4.4 of Enclosure 1 to the request notes that CPM was collected at the ends of the sample tendons during each of the surveillances and tested for chlorides, nitrates, sulfides, absorbed water content, and, since the 15-year surveillance, the reserve alkalinity (expressed as neutralization base number). Section 4.3 of Enclosure 1 to the request states that end anchorage areas were visually examined for presence of free water during each of the surveillances.
The NRC staff reviewed the summary information and plant-specific data provided in Subsections 4.4.1 through 4.4.3 of Enclosure 1 to the request and noted that for corrosive ions and absorbed water content, every test result was well below the acceptance criteria stated in Subsection 4.4.1 and 4.4.3, respectively. In addition, all neutralization number test results were above the lower limit acceptance criterion stated in Subsection 4.4.2. The NRC staff also noted in Subsection 4.3.2 of Enclosure 1 to the request that no free water has been observed during any of the examinations performed.
Based on the adequate test results, and no indication that the results will degrade over time, the NRC staff finds it acceptable to extend the interval of the CPM and free water tests (ASME Code,Section XI, Table IWL-2500-1 (L-B), Item Nos. L2.40 and L2.50), from 5 years to 10 years for VCSNS, Unit 1 for the third 10-year CISI interval. In addition, based on past examination results, the CPM appears to be retaining its corrosion protection function, and the staff finds it is acceptable to waive the requirement to perform the tests of CPM for corrosive ions and reserve alkalinity (base number) for the third CISI interval for VCSNS, Unit 1 because these tests may not be necessary unless evidence of active corrosion is found from visual examinations of anchorage hardware/wires, or the quantity of absorbed water in the CPM is above the acceptance limit; in which case the samples are collected at an anchorage where free/absorbed water and/or corrosion is found or if specified by the RE. No such conditions exist as of the last inspection. The NRC staff also noted that free water, if found, will continue to be collected and analyzed to determine pH as required by Subsection IWL. Accordingly, the next CPM and free water examination and testing will be conducted in 2031 (+/- 1 year) on VCSNS, Unit 1.
Summary Based on the above, the NRC staff finds that the licensee has demonstrated sufficient performance of the unbonded post-tensioning system by presenting adequate plant-specific post-tensioning system inspection results, operating experience and corrective actions, and technical evaluations demonstrating applied tendon prestress level will remain acceptable beyond the deferred next inspection. Therefore, the NRC staff finds that the use of proposed alternative RR-24-123 for VCSNS, Unit 1, for the third 10-year CISI interval would provide an acceptable level of quality and safety.
The NRC staff reviewed the proposed alternatives for the third 10-year IWL CISI interval for VCSNS, Unit 1, as follows:
The alternative would authorize to extend the interval of the concrete containment unbonded post-tensioning system examinations (ASME Code,Section XI, Table IWL 2500-1 (L-B), Item Nos. L2.10, L2.20, L2.30, L2.40 and L2.50) from 5 to 10 years for a one-time deferral for VCSNS, Unit 1.
The alternative would eliminate tendon wire examinations and tests (ASME Code,Section XI, Table IWL 2500-1 (L-B), Item No. L2.20) for VCSNS, Unit 1, with the condition that the RE should consider wire removal and examination and testing if observed end anchorage conditions indicate the possibility of wire degradation.
The alternative would limit the corrosion protection medium (CPM) chemical tests (ASME Section XI, Subsection IWL, Table IWL-2500-1 (L-B), Item No. L2.40) for VCSNS, Unit 1, to the determination of sample absorbed water content unless measured water content exceeds the Table IWL-2525-1 acceptance limit and/or conditions at the anchorage where the sample was collected are judged by the RE to justify additional tests.
Based on the above, the NRC staff finds sufficient basis to authorize a one-time extension of the interval between post-tensioning system examinations based on its review of the plant-specific inspection results and operating experience provided in the request through December 31, 2026. The NRC staff is not making a conclusion with regard to the extended inspection interval for future CISI intervals through the end of the renewed license without reviewing updated plant-specific post-tensioning system examination results from the third CISI interval. Since the CISI requirements beyond the third 10-year interval at VCSNS, Unit 1 have not yet been established in accordance with 10 CFR 50.55a(g)(4)(ii), no authorization can be made for subsequent intervals after the third 10-year CISI interval. Future inspections or requests for relief, as needed for those intervals, will be reviewed separately by the NRC.
4.0 CONCLUSION
Based on the above, the NRC staff concludes that RR-24-123 has adequately addressed all the regulatory requirements set forth in 10 CFR 50.55a(z)(1). Further, the proposed alternative provides an acceptable level of quality and safety in lieu of the specified ASME OM Code requirements. Therefore, the NRC authorizes Relief Request RR-24-123 for the Third 10-year IWL ISI interval, which at VCSNS Unit 1 ends on December 31, 2026.
All other ASME Code requirements for which relief has not been specifically requested and approved in this relief request remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.
Principal Contributors: S. Park, NRR S. Lai, NRR Date: March 3, 2025
ML25022A098 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DEX/ESEB/BC NRR/DORL/LPL2-1/BC NAME GEMiller KZeleznock ITseng MMarkley DATE 01/23/2025 01/27/2025 01/27/2025 03/03/2025 OFFICE NRR/DORL/LPL2-1/PM NAME GEMiller DATE 03/03/2025