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==SUBJECT:==
==SUBJECT:==
COLUMBIA GENERATING STATION
COLUMBIA GENERATING STATION, NRC SECURITY INSPECTION REPORT 05000397/2018404
, NRC SECURITY INSPECTION REPORT 05 000397/2018404


==Dear Mr. Sawatzke:==
==Dear Mr. Sawatzke:==
On July 12, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed a security inspection at your Columbia Generating Station
On July 12, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed a security inspection at your Columbia Generating Station. The NRC inspectors discussed the results of this inspection with Mr. G. Hettel, Chief Nuclear Officer, and other members of your staff. The inspectors documented the results of this inspection in the enclosed inspection report.
. The NRC inspector s discussed the results of this inspection with Mr. G. Hettel, Chief Nuclear Officer, and other members of your staff. The inspector s documented the results of this inspection in the enclosed inspection report.


No NRC-identified or self-revealing findings were identified during this inspection.
No NRC-identified or self-revealing findings were identified during this inspection.


In accordance with Title 10 of the Code of Federal Regulations 2.390, "Public Inspections, Exemptions, Requests for Withholding," of the NRC's "Agency Rules of Practice and Procedure," a copy of this letter will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Agency Rules of Practice and Procedure," a copy of this letter will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of ADAMS.
 
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).


Sincerely,
Sincerely,
/RA by DAHolman Acting For/
/RA by DAHolman Acting For/  
Jeremy R. Groom, Chief Plant Support Branch 1 Division Reactor Safety Docket No s. 50-397 License No. NPF-21 Enclosure:  
 
Jeremy R. Groom, Chief Plant Support Branch 1 Division Reactor Safety  
 
Docket Nos. 50-397 License No. NPF-21  
 
Enclosure:
Inspection Report 05000397/2018404
 
Enclosure U.S. NUCLEAR REGULATORY COMMISSION


==Inspection Report==
==Inspection Report==
05000397/2018404 Enclosure U.S. NUCLEAR REGULATORY COMMISSION
Docket Number:
05000397  
 
License Number:
NPF-21


==Inspection Report==
Report Number:
Docket Number
05000397/2018404  
: 05000397 License Number: NPF-21 Report Number
 
: 05000397/2018404 Enterprise Identifier:
Enterprise Identifier:
I-2018-404-011 Licensee: Energy Northwest Facility: Columbia Generating Station Location: Richland, WA Dates: July 9-12 , 2018 Inspector s: J. Larsen, Senior Physical Security Inspector A. Meyen, Physical Security Inspector Approved By:
I-2018-404-011  
Jeremy R. Groom Chief, Plant Support Branch 1 Division of Reactor Safety 2
 
Licensee:
Energy Northwest  
 
Facility:
Columbia Generating Station  
 
Location:  
 
Richland, WA  
 
Dates:
July 9-12, 2018  
 
Inspectors:
J. Larsen, Senior Physical Security Inspector  
 
A. Meyen, Physical Security Inspector  
 
Approved By:
Jeremy R. Groom  


=SUMMARY=
Chief, Plant Support Branch 1
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensee's performance by conducting a Baseline Security Inspection at the Columbia Generating Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC's program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.


NRC identified and self-revealed findings, violations, and additional items are summarized in the table below.
Division of Reactor Safety


List of Findings and Violations No Findings were identified.
=SUMMARY=
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Baseline Security Inspection at the Columbia Generating 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. NRC identified and self-revealed findings, violations, and additional items are summarized in the table below.


3
===List of Findings and Violations===
No Findings were identified.


=INSPECTION SCOPES=
=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. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2201, "Security Inspection Program for Commercial Nuclear Power Reactors."
Inspections were conducted using the appropriate portions of the inspection procedures (IPs)in effect at the beginning of the inspection unless otherwise noted. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2201, Security Inspection Program for Commercial Nuclear Power Reactors. 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.
 
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.


==71130.04 - Equipment Performance, Testing, and Maintenance==
==71130.04 - Equipment Performance, Testing, and Maintenance==
{{IP sample|IP=IP 71130.04|count=1}}
{{IP sample|IP=IP 71130.04|count=1}}


The inspectors evaluated the security equipment performance, testing and maintenance program. The following elements were evaluated:
The inspectors evaluated the security equipment performance, testing and maintenance program. The following elements were evaluated:  
Tier I: all requirements Tier II: all requirements Tier III: all requirements
 
Tier I: all requirements  
 
Tier II: all requirements  
 
Tier III: all requirements


==71130.07 - Security Training==
==71130.07 - Security Training==
{{IP sample|IP=IP 71130.07|count=1}}
{{IP sample|IP=IP 71130.07|count=1}}


The inspectors evaluated the security training program. The following elements were evaluated:
The inspectors evaluated the security training program. The following elements were evaluated:  
Tier I: all requirements Tier II: all requirements Tier III: all requirements  
 
Tier I: all requirements  
 
Tier II: all requirements  
 
Tier III: all requirements


==INSPECTION RESULTS==
==INSPECTION RESULTS==
Line 77: Line 118:


==EXIT MEETINGS AND DEBRIEFS==
==EXIT MEETINGS AND DEBRIEFS==
On July 12, 201 8, the inspector s telephonically presented the Baseline Security Inspection results to Mr. G. Hettel, Chief Nuclear Officer
On July 12, 2018, the inspectors telephonically presented the Baseline Security Inspection results to Mr. G. Hettel, Chief Nuclear Officer, and other members of the licensees staff. The inspectors asked whether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified.
, and other members of the licensee's staff. The inspector s asked whether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified.


=DOCUMENTS REVIEWED=
=DOCUMENTS REVIEWED=


Type Designation
Type
Designation
Description or Title
Description or Title
Revision 71130.04 Procedure               Manuals                           MIS
Revision
: [[contact::C.     SPIP-SEC-09 Intrusion Detection System]], Alarms, Annunciators, Operability Test, Inspection Page: 1 of 17
71130.04
and Maintenance Records
Procedure  
SPIP-SEC-10 Special Purpose Detectors, Operability Test, Inspection, and Maintenance Page: 1 of 18
 
Records   10  SPIP-SEC-11 Protective Lighting  
Manuals  
- Test Inspection and Maintenance Records   07 SPIP-SEC-37 Bullet Resistant Enclosure Officer
 
SPIP-SEC-48 Itemizer 3 Explosive Detector
MISC.  
SPIP-SEC-49 Intrusion Detection System Operability Test
 
SPIP-SEC-50 Door Operability Test
SPIP-SEC-09
10.28.28 Security Door Maintenance
Intrusion Detection System,
10.28.29 Outdoor Security Lighting Inspection and Maintenance
Alarms, Annunciators, Operability
10.28.30 Setup And Test
Test, Inspection Page: 1 of 17
-Balanced Magnetic Switches
and Maintenance Records  
10.28.45 Setup and Test  
 
- Microwave Link  
SPIP-SEC-10
- OMNI Spectra Model 300B
Special Purpose Detectors,
10.28.46 Setup and Test  
Operability Test, Inspection, and
- Microwave Link  
Maintenance Page: 1 of 18
- OMNI Spectra Model 310B
Records  
10.28.47 Setup, Test & Maintenance of CCTV Cameras
 
10.28.52 Hand Geometry System Probability Test
SPIP-SEC-11
10.28.59 Setup and Test/Probability of Detection  
Protective Lighting - Test
- Explosive GE Entryscan 4
Inspection and Maintenance
10.28.60 Setup and Test/Probability of Detection  
Records  
- Metor 300 Metal Detection System
 
10.28.62 Inspection and Testing the Perifeld-M Detection System
SPIP-SEC-37
10.28.65 Setup and Test  
Bullet Resistant Enclosure Officer
- Intrusion Detection IPID  
SPIP-SEC-48
- ECSI International
Itemizer 3 Explosive Detector  
10.28.66 IPID Intrusion Probability Testing
 
SPIP-SEC-49
Intrusion Detection System
Operability Test  
 
SPIP-SEC-50
Door Operability Test
10.28.28
Security Door Maintenance
10.28.29
Outdoor Security Lighting
Inspection and Maintenance  
 
10.28.30
Setup And Test-Balanced
Magnetic Switches  
 
10.28.45
Setup and Test - Microwave Link -
OMNI Spectra Model 300B  
 
10.28.46
Setup and Test - Microwave Link -
OMNI Spectra Model 310B  
 
10.28.47
Setup, Test & Maintenance of
CCTV Cameras  
 
10.28.52
Hand Geometry System
Probability Test  
 
10.28.59
Setup and Test/Probability of
Detection - Explosive GE
Entryscan 4  
 
10.28.60
Setup and Test/Probability of
Detection - Metor 300 Metal
Detection System  
 
10.28.62
Inspection and Testing the
Perifeld-M Detection System  
 
10.28.65
Setup and Test - Intrusion
Detection IPID - ECSI International  
 
10.28.66
IPID Intrusion Probability Testing  
 
Audit/Assessment
Audit/Assessment
Energy Northwest Snapshot Self
Energy Northwest Snapshot Self-
-Assessment Report for Equipment Testing and Maintenance 4
Assessment Report for Equipment
-19-18 Security Plan Physical Security Plan
Testing and Maintenance 4-19-18
Logs Security Event Logs
Security Plan
Dates, 6-1-17 to 6-30-18
Physical Security Plan  
Type Designation
 
Logs
Security Event Logs
Dates, 6-1-17 to 6-30-18  
 
Type
Designation
Description or Title
Description or Title
Revision     Report Alarm/Event Condition Report  
Revision  
(Inspection Testing) 7
 
-10-18 Security Force Activity Report
Report
6-25 & 28-18 Firearms Shift Change Equipment Inventory
Alarm/Event Condition Report  
Firearms 2018 Handgun Inventory and Maintenance Status
(Inspection Testing) 7-10-18
Firearms 2018 Rifle Inventory and Maintenance Status
Security Force
Firearms Armorer Certificates Rifle and Handgun   Barrier Nasatka Barrier Manual Operation Diagran   Security Defined Owner Controlled Area SDOCA Record of Physical Checks 7-2&5-18 Communications
Activity Report
6-25 & 28-18
Firearms
Shift Change Equipment Inventory  
 
Firearms
2018 Handgun Inventory and
Maintenance Status  
 
Firearms
2018 Rifle Inventory and
Maintenance Status  
 
Firearms
Armorer Certificates Rifle and
Handgun  
 
Barrier
Nasatka Barrier Manual Operation
Diagran
Security Defined
Owner Controlled
Area
SDOCA Record of Physical
Checks 7-2&5-18
Communications
Motorola Survey Test Results
Motorola Survey Test Results
Condition Report 382320 382321 371689 364640 371688 382333 380357 378508 375260 379587   Inspection Procedure Type Designation
Condition
Description or
Report
Title Revision 71130.07 Procedure             MISC. Lesson Plans SPIP-TQS-02 Security Force Training Program
2320
SPIP-TQS-03 Security Force Training Program Description
2321
SPIP-TQS-04 Security Training Material Preparation and Examination Administration
371689
SPIP-TQS-05 Security Training Corrective Action Program 11 SPIP-TQS-06 Managing Security Qualifications
364640
SPIP-TQS-07 Security Training Range Operation Procedure 24  SPIP-TQS-08 Security Officer Course Student Expectations
371688
2333
380357
378508
375260
379587  
 
Inspection
Procedure Type
Designation
Description or Title
Revision
71130.07
Procedure  
 
MISC.  
 
Lesson
Plans
SPIP-TQS-02
Security Force Training Program  
 
SPIP-TQS-03
Security Force Training Program
Description  
 
SPIP-TQS-04
Security Training Material
Preparation and Examination
Administration  
 
SPIP-TQS-05
Security Training Corrective Action
Program
SPIP-TQS-06
Managing Security Qualifications  
 
SPIP-TQS-07
Security Training Range Operation
Procedure  
 
SPIP-TQS-08
Security Officer Course Student
Expectations  
 
Audit/Assessment
Audit/Assessment
Energy Northwest Snapshot Self
Energy Northwest Snapshot Self-
-Assessment Report for Security Training, November, 2017
Assessment Report for Security
Training, November, 2017
Security Plan
Security Plan
Physical Security Plan
Physical Security Plan
Security Plan
Security Plan
Training and Qualification Plan
Training and Qualification Plan  
Logs Security Event Logs
 
Dates, 6-1-17 to 6-30-18 PFT Physical Fitness Test Analysis
Logs
Lesson Use of Force
Security Event Logs
Lesson Tampering Lesson Field Protective Mask
Dates, 6-1-17 to 6-30-18
PFT
Physical Fitness Test Analysis
Lesson
Use of Force
Lesson
Tampering
Lesson
Field Protective Mask  
 
Inspection
Procedure Type
Designation
Description or Title
Revision
OJT/TPE
Hour OJT Training
 
Range
Day Fire Rifle/Pistol Qualification
Course of Fire
 
Range
Night Fire Rifle/Pistol Course of
Fire
 
Range
Enhanced Weapons Course of
Fire
Range
Tactical Course of Fire/Analysis
Condition
Report
356219
373488
371689
364640
371688
 
ML18220A868
SUNSI Review
ADAMS:
Non-Publicly Available
Non-Sensitive
Keyword:
By: JRL
Yes No
Publicly Available
Sensitive
NRC-002
OFFICE
SPSI/PSB1
C:PSB1
C:PBA
C:PSB1
 
NAME
JLarsen
JGroom
MHaire
JGroom
 
SIGNATURE
/RA by
phone/
/RA by
DAHolman
Acting For/
/RA by
RDAlexander
Acting For/
/RA by
DAHolman
Acting For/


Inspection Procedure Type Designation
DATE
Description or
08/07/18
Title Revision OJT/TPE 40 Hour OJT Training
08/07/18
Range Day Fire Rifle/Pistol Qualification Course of Fire
08/08/18
Range Night Fire Rifle/Pistol Course of Fire  Range Enhanced Weapons Course of Fire  Range Tactical Course of Fire/Analysis
08/08/18
Condition Report 356219 373488 371689 364640 371688
B. Sawatzke
COLUMBIA GENERATING STATION , NRC SECURITY INSPECTION REPORT
05000397/2018404 - DATED AUGUST
8, 2018  DISTRIBUTION
: KKennedy, RA
SMorris, DRA
AVegel, DRP
MShaffer, DRS
RLantz, DRP
JClark, DRS
DCylkowski, RC
MHaire, DRP
RAlexander, DRP
LNewman, DRP GKolcum, DRP
LBrandt, DRP
MBennett, DRP
JBowen, RIV/OEDO
VDricks, ORA
JWeil, OCA
JKlos, NRR
AMoreno, RIV/CAO
BMaier, RSLO
GGeorge, IPAT
PJayroe, IPAT
MHerrera, DRMA
R4Enforcement
cc:
}}
}}

Latest revision as of 15:24, 5 January 2025

NRC Security Inspection Report 05000397/2018404
ML18220A868
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 08/08/2018
From: Jeremy Groom
Plant Support Branch-1
To: Sawatzke B
Energy Northwest
JAMES LARSEN
References
IR 2018404
Download: ML18220A868 (8)
v • d • e


Text

August 8, 2018

SUBJECT:

COLUMBIA GENERATING STATION, NRC SECURITY INSPECTION REPORT 05000397/2018404

Dear Mr. Sawatzke:

On July 12, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed a security inspection at your Columbia Generating Station. The NRC inspectors discussed the results of this inspection with Mr. G. Hettel, Chief Nuclear Officer, and other members of your staff. The inspectors documented the results of this inspection in the enclosed inspection report.

No NRC-identified or self-revealing findings were identified during this inspection.

In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Agency Rules of Practice and Procedure," a copy of this letter will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of 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 by DAHolman Acting For/

Jeremy R. Groom, Chief Plant Support Branch 1 Division Reactor Safety

Docket Nos. 50-397 License No. NPF-21

Enclosure:

Inspection Report 05000397/2018404

Enclosure U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number:

05000397

License Number:

NPF-21

Report Number:

05000397/2018404

Enterprise Identifier:

I-2018-404-011

Licensee:

Energy Northwest

Facility:

Columbia Generating Station

Location:

Richland, WA

Dates:

July 9-12, 2018

Inspectors:

J. Larsen, Senior Physical Security Inspector

A. Meyen, Physical Security Inspector

Approved By:

Jeremy R. Groom

Chief, Plant Support Branch 1

Division of Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Baseline Security Inspection at the Columbia Generating 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. NRC identified and self-revealed findings, violations, and additional items are summarized in the table below.

List of Findings and Violations

No Findings were identified.

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. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2201, Security Inspection Program for Commercial Nuclear Power Reactors. 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.

71130.04 - Equipment Performance, Testing, and Maintenance

Main article: IP 71130.04

The inspectors evaluated the security equipment performance, testing and maintenance program. The following elements were evaluated:

Tier I: all requirements

Tier II: all requirements

Tier III: all requirements

71130.07 - Security Training

Main article: IP 71130.07

The inspectors evaluated the security training program. The following elements were evaluated:

Tier I: all requirements

Tier II: all requirements

Tier III: all requirements

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

On July 12, 2018, the inspectors telephonically presented the Baseline Security Inspection results to Mr. G. Hettel, Chief Nuclear Officer, and other members of the licensees staff. The inspectors asked whether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified.

DOCUMENTS REVIEWED

Type

Designation

Description or Title

Revision

71130.04

Procedure

Manuals

MISC.

SPIP-SEC-09

Intrusion Detection System,

Alarms, Annunciators, Operability

Test, Inspection Page: 1 of 17

and Maintenance Records

SPIP-SEC-10

Special Purpose Detectors,

Operability Test, Inspection, and

Maintenance Page: 1 of 18

Records

SPIP-SEC-11

Protective Lighting - Test

Inspection and Maintenance

Records

SPIP-SEC-37

Bullet Resistant Enclosure Officer

SPIP-SEC-48

Itemizer 3 Explosive Detector

SPIP-SEC-49

Intrusion Detection System

Operability Test

SPIP-SEC-50

Door Operability Test

10.28.28

Security Door Maintenance

10.28.29

Outdoor Security Lighting

Inspection and Maintenance

10.28.30

Setup And Test-Balanced

Magnetic Switches

10.28.45

Setup and Test - Microwave Link -

OMNI Spectra Model 300B

10.28.46

Setup and Test - Microwave Link -

OMNI Spectra Model 310B

10.28.47

Setup, Test & Maintenance of

CCTV Cameras

10.28.52

Hand Geometry System

Probability Test

10.28.59

Setup and Test/Probability of

Detection - Explosive GE

Entryscan 4

10.28.60

Setup and Test/Probability of

Detection - Metor 300 Metal

Detection System

10.28.62

Inspection and Testing the

Perifeld-M Detection System

10.28.65

Setup and Test - Intrusion

Detection IPID - ECSI International

10.28.66

IPID Intrusion Probability Testing

Audit/Assessment

Energy Northwest Snapshot Self-

Assessment Report for Equipment

Testing and Maintenance 4-19-18

Security Plan

Physical Security Plan

Logs

Security Event Logs

Dates, 6-1-17 to 6-30-18

Type

Designation

Description or Title

Revision

Report

Alarm/Event Condition Report

(Inspection Testing) 7-10-18

Security Force

Activity Report

6-25 & 28-18

Firearms

Shift Change Equipment Inventory

Firearms

2018 Handgun Inventory and

Maintenance Status

Firearms

2018 Rifle Inventory and

Maintenance Status

Firearms

Armorer Certificates Rifle and

Handgun

Barrier

Nasatka Barrier Manual Operation

Diagran

Security Defined

Owner Controlled

Area

SDOCA Record of Physical

Checks 7-2&5-18

Communications

Motorola Survey Test Results

Condition

Report

2320

2321

371689

364640

371688

2333

380357

378508

375260

379587

Inspection

Procedure Type

Designation

Description or Title

Revision

71130.07

Procedure

MISC.

Lesson

Plans

SPIP-TQS-02

Security Force Training Program

SPIP-TQS-03

Security Force Training Program

Description

SPIP-TQS-04

Security Training Material

Preparation and Examination

Administration

SPIP-TQS-05

Security Training Corrective Action

Program

SPIP-TQS-06

Managing Security Qualifications

SPIP-TQS-07

Security Training Range Operation

Procedure

SPIP-TQS-08

Security Officer Course Student

Expectations

Audit/Assessment

Energy Northwest Snapshot Self-

Assessment Report for Security

Training, November, 2017

Security Plan

Physical Security Plan

Security Plan

Training and Qualification Plan

Logs

Security Event Logs

Dates, 6-1-17 to 6-30-18

PFT

Physical Fitness Test Analysis

Lesson

Use of Force

Lesson

Tampering

Lesson

Field Protective Mask

Inspection

Procedure Type

Designation

Description or Title

Revision

OJT/TPE

Hour OJT Training

Range

Day Fire Rifle/Pistol Qualification

Course of Fire

Range

Night Fire Rifle/Pistol Course of

Fire

Range

Enhanced Weapons Course of

Fire

Range

Tactical Course of Fire/Analysis

Condition

Report

356219

373488

371689

364640

371688

ML18220A868

SUNSI Review

ADAMS:

Non-Publicly Available

Non-Sensitive

Keyword:

By: JRL

Yes No

Publicly Available

Sensitive

NRC-002

OFFICE

SPSI/PSB1

C:PSB1

C:PBA

C:PSB1

NAME

JLarsen

JGroom

MHaire

JGroom

SIGNATURE

/RA by

phone/

/RA by

DAHolman

Acting For/

/RA by

RDAlexander

Acting For/

/RA by

DAHolman

Acting For/

DATE

08/07/18

08/07/18

08/08/18

08/08/18

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