ML17298A416
| ML17298A416 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 11/01/2017 |
| From: | Markley M Plant Licensing Branch II |
| To: | Hutto J Southern Nuclear Operating Co |
| Williams S, NRR/DORL/LPLII-1, 415-1009 | |
| References | |
| EPID L-2017-LLR-0123 | |
| Download: ML17298A416 (12) | |
Text
(1 UNITED STATES 0
3:: NUCLEAR REGULATORY COMMISSION 0 WASHINGTON. D.C 20555-0001
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November 1, 2017
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Mr. James J. Hutto Regulatory Affairs Director Southern Nuclear Operating Company, Inc.
P.O. Box 1295 I Bin 038 Birmingham, AL 35201-1295
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 - INSERVICE INSPECTION ALTERNATIVE FOR CODE CASE N-786-1 (FNP-ISl-ALT-22)
Dear Mr. Hutto:
By letter dated October 24, 2017, Southern Nuclear Operating Company, Inc. (SNC, the licensee), submitted a relief request (FNP-ISl-ALT-22) for the Joseph M. Farley Nuclear Plant, Units 1 and 2. The licensee proposed to use the American Society of Mechanical Engineers (ASME) of Code Case N-786-1 as an alternative. Code Case N-786-1 permits installation of technically sound, long-term repairs in the form of full-structural Type B reinforcing sleeves for piping systems.
Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z)(2), the licensee proposed to use an alternative on the basis that complying with the specified requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the proposed alternative and concludes, as set forth in the enclosed safety evaluation, that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(2). Therefore, the NRC staff authorizes the use of alternative request FNP-ISl-ALT-22, for Joseph M. Farley Nuclear Plant, Units 1 and 2, for the fourth 10-year ISi interval, which is scheduled to end on November 30, 2017.
All other ASME Code,Section XI, requirements for which relief was not specifically requested and authorized herein by the NRC staff remain applicable, including third-party review by the Authorized Nuclear lnservice Inspector.
J. J. Hutto If you have any questions, please contact the Senior Project Manager, Shawn Williams, at 301-415-1009 or by e-mail at Shawn.Williams@nrc.gov.
Sincerely, Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364
Enclosure:
Safety Evaluation cc: Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST FNP-ISl-ALT-22, REGARDING CODE CASE N-786-1 SOUTHERN NUCLEAR OPERATING COMPANY, INC.
JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-348 AND 50-364
1.0 INTRODUCTION
By letter dated October 24, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17299A685), Southern Nuclear Operating Company (SNC, the licensee) submitted a request to the U.S. Nuclear Regulatory Commission (NRC) for the use of alternatives to the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, Article IWA-4000, for the specific repair/replacement activity identified in proposed alternative FNP-ISl-ALT-22 at Joseph M. Farley Nuclear Plant (FNP),
Units 1 and 2.
Specifically, pursuant to Title 10 of the Code of Federal Regulations (1 O CFR) 50.55a(z)(2),
SNC proposed an alternative to use ASME Code Case N-786-1, "Alternative Requirements for Sleeve Reinforcement of Class 2 and 3 Moderate Energy Carbon Steel Piping Section XI, Division 1" (Code Case), to repair defects in ASME Code Class 2 and 3 moderate energy piping without removing the existing defect by installing sleeves around the piping, thereby restoring structural integrity and/or leak tightness to the degraded pipe on the basis that compliance with the specified ASME Code repair would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
2.0 REGULATORY EVALUATION
Adherence to Section XI of the ASME Code is mandated by 10 CFR 50.55a(g)(4), which states, in part, that ASME Code Class 1, 2, and 3 components (including supports) will meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code,Section XI.
The regulation in 10 CFR 50.55a(z) states, in part, that alternatives to the requirements of paragraph (g) of 10 CFR 50.55a may be used, when authorized by the NRC, if the licensee demonstrates that (1) the proposed alternative provides an acceptable level of quality and safety, or (2) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Enclosure
Based on the above, the NRC staff finds that regulatory authority exists for the licensee to request the use of an alternative and the NRC to authorize the proposed alternative.
3.0 TECHNICAL EVALUATION
3.1 Licensee's Proposed Alternative 3.1.1 ASME Code Component(s) Affected The affected components are ASME Code Class 2 and 3 moderate energy carbon steel piping systems that carry fluid at a maximum operating temperature and pressure of less than or equal to 200 degrees Fahrenheit (°F) and 275 pounds per square inch gauge (psig), respectively.
3.1.2 Applicable Code Edition and Addenda The Code of Record for the fourth 10-year inservice inspection (ISi) interval at FNP, Units 1 and 2, is the ASME Code,Section XI, 2001 Edition through the 2003 Addenda. The fourth 10-year ISi interval at FNP began on December 1, 2007, and is scheduled to end on November 30, 2017.
3.1.3 Applicable Code Requirement Article IWA-4000 of the ASME Code,Section XI, provides requirements for welding, brazing, metal removal, and installation of repair/replacement activities.
3.1.4 Reason for Request In its letter dated October 24, 2017, the licensee stated that repair and replacement provisions of IWA-4000 cannot always be utilized when degradation or leakage is identified during plant operations. Other approved alternative repair or evaluation methods are not always practicable because of wall thinness and/or moisture issues.
The licensee stated the proposed alternative will permit installation of technically sound temporary repairs, in the form of Type A or partial-structural Type B reinforcing sleeve, while providing time to plan and prepare for a permanent repair. The Code Case also permits long-term repairs in the form of full-structural Type B reinforcing sleeves for locally degraded piping.
3.1.5 Proposed Alternative and Basis for Use Pursuant to 10 CFR 50.55a(z)(2), the licensee proposes to implement ASME Code Case N-786-1, in lieu of the requirements of ASME Code,Section XI, Article IWA-4000, for repair of degradation in Class 2 and 3 carbon steel piping systems with less than or equal to 200 °F (93 degrees Celsius) and less than or equal to 275 psig (1.9 MPa) for maximum operating conditions, resulting from mechanisms such as localized erosion, corrosion, cavitation, or pitting, but excluding conditions involving any form of cracking. The licensee stated that these types of defects are typically identified by small leaks in the piping system or by preemptiv~. non-Code required ultrasonic thickness measurements performed to monitor for degradation mechanisms.
Code Case N-786-1 provides the design of Type A, partial-structural Type B, and full-structural Type B sleeves to repair the subject pipe. The three types of sleeve reinforcements provided in the Code Case are described below.
Type A Sleeve Type A reinforcing sleeves, as shown in Figure 1 of Code Case N-786-1, may be used for structural reinforcement of thinned areas which are not expected to penetrate the wall and cause leakage. The piping longitudinal stresses must meet the requirements of the Construction Code. Type A reinforcing sleeves have a maximum service life of the time until the next refueling outage.
Partial-Structural Type B Sleeve Partial-structural Type B reinforcing sleeves, as shown in Figure 2 of Code Case N-786-1, may be used for pressure plus partial-structural reinforcement of thinned areas that penetrate, or are expected to penetrate the wall and cause leakage. Partial-structural reinforcement is designed to accommodate design loadings at the segment being reinforced, taking partial credit for the degraded segment after factoring in predicted degradation over the life of the repair. Partial credit is considered taken if the design relies on any portion of the segment of piping beneath the sleeve, other than the base metal beneath the attachment welds, to provide structural or pressure integrity. Partial-structural reinforcing sleeves shall have a maximum service life of the time until the next refueling outage.
Full-Structural Type B Sleeve Full-structural Type B reinforcing sleeves, as shown in Figure 2 Code Case N-786-1, may be used for pressure plus full-structural reinforcement of thinned areas that penetrate, or are expected to penetrate the wall and cause leakage. Full-structural reinforcement is designed to accommodate pressure plus axial and circumferential design loadings at the location for the design life of the repair without taking credit for any portion of the degraded segment.
Full-structural reinforcement sleeves shall be removed and the piping repaired or replaced in accordance with Article IWA-4000 no later than the end of the design life of the repair.
As stated in its letter dated October 24, 2017, the licensee's proposed alternative will follow Code Case N-786-1 with the following restrictions and clarifications:
- 1) When gasket material is used in accordance with paragraph 4(b) of the Code Case (water backed applications), SNC will also require removal of any residual moisture by heating prior to welding.
- 2) Regarding paragraph 8(c) and 8(c)(1) of the Code Case, SNC will implement the thickness monitoring inspections of full-structural Type B sleeves at every refueling outage, and will schedule more frequent thickness monitoring, when appropriate based on degradation rates that are calculated using the reductions in thicknesses observed between scheduled thickness monitoring inspections.
- 3) Sections 1, 3, 5, and 6 of the Code Case specify that materials, design, installation, and examination of reinforcement sleeves shall be performed in accordance with the Construction Code or ASME Section Ill applicable
to FNP. As allowed by IWA-4200 and IWA-4411, later Editions and Addenda of the Construction Code or ASME Section Ill may be used provided any required reconciliations are performed. However, only Editions/Addenda of ASME Section Ill that have been approved by the NRC in 10 CFR 50.55a will be used.
- 4) FNP performs repair/replacement activities in accordance with a Repair/Replacement Program based on the 2001 Edition/2003 Addenda of ASME Section XI for the current Inspection Interval. Therefore, this Edition/Addenda of ASME Section XI will be used by Farley Nuclear Plant whenever the Code Case refers to IWA-4000.
- 5) If a buried piping system carrying radioactive fluid is repaired using this alternative, FNP will monitor for radioactive fluid leakage in accordance with the standard plant monitoring practices for all buried piping containing radioactive fluids. FNP is committed to implementation of Nuclear Energy Institute (NEI) 07-07, "Industry Ground Water Protection Initiative - Final Guidance Document," dated August 2007, in addition to monitoring in accordance with ASME Code Case N-786-1.
The licensee stated that Code Case N-786-1 was approved by ASME Board on Nuclear Codes and Standards in January 2015. However, it has not been incorporated into NRC Regulatory Guide 1.147, "lnservice Inspection Code Case Acceptability, ASME Section XI, Division 1," and, thus, is not available for application at nuclear power plants without specific NRC approval.
3.1.6 Hardship Justification The licensee stated that the proposed alternative provides technically sound temporary repairs in the form of reinforcing sleeves where there is inadequate time for evaluation, design, material procurement, planning and scheduling of an appropriate permanent repair or replacement, due to the impact on system availability, maintenance rule applicability, or availability of replacement materials. Additionally, the proposed alternative provides technically sound long-term repairs configured to permit ongoing degradation monitoring, equal to or exceeding the level of quality and safety associated with permanent ASME Code repairs or replacements. The licensee stated that performing repairs in accordance with Article IWA-4000 could, in some cases, necessitate extending technical specification actions to install a permanent repair/replacement, putting the plant at higher safety risks than warranted compared with the short time necessary to install a technically sound sleeve repair. The licensee further stated that without the use of this Code Case in some situations, it may be necessary to shut down the plant in order to perform an ASME Code repair/replacement activity; however, this results in an unnecessary plant transient and the loss of safety system availability as compared to maintaining the plant online.
3.1. 7 Duration of Proposed Alternative The licensee requested the proposed alternative for the remainder of fourth 10-year ISi interval at FNP, Units 1 and 2, which is scheduled to end on November 30, 2017. Any Type A and partial-structural Type B reinforcing sleeves installed before the end of the fourth 10-year ISi interval will be removed during the next refueling outage, even if that refueling outage occurs after the end of the 10-year ISi interval.
3.2 NRC Staff's Evaluation The NRC staff considered the licensee's proposed alternative to consist of the Code Case, which has not been approved for use by the NRC, and the clarification/restrictions as discussed above. For clarity, the NRC staff's review of the proposed alternative will follow the organizational structure of the Code Case. The NRC staff notes that not all portions of the Code Case are discussed below; however, use of the Code Case requires that the licensee comply with the Code Case in its entirety.
3.2.1 General Requirements The licensee proposed no modifications to Section 1, General Requirements, of the Code Case.
The NRC staff finds acceptable that the design, material, and installation of the sleeve will follow the ASME Code,Section XI, Article IWA-4000 and Subarticle IWA-4150.
The NRC staff notes that paragraph 1(e) of the Code Case limits the repair to piping that is not required to be examined by ultrasonic examination, during ISi examinations, to be of significance as ultrasonic examinations may not provide reliable results when performed through sleeves once they are installed on a pipe. Therefore, the NRC staff finds the limitation imposed by paragraph 1(e) acceptable.
Paragraph 1(f) of the Code Case prohibits the application of reinforcing sleeves to pumps, valves, expansion joints, vessels, heat exchangers, tubing, flanges, flanged joints, socket welded or threaded joints, or branch connection welds. The NRC staff finds these limitations acceptable because the sleeve design, as specified in the Code Case, is not suitable to be used in the aforementioned configurations such as pumps, valves, and flanges.
The NRC staff finds that the contents of Section 1 of the Code Case provide reasonable assurance for the structural integrity of the pipes using the sleeve repair method.
3.2.2 Initial Evaluation The licensee proposed no modifications to Section 2, Initial Evaluation, of the Code Case.
The NRC staff finds that paragraph 2(a) of the Code Case, which requires the extent of the initial inspection be based on the corrosion mechanism involved but will extend at least a distance of 0.75../ RTnom (R is the radius of the pipe and Tnom is the thickness) beyond the edge of any sleeve attachment weld, to be a reasonable inspection distance to assure that the sleeve repair will be welded to a section of pipe with sufficient strength to support the repair.
The NRC staff finds that paragraph 2(b) of the Code Case, which requires that the extent and rate of degradation in the piping be evaluated to ensure that there no other unacceptable locations within the surrounding area that could affect the integrity of the reinforced areas for the life of the repair, provides reasonable assurance that degradation in the area surrounding the repair will not affect the integrity of the repair and is, therefore, acceptable.
The NRC staff finds that paragraph 2(c) of the Code Case provides specific guidance (i.e., the ASME Code,Section XI, Paragraph IWA-4311) to evaluate the impact of the sleeve and attachment weld on the pipe. The NRC staff finds this acceptable because the impact of the
change in design and configuration of the piping, as a result of the installation of the sleeve, will be evaluated in accordance with ASME Code,Section XI.
As stated in the proposed alternative, if the cause of the degradation is not determined, the maximum permitted service life of any reinforcing sleeve shall be the time until the next refueling outage. The NRC staff finds this limitation acceptable because it is a defense-in-depth measure to prohibit the long-term use of the sleeve if the pipe degradation is unknown.
The NRC staff finds the initial evaluation requirements in Section 2 of the Code Case as proposed by the licensee to be acceptable.
3.2.3 Design The licensee proposed no modifications to Section 3, Design, of the Code Case, except the additional clarification, as discussed below:
The NRC staff finds that the design as required in paragraphs 3.1 (a) and 3.1 (b) and additional clarification on the sleeve service life acceptable because the allowable duration for use of each type of sleeve to be consistent with the intended function described as well as initial and subsequent inspection requirements.
The NRC staff finds paragraph 3.2(a) acceptable because the sleeve design will follow the ASME Code, Section Ill, NC/ND-3100 and NC/ND-3600, and Section Ill Appendices, such as Mandatory Appendix II.
The NRC staff finds the method used to determine the degradation rate selected for the design of the sleeve specified in paragraph 3.2(k) of the Code Case to be of critical importance to the acceptability of the proposed alternative. The NRC staff finds that: (a) the use of plant-specific, measured corrosion rates; (b) the requirement that the corrosion mechanism be determined or the repair removed at the next refueling outage; and (c) the use of a safety factor of either 2 or 4 as required in paragraph 3.2(k) of the Code Case will provide an adequate corrosion rate to ensure that the sleeves will perform their intended functions for either the life of the repair (Type A and partial-structural Type B) or until the next scheduled inspection (full-structural Type B). The NRC staff further finds acceptable that the proposed alternative has specified acceptance criteria to remove a degraded full-structural Type B sleeve prior to either the sleeve, attachment welds, or the pipe wall beneath the attachment welds reaching the minimum design thickness as required by the Construction Code or the ASME Code, Section Ill.
The NRC staff finds paragraph 3.2(o) of the Code Case acceptable because it permits branch connections less than 1-inch or smaller in size to be installed on sleeve only for the filling or venting purposes during installation or leakage testing of the sleeve. The NRC staff finds that the small branch connection will not affect the structural integrity of the sleeve significantly.
3.2.4 Water-Backed Applications The licensee proposed no modifications to Section 4, Water Backed Applications, of the Code Case, except the additional limitation discussed below.
Paragraph 4(a) of the Code Case requires that the shielded metal arc welding and low-hydrogen electrodes be used to weld the sleeves on water-backed piping. The low-hydrogen electrode will minimize the introduction of hydrogen in the finished weld, thereby
minimizing the potential for weld cracking. Therefore, the NRC staff finds paragraph 4(a) of the Code Case acceptable.
For piping materials other than P-No. 1 Group 1, the licensee will perform a surface examination of welds no sooner than 48 hours2 days <br />0.286 weeks <br />0.0658 months <br /> after completion of welding as required in paragraph 4(c).
The NRC staff finds this requirement acceptable because in the unlikely event that hydrogen cracking occurs, it would occur within 48 hours2 days <br />0.286 weeks <br />0.0658 months <br /> and thus be detected during the surface examination of a completed weld.
Regarding paragraph 4(b) of the Code Case, the proposed alternative states that Type B reinforcing sleeves may be applied to leaking systems by installing a gasket or sealant between the sleeve and the pipe, and then clamping the reinforcing sleeve halves to the piping prior to welding. If welding of any type of sleeve occurs on a wet surface, the maximum permitted life of the sleeve will be the time until the next refueling outage. The NRC staff finds that the limitation for a sleeve that is welded on a wet surface is acceptable because this limitation ensures that the sleeve repair will only be effective for a short duration to minimize the potential extent of degradation prior to a permanent repair being performed.
In addition, the licensee stated that when gasket material is used in accordance with paragraph 4(b) of the Code Case in water-backed applications, it will require removal of any residual moisture by heating prior to welding. The NRC staff finds this requirement acceptable because residual moisture, which is detrimental to welding, will be removed prior to welding.
3.2.5 Installation The licensee proposed no modifications to Section 5, Installation, of the Code Case:
The NRC staff finds that paragraphs 5(a), (b), (c), (d), and (f) of Code Case N-786-1 appropriately address weld joint fit-up, cleanliness, and control of moisture and are, therefore, acceptable. If welding of any type of sleeve occurs on a wet surface, the maximum permitted life of the sleeve will be the time until the next refueling outage.
The NRC staff finds that the welding requirements in paragraph 5(e) are acceptable because welding of the sleeve will follow the ASME Code,Section IX, and the Construction Code.
Paragraph 5(g) of the Code Case specifies the need for venting during the final closure weld or pressure testing. The NRC staff determines that the limitation on the use of branch connections for the above-stated purposes to 1-inch normal pipe size or smaller as specified in paragraph 3.2(o) of the Code Case to be reasonable because the limitation on branch connection size is needed to minimize any adverse loadings from the branch connection to affect the structural integrity of the installed sleeve.
3.2.6 Examination The licensee proposed no modifications to Section 6, Examination, of the Code Case, which provides requirements for the acceptance examination of the repaired pipe immediately after the sleeve installation.
The proposed alternative will follow the requirements of the Construction Code or the ASME Code, Section Ill, in the acceptance examination of the installed sleeve and will disposition any examination results accordingly as stated in paragraph 6(a) of the Code Case. Therefore, the
NRC staff finds the acceptance examination is adequate to provide reasonable assurance of the structural integrity of the repaired pipe and is, therefore, acceptable.
3.2.7 Pressure Testing The licensee proposed no modifications to Section 7, Pressure Testing, of the Code Case. The NRC staff finds that the proposed pressure testing is acceptable because it is consistent with Article IWA-5000 of the ASME Code,Section XI.
3.2.8 lnservice Examination The licensee proposed no modifications to Section 8, lnservice Examination, of the Code Case.
The Code Case requires the following inservice examinations of full-structural Type B sleeves:
(1) Examine the full-structural Type B sleeve, attachment weld and underlying base metal every refueling outage to ensure that minimum required thickness per the Construction Code or the ASME Code, Section Ill, is not violated; (2) Perform more frequent inspections of the thickness when warranted by the degradation rate; (3) Make physically accessible for the inspection of the buried pipe after repaired by a full-structural Type B sleeve; (4) Continue to monitor and evaluate wall thickness of any full-structural Type B sleeve inservice after the end of the ISi intervals; and (5) Remove the full-structural Type B sleeve prior to infringing upon design minimum wall thickness.
The NRC staff determined that the proposed ISi for the full-structural Type B sleeve is acceptable because the inspection frequency, inspection accessibility, and acceptance criteria are adequate to monitor the condition of the full-structural Type B sleeve repair and provides reasonable assurance that the sleeve will maintain structural integrity while in service.
The Code Case requires monthly monitoring of the Type A sleeve and partial-structural Type B sleeve. If these sleeve repairs are inaccessible for direct observation, the licensee may visually evaluate the surrounding area of the repaired pipe location or leakage collection system if available. The NRC staff finds that a monthly visual examination is sufficient to monitor the structural integrity and leak tightness of the Type A sleeve and partial-structural Type B sleeve because these two sleeve repairs have a limited design life to the next refueling outage.
3.2.9 Hardship Justification The NRC staff evaluated the technical aspects of this request against the criteria contained in 10 CFR 50.55a(z)(2) (i.e., the existence of a hardship or unusual difficulty without a compensating increase in quality or safety). The NRC staff finds that performing the specified ASME Code compliant repairs could result in higher risk associated with system unavailability as a result of taking the affected system piping out of service. In addition, performing the specified ASME Code compliant repairs could cause an unnecessary plant shutdown, resulting
in an unnecessary plant transient. The NRC staff, therefore, finds that requiring an ASME Code compliant repair is a hardship without a compensating increase in plant quality or safety.
3.2.1 O Summary Based on the above, the NRC staff concludes that the proposed alternative will provide reasonable assurance of the structural integrity and leak tightness of the repaired pipe because:
(1) the scope of sleeve application is clearly defined; (2) the licensee will design and install the sleeve in accordance with the Construction Code, and the ASME Code, Sections Ill (as applicable), IX, and XI; (3) the proposed evaluation of the degraded pipe prior to sleeve installation is adequate; (4) welding associated with the sleeve repair will be performed in accordance with the ASME Code,Section IX and the Construction Code; (5) the proposed acceptance examinations, preservice and inservice examinations are adequate to verify the pipe wall thickness and the condition of the repair; and (6) the licensee will perform pressure testing in accordance with the ASME Code,Section XI, Article IWA-5000.
4.0 CONCLUSION
As set forth above, the NRC staff determined that the proposed alternative provides reasonable assurance of structural integrity and leak tightness of the subject piping and that complying with the specified ASME Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(2). Therefore, the NRC staff authorizes the use of proposed alternative FNP-ISl-ALT-22 for the repair of ASME Code Class 2 and 3 moderate energy carbon steel piping at FNP, Units 1 and 2, for the fourth 10-year ISi interval.
The authorization of proposed alternative FNP-ISl-ALT-22 does not imply or infer NRC approval of ASME Code Case N-786-1.
All other ASME Code,Section XI, requirements for which relief was not specifically requested and authorized by the NRC staff will remain applicable, including third-party review by the Authorized Nuclear lnservice Inspector.
Principal Contributor: R. Davis Date: November 1, 2017
ML17298A416 *via e-mail OFFICE NRR/DORULPL2-1 /PM NRR/DORULPL2-1 /LA NRR/DMLR/MPHB/BC* N RR/DORULPL2-1 /BC NAME SWilliams KGoldstein (JBurkhardt for) DAiiey MMarkley DATE 10/31/2017 10/31/2017 10/30/2017 11/01/2017