ML18067A073

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Relief Request No. 56 to Extend Third 10-year Inservice Inspection Interval for Unit 2, and to Adopt 2013 Edition of ASME Section XI for the Fourth 10-year Interval
ML18067A073
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 03/09/2018
From: Robert Pascarelli
Plant Licensing Branch IV
To: Bement R
Arizona Public Service Co
Lingam S, 301-415-1564
References
EPID L-2017-LLR-0139
Download: ML18067A073 (11)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION Mr. Robert S. Bement Executive Vice President Nuclear/

Chief Nuclear Officer Mail Station 7602 Arizona Public Service Company P.O. Box 52034 Phoenix, AZ 85072-2034 WASHINGTON, D.C. 20555-0001 March 9, 2018

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3-RELIEF REQUEST NO. 56 TO EXTEND THIRD 10-YEAR INSERVICE INSPECTION INTERVAL FOR UNIT 2, AND TO ADOPT 2013 EDITION OF ASME CODE, SECTION XI, FOR THE FOURTH 10-YEAR INTERVAL FOR UNITS 1, 2, AND 3 (EPID L-2017-LLR-0139)

Dear Mr. Bement:

By letter dated November 10, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17318A472), as supplemented by letter dated March 2, 2018 (ADAMS Accession No. ML18061A158), Arizona Public Service Company (the licensee),

submitted Relief Request No. 56, which seeks an extension to the third 10-year inservice inspection (ISi) interval pursuant to Title 10 of the Code of Federal Regulations ( 10 CFR)

Section 50.55a(z)(1), "Acceptable level of quality and safety," for Palo Verde Nuclear Generating Station (PVNGS), Unit 2. In this relief request, the licensee proposed an alternative to the requirements of American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (ASME Code),Section XI, IWA-2430, for PVNGS, Unit 2.

Specifically, the licensee proposed an extension to the third 10-year ISi interval for PVNGS, Unit 2, by approximately 8 months past the Code-allowed one-year extension (approximately 20 months total extension). In its submittal by letter dated November 10, 2017, the licensee also indicated that the planned third 10-year ISi interval examinations have been completed for Unit 2 and the interval closeout is in progress. However, in its submittal by letter dated March 2, 2018, the licensee stated that during the course of the closeout review, a limited number of ISi examinations were identified that were either not included in a previous relief request or were not performed during the third ISi interval for Unit 2, which currently ends on March 17, 2018. The licensee is planning to perform the identified examinations during the Unit 2 fall 2018 refueling outage for four ASME items.

In addition, the licensee proposed an alternative to 10 CFR 50.55a(g)(4)(ii), "Applicable ISi Code: Successive 120-month intervals," that would require PVNGS, Units 1, 2, and 3, to use the 2008 Edition of Section XI of the ASME Code, which was in effect 12 months prior to the scheduled start of the respective fourth 10-year ISi intervals for each unit. Pursuant to 10 CFR 50.55a(g)(4)(iv), "Applicable ISi Code: Use of subsequent Code editions and addenda," the licensee requested U.S. Nuclear Regulatory Commission (NRC) authorization to adopt the 2013 Edition of Section XI of the ASME Code for all three PVNGS Units for the fourth

10-year ISi interval programs, which was incorporated by reference in the 10 CFR 50.55a rule published in the Federal Register(FR) on July 18, 2017 (82 FR 32934). The licensee indicated that the relief request is to better align the fourth 10-year ISi intervals and the Code-required repair/replacement process with scheduled outages.

The NRC staff reviewed the licensee's submittal and determined that the proposed alternative for Unit 2 would provide an acceptable 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)( 1 ). Therefore, the NRC staff authorizes the extension of third 10-year ISi interval from March 17, 2018, to October 31, 2018, for PVNGS, Unit 2.

The NRC staff also reviewed the licensee's request to use the 2013 Edition of ASME Code,Section XI, for each of the three PVNGS Units for the fourth 10-year ISi interval programs. The NRC staff determined that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(g)(4)(iv).

All other ASME Code,Section XI requirements for which relief was not specifically requested and approved remain applicable, including the third-party review by the Authorized Nuclear lnservice Inspector.

If you have any questions, please contact the Project Manager, Siva P. Lingam, at 301-415-1564 or via e-mail at Siva.Lingam@nrc.gov.

Sincerely}

Docket Nos. STN 50-528, STN 50-529, and STN 50-530

Enclosures:

1. Safety Evaluation for Unit 2
2. Safety Evaluation for Units 1, 2, and 3 cc: Listserv

~--v~

Robert J. Pascarelli, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

1.0 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST NO. 56 TO EXTEND THIRD 10-YEAR INSERVICE INSPECTION INTERVAL FOR UNIT 2 ARIZONA PUBLIC SERVICE COMPANY PALO VERDE NUCLEAR GENERATING STATION, UNIT 2 DOCKET NO. 50-529 INTRODUCTION By letter dated November 10, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17318A472), as supplemented by letter dated March 2, 2018 (ADAMS Accession No. ML18061A158), Arizona Public Service Company (APS, the licensee),

submitted Relief Request No. 56 (RR-56), which seeks an extension to the third 10-year inservice inspection (ISi) interval pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(z)(1 ), "Acceptable level of quality and safety," for Palo Verde Nuclear Generating Station (PVNGS), Unit 2. In this relief request, the licensee proposed an alternative to the requirements of American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (ASME Code),Section XI, IWA-2430, for PVNGS, Unit 2.

Specifically, the licensee proposed an extension to the third 10-year ISi interval for PVNGS, Unit 2, by approximately 8 months past the Code-allowed one-year extension (approximately 20 months total extension). In its submittal by letter dated November 10, 2017, the licensee also indicated that the planned third 10-year ISi interval examinations have been completed for Unit 2 and the interval closeout is in progress. However, in its submittal by letter dated March 2, 2018, the licensee stated that during the course of the closeout review, a limited number of ISi examinations were identified that were either not included in a previous relief request or were not performed during the third ISi interval for Unit 2, which currently ends on March 17, 2018. The licensee is planning to perform the identified examinations during the Unit 2 fall 2018 refueling outage for four ASME items.

In addition, the licensee proposed an alternative to 10 CFR 50.55a(g)(4)(ii}, "Applicable ISi Code: Successive 120-month intervals," that would require PVNGS, Units 1, 2, and 3 to use the 2008 Edition of Section XI of the ASME Code, which was in effect 12 months prior to the scheduled start of the respective fourth 10-year ISi intervals for each unit. Pursuant to 10 CFR 50.55a(g)(4)(iv), "Applicable ISi Code: Use of subsequent Code editions and addenda," the licensee requested U.S. Nuclear Regulatory Commission (NRC) authorization to adopt the 2013 Edition of Section XI of the ASME Code for all three PVNGS Units for the fourth 10-year ISi interval programs, which was incorporated by reference in the 10 CFR 50.55a rule published in the Federal Register(FR) on July 18, 2017 (82 FR 32934). The licensee indicated that the relief request is to better align the fourth 10-year ISi intervals and the Code-required repair/replacement process with scheduled outages. This part of RR-56 is evaluated under.

An e-mail was sent from the licensee on February 14, 2018, to clarify technical concerns (ADAMS Accession No. ML18045A173).

2.0 REGULATORY EVALUATION

The licensee requested that the Unit 2 third ISi interval be extended by approximately 8 months beyond the Code-allowed one-year extension as an alternative to the requirements of ASME Code,Section XI, Subparagraph IWA-2430.

Paragraph 50.55a(g)(4), "lnservice inspection standards requirement for operating plants," of 10 CFR requires, in part, that the components that are classified as ASME Code Class 1, Class 2, and Class 3 must meet the requirements set forth in the editions and addenda of ASME Code,Section XI that are incorporated by reference in 10 CFR 50.55a, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The provision in 10 CFR 50.55a(z)( 1) allows that alternatives to the requirements of paragraph 50.55a(g) of 10 CFR may be used when authorized by the NRC, if the licensee demonstrates that the proposed alternative provides an acceptable level of quality and safety.

Based on the foregoing discussion and subject to the following technical evaluation, 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 ASME Code Components Affected

The proposed relief request applies to Class 1, 2, and 3 pressure retaining components and their supports.

3.2 Applicable ASME Code Edition and Addenda The current Code of Record for PVNGS, Unit 2, is the 2001 Edition of ASME Code,Section XI, through the 2003 Addenda.

3.3 Applicable ASME Code Requirement Subparagraph IWA-2430(b) of ASME Code,Section XI, requires the inspection interval to be determined by calendar years following placement of the plant into commercial service.

Paragraph IWA-2432, "Inspection Program B," specifies that the first inspection interval is 10 years following the initial start of plant commercial service and that each of the successive inspection Intervals is 10 years following the previous inspection interval.

Subparagraph IWA-2430(d)(1) states that each inspection interval may be extended as much as one year. The subparagraph also requires that the interval adjustments shall not cause successive intervals to be altered by more than one year from the original pattern of intervals.

3.4 Licensee's Proposed Alternative The licensee proposed to extend the Unit 2 third inspection interval by approximately 8 months past the Code-allowed one-year extension (with the extended end date of October 31, 2018, coincident with the end date of Unit 2 Refueling Outage 21 ). Accordingly, the Unit 2 fourth 10-year inspection interval is scheduled for November 1, 2018, through October 31, 2028. The licensee also proposed that the relief request resets the Unit 2 ISi intervals such that, the Code-allowable one-year extension will remain available for future contingencies.

3.5 Licensee's Basis of the Proposed Alternative The proposed end date of the Unit 2 third inspection interval (October 31, 2018) is scheduled between the third inspection interval end dates of Units 3 and 1 (i.e., May 31, 2018, and May 31, 2019, respectively, as the ASME Code allows a one-year extension). This alternative will better align the fourth inspection intervals of Units 1, 2, and 3. Therefore, the proposed alternative will allow more effective and efficient use of resources for the development and implementation of ISi programs at PVNGS based on a common latest edition of ASME Code,Section XI, as incorporated by reference in 10 CFR 50.55a. The licensee has utilized the year extension within past inspection intervals to perform specific examinations at Unit 2, but has not changed the overall interval dates by use of the provisions of IWA-2430.

3.6

NRC Staff Evaluation

The proposed alternative will increase the duration of the third inspection interval at PVNGS, Unit 2, by approximately 8 months beyond the Code-allowed one-year extension (i.e.,

approximately 8 months from March 17, 2018, to October 31, 2018). Therefore, the NRC staff's review focused on its effect on the implementation of the ASME Code-required ISi activities and the integrity of the affected components in order to determine whether the proposed alternative will provide an acceptable level of quality and safety.

In its review, the NRC staff evaluated whether the proposed interval extension has a potential impact on (a) the previously approved relief requests and (b) the periodic examination intervals based on specific time periods (such as calendar years and effective full power years). In the e-mail dated February 14, 2018, the licensee provided the following information to address these topics. The licensee indicated that it reviewed the approved relief requests that terminate at the end of the original third ISi interval of Unit 2. The licensee confirmed that none of these relief requests are required to be extended, nor will they be used during the proposed interval extension period. In addition, the licensee clarified that the proposed interval extension will not extend the examination intervals that are based on specific time periods (as may be scheduled for the examinations related to specific flaw analyses, ASME Code Case N-729 or ASME Code Case N-770, etc.). The NRC staff finds that the proposed Unit 2 interval extension does not have an adverse effect on the previously approved relief requests or the existing examination intervals based on specific time periods.

In its letter dated March 2, 2018, the licensee further indicated that it completed the planned third ISi interval examinations for Unit 2 and subsequently performed the closeout review of the third inspection interval. The licensee indicated that the interval closeout review discovered a limited number of examinations that had been omitted inadvertently or performed inadequately (e.g., examinations with insufficient sample sizes or per irrelevant performance demonstration procedures). The licensee confirmed that the discovered items were entered in the corrective action program and will be inspected during the next refueling outage (i.e., Refueling Outage 21 in the fall of 2018) in accordance with the requirements of ASME Code,Section XI.

In its review, the NRC staff finds that no adverse safety impact is associated with performing the examinations as indicated by the licensee. The licensee's March 2, 2018, letter, also indicates that the interval closeout review found the need for submittal of a separate relief request to address an attachment weld examination within the reactor vessel. The NRC staff noted that this item, which will be addressed in a separate relief request, is not within the scope of this safety evaluation.

In addition, the NRC staff evaluated the potential impact of the proposed third interval extension on the inspection sequence and completion pattern for the fourth ISi interval at Unit 2. The NRC staff noted that Tables IWB-2412-1, IWC-2412-1 and IWD-2412-1 of ASME Code,Section XI (for Class 1, 2, and 3 components), specify that three inspection periods in each inspection interval end at 3rd, 7th, and 101h calendar years within the interval, respectively.

These tables also specify the minimum examination percentage to be completed for each inspection period (i.e., 16, 50, and 100 percent for the first, second and third inspection period, respectively). Subparagraph IWA-2430(d)(3) of ASME Code,Section XI, further allows that an inspection period may be reduced or extended by as much as one year within the inspection interval to coincide with a refueling outage.

Given the Code-allowed one-year flexibility for inspection period schedules and the Unit 2 refueling outage pattern, the NRC staff finds that the proposed extension (approximately 8 months) of the third ISi interval does not significantly affect the inspection sequence and completion pattern for the inspection periods of the fourth interval. Therefore, the staff finds the proposed third interval extension provides acceptable, timely completion of a subsequent ISi at Unit 2.

The licensee also proposed that the Code-allowable one-year extension will remain available for future contingencies after the reset of the Unit 2 third ISi interval. The NRC staff finds that the proposal is acceptable because (a) the ongoing ISi can effectively monitor and confirm the integrity of the components subject to ISi and (b) this relief request does not affect the periodic examination intervals based on specific time periods as discussed above.

4.0 CONCLUSION

As set forth above, the NRC staff reviewed the licensee's submittal and determined that the proposed alternative for Unit 2 would provide an acceptable 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)( 1 ). Therefore, the NRC staff authorizes the extension of third 10-year ISi interval from March 17, 2018, to October 31, 2018, for PVNGS, Unit 2.

All other ASME Code,Section XI, requirements for which relief was not specifically requested and approved remain applicable, including the third-party review by the Authorized Nuclear lnservice Inspector.

Principal Contributor: S. Min, NRR/DMLR/MPHB Date:

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST NO. 56 TO ADOPT THE 2013 EDITION OF ASME CODE SECTION XI FOR THE FOURTH 10-YEAR INSPECTION INTERVAL FOR ALL THREE UNITS ARIZONA PUBLIC SERVICE COMPANY PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 DOCKET NOS. 50-528, 50-529, AND 50-530

1.0 INTRODUCTION

By letter dated November 10, 2017 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML17318A472) as supplemented by letter dated March 2, 2018 (ADAMS Accession No. ML18061A158), Arizona Public Service Company (APS, the licensee) submitted Relief Request 56 (RR-56) for the Palo Verde Nuclear Generating Station (PVNGS),

Units 1, 2, and 3, to use a later edition of American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, "Rules for lnservice Inspection [ISi] of Nuclear Power Plant Components."

Specifically, pursuant to Title 10 of the Code of Federal Regulations ( 10 CFR),

Section 50.55a(g)(4))(iv), "Applicable ISi Code: Use of subsequent Code editions and addenda," the licensee requested that PVNGS, Units 1, 2, and 3, be permitted to use the recently approved 2013 Edition of ASME Code,Section XI, for the fourth 10-year ISi intervals (as incorporated by reference in 10 CFR 50.55a). In RR-56, the licensee also proposed to extend the Unit 2 third 10-year ISi interval and that part of RR-56 is evaluated under.

2.0 REGULATORY EVALUATION

The U.S. Nuclear Regulatory Commission (NRC) staff notes that in its request the licensee proposed an alternative to the requirements of the ASME Code (i.e., the use of a later edition of the Code) in accordance with 10 CFR 50.55a(g)(4)(iv). The staff also notes that paragraph 50.55a(g)(4)(iv) of 10 CFR states the following:

lnservice examination of components and system pressure tests may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in paragraph (a) of this section, subject to the conditions listed in paragraph (b) of this section, and subject to Commission approval. Portions of editions or addenda may be used, provided that all related requirements of the respective editions or addenda are met.

Given that the licensee has proposed the use of a later edition of the ASME Code pursuant to 10 CFR 50.55a(g)(4)(iv) and that 10 CFR 50.55a(g)(4)(iv) specifically permits the use of later editions of the ASME Code subject to technical criteria, which will be considered below, the NRC staff finds that regulatory authority exists to authorize the use of a subsequent edition of the ASME Code, as requested by the licensee.

3.0 TECHNICAL EVALUATION

3.1 ASME Code Components Affected

The proposed relief request applies to Class 1, 2, and 3 pressure retaining components and their supports.

3.2 Applicable ASME Code Edition and Addenda The current Code of Record for the third ISi intervals for PVNGS, Units 1, 2 and 3, is the 2001 Edition of ASME Code,Section XI, through the 2003 Addenda. The licensee also indicated that the 2007 Edition with the 2008 Addenda of the ASME Code is the applicable Code edition and addenda for the fourth ISi interval of each unit because the edition and addenda of the ASME Code would be in effect 12 months prior to the scheduled start of the respective fourth ISi interval for each unit.

In lieu of the 2007 Edition with the 2008 Addenda of ASME Code,Section XI, the licensee proposed to use the 2013 Edition of ASME Code,Section XI, for the fourth inspection intervals at PVNGS, Units 1, 2, and 3, as described in Table 1 below. The licensee also requested that the repair and replacement programs at PVNGS, Units 1, 2, and 3, in accordance with the 2013 Edition of the ASME Code, begin on a common date (June 1, 2018) coincident with the proposed first implementation of the fourth ISi interval (i.e., start date of Unit 3 fourth ISi interval).

Table 1. Code Edition/Addenda for PVNGS Units ISi Interval Unit Code Edition/Addenda<1>

Start Date End Date 1

2001 Edition through 2003 Addenda July 18, 2008 May 31, 2019(2>

Third 2

2001 Edition through 2003 Addenda March 18, 2007 October 31, 2018(3>

3 2001 Edition through 2003 Addenda January 11, 2008 May 31, 2018(2) 1 2013 Edition (Proposed)

June 1, 2019 July 17, 2028 Fourth 2

2013 Edition (Proposed)

November 1, 2018 October 31, 2028 3

2013 Edition (Proposed)

June 1, 2018 January 10, 2028 Notes:

( 1) The repair and replacement programs of Units 1, 2 and 3, in accordance with the 2013 Edition of ASME Code,Section XI, are proposed to begin on a common date (June 1, 2018) coincident with the proposed first implementation of the fourth ISi interval (i.e., start date of the Unit 3 fourth ISi interval).

(2) These end dates of the third ISi intervals for Units 1 and 3 are based on Code-allowed extension (up to 1 year).

(3) This end date is based on the relief request (RR-56) to extend the Unit 2 third inspection interval by approximately 8 months beyond the Code-allowed one-year extension. This part of RR-56 is evaluated in another safety evaluation.

The licensee indicated that the 2013 Edition of ASME Code,Section XI, was incorporated by reference in 10 CFR 50.55a with an effective date of August 17, 2017 (as published in the Federal Register(FR) on July 18, 2017 (82 FR 32934)). The licensee also indicated that the proposed use of the latest approved edition of the ASME Code for the fourth ISi intervals and the repair/replacement processes (beginning on June 1, 2018) allows effective and efficient use of resources for development and implementation of PVNGS ISi programs. The license further indicated that the use of the approved edition of the ASME Code will provide an acceptable level of quality and safety.

3.3

NRC Staff Evaluation

Based on the requirements in 10 CFR 50.55a(g)(4)(iv), the NRC staff considered the following criteria in its review of the licensee's application:

1) The proposed edition/addenda of the ASME Code is incorporated by reference in 10 CFR 50.55a(a).
2) The proposed edition/addenda of the ASME Code is subject to the conditions listed in 10 CFR 50.55a(b).
3) The licensee shall request Commission approval to use the proposed edition/addenda of the ASME Code.
4) If only portions of editions or addenda are to be used all related requirements of the respective editions or addenda must be met.

In evaluating the first criterion (i.e., that the proposed edition/addenda of the ASME Code has been incorporated by reference in 10 CFR 50.55a(a)), the NRC staff notes that the 2013 Edition of ASME Code,Section XI, has been incorporated by reference in 10 CFR 50.55a(a) as the related Final Rule (82 FR 32934 ). Therefore, the NRC staff finds that the first criterion has been satisfied.

In evaluating the second criterion (i.e., that the conditions listed in 10 CFR 50.55a(b) are satisfied for the proposed subsequent edition and addenda of the ASME Code,Section XI), the NRC staff notes that the licensee proposed to use the 2013 Edition of ASME Code,Section XI, as incorporated by reference in 10 CFR 50.55a, with the conditions that are applied for the Code edition. Therefore, the NRC staff finds that the second criterion has been satisfied.

In evaluating the third criterion (i.e., that the licensee shall request Commission approval to use the proposed edition/addenda of the ASME Code), the NRC staff notes that the licensee's relief request constitutes a request to the Commission for approval to use a subsequent edition/addenda of the ASME Code. Therefore, the NRC staff finds that the third criterion has been satisfied.

In evaluating the fourth criterion (i.e., that if portions of subsequent editions or addenda of the ASME Code,Section XI are used, all related requirements of the respective editions or addenda must be met), the NRC staff notes that the licensee proposed to use all relevant requirements specified in the 2013 Edition of the ASME Code, as incorporated by reference in 10 CFR 50.55a, in the development and implementation of PVNGS ISi programs and activities.

Therefore, the NRC staff finds that the fourth criterion is not applicable.

Based on the above, the NRC staff finds that the criteria contained in 10 CFR 50.55a(g)(4)(iv) are satisfied. Therefore, the NRC staff finds that the licensee's request to use the 2013 Edition of ASME Code,Section XI, is acceptable for the fourth interval ISi programs and the repair/replacement programs (beginning on June 1, 2018, to the respective end of fourth ISi interval) at PVNGS, Units 1, 2, and 3, as described in Section 3.3 of this safety evaluation.

4.0 CONCLUSION

As set forth above, the NRC staff determines that the use of a later edition of ASME Code,Section XI requirements is acceptable. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(g)(4)(iv). Therefore, the NRC staff approves the use of the 2013 Edition of ASME Code,Section XI, for the fourth interval ISi programs and the repair/replacement programs (beginning on June 1, 2018) at PVNGS, Units 1, 2 and 3, as described in Section 3.2 of this safety evaluation.

All other ASME Code,Section XI requirements for which relief was not specifically requested and approved remain applicable, including third-party review by the Authorized Nuclear lnservice Inspector Principal Contributor: S. Min, NRR/DMLR/MPHB Date: March 9, 2018

ML18067A073

  • SE via email OFFICE NRR/DORULPL4/PM NRR/DORULPL4/LA NRR/DMLR/MPHB/BC*

NRR/DORULPL4/BC NAME Slingam PBlechman DAIiey RPascarelli (LRegner for)

DATE 03/09/2018 03/09/2018 03/06/2018 03/09/2018