ML19338G372

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Alternative Requests RR-05-01 and RR-05-02 for the Fifth 10-Year Inservice Inspection Interval
ML19338G372
Person / Time
Site: Millstone Dominion icon.png
Issue date: 12/18/2019
From: James Danna
NRC/NRR/DORL/LPL1
To: Stoddard D
Dominion Energy Nuclear Connecticut
Guzman R
References
EPID L-2019-LLR-0031, EPID L-2019-LLR-0032
Download: ML19338G372 (12)


Text

December 18, 2019 Mr. Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Blvd.

Glen Allen, VA 23060-6711

SUBJECT:

MILLSTONE POWER STATION, UNIT NO. 2 - ALTERNATIVE REQUESTS RR-05-01 AND RR-05-02 FOR THE FIFTH 10-YEAR INSERVICE INSPECTION INTERVAL (EPID L-2019-LLR-0031 AND EPID L-2019-LLR-0032)

Dear Mr. Stoddard:

By letter dated March 29, 2019 (Agencywide Documents Access and Management System Accession No. ML19106A049), Dominion Energy Nuclear Connecticut, Inc. (the licensee) submitted alternative requests RR-05-01 and RR-05-02 for the fifth 10-year inservice inspection (ISI) interval for Millstone Power Station, Unit No. 2 (Millstone 2).

Specifically, pursuant to Title 10 of the Code of Federal Regulations 50.55a(z)(1) and (z)(2), the licensee requested to use the proposed alternative request RR-05-01 on the basis that the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),

Section XI requirements constitute a hardship without a compensating increase in quality and safety and proposed alternative request RR-05-02 on the basis that the proposed alternative provides an acceptable level of quality and safety.

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the subject requests and concludes, as set forth in the enclosed safety evaluation, that the licensee has adequately addressed all the regulatory requirements set forth in 10 CFR 50.55a(z)(1) and 10CFR 50.55a(z)(2). Therefore, the NRC staff authorizes RR-05-01 and RR-05-02 for the duration of the fifth 10-year inservice inspection interval at Millstone 2, which is scheduled to begin on April 1, 2020, and end on March 31, 2030.

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 Inservice Inspector.

D. Stoddard If you have any questions, please contact the Millstone Project Manager, Richard Guzman, at 301-415-1030 or by e-mail to Richard.Guzman@nrc.gov.

Sincerely,

/RA/

James G. Danna, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-336

Enclosure:

Safety Evaluation cc: Listserv

Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ALTERNATIVE REQUESTS RELATED TO THE FIFTH 10-YEAR INSERVICE INSPECTION INTERVAL DOMINION ENERGY NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION, UNIT NO. 2 DOCKET NO. 50-336

1.0 INTRODUCTION

By letter dated March 29, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19106A049), Dominion Energy Nuclear Connecticut, Inc. (the licensee) submitted alternative requests for the fifth 10-year inservice inspection (ISI) interval at Millstone Power Station, Unit No. 2 (Millstone 2), which is scheduled to begin on April 1, 2020, and end on March 31, 2030. The licensee requested relief from the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code).

The licensee requested proposed alternative, RR-05-01, to conduct the required VT-2 examination of the lower portion of the reactor pressure vessel (RPV) at ambient conditions rather than at normal operating pressure (NOP) and normal operating temperature (NOT).

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z)(2), the licensee requested to use proposed alternative RR-05-01 on the basis that the ASME Code requirements constitute a hardship without a compensating increase in quality and safety.

The licensee also requested proposed alternative, RR-05-02, to use phased array ultrasonic testing (PAUT) in lieu of the required radiographic testing (RT) in the examination of welds in ferritic and austenitic piping as part of the repair and replacement activities at Millstone 2.

Specifically, pursuant to 10 CFR 50.55a(z)(1), the licensee requested to use proposed alternative RR-05-02 on the basis that the alternative provides an acceptable level of quality and safety.

2.0 REGULATORY EVALUATION

The regulation in 10 CFR 50.55a(g)(4) states, in part, that ASME Code Class 1, 2, and 3 components (including supports) must meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in Section XI of the applicable editions and addenda of the ASME Code to the extent practical within the limitations of design, geometry, and materials of construction of the components. The pressure retaining components of the pressure retaining boundary are categorized as ASME Code Class 1 components. Therefore, per 10 CFR 50.55a(g)(4), ISI of these components must be performed in accordance with Section XI of the applicable edition and addenda of the ASME Code.

The regulations in 10 CFR 50.55a(z) state: Alternatives to the requirements of paragraphs (b) through (h) of this section or portions thereof may be used when authorized by the Director, Office of Nuclear Reactor Regulation.

In proposing alternatives, a licensee must demonstrate that the proposed alternatives provide an acceptable level of quality and safety (10 CFR 50.55a(z)(1)), or compliance would result in hardship or unusual difficulty, without a compensating increase in the level of quality and safety (10 CFR 50.55a(z)(2)). Section 50.55a of 10 CFR allows the U.S. Nuclear Regulatory Commission (NRC or the Commission) to authorize alternatives and to grant relief from ASME Code requirements upon making the necessary findings.

Based on the above, and subject to the following technical evaluation, the NRC staff finds that regulatory authority exists for the licensee to request, and the Commission to authorize, the alternatives requested by the licensee.

3.0 TECHNICAL EVALUATION

3.1 Licensees Request for Alternative RR-05-01 The request is proposed in accordance with 10 CFR 50.55(z)(2) for the duration of the fifth 10-year ISI interval at Millstone 2. The fifth 10-year ISI interval for Millstone 2 is scheduled to begin on April 1, 2020, and end on March 31, 2030.

ASME Code Components Affected The request applies to the system leakage test requirements for all Class 1 pressure retaining components contained in Category B-P, Item No. B15.10, in Section XI of the ASME Code. The request is applicable to the performance of VT-2 pressure testing of the lower portion of the RPV.

ASME Code Edition and Addenda The Code of Record for the inspection of ASME Code Class 1, 2, and 3 components is the 2013 Edition of the ASME Code,Section XI (No Addenda).

Applicable Code Requirements The applicable inspection requirement for this component is contained in Examination Category B-P, Item No. B15.10, which is listed in Table IWB-2500-1, Examination Categories, of the ASME Code,Section XI. This item requires a system leakage test and VT-2 visual examination every refueling outage of all pressure containing components, as indicated in Article IWB-5220, System Leakage Test, of the ASME Code,Section XI. The licensee proposes to eliminate the ASME Code requirement to perform a system leakage test by conducting a hydrostatic test at normal operating pressure. Instead, the licensee proposes to perform the required VT-2 visual examination during ambient conditions following the reactor cooling system cooldown. The licensee proposes to look for evidence of leakage and boric acid corrosion during the proposed VT-2 examination at ambient conditions.

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Reason for Request===

The licensee states, in part:

Pursuant to the provisions of 10 CFR 50.55a(z)(2), Dominion Energy Nuclear Connecticut, Inc. (DENC) requests Nuclear Regulatory Commission (NRC) approval to perform the examination of the lower portion of the RPV at Millstone Power Station Unit 2 (MPS2) at different plant conditions than those required by the ASME Code. Due to the harsh conditions in the area of the RPV, performance of required examinations during a system leakage or hydrostatic test at normal operating pressure and temperature (NOP/NOT) represents undue hardship without a commensurate safety benefit.

Figure 1 provides an illustration of the arrangement of the RPV area. This area is classified as a confined space with limited air circulation and limited access.

With the RCS at NOP/NOT conditions, ambient temperatures in this area are very high due to the uninsulated condition of the RPV. The high air temperature in this area creates a significant safety hazard to personnel entering this space.

Additionally, the elevation of the RPV in the cubicle is relatively low with about a 2-foot distance between the floor and bottom of the vessel. The distance between the floor and the RPV poses an additional hazard to personnel in the area regarding inadvertent contact with the uninsulated vessel surface and the consequential potential for a severe burn.

In Mode 3 (Hot Standby - NOP/NOT conditions) through Mode 6 (Refueling),

radiation dose rates under the vessel are estimated to be approximately 2 to 4 R/Hr. Since no significant reduction in radiation exposure would be expected while performing the pressure testing in Mode 6 versus Mode 3, radiation exposure is not included as a reason for the request.

Proposed Alternative and Basis for Use The licensee states:

DENC proposes to conduct the VT-2 examination of the pressure retaining surfaces of the lower portion of the RPV following plant cooldown during each refueling outage (at ambient conditions). With the substantially lower RCS temperatures, the lower vessel area will also be at a lower temperature and therefore less hazardous to personnel.

The objective of the required VT-2 examination at NOP/NOT conditions is to detect evidence of leakage and thereby verify the integrity of the RCS pressure boundary. DENC believes that this objective can be achieved by the same VT-2 visual examination performed following the RCS cooldown. Since there is no insulation on the RPV in this area, evidence of leakage and boric acid corrosion occurring during the fuel cycle would be detected by visual examination following plant cooldown. The ability to visually detect evidence of leakage and boric acid corrosion in this area during the refueling outage provides reasonable assurance of leak tight integrity of the lower portion of the RPV without exposing personnel to the environmental hazards associated with entry into this area during Mode 3 at NOP/NOT conditions.

Note that there are no bottom mounted instrumentation nozzles on the RPV at MPS2. Consequently, degradation in the vessel wall with the potential to challenge the pressure boundary integrity is not expected in the absence of penetrations.

NRC Staff Evaluation

The regulation in 10 CFR 50.55a(g)(4) requires ISI of ASME Code Class 1 components to be performed in accordance with Section XI of the ASME Code. Table IWB-2500-1, Item 15.10, of Section XI requires all pressure retaining components to undergo a system leakage test in accordance with Article IWB-5220 of Section XI. Article IWB-5220 requires the system leakage test to be conducted at a pressure not less than that corresponding to 100 percent rated power.

While the licensee stated in its submittal that the ASME Code also requires the system leakage test to be conducted at a temperature not less than that corresponding to 100 percent rated power, the staff notes that Articles IWB-5230 and IWB-5240 of Section XI allow the licensee to use temperatures lower than corresponding to 100 percent rated power, provided that higher pressures in accordance with Table IWB-5230-1 are used. For any test temperature, Articles IWB-5230 and IWB-5240 also require that the test pressure shall not exceed the limiting conditions specified in the plant technical specifications. The licensee stated its basis for hardship is that the ASME Code requires hydrostatic testing at NOP/NOT conditions and that a hazardous condition exists at NOP/NOT for the following reasons:

The area between the reactor vessel and the concrete shielding is classified as a confined space with a distance of approximately 2 feet between the floor and the bottom of the vessel.

The confined space has limited air circulation and limited access.

The reactor vessel is uninsulated and a burn hazard when at normal operating temperatures.

The combination of confined space, limited air circulation, limited access, and uninsulated reactor vessel constitutes a serious safety hazard to personnel performing the examinations required by the ASME Code during NOP/NOT conditions.

While the NRC staff agrees that a hazardous condition exists at NOT conditions, the staff notes that the ASME Code allows hydrostatic testing at temperatures less than NOT, provided the NOP meets the test pressure requirements of Articles IWB-5230 and IWB-5240 of Section XI of the ASME Code. Performing the test at ambient conditions is not always permitted by the ASME Code, as the test pressure required must not exceed the limiting conditions specified in the plant technical specifications. The licensee proposed to verify the integrity of the RPV by conducting the VT-2 examination of the pressure retaining surfaces of the lower portion of the RPV following plant cooldown during each refueling outage. The NRC staff finds that since the vessel bottom is uninsulated, any evidence of leakage and boric acid corrosion that occurred during the previous fuel cycle can be readily detected by visual examination during the refueling outage. Therefore, the NRC staff finds that the objective of the VT-2 visual examination is met.

In summary, the NRC staff concludes that the licensees proposed alternative is acceptable, since performing the inspection of Examination Category B-P, Item No. B15.10 pressure retaining components in accordance with the ASME Code requirements would constitute a hardship without a compensating increase in quality and safety.

3.2 Licensees Request for Alternative RR-05-02 The request is proposed in accordance with 10 CFR 50.55a(z)(1) for the duration of the fifth 10-year ISI interval at Millstone 2. The fifth 10-year ISI interval for Millstone 2 is scheduled to begin on April 1, 2020, and end on March 31, 2030.

ASME Code Components Affected All ASME Code,Section XI ferritic and austenitic piping welds requiring radiography during repair/replacement activities at Millstone 2.

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Applicable Code Edition and Addenda===

The Code of Record for the fifth 10-year ISI interval is the 2013 Edition of the ASME Code,Section XI (No Addenda).

Applicable Code Requirements Paragraph IWA-4221 of the 2013 Edition of the ASME Code,Section XI, requires the owner to meet the applicable Construction Code requirements when performing repair and replacement activities. Article IWA-4520 of the 2013 Edition requires that welding or brazing areas and welded joints made for fabrication or installation of items be examined in accordance with the Construction Code identified in the repair/replacement plan with certain specified exceptions.

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Reason for Request===

The licensee states that replacement of piping is periodically performed in support of the flow accelerated corrosion program, as well as other repair and replacement activities. The use of encoded PAUT in lieu of RT to perform the required examinations of the repaired or replaced welds would eliminate the safety risk associated with performing RT, which includes planned exposure and the potential for accidental personnel exposure to plant workers. PAUT also minimizes the impact on other outage activities normally involved with performing RT such as limited access to work. In addition, the licensee stated that encoded PAUT is equivalent or superior to the ASME Code-required RT examination for ASME ferritic and austenitic piping repair/replacement welds for detecting and sizing critical (planar) flaws such as cracks and lack of fusion. PAUT provides sizing capabilities for both depth and length dimensions of the flaw, which are required to apply the acceptance criteria of the applicable Code case. RT does not provide depth sizing capabilities.

Proposed Alternative The licensee proposes to perform encoded PAUT in lieu of RT. Important aspects of the proposed alternative include:

The examinations will be spatially encoded, and the data will be recorded.

The licensee will store the electronic data files for the encoded PAUT as archival-quality records permitting offline analysis of images built from the data.

The examination volume shall include 100 percent of the weld volume and the weld-to-base metal interface.

All detected axial and circumferential flaws shall be evaluated as planar flaws and compared to the preservice acceptance standards for volumetric examination in accordance with ASME Code,Section XI, Articles IWB-3000, IWC-3000, or IWD-3000, as applicable.

The written ultrasonic examination procedure will be qualified by performance demonstration. Ultrasonic examination personnel shall be qualified to detect and size flaws with the qualified procedure using blind performance demonstration testing.

The proposed alternative is based on and is similar to the provisions of ASME Code Case N831-1, Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic or Austenitic Pipe Section XI, Division 1.

Basis for Use The licensee states:

The basis for this proposed alternative is that encoded PAUT is equivalent or superior to RT for detecting and sizing critical (planar) flaws. In this regard, the basis for the proposed alternative was developed from numerous codes, code cases, associated industry experience, articles, and the results of RT and encoded PAUT examinations. The examination procedure and personnel performing examinations are qualified using representative piping conditions and flaws that demonstrate the ability to detect and size flaws that are both acceptable and unacceptable to the defined acceptance standards. The demonstrated ability of the examination procedure and personnel to appropriately detect and size flaws provides an acceptable level of quality and safety alternative as allowed by 10 CFR 50.55a(z)(1).

NRC Staff Evaluation

The NRC staff has evaluated proposed alternative RR-05-02 pursuant to 10 CFR 50.55a(z)(1) and has determined that the proposed alternative provides an acceptable level of quality and safety. In evaluating the licensees proposed alternative, the staff considered the following aspects of the licensees basis: (1) the effectiveness of encoded PAUT for repair/replacement weld inspection, and (2) the ability of encoded PAUT to detect structurally-significant fabrication flaws in ferritic steel or austenitic stainless-steel piping welds. The staff notes that if these two criteria are met, then the proposed alternative provides an acceptable level of quality and safety.

As stated above, the proposed alternative is based on, and is similar to, the provisions of ASME Code Case N-831-1. The staff notes that a related ASME Code Case N-831, Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic Pipe Section XI, Division 1, has been incorporated by reference into the NRC proposed rule in Federal Register notice dated August 16, 2018 (83 FR 40685), by inclusion in draft NRC Regulatory Guide 1.147, Revision 19, Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1 (with a condition that prohibits its use on new reactor construction).

Effectiveness of Encoded PAUT in Lieu of RT for Repair/Replacement Weld Inspection Since 2009, the NRC has been assessing the effectiveness of the PAUT technique in lieu of RT technique through literature reviews and confirmatory experimental work to validate findings.

While each technique is capable of detecting a spectrum of flaws resulting from fabrication welding processes, the difference in physical/material interactions can make one technique more sensitive to certain fabrication flaw types than the other technique. In NRC NUREG/CR-7204, Applying Ultrasonic Testing In Lieu of Radiography for Volumetric Examination of Carbon Steel Piping, published September 2015 (ADAMS Accession No. ML15253A674), the NRC staff concluded that the encoded PAUT technique, as compared to RT, provides an equally effective examination for identifying the presence of fabrication flaws in the ferritic steel piping welds. However, the encoded PAUT is more effective for detection of planar flaws than small volumetric flaws (i.e., volumetric flaws with less than 0.15 inches in diameter, which is acceptable by the Construction Code). Thus, the NRC staff finds the use of the PAUT technique in lieu of RT technique acceptable for the repair/replacement weld inspection.

Electric Power Research Institute (EPRI) Technical Report No. 3002010297, Technical Basis for Substituting Ultrasonic Testing for Radiographic Testing for New, Repaired, and Replacement Welds for ASME Section XI, Division 1, Stainless Steel Piping, dated June 2017, summarizes EPRIs performance-based approach based on ASME Code,Section XI, Appendix VIII, to demonstrate the effectiveness of the encoded PAUT for detection and sizing fabrication flaws in the austenitic stainless-steel piping welds. The NRC staff noted that the EPRI report showed (1) the encoded PAUT is an effective technique as compared to RT for detection and sizing fabrication flaws within the ferritic steel or austenitic stainless-steel welds, and (2) the ASME Code,Section XI, Appendix VIII root mean square error (RMSE) criteria for flaw length and depth sizing were met.

Based on the above studies, the NRC staff finds that there is sufficient technical basis for the use of encoded PAUT in lieu of RT for repair/replacement inspection of the ferritic steel or austenitic stainless-steel piping welds. The encoded PAUT, as compared to RT, was shown to be an effective technique for both detection and characterization of fabrication flaws in the repaired/replaced ferritic steel or austenitic stainless-steel piping welds; therefore, the staff finds it acceptable.

Assurance of Detection of Structurally-Significant Fabrication Flaws In evaluating the licensees proposed alternative requirements, the staff assessed the adequacy of the licensees technical basis, which includes the performance demonstration and qualification of the encoded PAUT procedure, the requirement to achieve 100 percent coverage of the examination volume, and flaw acceptance criteria.

The NRC staff verified that:

1) The licensee will examine 100 percent of the weld volume and the weld-to-base-metal interface.
2) The licensee will perform the encoded PAUT using procedures, equipment, and personnel qualified by performance demonstration.
3) The procedures will be demonstrated by using either a blind test or a nonblind test. The demonstration specimen set will include a minimum of 30 flaws covering a range of sizes, positions, orientations, and types of fabrication flaws. The demonstration set will include specimens to represent the minimum and maximum diameter and thickness covered by the procedure.
4) Personnel will be qualified for detection and sizing fabrication flaws by performance demonstration using the qualified procedure. The personnel performance demonstration will be conducted using a blind test (i.e., the flaw information is not provided). The demonstration specimen set will contain at least ten flaws covering a range of sizes, positions, orientations, and types of fabrication flaws.

The staff also reviewed additional details regarding the licensees performance demonstration and qualification of the encoded PAUT procedure:

1) The demonstration specimens will include both planar and volumetric fabrication flaws (e.g., lack of fusion, crack, incomplete penetration, slag inclusions) representative of the welding process. The flaws will be distributed throughout the examination volume. The flaw through-wall heights for the performance demonstration will be based on the preservice acceptance standards for volumetric examination in accordance with the ASME Code,Section XI, IWB-3400, IWC-3400, or IWD-3400, as applicable. At least 30 percent of the flaws will be classified as acceptable planar flaws, with the smallest flaws being at least 50 percent of the maximum allowable size based on the applicable aspect ratio for the flaw.
2) Personnel will be qualified for flaw length sizing when the RMSE of the flaw lengths estimated by ultrasonic examinations, as compared with the true lengths, does not exceed 0.25 inches for nominal pipe size 6 inches and smaller, and 0.75 inches for pipe diameter larger than nominal pipe size 6 inches.
3) Personnel will be qualified for flaw through-wall height sizing when the RMSE of the flaw through-wall heights estimated by ultrasonic examinations, as compared with the true through-wall heights, does not exceed 0.125 inches.
4) The licensee will treat all flaws detected using angle-beam ultrasonic inspections as planar flaws and will evaluate the flaws against the preservice acceptance standards in the ASME Code,Section XI, IWB-3400, IWC-3400, or IWD-3400, as applicable.
5) The licensee will store the electronic data files for the encoded PAUT as archival-quality records permitting offline analysis of images built from the data.

Based on the above, the NRC staff finds that the licensees proposed performance demonstration for the encoded PAUT, which includes procedures demonstration and personnel qualification, is adequate because it is either consistent with or exceeds the provisions of ASME Code,Section XI, Appendix VIII, for the ferritic steel or austenitic stainless-steel piping welds.

In addition, the NRC staff notes that while IWB-3400, IWC-3400, and IWD-3400 of the ASME Code,Section XI, allow larger flaws to remain in service than that of NB-5330, NC-5330, and ND-5330 of Section Ill, the use of Section XI acceptance standards has proven to be effective for the inspection of piping welds. The NRC staff finds that the use of ASME Code,Section XI acceptance standards is appropriate for the proposed alternative, as the alternative is for repair and replacement activities and not for new plant construction. Therefore, the NRC staff finds that the licensees proposed encoded PAUT for the repair and replacement weld inspection is acceptable because it provides reasonable assurance that any structurally significant fabrication defects in repaired/replaced welds be detected.

4.0 CONCLUSION

As set forth above, the NRC staff has determined that proposed alternative RR-05-01 provides an acceptable level of quality and safety and that the ASME Code requirements constitute a hardship without a compensating increase in quality and safety. Accordingly, the staff concludes that the licensee has adequately addressed all the regulatory requirements set forth in 10 CFR 50.55a(z)(2). Therefore, the NRC staff authorizes proposed alternative RR-05-01 at Millstone 2, for the fifth 10-year ISI interval, which is scheduled to begin on April 1, 2020, and end on March 31, 2030.

The NRC staff also concludes that the licensee's proposed alternative RR-05-02 to use PAUT in lieu of RT provides reasonable assurance of structural integrity and leaktightness of ferritic and austenitic piping welds requiring radiography during repair and replacement activities. Thus, ultrasonic examination using the procedure described in RR-05-02 will provide an acceptable level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all the regulatory requirements set forth in 10 CFR 50.55a(z)(1).

Therefore, the NRC staff authorizes the use of proposed alternative RR-05-02 for the fifth 10-year ISI interval for Millstone 2, which is scheduled to begin on April 1, 2020, and end on March 31, 2030. The NRC staff notes that the approval of proposed alternative RR-05-02 does not imply or infer the NRC approval of ASME Code Case N-831-1 for generic use.

All other requirements of the ASME Code for which relief has not been specifically requested remain applicable, including third-party review by the Authorized Nuclear lnservice Inspector.

Principal Contributors: J. Jenkins B. Fu Date: December 18, 2019

ML19338G372

  • by e-mail OFFICE DORL/LPL1/PM DORL/LPL1/LA DMLR/MVIB/BC*

DMLR/MPHB/BC(A)*

NAME RGuzman LRonewicz DAlley ABuford DATE 12/12/2019 12/12/2019 07/03/2019 10/08/2019 OFFICE DORL/LPL1/BC DORL/LPL1/PM NAME JDanna RGuzman DATE 12/18/2019 12/18/2019