ML20127B694

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Recommends Rev to 10CFR50.55a,incorporating Winter 1982 Addenda to ASME Code W/O Exception.Supplemental Provisions Necessary to Assure Consistency Between Code & Staff Position Would Unduly Burden 10CFR50.55a Rule Rev
ML20127B694
Person / Time
Issue date: 05/21/1984
From: Grace J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To: Arlotto G
NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
Shared Package
ML20127B699 List:
References
FRN-50FR20574, RULE-PR-50 AA83-1, NUDOCS 8406010149
Download: ML20127B694 (2)


Text

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[ c, UNITED STATES P.D R nc, j NUCLEAR REGULATORY COMMISSION

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MAY 21 B84 1.EMORAhDUM FOR: Guy A. Arlotto, Director Division of Engineering Technology, RES FROM: J. Nelson Grace, Director Division of Quality Assurance, Safeguards, and Inspection Programs Office of Inspection and Enforcement

SUBJECT:

END0RSEMENT OF THE WINTER 1982 ADDENDA INCORPORATING ANSI /ASME NQA-1-1979

REFERENCE:

Memorandum from J. M. Taylor to G. A. Arlotto Dated August 24, 1983, subject as above In the referenced memorandum, we indicated that the DQASIP staff was in the process of narrowing the choices on the approach to be used in endorsing ANSI /ASME NQA-1-1979, " Quality Assurance Program Requirements for Nuclear Facilities," as it relates to the Winter 1982 Addenda to the ASME Code. This is to advise you of the position we have reached on this matter.

We recomend that you proceed with your revision to 10 CFR 50.55a, incorporating by reference the Winter 1982 Addenda without exception. 0ur staff has determined that taking exceptions to the QA provisions of these Addenda is not practical at this time.

Our primary reason for adopting this approach is that there have been a large number of additions to NQA-1 since the 1979 version was published. Our staff position on NQA-1, which will appear in Revision 3 to Regulatory Guide 1.28, is formulated around the 1983 version of NQA-1 including these changes. The supplemental provisions that might be necessary to assure consistency between the Code and the staff position on ANSI /ASME NQA-1-1983 would unduly burden the 10 CFR 50.55a rule revision. We have determined that a more practical approach would be to use the regulatory positions of Revision 3 to Regulatory Guide 1.28, in conjunction with the Code, where the Code does not address all the applicable activities of NQA-1-1983 in sufficient detail, as has been past practice. This approach with regard to endorsing the Winter 1982 Addenda does not imply that we have found the Code's QA requirements to be equivalent to the provisions of our current and proposed revisions to both Regulatory Guides 1.28 and 1.33;.nor should it be construed that we feel the. Winter 1982 Addenda QA requirements are adequate in terms of accepting the ASME/NB nuclear accreditation program as outlined in the NRC/ASME/NB Exchange of Correspondence dated February 4, 1981. It is our position that until the Code QA requirements are equivalent to the pertinent NRC regulations and regulatory guides, applicants and licensees should commit to Regulatory Guides 1.28 and 1.33 or FYO GoI o/ Pt m -

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Guy Arlotto provide acceptable alternatives, as applicable, for either CP or OL, and continue to fulfill their commitments.

We have mentioned Regulatory Guide 1.33 in this discussion, despite the inclusion of NQA-1-1979 in Section XI of the Code via the Winter 1982 Addenda, for two reasons. First, Regulatory Guide 1.33, by its endorsement with supplemental provisions of ANS-3.2, provides more specific QA program requirements for operations than does NQA-1 (either version), and should be used in conjunction with Section XI of the Code where the Code does not address all the applicable activities of AMS-3.2, as supplemented by Regulatory Guide 1.33, in sufficient detail. Second, our proposed Revision 3 to Regulatory Guide 1.33 will refer to NQA-1-1983 in lieu of the 1979 version, which is referenced in the most recent version of the ANS-3.2 standard. ANSI /ANS 3.2-1982 refers to NQA-1-1979 for requirements and guidance for a number of activities.

We are currently working with a Section III Task Group to evaluate the regulatory positions of our proposed Revision 3 to Regulatory Guide 1.28, as they pertain to the Code, in order to achieve equivalence of the QA requirements of future Code Addenda and Regulatory Guide 1.28. This activity will hopefully facilitate NRC acceptance of the ASME/NB nuclear accreditation program.

We would appreciate being kept current on the progress of your 10 CFR 50.55a rulemaking. If you need any additional information for your activities, please contact Melinda Malloy (X24532) of the Quality Assurance Branch.

. . h J. Nelson Grace, Director Division of Quality Assurance, Safeguards, and Inspection Programs Office of Inspection and Enforcement

Enclosure:

Memorandum for Arlotto from Taylor dated August 24, 1983 cc: W.F. Anderson, IE R.J. Bosnak, NRR bh

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l WASHINGT ON. D. C. 20555 MAY 131985

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Mr. James B. MacRae Office of Management and Budget Reports Management, Room 3201 New Executive Office Building Washington, D.C. 20503

Dear Mr. MacRae:

In accordance with Section 3507 of Public Law 96-511 of December 11, 1980, and regulations of the Office of Management and Budget, I am enclosing for 0MB review copies of Standard Fonn-83 and the Supporting Statement for 10 CFR 50, Domestic Licensing of Production and Utilization Facilities The estimated respondent burden is 3517 hours0.0407 days <br />0.977 hours <br />0.00582 weeks <br />0.00134 months <br /> per year.

In accordance with NTC's procedures, my staff has made an independent review of the practical utility and necessity for the proposed information collection and we are in concurrence with this proposal. We have also reviewed for duplication and found no similar requirement in the agency.

Therefore, we are transmitting this material for appropriate OMB review and approval. ,

Sincerely, 7

h s. .JN, Patricia G. Norry, irect Office of Administration

Enclosures:

As stated

s,.eoa.o 83 .

Request f or OMB Review

. 15+e, Sepiembre tM3; important Send three copies of this form. the material to be rev,ewed. sr Read instructeons betore completing f orm. Do not use the same Sr 83 paperwork-three copies of the supporting statement, to

1) request both an Esecutive Order 12291 review and approval under the Paperwork Recuttion Act. Offree of information and Regulatory Aff airs Answer all questions in Part 1. If this request es for review under E.O. Office of Management and Budget 12291 complete Part 11 and sign the reguiatory certification. If this Attention. Docket Library Room 3201 request is for approsat under the Paperwork Reducteon Act and 5 CFR Washington DC 20503 1320, skip Part 11 complete Part fit and sign the paperwork certification.

i PART l.-Complete This Part for All Requests.

2. Agency code
1. Department / agency and Bureau /ottice originating request U.S. Nuclear Regulatory Commission 3 1 5 0 Telephone nomDer
3. Name of person who can best answer Questions regarding this request

< 301 3 443-7862 G. C. Millman c.Tatie of information coffection or rulernaking .

10 CFR 50, Domestic Licensing of Production and Utilization Facilities

b. Lega; authorsty ^ or informatson co\bection or ruit (ct e United States Code. Pubhc law, or becutive Oraer)

. o, Atomic Energy Act of 1954, as amended use

6. Aff ected public (checA att that apply) s O rederaiagencies or empioyees

- 6 O Non-pror,t institutions

  • 1 E Individuals or households 3 0 rarms a G E..isinesses or other for protit 7 0 smait businesses or organeations 2 O stateoriocaigovernments PART ll.-Complete This Part Only if the Request is for OMB Review Under Executive Order 12291
7. Regulation identifier Number (RIN)

. or, None assigned C

_ _ _ _ ~ _ _ _

Type of revleiv requested

8. Type of submission (check one m each category)

Classification ,

Stage of development } Q standard 1 O eroposedord, art 2 O pending 1 O u ajor .

'2 O renaiorinienmtinai.withoriorproposai 3 0 cmergency 2 O Nonmajor 3 0 rinai or intenm snat. -ithout prior proposat a O statutoryorjudicaideadiine

9. CF R section atfected CFR ,
10. Does thrs reFulatiori contain reporting or recordseeping requirements that require oMB approvat under the Paperwork Reduction Act. O ves and 5 CrR 1320? . .

1 O yes 2 ll, if a major rule. is there a regulatory impact analysis attached? .. . .

30ves a tt"No." did oM9 waive the analysis?

Certification f or Regulatory submissions in submrtting this request ior oMB review. the authoraed regulatory contatt and the progsam of ficial certify that the equirements of E policy directrves have been complied with Date signature of programoffical _

\

signature at authoracc regulatory contact U*

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12. lOMb ane only) 5tr ee.cic.- t3 :

Pee.w a eo.t.nm eno.c e gg F'rw ^

N5N 7540 00 LW G14 5 cr 9 2r0 a : L t

PART lli.-Czrnplete This Part Only if the Request is for Approvat of a Colfsction )

of Inforrnation Under the Pzperwork Reduction Act and_5 CFR 1320.

The NPRM updates existing references to specif ic

13. abstract.-oescnee nceds. uses and artected puer.c in so words or iess sections of the ASME Boiler and Pressure Vessel Code that set forth These requirements requirements byprovide which that  !

nuclear power plant components are constructed and inspected. The records can be used plant owners maintain records of certain safety related Theactivities.

recordkeeping applies to the owners by NRC to audit the performance of these activities. f of nuclear oower olants and does not affect the general oublic. .

14. Type of information coltection (check only one)

Information collections not containedin rules 2 O Emergency submission (cerfi/scshon attached) 10 aeguiar submiss.on Information collections contained in rufes 7. Enter date of espected or actual Federal s rinai or interim final without pnor NPRM 3 O Existing regu'ation (no cheare proposed) Register pun 6 cation at ini, stage or ruiemaki,.

A O Regutar subrnission 4O Notice of proposed rulemaking(NPRM) (month, day, year): Mav 1985 s O Emergency submission (certification attached) 5 0 rinai, NPRM was previousiy pubisshed _

15. Type of review requeste6 (chech only one) 4 O Reinstatement of a previous >y approved coriection for wnien app,o,ar 10 New coiiection has expired 2 U Revision of a currently approved ccitection 5 O Esisting collection in use without an oMB control number 3 O Estensionof the eno;<stion date of a currentry approved correction without any change in the substance or in the method of collection
22. Purpose of informatson collection (check as many as apply)
16. Agency teport form number (s)(include standard /optionalform nutnber(s))

1 O Appiication for benefits N/A 2 O Program evaluation 3 0 cenerar purpose star,stics

17. Annuai reporting or disclosure burden 4 Q Regulatory or comphance 1 Number of respondents . .. .

5 O Program planning or management 2 Number of responses per responcent .....

6 0 Research 3 Tital annual responses (line i times Inne 2) . .

. . 7 O Audit

'4 grs per response ........

5 Total hours frine 3 times line 4) 23. Frequency of recordkeepmg or reporting (check allthatapply)

18. A,nnuai recordkeeping burden 1 O Recordkeeping 1 Number of recordkeepers ......

R*Forfins 2 Annual hours per recordkeeper. ...

3 Tital recordkeeping hours (line I times line 2) . 2 O Onoccasion years 3 Weekly a Recordkeeping retention period .

4 O Monthly

19. Totit annual burden 6'008'370 s O Quarterfy 1 Requested (line J7 5 plusline 18 3) . . ...

s O semi-annuairy 2 tn current oM8 inventory ... . .

6.008.370 0 7 O Annua!ir 3 Difference (line J less fine 2) 8 O B.enniafty Esplinatian of Eritterence 9 0 other(desence):

4 Program change . .

5 Adjustmer.t . 24. Respondents

  • obtgation to comply (check the strongest ochgation thst apphes
20. Curesnt (most recent) oMB controi number o< comment number voiuntary 3150-0011 1
21. Requested espiration cate
  • 2 O Required to obtain or retain a benefit 3a uandatory 6/85 Yes C N<
25. Ars the respondents pnmanly educational agencies or inst,tutions or is the pnmary purpose of the collection related to F
16. Dois the agency use sampimg to select respondents or does the agency recommend or presenbe the use of sampting

. O Yesor G N stati by respondents? . .

27. Regulatory authoney for the information couection  : or. Other (speofy);
o, FR 10 cFn 50.55a Pip
rwick Certificat6sn In submittirg this re,sest for oMB approval, the agency head. the senior official or an authorned representative. ce Prrricy f.ct. statishcal standards or directives. a,d any other applicabie information policy directives have Deen Date compbed with.

S'gniture of pragram att.ciaa Date

$ cat.,*e e amy rex. tre sen.or ett.cai or ar rej remese,taNe K

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Supporting Statement for Information Collection Requirements in 10 CFR 950.55a

1. Justification
a. Need for the Information Collection NRC Regulations in 10 CFR 550.55a incorporate by reference Section III, Division 1, and Section XI. Division 1, of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code). These sections of the ASME Code set forth the requirements to which nuclear power plant components are designed, constructed, tested and inspected. Inherent in these requirements are certain recordkeeping functions.

Incorporation of the Winter 1982 Addenda, Summer 1983 Addenda, Winter 1983 Addenda, Summer 1984 Addenda, and 1983 Edition for Section III, Division 1, of the ASME Code would add the following recordkeeping requirements. .

Section III o Winter 1982 Addenda NB-2125, Fabricated Hubbed Flanges - New provision for surface examination requires documentation of examination results.

o Summer 1983 Addenda No additional recordkeepjng o Winter 1983 Addenda NCA-3650, Design Documents for A)purtenances -

Requires Design Document for eac1 appurtenance that is to be attached to a component unless it is already included in the component Design Documents.

o Summer 1984 Addenda NB/NC-7240, Review of (Overpressure Protection) Report After Installation - Addendum to report required to document any modification of the installation from that used for preparation of the Overpressure Pro-tection Report.

ND-7200, Overpressure Protection Report - Requires overpressure protection report for Class 3 components to define the protected systems and the integrated overpressure protection provided, and (ND-7240) documentation of any modification of the installation from that used for preparation of the Overpressure Protection Report.

I o 1983 Edition All requirements, except those for Winter 1982 Addenda, previously incorporated in separate amendments to 10 CFR 450.55a.

lThe 1983 Edition of Section III is equivalent to the 1980 Edition, as modified by the Summer 1980 Addenda, Winter 1980 Addenda, Summer 1981 Addenda, Winter 1981 Addenda, Summer 1982 Addenda, and the Winter 1952 Addenca.

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Incorporation of the Winter 1982 Addenda, Summer 1983 Addenda, and

- the 1983 Edition of Section XI, Division 1, of the ASME Code would add the following recordkeeping requirements.

Section XI o Winter 1982 Addenda IWA-6220(b), Preparation (of Records and Reports) - Requires preparation of owner's Report for Repairs or Replacements (Form NIS-2).

o Summer 1983 Addenda No additional recordkeeping 2

o 1983 Edition All requirements, except those for Winter 1982 Addenda, previously incorporated in separate amendments to 10 CFR s50.55a. ,

The Winter 1982 Addenda of the ASME Code references ANSI /ASME NQA-1-1979,

" Quality Assurance Program Requirements for Nuclear Power Plants."

NQA-1-1979 is based upon the contents of ANSI /ASME N45.2-1979, " Quality Assurance Program Requirements for Nuclear Facilities" and seven daughter standards. These standards are referenced in Regulatory Guides 1.28, 1.58,1.64,1.74,1.88,1.123,1.144, and 1.146 as providing methods acceptable for implementing certain NRC quality assurance program requirements. NQA-1-1979 incorporates no recordkeeping beyond that originally required by the N45 standards upon which it is based. There is, therefore, no additional recordkeeping burden associated with the endorsement of NQA-1-1979.

b. Practical Utility of the Information Collection These records are used by the licensees, National Board inspectors, insurance companies, and the NRC in the review of a variety of ectivities, many of which affect safety. The records are generally historical in nature and provide data on which future activities can be based. NRC Inspection and Enforcement personnel can spot check the records required by the ASME Code to determine, for example, if proper inservice examination test methods were utilized.
c. Duplication With Other Collections of Information ASME requirements are incorporated to avoid the need for writing equivalent NRC requirements. The final rule will not duplicate the information collection requirements contained in any other generic regulatory requirement.
d. Consultations Outside the NRC No consultations.

2The 1983 Edition of Section XI is equivalent to the 1980 Edition, as modified by the Winter 1980 Addenda, Winter 1981 Addenda, and the Winter 1982 Addenda.

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. e. Other Supporting Information NRC applicants and licensees have been complying with the information collection requirements of the ASME Code since 1971.

No problems with these information collection requirements have been identified to the NRC by the applicants or licensees.

2. Description of the Information Collection
a. Number and Type of Respondents In general, the information collection requirements incurred b;y

%50.55a through endorsement of the Code apply to the owners of the 34 nuclear power plants under construction and to the owners of the 93 nuclear power plants in operation. The actual number of plants that would implement the edition and addenda addressed.

by the proposed revision, and thereby be affected by their information collection requirements, is dependent on a variety of factors. These factors include whether the application is for Section III or Section XI, the class and type of components involved, the dates of the construction permit and construction permit application, the schedule of the inservice inspection program, and whether the plant voluntarily elects to implement updated editions and addenda of the ASME Code,

b. Reasonableness of the Schedule for Collecting Information The information is generally 'not collected, but is retained by the licensee to be made available to the NRC in the event of an NRC inspection or audit.
c. Method of Collecting the Information .

See Item 2(b).

d. Adequacy of the Description of the Information The ASME Code provides listings of information required and specific forms to assist, where necessary, in docunenting required information.
e. Record Retention Period The retention period for information is in accordance with a schedule provided in Table NCA-4134.17-1 of the ASME Code. The retention periods for information keeping requirements specified in Item 1.a above are:

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- Information Retention Period (3)

Design document for appurtenances Lifetime Overpressure protection report Lifetime Reports for repair and replacement Lifetime Final nondestructive examination report Lifetime Lifetime retention of the above records is necessary to ensure adequate historical information on the design and examination of components and systems to provide a basis for evaluating degra-dation of these components and systems at any time during their service lifetime.

3. Estimate of Burden
a. Estimated Hours The information collection requirements inherent in incorporating by reference the latest edition and addenda of Section III, Division 1, and Section XI. Division 1, of the ASME Code are identified in Item 1.a above. These requirements may be categorized in terms of Section III requirements that document component / system design and the results of construction exaninations, and Section XI requirements that document repairs and replacements.

The additional Section III requirements incur a one-time burden on plants under construction.- The information collection requirements associated with the proposed edition and addenda are generation of the design documents for appurtenances and the overpressure protection report. Section 50.55a specifies that the Code Edition, Addenda, and optional Code Cases to be applied to reactor coolant pressure boundary, and Quality. Group B and Quality Group C components must be determined by the provisions of paragraph NCA-ll40 of Subsection NCA of Section III of the ASME Code. NCA-1140 specifies that the owner (or his designee) shall establish the ASME Code edition and addenda to be included in the Design Specifications, but that in no case shall the Code edition and addenda dates established in the Design Specifications be earlier than three years prior to the date that the nuclear power plant construction permit is docketed. NCA-1140 further states that later ASME Code editions and addenda may be used by mutual consent of the Owner (or his designee) and Certificate Holder. The earliest Section III addenda being addressed in the proposed rule is the Winter 1982 Addenda. Since the last plant to be docketed that is still under construction was docketed in October 1974 (Palo Verde Units 1, 2, 3), there is no plant under construction for which implementation of the Section III edition and addenda specified in the proposed rule is a requirement. Plants may implement these improved rules on a voluntary basis, but unless they make that choice, there is no additional paperwork burden associated with incorporating the proposed Section III edition and addenda.

3 Service lifetime of the component or system.

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O' The additional Section XI requirements incur a burden associated with the documentation of component repairs and replacements.

To facilitate this documentation,Section XI provides Form NIS-2, " Owners' Report for Repairs or Replacements."

Information required by this form relates to identifying the owner and facility; identifying the components repaired or replaced and replacement components; identifying the type of

- work, the repair organization and by whom the work was performed; and identifying the type of tests conducted. A portion of this information, such as that to identify the owner, facility and components is already required by Form NIS-1,

" Owners' Data Report for Inservice Inspections," (Form NIS-1 was part of an addenda previously incorporated by reference into

%50.55a). Most of the remaining information required by form NIS-2 can be obtained from the previously prepared component work / repair order. It is estimated that the time required to complete the required documentation on Form NIS-2 is ten hours.

Nuclear power plants are required to update their inservice inspection programs by incorporating into their initial 120-month inspection interval requirements of the latest edition and addenda of Section XI, Division 1, that have been incorporated by reference into s50.55a as of 12 months prior to the date of issuance of the operating license; and by incorporating into successive 120-month inspection intervals requirements of the latest edition and addenda of Section XI that have been incorporated'by reference as of 12 months prior to the start of a 120-month inspection interval. On this basis, many plants will at one time be required to implement the Section XI, Division 1, edition and addenda specified in the proposed rule. The number of plants that will be implementing the specified editJon and addenda will grow gradually as each plant updates its inservice inspection program at the 10-year interval. Therefore, conservatively, the total number of plants that may ultimately be required to implement the specified edition and addenda is 127 (i.e., 93 operating plants and 34 plants under construction).

Inservice inspections are typically performed at the time of refueling (i.e., approximately every 18 months). The need to complete an NIS-2 form would occur as a result of a repair required by the results of an inservice inspection, or as a result of an unanticipated repair between refuelings. It is estimated that 2 NIS-2 forms are completed for repairs resulting from the inspection and 2 for repairs required during operation.

Assuming applicability to 127 plants, and the completion of 4 NIS-2 forms by each plant every 16 months, with ten hours required to collect information and complete each form, it is estimated that the total time required by all utilities to complete the NIS-2 form is approximately 3400 hours0.0394 days <br />0.944 hours <br />0.00562 weeks <br />0.00129 months <br /> / year (i.e.,

4 forms x 127 plants = 508 forms per 18 months, 508 forms x 2 =

1016 forms per 3 years, 1016 forms / 3 = 339 forms per year, 339 forms x 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per form = 3390 hours0.0392 days <br />0.942 hours <br />0.00561 weeks <br />0.00129 months <br /> per year). The time required to maintain these repair and replacement records for A-5

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the period noted in Item 2.e is estimated to be 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> / year for each plant. Thus, the total time required by all utilities to 4 complete and main %ain the NIS-2 form is approximately 3517 hours0.0407 days <br />0.977 hours <br />0.00582 weeks <br />0.00134 months <br /> / year.

b. Estimated Cost Required to Ros nd to the Collection Based upon the hours specified in Item 3.a it is estimated that the cost of responding to the information collection required by the Section III, Division 1, and Section XI, Division 1, edition and addenda specified in the proposed amendment to 50.55a is a total of $211,020/ year (3517 hrs x $60/hr) for 127 plants,
c. Source of Burden Data and Method for Estimating Burden Estimates of the number of NIS-2 forms that are completed during a year and the time required to collect the necessary information and to complete the forms, were obtained from utility staff inservice inspection specialists and NRC staff in the Office of Inspection and Enforcement (regional and headquarters) engaged in inservice inspection activities.
d. Reasonableness of Burden Estimate The estimate of the burden is considered reasonable because of the reliable source of the burden data.
4. Estimate of Cost to the Federal Go'vernment NRC inspection personnel who audit plant quality assurance records would include in their audit verification of the proper implementation of the NIS-2 form. The time associated with NRC inspectors verifying use of the NIS-2 form would be extremely sba-11 when the activity is performed as part of a normal quality assurance audit.

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APPENOlX 11 - M ANDATORY Form N15-2 WE2 FORM NIE 2 OWNER's REPORT FOR REPAtRE OR REPLACEMENTS As Required by the Prov6sions of the ASME Code section XI

1. Ownee Date home thee
  • ot Asee.

2.Piem Un.t Home Aseree. Rece. orein.seuen e.o. we., Joe he., etc.

3. wort Performed try Type Code Symbol Stamp
    • Authomai.on No.

E aperaten Dete As ere.

4 edent.fceton of system 4

6. tel AppicatWe Constructen Code 19 E dit en. Addende. Code Case (b) Applicatse Esitea of Secten X1 Ut t.aed for Repe rs or Raptocements 19
6. Ident festen of Components or Replaced and Reptscement Components F

ASME (ede Repe. red, Stamped Nat.onet Other v es, Replaced, tYes Nameo' Name acturer toerd istNo No. Identif cation 8vitt ce Repiecement or Nol Correonent Manufacturer A

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7. Descreten of Wort
8. Tests Conducted Hydrostatec Pneumet< 0 Nam an' ooerstiae Pres ore Other u Prew-v ps; Test Temp. *F NOTE. Supolementet sheets in form of sets, sketches. or desengs mov be used, provided til sWe is 84 in. s 11 in., D1 enforms.

ten 6n items 1 through 6 on the report is included on each sheet, and (3) each sheet is numbered and the number of sheets es encorded et the top of this foM. ,

112/821 This Form (E00030) mov be octs.ned from the Order Dept., ASME,345 E. 47th St., New York, N Y 10017 i

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l Forsn N15 2 I SECHON,XI - DIVISION l o g FORM NIEJ ISed) e we Asetiseade hsonwteetwWe Date Reeerm se be arteetes e

CERTIFICATE OF COMPLtANCE pre certd, that she statements mese in the repon are sorreci end this conforms to the rules of the ASME Code.Section XI.

Type Coor Symbot Stamp nN Exp6est'en Dete Certificate of Authorst ,

M ^ Dete 19 Sqwd

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m CEF TE OF INSERVIOE INSPECTION

t. iS* unortsared, ho6dene a wered in egetional Board of toiter and Prensare Vowel Inspectors and the State

- of or Prowmco et A heWe Irl@ected 9te e6nts descritged in the Ommer's Report during the persod M M _to and eten that to the tuost of any knowledge and tuotief, the noticans and taken sorrecteve sneestas descrRaed in this Ovmer's Report in acconsance with the requerements of XI.

By sagneng this certdicate neither the Inspector nor his eruployer ny guerrenty, empressed or irnplied, concerneng the F the snapoctor nor hes ernpaoyer esemeratens and correcteve measures esser 1Esed in thes Owner) shall tue last:6e in any menner for any personal inputy or property r s Ices from or connected with th6s enspecten.

Commissions enas= tere saensivre wette ns, state. Province, ens a runo-te Dete 18 0 2/82)

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