ML21134A006
| ML21134A006 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 08/03/2021 |
| From: | Nancy Salgado Plant Licensing Branch III |
| To: | Rhoades D Exelon Generation Co, Exelon Nuclear |
| Wiebe J | |
| References | |
| EPID L-2020-LLR-0099, EPID L-2020-LLR-0100 | |
| Download: ML21134A006 (1) | |
Text
August 3, 2021 Mr. David P. Rhoades Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO)
Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
BRAIDWOOD STATION, UNITS 1 AND 2 AND BYRON STATION, UNIT NOS. 1 AND 2 - PROPOSED ALTERNATIVE TO THE REQUIREMENTS OF THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER & PRESSURE VESSEL CODE (EPIDS L-2020-LLR-0099 and L-2020-LLR-0100)
Dear Mr. Rhoades:
By letter dated July 24, 2020, as supplemented by letter dated February 10, 2021, Exelon Generation Company, LLC (the licensee) submitted requests to the U.S. Nuclear Regulatory Commission (NRC) for the use of an alternative to certain American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, requirements at Braidwood Station, Units 1 and 2, and Byron Station, Unit Nos. 1 and 2.
Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z)(1), the licensee requested to use the proposed alternative on the basis that the alternative provides an acceptable level of quality and safety. The regulations in 10 CFR 50.55a(z) allow the NRC staff to authorize alternatives to the requirements in paragraphs (b) through (h) of 10 CFR 50.55a.
The requirements for 10-year inservice inspection (ISI) intervals after the initial 120-month inspection interval are established by 10 CFR 50.55a(g)(4)(ii), and require licensees to comply with the Code requirements incorporated by reference in 10 CFR 50.55a(a) 18 months prior to the start of the ISI interval.
As set forth in the enclosed safety evaluation, the NRC staff has determined that the proposed alternative provides an acceptable level of quality and safety for the third inspection interval.
Accordingly, the NRC staff concludes that the licensee has adequately addressed the regulatory requirements set forth in 10 CFR 50.55a(z)(1) for the third inspection interval. Since the containment ISI requirements beyond the third 10-year intervals at Braidwood and Byron have not yet been established in accordance with 10 CFR 50.55a(g)(4)(ii), no authorization can be made at this time for subsequent ISI intervals following the third inspection interval. Therefore, the NRC staff authorizes the proposed alternative RR-I4R-11 at Braidwood and RR-I4R-18 at Byron only for their respective third 10-year IWL ISI intervals.
All other ASME Code,Section XI, requirements for which relief was not specifically requested and authorized remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
If you have any questions, please contact Joel S. Wiebe at 301-415-6606 or Joel.Wiebe@nrc.gov.
Sincerely, Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-456, STN 50-457, STN 50-454, and STN 50-455
Enclosure:
Safety Evaluation cc: ListServ Nancy L.
Salgado Digitally signed by Nancy L. Salgado Date: 2021.08.03 12:00:46 -04'00'
Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION PROPOSED ALTERNATIVE RR-I4R-11 (BRAIDWOOD UNITS 1 AND 2) AND RR-I4R-18 (BYRON UNIT NOS. 1 AND 2) REGARDING UNBONDED POST-TENSIONING SYSTEM INSERVICE INSPECTION REQUIREMENTS EXELON GENERATION COMPANY, LLC.
DOCKET NOS. STN 50-456, STN 50-457, STN 50-454, AND STN 50-455
1.0 INTRODUCTION
By letter dated July 24, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20206L135), as supplemented by letter dated February 10, 2021 (ADAMS Accession No. ML21041A519), Exelon Generation Company (the licensee), requested authorization of proposed alternatives to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, Subsection IWL, for Braidwood Station (Braidwood), Units 1 and 2 and Byron Station (Byron), Unit Nos. 1 and 2.
The licensee proposed to extend the interval between post-tensioning system examinations and testing and detailed visual examination of concrete adjacent to tendon bearing plates from 5 years to 10 years. The licensee also proposed to eliminate the requirement for wire extraction and testing. The licensee further proposed to limit corrosion protection medium (CPM) chemical tests to water content, unless additional tests are specified by the Responsible Engineer (RE).
The licensee requested that the alternatives be authorized for use for the remaining periods of extended operation, which end on October 17, 2046 (Braidwood, Unit 1), December 18, 2047 (Braidwood, Unit 2), October 31, 2044 (Byron, Unit 1), and November 6, 2046 (Byron, Unit 2).
Pursuant to the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.55a Codes and standards, specifically 10 CFR 50.55a(z)(1), the licensee requested to use the proposed alternative to the examination requirements of the ASME Code,Section XI, Subsection IWL, related to the containment unbonded post-tensioning system on the basis that the alternative provides an acceptable level of quality and safety.
2.0 REGULATORY EVALUATION
Pursuant to 10 CFR 50.55a(g)(4), throughout the service life of a nuclear power facility, components that are classified as Class CC pressure retaining components must meet the requirements set forth in Section XI of the ASME Code, Subsection IWL, as incorporated by reference in paragraph (a)(1)(ii) subject to the conditions listed in paragraph (b)(2)(ix) of 10 CFR 50.55a.Section XI, Subsection IWL, of the ASME Code provides rules for inservice inspection (ISI) and repair/replacement activities of the reinforced concrete and post-tensioning system components of Class CC containment structures. Alternatives to the requirements of 10 CFR 50.55a may be authorized by the NRC pursuant to 10 CFR 50.55a(z)(1) if the licensee demonstrates that the proposed alternative would provide an acceptable level of quality and safety.
The regulations in 10 CFR 50.55a(z) allow the NRC staff to authorize alternatives to the requirements in paragraphs (b) through (h) of 10 CFR 50.55a. The requirements for subsequent 10-year ISI intervals are established by 10 CFR 50.55a(g)(4)(ii), and require licensees to comply with the Code requirements incorporated by reference in 10 CFR 50.55a(a) 18 months prior to the start of the ISI interval.
The licensee proposed an alternative to code requirements for the examination of unbonded post-tensioning system in Table IWL-2500-1 (L-B), Examination Category L-B, and the 5-year ISI schedule (examination frequency) specified in Subarticle IWL-2420 Unbonded Post-Tensioning Systems to extend the examination frequency to 10 years, not perform wire extraction and testing permanently, and limit CPM chemical tests to only absorbed water content, unless additional tests are specified by the RE.
The Braidwood third interval containment ISI (CISI) program complies with the 2013 Edition of the ASME Code. The Braidwood, Unit 1, third CISI interval began on August 29, 2018, and is currently scheduled to end on July 28, 2028. The Braidwood, Unit 2, third CISI interval began on November 5, 2018, and is currently scheduled to end on October 16, 2028.
The Byron, Units 1 and 2, third interval CISI program complies with the 2007 Edition with the 2008 Addenda of the ASME Code. The Byron, Units 1 and 2, third CISI interval began on July 16, 2016, and is currently scheduled to end on July 15, 2025.
The licensee requested authorization for use of the proposed alternative for the third ISI interval pursuant to 10 CFR 50.55a(z)(1), on the basis that it provides an acceptable level of quality and safety, based on performance of its post-tensioning system components as supported by documented data of past plant-specific examinations, and testing and operating experience.
3.0 TECHNICAL EVALUATION
3.1 Licensees Proposed Alternative The licensees proposed alternative requests RR-I4R-11 (Braidwood) and RR-I4R-18 (Byron) are applicable to the Unbonded Post-Tensioning System Components of the Containment Buildings. Specifically, the request is against the following examination requirements in Table IWL-2500-1 (L-B) of the ASME Code,Section XI, Subsection IWL.
Item No. L2.10 requires that selected tendon force and elongation be measured every 5 years in accordance with IWL-2522.
Item No. L2.20 requires that tendon single wire samples be removed and examined for corrosion and mechanical damage as well as tested to obtain yield strength, ultimate tensile strength, and elongation on each removed wire. This inspection must be done every 5 years in accordance with IWL-2523.
Item No. L2.30 requires that a detailed visual examination on selected tendon anchorage hardware and adjacent concrete extending 2 feet from the edge of the bearing plate be performed every 5 years in accordance with IWL-2524. In addition, the quantity of free water released from the anchorage end cap, as well as any free water that drains from the tendon during examination, must be documented.
Item No. L2.40 requires that samples of selected tendon CPM be obtained and analyzed every 5 years in accordance with IWL-2525.
Item No. L2.50 requires that samples of free water be obtained and analyzed every 5 years in accordance with IWL-2525.
The licensees proposed alternative, corresponding to the above code requirements, are requested for the remainder of the current third and subsequent fourth and fifth CISI intervals for Byron and Braidwood, and are requested to continue until the end of the current period of extended operation for each Unit. The alternative is as follows:
Item No. L2.10: the licensee proposed to extend the interval of the examination from 5 to 10 years.
Item No. L2.20: the licensee proposed to eliminate this examination and testing entirely.
Item No. L2.30: the licensee proposed to extend the interval of the examination from 5 to 10 years.
Item No. L2.40: the licensee proposed to extend the interval of the examination from 5 to 10 years. The licensee also proposed that routine CPM testing be limited to determination of absorbed water content and that additional tests for corrosive ion concentration and neutralization number need only be performed if corrosion or moisture conditions favoring corrosion are found, in which case, tests will be performed as specified by the RE.
Item No. L2.50: the licensee proposed to extend the interval of the examination from 5 to 10 years.
To demonstrate that the proposed alternative actions will provide an acceptable level of quality and safety, the licensee provided the information summarized below. The licensee also provided additional benefits to the deferral of the physical testing, such as less exposure of personnel to industrial safety hazards and undesirable conditions, and a reduction of unnecessary loading cycles on the tendons and environmental waste.
The licensee stated that ASME Section XI, Subsection IWL, requires periodic visual examination and physical testing of Containment Building concrete as well as physical testing of post-tensioning systems. The examination and testing to date have indicated that the post-tensioning system is expected to maintain its safety-related function through the period of extended operation for Braidwood, Units 1 and 2, and Byron, Unit Nos. 1 and 2. In its request, the licensee noted that the proposed alternative only apply to the tendon tests and associated examinations that require close-in access to tendon end anchorage areas. General visual or detailed visual examinations of accessible containment concrete surfaces, bearing plates, and tendon end caps will continue to be performed at the required 5-year interval in accordance with Table IWL-2500-1 (L-A), IWL-2410, and IWL-2510. If these visual examinations reveal conditions that could indicate degradation of tendons or tendon hardware components, additional examinations per Item Nos. L2.10, L2.20, L2.30, L2.40 or L2.50 may be conducted, as determined and documented by the RE.
The licensee provided the following example conditions that could require removal of the tendon end cap and further examination per Item Nos. L2.10, L2.20, L2.30, L2.40, and L2.50:
Evidence of possible damage to the enclosed post-tensioning hardware as indicated by conditions such as end cap deformation found during external visual examination.
Conditions observed by removal of the end cap would determine the extent of additional examinations per Item Nos. L2.10, L2.20, L2.30, L2.40, or L2.50.
Active corrosion on a bearing plate or end cap that requires further investigation as determined by the RE in an engineering evaluation.
Evidence of CPM leakage will be evaluated, and a plan developed that requires further investigation and corrective actions as defined in an engineering evaluation documented by the RE.
The licensees request provides plant-specific examination results on Byron, Unit Nos. 1 and 2, and Braidwood, Units 1 and 2, as a basis for the proposed deviations from the ASME Code,Section XI, requirements.
3.2 U.S. Nuclear Regulatory Commission (NRC) Staff Evaluation The NRC staff reviewed the information provided in the proposed alternative request and noted that the licensee will continue to conduct the general visual examinations and detailed visual examination of suspect areas on a 5-year interval as required by Table IWL-2500-1 (L-A)
Examination Category L-A, Concrete. Any indications identified during these examinations may lead to additional examinations in accordance with Table IWL-2500-1 (L-B), Examination Category L-B, Unbound Post-Tensioning System, as determined by the RE. As required by IWL-2511, this would include examination of the concrete surfaces and tendon end anchorage areas (end caps, bearing plates, concrete in the area) on a 5-year interval to identify evidence of damage, deformation, water intrusion, corrosion, cracking, or CPM leakage. Tendon end caps are required to be removed for this examination if there is evidence of tendon end cap deformation or damage. The staff also reviewed the plant-specific information and summary results of examinations conducted for each of the requirements of Section XI, Subsection IWL, Table IWL-2500-1 (L-B), Item Nos. L2.10, L2.20, L2.30, L2.40, and L2.50. A summary of the staffs evaluation of each item number is provided below.
Item No. L2.10, Tendon Force Trends and Forecasts Section 2 of Part D of the licensees request states that Byron, Unit Nos. 1 and 2, measured force trends and forecasts provide ample evidence that mean prestressing in the containment wall and dome will remain above the lower limits specified in Calculation 5.2.2-BYR01-009 until well after the September 2029 deadline for completion of the next surveillance if the interval is extended to 10 years. Section 2 of Part E states that Braidwood, Units 1 and 2, measured force trends and forecasts provide ample evidence that mean prestressing in the containment wall and dome will remain above the lower limits specified in Calculation 5.2.2-BRW-13-0021-S until well after the May 2027 deadline for completion of the next surveillance if the interval is extended to 10 years.
The NRC staff reviewed the lift-off force data and verified that the projected forces remain above the minimum required value (MRV) through the next inspection and through the end of the current operating license. Based on the statistical analyses of past surveillance results, and the significant margin between the measured force trend (forecast) values and the MRV, the staff finds it acceptable to extend the interval of the post-tensioning system examinations and tests (ASME Section XI, Table IWL-2500-1(L-B), Item No. L2.10) from 5 years to 10 years for the third 10-year Byron and Braidwood IWL ISI intervals.
Item No. L2.20, Wire Examination and Test Results Byron:
Section 3.1 of Part D stated that the entire length of each extracted wire was visually examined for signs of damage and corrosion. None of the 17 wires extracted from Unit 1 tendons and the 15 wires extracted from Unit 2 tendons had signs of damage. The condition of most extracted wires was judged to be Level A (1), bright metal with no evidence of corrosion. Level B (2), light rust with no pitting, was observed on a few of the extracted wires. No Level C (3) or higher corrosion was found. There is no indication in any of the surveillance reports that observed corrosion was active. Section 3.4 of Part D of the relief request stated that visual examination of 32 wires extracted from hoop, vertical, and dome tendons between 1984 and 2019 has uncovered no evidence of inservice damage (damage other than that occurring prior to or at the time of initial tensioning or re-tensioning), active corrosion or an unacceptable level of preexisting (prior to tendon duct filling) corrosion.
Section 3.2 of Part D stated that the tensile strength of all specimens exceeds the 240 kilo-pound per square inch (kpsi) minimum specified in ASTM A421. The NRC staff reviewed the results of the tests, as summarized in Tables 9 (for Unit 1) and 10 (for Unit 2) of Part D of the relief request and found that all the tensile tests were above the minimum specified value of 240 kpsi.
The NRC staff finds that Part D, Table 12 - Byron, Unit No. 2, Wire Test Results/Elongation at Failure, shows that the mean value for all test wires from year 1 through year 35 are above 4 percent of the ASME Codes requirement. Since the examination and testing of sample wires has shown no degradation of condition, strength, or the mean elongation value, and has not identified any cases of active corrosion, the staff finds it acceptable to waive the requirement for sample wire removal and testing (ASME Section XI, Table IWL-2500-1 (L-B), Item No. L2.20) for the third 10-year IWL ISI interval Braidwood:
The condition of most extracted wires from Braidwood, Units 1 and 2, was judged to be Level A (1), bright metal with no evidence of corrosion. Level B (2), light rust with no pitting, was observed on a few of the extracted wires. Level E (5), rust with pitting greater than 0.006 in depth, was found on segments of the wires extracted from three tendons. There is no indication in any of the surveillance reports that observed corrosion was active. Also, tensile tests confirmed that wire strength and ductility were not adversely affected by the observed corrosion.
The NRC staff finds that Part E, Table 10 - Braidwood, Unit 2, Wire Test Results/Ultimate Tensile Strength, confirms that the corrosion has not reduced the strength and ductility of these wires. The staff also finds that Table 9 - Braidwood, Unit 1, Wire Test Results/Ultimate Tensile Strength, shows all test wires exceeded the 240 kpsi strength.
Visual examination of the extracted wires did not identify any evidence of active corrosion on the wires. Since the examination and testing of sample wires has shown no degradation of condition, strength, or elongation, and has not identified any cases of active corrosion, the NRC staff finds it acceptable to waive the requirement for sample wire removal and testing (ASME Code,Section XI, Table IWL-2500-1 (L-B), Item No. L2.20) for the third 10-year IWL ISI interval.
Item No. L2.30, Anchorage Hardware and Surrounding Concrete Inspection Part D (Byron), Section 4.6, stated that tendon end anchorage hardware and adjacent concrete have performed well throughout the life of the plant (through the most recent surveillance in 2019) and show no trends of deteriorating condition. Free water has been found during end anchorage examinations, but it has not caused corrosion. All sample analyses have shown the free water to be alkaline with a pH greater than seven and, therefore, noncorrosive. There have been no findings of active corrosion on bearing plate areas within the end cap gasket ring, anchor heads, shims, or wires. Corrosion observed on exposed areas of bearing plates is minor (depth of pitting/loss of metal small relative to plate thickness) and has no structural significance. All observed corrosion has been found acceptable with no indication that the incidence of corrosion is increasing over time.
Only 11 discontinuous wires (wires with unseated button heads not verified to be continuous or wires with missing button heads) not previously reported have been found. These represent only a miniscule fraction (less than 0.03 percent) of the ~39,000 wires comprising the 230 tendons examined. No damage, cracking or distortion has been found during visual examinations of bearing plates, anchor heads, and shims. Cracking of concrete adjacent to bearing plates is limited to that resulting from shrinkage and presence of stress risers (plate corners, dome pocket concrete edges) or that due to rapid drying following initial placement of thin sections in pocket areas. There has been no evidence of structural cracks (those caused by applied loads) in the vicinity of surveillance sample tendon end anchorages. Only six anchorage area cracks, two at Unit 1 anchorage areas and four at Unit 2 anchorage areas, wider than 0.010 have been documented. All of these are noted in the first and third examination year reports. No cracks greater than 0.010 inches in width are noted in later reports. All observed cracks were judged to have no structural significance.
Part E (Braidwood), Section 4, stated no active corrosion was observed on anchor heads, bushings, shims, button heads or areas of bearing plates that are enclosed by the end cap gasket and protected by CPM.
Section 4.1 stated that corrosion observed during the eight surveillances conducted to date leads to the following conclusions.
Corrosion observed on system anchorage components is inactive and is presumed to have occurred prior to or during construction and prior to CPM installation While there is evidence that anchor heads, shims, and a few button heads experienced corrosion during construction or earlier, any such corrosion is now inactive As there is no evidence of significant active corrosion occurring since the completion of construction and the injection of CPM into the tendon end caps and ducting, there is no need to continue examining for corrosion at 5-year intervals; increasing the examination interval to 10 years will not result in a failure to uncover an unacceptable condition that has developed over the interval The NRC staff reviewed the data presented by the licensee during the past eight surveillances.
The data indicate that there is: (1) no active corrosion on anchor heads, bushings, shims, button heads, or areas of bearing plates, (2) no acidic water in the free water, (3) no structural cracks in concrete, and (4) no significant numbers of discontinuous wires.
Therefore, the NRC staff finds it acceptable to extend the interval of the anchorage hardware examinations (ASME Section XI, Table IWL-2500-1(L-B), Item No. L2.30) from 5 years to 10 years for the third 10-year IWL ISI Interval for Byron and Braidwood.
Item Nos. L2.40 and L2.50, CPM, and Free Water Testing Part D, Sections 4.2 and 5, and Part E, Sections 4.2 and 5, show the results of CPM tests from Byron and Braidwood. The results show the absorbed water content, corrosive ion concentrations, and neutralization number during the past eight surveillances spanning a period of three decades from 1987 to 2016, and confirm that acceptance criteria have been met and that there are no discernible trends over time indicating that the corrosion protection capacity of the CPM is degrading over time.
In particular:
All reported absorbed water content values are below the 1 percent (of dry weight) upper limit except four samples that exceeded 10 percent but did not show a trend with time.
All corrosive ion concentrations are below the ten parts per million upper limit and many are below the indicated limit of resolution applicable to the ion.
All neutralization numbers are acceptable. There is no apparent trend to the neutralization number data which leads to the conclusion that the corrosion protection capacity of the CPM is degrading with time.
Based on the above data, the licensee concluded: (1) that the interval between such tests can be extended to 10 years with no adverse consequences, and (2) unless evidence of active corrosion is found during visual examinations of end anchorage hardware and extracted wires or evidence of free water intrusion or the quantity of absorbed water is found to have increased over time, there should be no need to perform the tests for corrosive ions and neutralization number. Therefore, the licensee requested that these tests need be performed only if corrosion or moisture conditions favoring corrosion are found, in which case tests will be performed as specified by the RE.
Based on a review of the past inspection results, and there being no evidence of a negative trend in CPM quality, the NRC staff finds it acceptable to extend the interval of the CPM test for absorbed water and free water tests (ASME Code,Section XI, Table IWL-2500-1(L-B), Item Nos. L2.40 and L2.50) from 5 years to 10 years for the third 10-year IWL ISI intervals for Byron and Braidwood. In addition, the staff finds it is acceptable to waive the requirement to perform the tests of CPM for corrosive ions and neutralization number for the third IWL ISI intervals because these tests may not be necessary unless evidence of active corrosion is found from visual examinations of anchorage hardware/wires or the quantity of absorbed water in the CPM has increased with time. No such conditions of significance have been found during past examinations at Byron or Braidwood.
Summary Based on the above evaluation, the NRC staff determines that the licensee has demonstrated adequate performance of the unbonded post-tensioning system by presenting plant-specific (P-T) system inspection results and operating experience, and technical evaluations demonstrating applied tendon prestress will remain acceptable. Therefore, the NRC staff finds that the use of proposed alternative (RR-I4R-11 for Braidwood, Units 1 and 2, and RR-I4R-18 for Byron, Units 1 and 2) for the third 10-year IWL ISI intervals at Braidwood and Byron provides an acceptable level of quality and safety.
The regulations in 10 CFR 50.55a(z) allow the NRC staff to authorize alternatives to the requirements in paragraphs (b) through (h) of 10 CFR 50.55. The requirements for 10-year ISI intervals after the first inspection interval are established by 10 CFR 50.55a(g)(4)(ii), and require licensees to comply with the Code requirements incorporated by reference in 10 CFR 50.55a(a) 18.months prior to the start of the ISI interval. The ISI requirements for the third ISI intervals at Braidwood and Byron, as described in Section 2.0 of this safety evaluation, were established in accordance with 10 CFR 50.55a(g)(4)(ii). The ISI requirements for future ISI intervals at Braidwood and Byron have not yet been established, as it is unknown what Code requirements will be in effect 18 months prior to the start of those ISI intervals. Therefore, the NRC staff cannot presently approve the licensees request that this relief be made permanent until the end of the period of extended operation.
4.0 CONCLUSION
As set forth above, the NRC staff determines that the proposed alternative provides an acceptable level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed the regulatory requirements set forth in 10 CFR 50.55a(z)(1) for the third inspection intervals at Braidwood and Byron. Since the containment ISI requirements beyond the third 10-year intervals at Braidwood and Byron have not yet been established in accordance with 10 CFR 50.55a(g)(4)(ii), no authorization can be made for subsequent intervals after the third inspection intervals. Therefore, the NRC staff authorizes the proposed alternative RR-I4R-11 at Braidwood and RR-I4R-18 at Byron with the limitation that the alternative is authorized for use only for their respective third 10-year IWL ISI intervals.
All other ASME Code,Section XI, requirements for which the alternative was not specifically requested and authorized remain applicable, including a third-party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: J. Ma Date: August 3, 2021
ML21134A006 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DEX/ESEB/BC OGC NAME JWiebe SROHRER JColaccino STurk NLO DATE 5/17/20 5/17/21 4/30/21 8/2/2021 OFFICE NRR/DORL/LPL3/BC NAME NSalgado DATE 8/3/21