ML22136A113
| ML22136A113 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/21/2022 |
| From: | Nancy Salgado Plant Licensing Branch III |
| To: | Penfield R Energy Harbor Nuclear Corp |
| Wall S | |
| References | |
| EPID L-2021-LLR-0096, EPID L-2021-LLR-0097 | |
| Download: ML22136A113 (12) | |
Text
June 21, 2022 Mr. Rod L. Penfield Site Vice President Energy Harbor Nuclear Corp.
Perry Nuclear Power Plant P.O. Box 97, Mail Stop A-PY-A290 Perry, OH 44081-0097
SUBJECT:
PERRY NUCLEAR POWER PLANT, UNIT NO. 1 - ISSUANCE OF RELIEF RE: PROPOSED ALTERNATIVE REQUESTS VR-10, REVISION 0, AND VR-11, REVISION 0, ASSOCIATED WITH THE FOURTH 10-YEAR INSERVICE TESTING INTERVAL (EPIDS L-2021-LLR-0096; L-2021-LLR-0097)
Dear Mr. Penfield:
By letter dated December 28, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21362A448), Energy Harbor Nuclear Corp. (the licensee) submitted alternative requests Nos. VR-10, Revision 0, and VR-11, Revision 0, to the U.S. Nuclear Regulatory Commission (NRC) for the use of alternatives to certain inservice testing (IST) program requirements of the American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Section IST (OM Code) for the Perry Nuclear Power Plant, Unit 1 (PNPP).
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 in VR-10, Revision 0, and VR-11, Revision 0, on the basis that the proposed alternative will provide an acceptable level of quality and safety.
The NRC staff has reviewed the subject requests and concludes, as set forth in the enclosed safety evaluation, that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(1). Therefore, the NRC staff authorizes the proposed alternatives in VR-10, Revision 0, and VR-11, Revision 0, for the fourth 10-year IST interval at PNPP which began May 18, 2019, and is scheduled to expire May 17, 2029.
All other requirements in the ASME OM Code for which relief was not specifically requested and approved in this request remains applicable.
If you have any questions, please contact the Senior Project Manager, Scott Wall, at 301-415-2855 or e-mail at Scott.Wall@nrc.gov.
Sincerely, Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-440
Enclosure:
Safety Evaluation cc: Listserv Robert F.
Kuntz Digitally signed by Robert F. Kuntz Date: 2022.06.21 10:08:00 -04'00'
Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ALTERNATIVE REQUESTS VR-10 AND VR-11 FOURTH 10-YEAR INTERVAL INSERVICE TESTING INTERVAL ENERGY HARBOR NUCLEAR CORP.
PERRY NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-440
1.0 INTRODUCTION
By letter dated December 28, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21362A448), Energy Harbor Nuclear Corp. (the licensee) submitted alternative requests for VR-10, Revision 0, and VR-11, Revision 0, to the U.S. Nuclear Regulatory Commission (NRC or Commission) for the use of alternatives to certain inservice testing (IST) program requirements of the American Society of Mechanical Engineers (ASME)
Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Section IST (OM Code) for the Perry Nuclear Power Plant, Unit 1 (PNPP).
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 in VR-10, Revision 0, and VR-11, Revision 0, on the basis that the proposed alternative will provide an acceptable level of quality and safety.
2.0 REGULATORY EVALUATION
The NRC regulations in 10 CFR 50.55a(f)(4) state, in part, that throughout the service life of a boiling-or pressurized-water cooled nuclear power facility, pumps and valves that are within the scope of the ASME OM Code must meet the IST requirements (except design and access provisions) set forth in the ASME OM Code and addenda that become effective subsequent to editions and addenda specified in 10 CFR 50.55a(f)(2) and (3) and that are incorporated by reference in 10 CFR 50.55a(a)(1)(iv), to the extent practical within the limitations of design, geometry, and materials of construction of the components. The IST requirements for pumps and valves that are within the scope of the ASME OM Code but are not classified as ASME Code Class 1, Class 2, or Class 3, may be satisfied as an augmented IST program in accordance with 10 CFR 50.55a(f)(6)(ii) without requesting relief under 10 CFR 50.55a(f)(5) or alternatives under 10 CFR 50.55a(z). This use of an augmented IST program may be acceptable provided the basis for deviations from the ASME OM Code, as incorporated by reference in 10 CFR 50.55a, demonstrates an acceptable level of quality and safety, or that implementing the code provisions would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety, where documented and available for NRC review.
The NRC regulations in 10 CFR 50.55a(b)(3)(xi), OM condition: Valve Position Indication, state the following:
When implementing paragraph ISTC-3700, Position Verification Testing, in the ASME OM Code, 2012 Edition through the latest edition and addenda of the ASME OM Code incorporated by reference in paragraph (a)(1)(iv) of this section
[10 CFR 50.55a], licensees shall verify that valve operation is accurately indicated by supplementing valve position indicating lights with other indications, such as flow meters or other suitable instrumentation to provide assurance of proper obturator position for valves with remote position indication within the scope of Subsection ISTC including its mandatory appendices and their verification methods and frequencies.
The regulations in 10 CFR 50.55a(z) state, in part, that alternatives to the requirements in paragraphs (b) through (h) of 10 CFR 50.55a may be authorized by the NRC if the licensee demonstrates that: (1) the proposed alternative provides an acceptable level of quality and safety, or (2) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
3.0 TECHNICAL EVALUATION
The information provided by the licensee in support of the requests for alternatives to ASME OM Code requirements has been evaluated and the bases for disposition are documented below.
For clarity, the licensee's requests have been evaluated in several parts according to ASME OM Code testing category.
=
Applicable Code Edition and Addenda===
The 2012 Edition of the ASME OM Code, as incorporated by reference in 10 CFR 50.55a with conditions, is applicable to the current 10-year IST program interval at PNPP.
Duration of the Alternative The duration of the proposed alternatives is for the fourth 10-year ISI interval, which began on May 18, 2019, and is scheduled to end on May 17, 2029.
3.1 Proposed Alternative VR-10, Revision 0 3.1.1 ASME Code Components Affected The request applies to the components in the following table:
Table 1 Component ID Component Description Code Class Valve Category 1C41-F006 Standby Liquid Control Injection Outboard Check Valve 1
C*
1C41-F007 Standby Liquid Control Injection Inboard Check Valve 1
C*
1E12-F008 Shutdown Cooling OTBD Suction Isolation Valve 1
A 1E12-F009 Shutdown Cooling INBD Suction Isolation Valve 1
A 1E12-F041A Low Pressure Coolant Injection A Injection Check Valve 1
C*
1E12-F042A Low Pressure Coolant Injection A Injection Valve 1
A 1E12-F041B Low Pressure Coolant Injection B Injection Check Valve 1
C*
1E12-F042B Low Pressure Coolant Injection B Injection Valve 1
A The four pressure isolation valves (PIVs) identified as Category C valves also have the requirement of a Category A valve classification for which seat leakage is limited to a specific maximum amount in the closed position to fulfill their required function(s) and, therefore, are subject to the requirements of ASME OM Code, subsection ISTC, paragraph ISTC-3630.
3.1.2 Applicable Code Requirements ASME OM Code, Subsection ISTC, paragraph ISTC-3522, Category C Check Valves, subparagraph (a), states, in part, that During operation at power, each check valve shall be exercised or examined in a manner that verifies obturator travel by using the methods in para.
ISTC-5221.
ASME OM Code, Subsection ISTC, paragraph ISTC-3630, Leakage Rate for Other Than Containment Isolation Valves, states, in part, that Category A valves with a leakage requirement not based on an Owners 10 CFR 50, Appendix J program, shall be tested to verify their seat leakages are within acceptable limits. Valve closure before seat leakage testing shall be by using the valve operator with no additional closing force applied.
ASME OM Code, Subsection ISTC, paragraph ISTC-3630, subparagraph (a), Frequency, states that Tests shall be conducted at least once every 2 yr [years].
3.1.3 Reason for Request In accordance with 10 CFR 50.55a(z)(1), the licensee requests an alternative from the requirements of ASME OM Code, subsection ISTC, paragraph ISTC-3630(a), for the eight subject PIVs listed in the request. Additionally, for two of the subject PIVs (1C41-F006 and 1C41-F007), the licensee requests an alternative from the requirements of paragraph ISTC-3522. The basis is that the proposed alternative would provide an acceptable level of quality and safety while substantially lowering cumulative radiation exposure.
ASME OM Code, subsection ISTC, paragraph ISTC-3630, requires leakage rate testing for PIVs to be performed at least once every 2 years. PIVs are not directly included in the scope of performance-based testing as provided in 10 CFR Part 50, appendix J, Primary Reactor Containment Leakage Testing for Water-Cooled Reactors, Option B, Performance-Based Requirements. Some of these valves may be containment isolation valves (CIVs) but are out of the appendix J scope considering they are water sealed. Approval of this alternative will allow PIV testing at PNPP to be conducted on a performance-based frequency.
The PNPP technical specification 5.5.12, Primary Containment Leakage Rate Testing Program, contains a requirement to establish a leakage rate testing program in accordance with the guidelines contained in Nuclear Energy Institute (NEI) Topical Report NEI 94-01 (Revision 3-A), Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J, with conditions and limitations in NEI 94-01, Revision 2-A.
The Option B alternative for CIVs states that licensees should be allowed to adopt cost effective methods for complying with regulatory requirements. NEI 94-01, Revision 3-A, describes risk-informed basis for the extended test intervals under Option B. The CIVs that have demonstrated good performance by the successful completion of two consecutive leakage rate tests over two consecutive cycles may increase their test frequencies. It also states that if the component does not fail within two operating cycles, further failures appear to be governed by the random failure rate of the component. NEI 94-01 presents the results of a comprehensive risk analysis, with the conclusion that the risk impact associated with increasing [leak rate] test interval is negligible (i.e., less than 0.1 percent of total risk).
The eight PIV valves identified in this alternative are tested with water pressurized between 1040 and 1060 pounds per square inch gate (psig) as required by surveillance requirement 3.4.6.1. This request is intended to provide for a performance-based scheduling of PIV tests at PNPP. The reason for requesting this alternative is to reduce required resources and over 600 millirem (mrem) dose received for testing each outage.
NUREG-0933, Resolution of Generic Safety Issues, Issue 105, Interfacing Systems LOCA
[loss of coolant accident] at LWRs [light-water reactors], establishes the need for PIV leak rate testing based on three pre-1985 historical failures of applicable valves industry wide. All three failures were due to human error in operation or maintenance. None of the failures were due to in-service equipment degradation.
3.1.4 Licensees Proposed Alternative The licensee is requesting an alternative from ASME OM Code, subsection ISTC, paragraph ISTC-3630(a), for all eight subject valves, and an alternative from paragraph ISTC-3522, specifically, for the exercise close testing requirements for valves,1C41-F006 and 1C41-F007.
The proposed alternative from ASME OM Code, subsection ISTC, paragraph ISTC-3630(a), for the eight PIVs would establish the specific test interval for each PIV based on its historical performance and would be consistent with the CIV testing process under 10 CFR Part 50, Appendix J, Option B. Performance-based scheduling of the PIVs will be controlled like the methods described in NEI 94-01, Revision 3-A. The frequency of testing would range from every refueling outage (RFO) to every third RFO dependent on valve performance. Valves that have demonstrated good performance for two consecutive cycles may have their test interval extended up to 75 months. If a valve fails the leak rate test, the interval will be reduced back to the 2-year interval until the valve has re-established good performance.
The primary basis for this request is the historical performance of the PIVs. The historical performance of the eight subject valves over the past six consecutive RFOs is compiled in a table attached to alternative request VR-10. The historical test performance for the eight PIVs consistently demonstrates successful leakage test results.
Valve functional capability is demonstrated by the open and close exercise test for 1E12-F041A and 1E12-F041B, and the requirements of ASME OM Code, Mandatory Appendix III, section III-3300, Inservice Test, and section III-3600, MOV [motor-operated valve] Exercising Requirements, for 1E12-F008, 1E12-F009, 1E12-F042A, and 1E12-F042B. These tests are separate and distinct from the PIV testing and are performed in accordance with the requirements of the ASME OM Code. For valves 1C41-F006 and 1C41-F007, the proposed alternative from paragraph ISTC-3522 exercise close testing would credit the PIV leak rate testing and will be on the same frequency as the PIV leak rate testing. The exercise open testing of 1C41-F006 and 1C41-F007 will be retained on a RFO interval and will be demonstrated by the ability to flow 41.9 gallons per minute (gpm) from the standby liquid control system to the reactor pressure vessel. Considering the historical performance of the PIVs, it is clear the eight subject valves are exhibiting the required obturator movement to close and remain closed.
NEI 94-01, Revision 3-A, is not the sole basis for the request given that it does not address seat leakage testing with water. The NEI document is being cited as an approach analogous to the requested alternative method. If the proposed alternative is authorized and the valves exhibit good performance, the PIV test frequency will be altered as described in NEI 94-01, Revision 3-A, so that testing is not required every RFO. The extension of test frequencies will be consistent with the guidance provided for appendix J, Type C, leak rate tests as detailed in NEI 94-01, Revision 3-A, paragraph 10.2.3.2, Extended Test Interval.
3.1.5 NRC Staff Evaluation The licensee has proposed an alternative test in lieu of the requirements in 2012 Edition of the ASME OM Code, subsection ISTC, paragraph ISTC-3630(a) for eight PIVs at PNPP.
Specifically, the licensee proposed to functionally test and verify the leakage rate of these PIVs using the 10 CFR Part 50, Appendix J, Option B, performance-based schedule. The proposed alternative from ASME OM Code, subsection ISTC, paragraph ISTC-3630(a), for the eight PIVs would establish the specific test interval for each PIV based on its historical performance, and would be consistent with the CIV testing process under 10 CFR Part 50, Appendix J, Option B. Performance-based scheduling of the PIVs will be controlled like the methods described in NEI 94-01, Revision 3-A. The frequency of testing would range from every RFO to every third RFO dependent on valve performance. Valves that have demonstrated good performance for two consecutive cycles may have their test interval extended up to 75 months.
If a valve fails the leak rate test, the interval will be reduced back to the 2-year interval until the valve has re-established good performance.
The regulations in 10 CFR Part 50, Appendix J, Option B, allows a performance-based leakage test program. Guidance for implementation of acceptable leakage rate test methods, procedures, and analyses is provided in NRC Regulatory Guide (RG) 1.163, Performance Based Containment Leak Test Program (ML003740058). RG 1.163 endorses NEI Topical Report 94-01, Revision 0, Industry Guideline for Implementing Performance Based Option of 10 CFR 50, Appendix J, dated July 26, 1995, with the limitation that Type C components test interval cannot extend greater than 60 months. The current version of NEI 94-01 is Revision 3-A, which allows Type C CIV test intervals to be extended to 75 months with a permissible extension for non-routine emergent conditions of 9 months (84 months total).
The NRC staff finds the guidance in NEI 94-01, Revision 3-A, to be acceptable (ML121030286 and ML12226A546), with the following conditions:
- 1)
Extended interval for Type C local leakage rate tests (LLRTs) may be increased to 75 months with the requirement that a licensees post outage report include the margin between Type B and Type C leakage rate summation and its regulatory limit. In addition, a corrective action plan shall be developed to restore the margin to an acceptable level.
Extensions of up to nine months (total maximum interval of 84 months for Type C tests) are permissible only for non-routine emergent conditions. This provision (nine-month extension) does not apply to valves that are restricted and/or limited to 30-month intervals in Section 10.2 (such as boiling water reactor (BWR) main steam isolation valves (MSIVs))
or to valves held to the base interval (30 months) due to unsatisfactory LLRT performance.
- 2)
When routinely scheduling any LLRT valve interval beyond 60-months and up to 75-months, the primary containment leakage rate testing program trending or monitoring must include an estimate of the amount of understatement in the Types B & C total and must be included in a licensees post-outage report. The report must include the reasoning and determination of the acceptability of the extension, demonstrating that the LLRT totals calculated represent the actual leakage potential of the penetrations.
The licensee specifies that valve functional capability will be demonstrated by the open and close exercise test for 1E12-F041A and 1E12-F041B, and the requirements of ASME OM Code, Mandatory Appendix III, sections III-3300 and III-3600, for 1E12-F008, 1E12-F009, 1E12-F042A, and 1E12-F042B. For valves 1C41-F006 and 1C41-F007, the proposed alternative from paragraph ISTC-3522 exercise close testing requirement would credit the PIV leak rate testing and will be on the same frequency as the PIV leak rate testing. The exercise open testing of 1C41-F006 and 1C41-F007 will be retained on an RFO interval and will be demonstrated by the ability to flow 41.9 gpm from the standby liquid control system to the reactor pressure vessel. The NRC staff considers the specified actions to exercise valves 1C41-F006 and 1C41-F007 to provide a reasonable demonstration of exercising capability.
Based on the review of alternative request VR-10, the NRC staff has determined that the leakage rate testing and exercising for the specific valves as requested in VR-10 at PNPP will provide reasonable assurance of their operational readiness, including leak rate performance.
Therefore, the NRC staff finds that, for these specific valves, the implementation of the proposed alternative at PNPP provides an acceptable level of quality and safety in accordance with 10 CFR 50.55a(z)(1).
3.2 Proposed Alternative VR-11, Revision 0 3.2.1 ASME Code Components Affected In its application, the licensee states that the valves covered by ASME OM Code Case OMN-28 are those stem-disk separation non-susceptible valves with remote position indication within the scope of subsection ISTC of the ASME OM Code (2012 Edition) including its mandatory appendices and their verification methods and frequencies, in accordance with regulatory requirements. The licensee notes that a listing of the valves requiring position indication and testing in accordance with ISTC-3700 (Position Verification Testing) was submitted by correspondence to the Commission dated February 13, 2020 (ML20045E972), as part of the fourth 10-year IST program update and is maintained up to date as required by ASME OM Code.
3.2.2 Applicable Code Requirement Paragraph ISTC-3700, Position Verification Testing, of the ASME OM Code (2012 Edition), subsection ISTC, states:
Valves with remote position indicators shall be observed locally at least once every 2 yr [years] to verify that valve operation is accurately indicated. Where practicable, this local observation should be supplemented by other indications such as use of flow meters or other suitable instrumentation to verify obturator position. These observations need not be concurrent. Where local observation is not possible, other indications shall be used for verification of valve operation.
Position verification for active MOVs [motor-operated valves] shall be tested in accordance with Mandatory Appendix III of this Division.
The supplemental indication portion of ASME OM Code, subsection ISTC, paragraph ISTC-3700, is made mandatory by 10 CFR 50.55a(b)(3)(xi).
3.2.3 Reason for Request Pursuant to 10 CFR 50.55a(z)(1), the licensee proposed the alternative to the requirements of ASME OM Code, subsection ISTC, paragraph ISTC-3700. The position verification with supplemental position indication requires the valves to be exercised in the open and closed direction and the valves position verified by other indications such as the use of flow meters or other suitable instrumentation to verify obturator position. ASME OM Code Case OMN-28 has been determined to satisfy the valve position verification requirements in ASME OM Code, subsection ISTC, paragraph ISTC-3700, for valves that are not susceptible to stem-disk separation.
3.2.4 Licensees Proposed Alternative In lieu of compliance with ISTC-3700, the licensee proposes to implement ASME OM Code Case OMN-28 on the basis that it provides an acceptable level of quality and safety in accordance with 10 CFR 50.55a(z)(1).
The valves covered by this code case are those stem-disk separation non-susceptible valves with remote position indication within the scope of Subsection ISTC, including its mandatory appendices and their verifications methods and frequencies, in accordance with regulatory requirements. Valves with remote position indication within the scope of ASME OM Code, subsection ISTA, General Requirements, paragraph ISTA-1100, Scope, not satisfying the scope and provisions of this code case shall meet the valve position verification requirements in ASME OM Code, subsection ISTC, paragraph ISTC-3700, in accordance with regulatory requirements.
To categorize a valve as not susceptible to stem-disk separation, the valve shall have a documented justification that the stem-disk connection is not susceptible to separation based on the internal design, service conditions, applications, and evaluation of the stem-disk connection using plant-specific and industry operating experience, and vendor recommendations.
Valves with remote position indicators that are not susceptible to stem-disk separation shall be verified to accurately represent valve operation as discussed in paragraph 1.4, Position Verification Testing Requirements for Valves Not Susceptible to Stem-Disk Separation, of the code case.
Code Case OMN-28 was approved for use by the ASME on March 4, 2021, and is listed on the ASME OM Code Case index as being applicable to the 2012 Edition. The ASME OM Code, 2012 Edition, is the current applicable edition at PNPP.
3.2.5 NRC Staff Evaluation The NRC staff reviewed the provisions in the ASME OM Code Case OMN-28 used to demonstrate that the remote position indicators for valves that are not susceptible to stem-disk separation accurately represent valve operation (open and closed). The code case requires remote position verification for valves that are not susceptible to stem-disk separation to include:
(a) observation of evidence, such as changes in system pressure, flow rate, level, or temperature, that represent valve operation; (b) local observation of valve operation where practicable; and (c) stem-disk separation evaluation shall be documented and available for regulatory review demonstrating that the stem-disk connection is not susceptible to separation.
For active valves not susceptible to stem-disk separation, the code case states that these observations shall be performed at least once every 12 years. For passive valves not susceptible to stem-disk separation, the code case states that these observations shall be performed whenever the valve is stroked from its passive position or every 12 years, whichever is greater.
The licensee proposes to implement ASME OM Code Case OMN-28 in its entirety, without any deviations, for the specific valves referenced Section 3.2.1 of this safety evaluation. The NRC staff notes that, when implementing alternative request VR-11, the licensee will verify that valve operation is accurately indicated by supplementing valve position indicating lights with other indications, such as flow meters or other suitable instrumentation to provide assurance of proper obturator position for valves with remote position indication within the scope of ASME OM Code, subsection ISTC, including its mandatory appendices and their verification methods and frequencies.
Based on the review of VR-11 and the provisions in ASME OM Code Case OMN-28, the NRC staff has reasonable assurance that the remote position indicators for the valves specified in VR-11 will be properly verified to accurately represent valve operation (open and closed) at PNPP. Therefore, the NRC staff finds that, for these specific valves, the implementation of the proposed alternative at PNPP provides an acceptable level of quality and safety in accordance with 10 CFR 50.55a(z)(1).
4.0 CONCLUSION
As set forth above, the NRC staff finds that the proposed alternatives described in VR-10, Revision 0, for leakage rate testing and exercising for specific valves at PNPP, and VR-11, Revision 0, to implement ASME OM Code Case OMN-28 in its entirety, without any deviations, for the specified valves at PNPP, provide 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). Therefore, the NRC staff authorizes the licensee to use the proposed alternative requests:
VR-10, Revision 0, in lieu of the applicable requirements in the ASME OM Code (2012 Edition), subsection ISTC, paragraphs ISTC-3522 and ISTC-3630, as incorporated by reference in 10 CFR 50.55a; and VR-11, Revision 0, to implement the ASME OM Code Case OMN-28 in its entirety, as specified in its December 28, 2021, application, for the verification of valve position indication for valves at PNPP identified as having position indication requirements (referred to as PI [performance indicator] requirements) in the IST program plan submitted by correspondence to the Commission dated February 13, 2020 (ML20045E972), that are not susceptible to stem-disk separation, in lieu of the requirements in the ASME OM Code (2012 Edition), subsection ISTC, paragraph ISTC-3700, as incorporated by reference in 10 CFR 50.55a and supplemented by 10 CFR 50.55a(b)(3)(xi).
This authorization is for the remainder of the fourth 10-year IST program interval at PNPP which began on May 18, 2019, and is scheduled to end on May 17, 2029.
All other ASME OM Code requirements, as incorporated by reference in 10 CFR 50.55a, for which relief or an alternative was not specifically requested, and granted or authorized (as appropriate), in the subject request remain applicable.
Principal Contributors: Michael Breach, NRR Thomas G. Scarbrough, NRR Date: June 21, 2022
- via memo OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DEX/EMIB/BC* NRR/DORL/LPL3/BC NAME SWall SRohrer SBailey NSalgado (RKuntz for)
DATE 05/16/22 05/17/22 05/11/22 06/21/22