ML24101A277

Enclosure B: Beaver Valley Power Station, Unit 2 - Responses to Request for Additional Information - Refueling Outage 23 Steam Generator 180 Day Report

ML24101A277
Person / Time
Site:	Beaver Valley
Issue date:	03/31/2024
From:	James Smith Westinghouse
To:	Office of Nuclear Reactor Regulation
Shared Package
ML24101A274	List: L-24-055, Enclosure a: Westinghouse - Affidavit ML24101A275 ML24101A277
References
L-24-055 DMW-NRCD-RF-LR-000005 NP, Rev. 0
Download: ML24101A277 (1)

Text

Enclosure B L-24-055 Non-Proprietary Response to Request for Additional Information (Public)

(14 pages follow)

Westinghouse Non-Proprietary Class 3 Westinghouse Electric Company LLC DMW-NRCD-RF-LR-000005 NP-Attachment Revision 0 Beaver Valley Power Station, Unit 2 - Responses to Request For Additional Information -

Refueling Outage 23 Steam Generator 180 Day Report March2024 Author:

Jay R. Smith*

Component Design and Management Programs Verifier:

Mitchell D. Krinock*

Component Design and Management Programs Reviewer:

Gary W. Whiteman*

Licensing Engineering Approved:

Robert S. Chappo, Jr.*, Manager Component Design and Management Programs

©2024 Westinghouse Electric Company LLC All Rights Reserved

• Electronically approved records are authenticated in the Electronic Document Management System.

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• • • This record was final approved on 03/27/2024 09:14:19. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 Beaver Valley Power Station, Unit 2 - Responses to Request For Additional Information-Refueling Outage 23 Steam Generator 180 Day Report

Background

By letter dated October 31, 2023 (Reference 1 ), Energy Harbor Nuclear Corp. submitted the Unit #2 - 2R23 Steam Generator 180 Day Report summarizing the results of the Spring 2023 steam generator (SG) inspections performed at Beaver Valley Power Station, Unit 2 (BVPS-2). The inspections were performed during refueling outage 23 (2R23). Technical Specification (TS) Section 5.6.6.2 requires that a report be submitted within 180 days after the initial entry into hot shutdown (MODE 4) following completion of an inspection of the SGs performed in accordance with TS Section 5.5.5.2.

Responses to Request for Additional Information To complete its review of the inspection, the U.S. Nuclear Regulatory Commission (NRC) staff requests the following additional information (Reference 2):

RAil During RFO 22 (2R22), four tubes with +Point probe circumferential indications in the Alloy 800 nickel banded sleeve region were plugged. Information about these 2R22 indications (ML23304A213) was subsequently provided to the NRC in response to a request for additional information. Since that time additional investigation was performed, (e.g., mock-up samples fabrication and destructive analysis, eddy current analysis of sleeved tubes and mock-up samples,) to determine the cause of these indications. The investigations showed that the nickel band hardness is higher than the parent tube in the post hard roll condition and can make an impression or indentation in the parent tube, especially at the edge of the nickel. This resulted in the classification of benign indications in more than 40 sleeved tubes that either were in service and were inspected during 2R23 or were initially placed into service during 2R23:

a.

Provide more details about the sleeve mockup testing results including the nickel plating hardness relative to the parent tube hardness and degree of impression into the parent tube. Has the nickel plating composition, material properties, and sleeve plating process remained consistent over the sleeve population placed into service in the Beaver Valley Unit 2 SGs?

Response

During the initial causal investigation of the four 2R22 circumferential sleeve indications, a review of the eddy current data of the sleeve/tube/notch samples used for the site-specific qualification of the Ghent Version 2 probe for Alloy 800 (A800) mechanical sleeves was performed. The site-specific qualification (Reference 4) was performed in accordance with Appendix Hof the EPRI Steam Generator Examination Guidelines (Reference 3) and had been previously submitted to the NRC in Enclosure D of Reference 5.

For the qualification, nine (9) test sample assemblies were fabricated that contained 25 electro-discharge machine (EDM) axial and circumferential inner diameter notches placed in the parent tube inner diameter at the edges and middle of the sleeve nickel plating region. Each test sample simulated the lower tubesheet sleeve joint at the nickel band region and consisted of hard rolling the parent tube into a split collar and an A800 sleeve with the nickel band EDM notches was hard rolled into each tube/collar assembly. The hard rolling of the sleeve into the parent tube/collar assembly was performed with a torque of [

]a,c,e DMW-NRCD-RF-LR-000005 NP-Attachment Rev.0 Page 2 of 13

• • • This record was final approved on 03/27/2024 09:14:19. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 and was lower than the [

]a,c,e torque used in field sleeve installation to minimize the potential for altering the EDM notch flaws. These samples are herein referred to as the "Appendix H" samples. While the qualification was for the Ghent Version 2 probe, a combination probe was used that contained both Ghent Version 2 probe coils and +POINT probe coils.

The Ghent Version 2 probe and +POINT probe data from the Appendix H samples were reviewed by a team of four Level III Qualified Data Analysts as part of the investigation into the 2R22 sleeve indications.

Also reviewed, was the 2R22 indications and their associated post installation baseline inspection data that was collected prior to placing the sleeves into service. During these reviews, it was observed that most of the Appendix H samples, and the sleeve baseline data of the four (4) affected sleeves contained similar signals at the edge of the nickel band. Two of the Appendix H samples were selected for destructive examination to determine the cause of the signals.

The destructive examination of the Appendix H qualification samples was focused on physical features that may have caused the eddy current signals, such as metal smearing, nickel debonding, gaps or voids. The two samples were also ground and polished for examination by light optical microscopy (LOM) and scanning electron microscopy (SEM) to characterize any physical features that may have caused the signals.

Upon disassembly of the sleeve/tube samples, it was evident that marks or grooves were present on each sample and were located on the inner surface of the parent tube at locations adjacent to the edges of the nickel-plating region of the sleeve. The inner diameter surface conditions of each sample are shown in Figure 1 and Figure 2. Figure 1 shows the inner surface of the Sample S6 parent tube where there were 2 prominent grooved depressions or marks that traverse the entire tube circumference at the locations that are adjacent to the top and bottom edges of sleeve nickel plating. Figure 2 shows the inner surface of Sample S3 where the marks are not as prominent but are present and adjacent to lower edge of the sleeve nickel plating. The depths ranged from [

]b to [

t with an average of [

]bas measured by light optical microscopy.

Visual examination of the sleeves removed from Appendix H samples S3 and S6 revealed that the outer surface of the nickel-plated region contained small surface holes that were believed to be porosity. The porosity is more concentrated at the edges of the nickel plating as shown in Figure 3. Additionally, the lower edge of the nickel plating can be irregular (i.e., not smooth) as shown in the figure and from visual inspections of random sleeves in stock. The nickel band is a coating that is applied to the surface of the sleeve and has a design thickness of [

]a,c,e and is inherently raised higher than the surface of the tube. As shown in Figure 3, the edge of the nickel band is also slightly raised from the nominal thickness of the plating.

SEM examinations were performed on the parent tube inner surfaces and sleeves nickel-plating outer surfaces on both Appendix H samples. Figure 4 shows example SEM images of the sleeve outage surface at the lower nickel-plating edge and two images of the parent tube inner surface marks adjacent to the sleeve nickel-plating edge. Note that these images are typical and not necessarily in the same location. The SEM images of the nickel-plating edge do not show material distortions or smearing indicating deformations from the hard rolling process. The parent tube SEM images do not show evidence of cracking, linear indications, nor material scoring. The parent tube images are consistent with indentations or impressions that formed during the sleeve installation process where the hard rolling had pressed the raised nickel-DMW-NRCD-RF-LR-000005 NP-Attachment Rev.0 Page 3 of 13

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Westinghouse Non-Proprietary Class 3 plating at the edge into the tube material. This result and the lack of nickel-plating deformation suggested that the nickel-plating material is harder than the parent tube material.

Since the testing of the Appendix H samples showed grooves or marks on the inner surface of the parent tube adjacent to the nickel-platting edge for sleeves that were hard rolled to [

r,c,e (Figure 1 and Figure 2), a sleeve/tube/collar mock-up was fabricated with a sleeve installation torque of [

r,c,e which is the nominal torque for field installed sleeves. The objective of this test was to determine if the higher sleeve installation torque would produce the results observed in the Appendix H sample test.

This field installation mockup test showed that the upper and lower edges of the sleeve nickel-plating caused shallow impressions over the entire circumference of the parent tube. Figure 5 shows images of the parent tube inner diameter surface and the outer surface of the sleeve. It is noted that a step in the lower edge of the nickel-plating can be observed in the parent tube inner surface as shown in Figure 5. From the results of this test, it was concluded that the hardness of the nickel-plating may be higher than the Alloy 600MA tube. Consequently, hardness testing of the Appendix H and field installation mockup sleeves and tubes were performed. SEM or LOM examinations of these samples were not performed.

Eurofins EAG Materials Science was selected to perform the hardness testing because of their expertise in materials testing using nanoindentation technology for hardness testing of thin films. Hardness testing was performed on the following samples:

Appendix H Sample parent tube inner surface that was adjacent to the nickel-plating.

Appendix H Sample sleeve nickel-plating (sleeve was previously hard rolled to 42 inch-lbs).

Sleeve nickel-plating of a sleeve that was not hard rolled.

Field Installation Mock-up parent tube inner surface that was adjacent to the nickel-plating.

Field Installation Mock-up sleeve nickel-plating (sleeve was previously hard rolled to 130 in-lbs).

The hardness testing demonstrated that the nickel-plating hardness increases with the hard rolling expansion process. The hardness for a non-expanded nickel-plating material had a Vickers Hardness (HV) of [

t. When hard rolled to [

r,c,e, the hardness increased to [

]hand further increased to [

]h after hard rolling to [

]a,c,e_ The hardness results are shown in Table 1. The hardness of the Appendix H parent tube and the field installation inner surfaces that were adjacent to the nickel-plating was [

]h and [

]h, respectively. While the parent tube hardness of the Appendix H sample was slightly higher than the nickel-plating, it was judged that the lower hard roll torque having lower strain hardening, variabilities in test measurements, and local hardness variabilities would result in similar hardnesses given the destructive examination results. The field installation hardness increases of the nickel-plating clearly shows the strain hardening effects with increasing torque.

Figure 6 shows the Ghent Version 2 probe inspection of the sleeve/tube assembly prior to disassembly. The "ridge" or "ripple" signal was observed at the lower edge of nickel-plating. The signal is similar to those found in the Appendix H testing samples and found in field installed sleeves.

It was concluded that the signals found in the post sleeve installation baseline inspections are associated with an impression into the parent tube associated with irregular and raised edges of the nickel-plating.

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Westinghouse Non-Proprietary Class 3 Since these signals are an artifact of sleeve installation, these signals are benign and warrant monitoring as described in RAI Question #lb.

There have been no changes in the sleeve nickel-plating material composition, material properties, or fabrication processes for any of the sleeve batches installed at BVPS-2. All parameters have remained consistent for each sleeving campaign beginning in refueling outage 2R16 (Fall 2012).

Table 1. Sleeve Nickel-Plating and Parent Tube Hardness Test Results Sample Unexpanded Nickel-Plating Appendix H Nickel-Plating Aooendix H Parent Tube ID Field Installation Mockup Nickel-Platin~

Field Installation Mockup Parent Tube ID Groove Adjacent to Upper Edge ofNickel-Plating Groove Adjacent to Lower Edge of Nickel-Plating r

[

Hard Roll Torque NIA

[

]a,c,e

[

]a,c,e 1a,c,e

]a,c,e

Hardness, Hardness, Vickers HV Gpa (Kp/mm2) r lb

[

]b

[

]b

[

]b

[

t

[

t r

lb r

lb

[

]b

[

]b S6-EDM Flaw, Adjacent to Middle of Nickel-Plating at 90° Location Parent Tube Figure 1. Appendix H Sample S6 Parent Tube DMW-NRCD-RF-LR-000005 NP-Attachment Rev.0 Page 5 of 13

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Westinghouse Non-Proprietary Class 3 S3-EDM Flaw, Adjacent to Bottom ofNickel-Plating at 270° Location Grooves Adjacent to Lower Edge of Nickel-Plating Parent Tube Figure 2. Appendix H Sample S3 Parent Tube Typical Edge of Nickel Condition Edge of nickel raised relative to tube and balance of nickel-plating Figure 3. Appendix H Sample S6 Sleeve Nickel Band Region DMW-NRCD-RF-LR-000005 NP-Attachment Rev.0 Page 6 of 13

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Westinghouse Non-Proprietary Class 3 Figure 4. Example Appendix H Sleeve Nickel-Plating Edge and Parent Tube ID SEM Images Figure 5. Field Installation Mockup Destructive Test DMW-NRCD-RF-LR-000005 NP-Attachment Rev. 0 Page 7 of 13

• • • This record was final approved on 03/27/2024 09:14:19. (This statement was added bv the PRIME svstem upon its validation)

Westinghouse Non-Proprietary Class 3 I SCR[(II SETUP IIUTO_IIIIIIUSIS IIETMOHt:O

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Post Sleeve Installation-Ghent V2 "Ridge" Signal Figure 6. Post Hard Rolling Field Installation Mockup Ghent V2 Probe Inspection

b. Describe how circumferential cracking at this location, should it occur, would be differentiated from benign sleeve signal circumferential anomalies attributed to the sleeve installation process. How would benign sleeve indications be expected to change over time compared to a circumferential SCC indication? How are the results of the recent investigations being incorporated into guidance for eddy current data analysts?

Response

The industry approach to dispositioning benign signals, such as manufacturing burnish marks (MBM' s ),

dents/dings, and the benign signals from sleeve installation, is to evaluate the signal for change. The signal from the current inspection is typically compared to the historical data available for the benign signal, in this case, the post sleeve installation baseline inspection prior to placing the sleeve in service. The current inspection signal voltage, phase angle, and signal characteristics from the vertical and horizontal strip charts, Lissajous formation, and C-scan plots are compared to the baseline sleeve inspection. If change is observed, the signal is identified for diagnostic testing for confirmation either by re-inspection with the same probe or enhanced probe technology. For sleeve inspections, the Ghent Version 2 probe is qualified for sleeve inspection within the nickel-plated region at the lower hard roll joint within the tubesheet, and the +POINT probe is qualified for the remaining portions of the sleeve (Reference 4). For the benign signals associated with the edge of the nickel-plating, there may be influence of the nickel in the freespan portion where the +POINT probe is qualified, but the Ghent probe may provide better analysis due to the irregular edge of the nickel as shown in Figures 3, 4, and 5. The use of both probes are used when evaluating benign signals for change that may be indicative of inservice degradation.

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• • • This record was final approved on 03/27/2024 09:14:19. (This statement was added bv the PRIME svstem upon its validation)

Westinghouse Non-Proprietary Class 3 An example of a benign signal observed at the sleeve baseline inspection that changed at a later in service inspection is shown in Figure 7. Figure 7 shows the sleeve baseline +POINT inspection performed in 2018 of a sleeve installation benign signal at the lower edge of the nickel-plating and the 2021 inservice inspection of the same benign signal that had observable change. This signal was in tube SG B Rl 8C24 that was 1 of the 4 circumferential signals (SCI) reported during the 2021 inspection. Figure 7 clearly shows a change in signal voltage amplitude and a change in the C-scan flaw character from the baseline inspection to the 2021 inspection. The 2021 inservice C-scan in Figure 7 shows an indication originating from within the benign signal. This change resulted in the tube being plugged.

During each SG inspection at BVPS-2, the data from all sleeve inspections are analyzed by a Level III Resolution Analyst. Prior to performing analysis of sleeves, each Resolution Analysis is trained in sleeve inspection analysis techniques, the experiences with sleeve benign sleeve signals, signals with change, and the results from the conclusions from the investigations described in RAI #la response. The Appendix H qualification document for the +POINT probe and Ghent Version 2 probe (Reference 4) are reviewed with the analysts with a focus on the analysis set-ups and flaw reporting criteria. This information is supplemented with specific instructions for calibration, analysis set-ups, and examples of eddy current signals of flaws from the Appendix H qualification program. Additional training is given for the experiences with the 4 SCI signals reported at the lower edge of the nickel-plating in 2021 and the results of the causal investigations there were subsequently performed as described in the response to RAI #la above. The training included the investigation conclusions that the sleeve installation may cause benign sleeve signals at the edge of the nickel-plating as observed in the Appendix H qualification, mock-up testing, and field data. The 2021 SCI signals were reviewed along with the associated historical baseline sleeve data as examples of signals that had changed from the baseline inspections.

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I 202 1 Inservice Signal Figure 7. Benign Nickel Edge Signal at Baseline and Signal with Change at lnservice Inspection DMW-NRCD-RF-LR-000005 NP-Attachment Rev. 0 Page 9 of 13

• • • This record was final approved on 03/27/2024 09:14:19. (This statement was added bv the PRIME svstem upon its validation)

Westinghouse Non-Proprietary Class 3 RAil The comparison of 2R23 condition monitoring results to the previous inspection operational assessment projection is shown in a table (page 13 of29). For circumferential outside diameter stress corrosion cracking (ODSCC) occurring near the hot leg top-of-tubesheet in the transition expansion zone, the limiting measured indication is judged to be acceptable since the maximum depth from phase angle measurement overestimates the crack depth. In this case the flaw that contained the largest measured depth had an amplitude of 0.16 volts. The staff agrees that the low flaw amplitude seems inconsistent with the measured phase angle depth. The staff also notes that the phase angle sizing technique, based on EPRI ETSS 21410.1, was applied since a statistically acceptable correlation between signal amplitude and crack depth was not established during development of the sizing technique. Was a relationship between signal amplitude and crack depth used in other ways? For example, discuss if a site specific probability of detection (POD) function was developed for circumferential ODSCC at this location based on use of the EPRI model assisted probability of detection Code.

Response

A relationship between signal voltage amplitude and crack depth was developed by Westinghouse and used in the development of a maximum depth site-specific POD curve for circumferential ODSCC at expansion transitions. Although not a relationship for flaw depth, a voltage to flaw burst pressure correlation and a voltage to flaw percent degraded area (PDA) correlation were also developed by Westinghouse for circumferential ODSCC at expansion transitions. These voltage correlations were used in the tube integrity assessments as additional evaluation methods to provide defense-in-depth assessments to the traditional depth-based tube integrity assessment methods described in the EPRI SG Tube Integrity Assessment Guidelines (Reference 7). Descriptions and discussions of the signal voltage amplitude to depth, burst pressure, and PDA relationships are further discussed below.

A site-specific POD curve was generated for circumferential ODSCC at expansion transitions using the EPRI model assisted probability (MAPOD) methodology (Reference 6). The EPRI MAPOD code generates a log-logistic POD curve through a simulation process of generated binary detections and non-detections from a probabilistic sampling process that includes a flaw voltage to depth regression (Ahat). A logistic POD distribution was also explored that uses the same Ahat regression and MAPOD methodology as the log-logistic POD but was performed outside of the EPRI MAPOD code since the EPRI software does not generate the logistic POD distribution.

The Ahat regression used in the MAPOD methodology uses a flaw depth to flaw voltage amplitude to depth Ahat regression. The Ahat regression is based on the data set flaw contained the EPRI Examination Technique Specification Sheet (ETSS) 21410.1 for the +POINT probe detection of circumferential ODSCC at expansion transitions. ETSS 21410.1 is an Appendix H technique that contains the metallurgical maximum depths but does not provide the voltage amplitude sizing information necessary to create an Ahat regression. Westinghouse obtained the raw +POINT probe data for the flaws in the ETSS data set and was re-analyzed to obtain the voltage amplitude to metallurgical flaw depth correlation. Figure 8 provides the Ahat data and regression that was used for the site-specific POD development. The associated correlation coefficient (R2) of the Ahat regression is [

r,c,e, which is an acceptable correlation for the data set size. Note that the regression shown in the figure is in terms of the natural log (Ln) of metallurgical depth DMW-NRCD-RF-LR-000005 NP-Attachment Rev.0 Page 10 of 13

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Westinghouse Non-Proprietary Class 3 and the natural log of the vertical maximum voltage (Vvm) amplitude for use in the EPRI MAPOD software code.

Westinghouse had developed regressions to relate flaw voltage amplitude to flaw PDA size and to burst pressure for circumferential ODSCC at hard rolled expansion transitions. These were developed to provide an alternate tube integrity assessment method that does not require time consuming depth profiling and reduces the issues of phase-based depth sizing due to interferences created by the hard roll expansion geometry, tubesheet material, and deposits. The voltage to PDA and burst pressure regressions are to provide a defense-in-depth and alternate approach for comparison to the established traditional tube integrity methods described in the EPRI SG Integrity Assessment Guidelines (Reference 7). These voltage-based methods are not intended to be used as the primary means to establish compliance with the SG tube integrity performance criteria.

The data set that developed the voltage-based regressions for PDA and burst pressure consisted entirely of tubes removed from the SGs for destructive testing and burst testing (i.e., pulled tube data) that were provided in an EPRI technical report regarding structural integrity for circumferential indications with hard rolled tubesheet expansions (Reference 8). The data set was supplemented with [

r,c,e. The tubes selected for the regressions contained flaws that were [

r,c,e. The raw eddy current data was re-analyzed by Westinghouse to ensure that consistent sizing techniques were applied. Figure 9 provides the voltage to PDA and voltage to burst pressure regressions. Both regressions have acceptable correlation coefficients (R2) for the data set size. The burst pressure data in Figure 9 are the room temperature (RT) burst pressure values recorded during the destructive examinations. The normalized burst pressure regression shown by the red line in Figure 9 is the lower 95/50 burst pressure regression when the material properties are adjusted to 650°F.

Figure 8. ETSS 21410.1 Ahat Regression DMW-NRCD-RF-LR-000005 NP-Attachment Rev.0 a,c,e Page 11 of 13

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Westinghouse Non-Proprietary Class 3 a,c,e Figure 9. Voltage-Based Regressions for PDA and Burst Pressure RAI3 Identify the location(s) where Footnote 3 applies in the Operational Assessment Burst and Leakage Summary Table (page 22 of 29).

Response

The Operational Assessment Burst and Leakage Summary Table contained on pages 21 through 23 of the BVPS-2 180-Day SG Summary Report (Reference 1) lists the operational assessment model methodology used for each degradation mechanism evaluated, along with the projected results at the end of the next inspection interval. Footnote 3 of the table defines the cases where the Arithmetic Special Case OA method was used when Monte Carlo simulations were used to combine the uncertainties. Footnote 3 applies to the two degradation mechanisms: 1) Axial ODSCC at TSH (hot leg tubesheet) Case A and 2) Axial ODSCC at FDB (flow distribution baffle) Case A.

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• • • This record was final approved on 03/27/2024 09:14:19. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 References

1. Energy Harbor Nuclear Corporation Letter L-23-169, "Beaver Valley Power Station, Unit No. 2, Docket No. 50-412, License No. NPF-73, 180-Day Steam Generator Tube Inspection Report,"

October 31, 2023. (ADAMS Accession No. ML23305A095).

2. Nuclear Regulatory Commission Requestion for Additional Information Letter, "Beaver Valley, Unit 2 - 180 Days Steam Generator Report, Energy Harbor Nuclear Generating Station, Beaver Valley, Unit 2, Docket No. 05000412," Issue Date 02/14/2024. (ADAMS Accession No. ML24044A177)

3. Steam Generator Management Program: PWR Steam Generator Examination Guidelines:

Revision 8, EPRl, Palo Alto, CA: 2016. 3002007572.

4. Westinghouse Report SG-CDMP-19-17-P, Revision 1, "Qualification of an Examination Technique to Inspect Parent Tube Flaws Adjacent to the Nickel Band of an Alloy 800 Sleeve at Beaver Valley Unit 2," April 2020.

5. Energy Harbor Nuclear Corporation Letter L-20-071, "Beaver Valley Power Station, Unit No. 2, Docket No. 50-413, License No. NPF-73, License Amendment Request to Revise Technical Specification Requirements Related to Inspection Method and Service Life for Alloy 800 Steam Generator Tube Sleeves," June 25, 2020. (ADAMS Accession No. ML20177A272).

6. Steam Generator Management Program: Model Assisted Probability of Detection Using R (MAPOD-R) Version 2.1. EPRl, Palo Alto, CA: 2017. 3002010334.

7. Steam Generator Management Program: Steam Generator Integrity Assessment Guidelines, Revision 5. EPRl, Palo Alto, CA: 2021. 3002020909.

8. Electric Power Research Institute Technical Report: Depth Based Structural Analysis Methods for SG Circumferential Indications. EPRl, Palo Alto, CA: 1997. TR-107197.

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• • • This record was final approved on 03/27/2024 09:14:19. (This statement was added by the PRIME system upon its validation)

DMW-NRCD-RF-LR-000005 NP-Attachment_Revision_0 Revision 0 Non-Proprietary Class 3

• • This page was added to the quality record by the PRIME system upon its validation and shall not be considered in the page numbering of this document.**

Approval Information Author Approval Smith Jay R Mar-26-2024 15:15:10 Verifier Approval Krinock Mitchell Mar-26-2024 15:28:29 Reviewer Approval Whiteman Gary Mar-26-2024 15:30:46 Manager Approval Chappo jr. Robert Mar-27-2024 09:14:19 Files approved on Mar-27-2024

• • • This record was final approved on 03/27/2024 09:14:19. (This statement was added by the PRIME system upon its validation)