ML18085A145

Comment (2) by Frances A. Pimentel, on Behalf of NEI, on Tasks 1.1 and 1.2 of Flood Penetration Seal Performance at Nuclear Power Plants

ML18085A145
Person / Time
Site:	Nuclear Energy Institute
Issue date:	03/22/2018
From:	Pimentel F Nuclear Energy Institute
To:	May Ma Rules, Announcements, and Directives Branch
References
83FR7239 00002, NRC-2018-0028
Download: ML18085A145 (18)

Text

Page 1 of 1 As of: 3/23/18 6:45 AM Received: March 22, 2018 Status: Pending_Post PUBLIC SUBMISSION Tracking No. lk2-925v-boww Comments Due: March 22, 2018 Submission Type: Web Docket: NRC-2018-0028 Draft Flood Penetration Seal Performance at Nuclear Power Plants Literature Review (Task 1.1) and Test Methodology (Task 1.2)

Comment On: NRC-2018-0028-0001 Draft Flood Penetration Seal Performance at Nuclear Power Plants; Literature Review (Task 1.1) and Test Methodology (Task 1.2)

Document: NRC-2018-0028-DRAFT-0004 Comment on FR Doc# 2018-03340

--*--- - - * ------ ... - . - - - - - - - - - - - - - - - - - - - - * - - * * - - - - - - - * * - * - - - - - - - - - - - - - - - - - - - - - _J Submitter Information Name: Francis Pimentel Submitter's Representative: Anya Barry Organization: Nuclear Energy Institute General Comment See attached file(s)

Attachments 03-22-18 NRC_NEI_Draft 4 Flood Seal Testing Comments Letter

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03-22-18_NRC Industry Comments on Flood Seals_Attachment i 3 1:::.R 72.3 7'

'J/- 2 o/ 2 t)/8" SUNSI Review Complete Template = ADM - 013 E-RIDS= ADM-03 Add= Mcv.,.~ /-J. :x.cJl~y ( 11 JS3) https://www.fdms.gov/fdms/getcontent?objectid=0900006483040b7f&format=xm1&showorig=false 03/23/2018

FRANCIS PIMENTEL Senior Project Manager, Risk and Technical Support 1201 F Street, NW, Suite 1100 Washington, DC 20004 NUCLEAR ENERGY INST.ITUTE P: 202.739.8132 fap@nei.org nei.org

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March 22, 2018 Ms. May Ma Office of Administration Mail Stop: 1WFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Submitted via Regulations.gov

Subject:

NEI Comments on Task 1.1 and Task 1.2 of the project entitled, "Flood Penetration Seal Performance at Nuclear Power Plants," (Docket ID NRC-2018-0028).

Project Number: 689

Dear Ms. Ma:

c The Nuclear Energy Institute (NEI)1, on behalf of our members, appreciates the opportunity to provide comments on the subject Task 1.1 and Task 1.2 of the pr9ject entitled, "Flood Penetration Seal Performance at Nuclear Power Plants." The purpose of this letter is to provide the attached comments which recommend changes that would improve clarity and ensure quality data from experiments is being obtained.

We understand the purpose of this project is to perform a research task to "develop a flood penetration and testing methodology that could be used to assess the performance and reliability of those seals"2 that are credited for flood protection at nuclear power stations. The industry's position is aligned with the Task 1.1 Summary, which states that" ... the data provided in the various documents reviewed indicate that the majority of reported "failures" in flood barriers were the result of either unsealed penetrations or where a penetration seal assembly was either broken, degraded, or not properly installed."3 As the testing project *is focused on installed seal configurations, the industry strongly suggests that the project as proposed will be of limited value and should incorporate. walkdown and visual inspection methodology.

1 The Nuclear Energy Institute '(NEI) is the organization responsible for establishing unified policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.

2 ML18043B094, Flood Penetration Seal Performance at Nuclear Power Plants, Task 1.1, Draft for Comment dated 2/13/2018, page 2 3

Ibid, page 10 NUCLEAR. CLEAN AIR ENERGY

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Ms. May Ma March 22, 2018 Page 2 While we provided comments on both the draft Task 1.1 and Task 1.2 documents, we recommend that the subject of Task 1.1 include a review of seal testing already performed by the industry, and that this review be completed prior to further developing the draft test methodology discussed in Task 1.2.

We appreciate the NRC staff's consideration of the attached comments. If you have any questions concerning this letter and the attached table, please contact Jon Kapitz (202.739.8077; jkk@nei.org) or me (202. 739.8132; fap@nei.org).

Sincerely, Frances A. Pimentel Attachment c: Mr. Thomas Aird, RES/DRA/FXHAB, NRC Mr. Joseph Sebrosky, NRR/DLP/PBMB, NRC Mr. Juan F. Uribe, NRR/DLP/PBMB, NRC \

NRC Document Control Desk

Attachment Comments on Flood Penetration Seal Assemblies at Operating Nuclear Power Plants, Task 1.1 (ML18043B094):

Affected Section Comment/Basis Recommendation

1. Page 1 Task identifies ". '.. NRC Staff noted that there did Consider adding to review, documentation from pressure not appear to be any form of regimented test tests that were performed to qualify existing pressure methodologies being used by the Licensees to barrier (flood) penetrations seals as an extension to this verify or quantify the level of performance task.

associated with specific flood seal assemblies."

While requirements were not promulgated resulting in standardized test methodologies and establishing parameters for qualifying pressure resistant penetration seals, test strategies were established and tests were performed by industry for the design and qualification of these seals. Available test data can provide insights.

Outcome should align with industry testing if done appropriately; albeit resulting bounding parameters may not be consistent.

2. Page 1. "Without a set of The statement predetermines that the flood At the heart of the data analysis is to establish a test methodologies that can be barriers were not designed and assumes that that can support the design basis, but does not used to test and evaluate visual inspections of the design are inadequate to necessarily preclude that the testing methodology the performance of specific assess whether the barrier is installed correctly or proposed by one vendor is supported by the flood seal configurations, it effectively. manufacturer. The data analysis should have an element is not possible to verify of working with the original vendors to support whether whether or not a specific active testing is recommended along with the quality penetration seal assembly assurance requirements of installation.

can adequately support the flood mitigation requirements for the various NPPs."

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Attachment Affected Section Comment/Basis Recommendation

3. Page 2 Task identifies "the primary objective for this As noted above, recommend review of existing pressure initial review is to develop a series of candidate test documentation in conjunction with established seal flood penetration seal assemblies that will then be designs.

included as representative example seal configurations in the subsequent testing phase." The task identified the types of seals being used and could include a review of test documentation for these penetration seal configurations. Testing was often performed with QA oversight while some testing was

' performed and documented by independent test laboratories. It may be beneficial to consider existing seal designs with available test/acceptance documentation to identify open issues or concerns requiring further research and/or validation.

4. Page 3. "The majority of The statement assumes that an applicable data

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Ensure that data includes both pre-and post-General the assemblies contained spread can be assessed from a sample of 4 plants Design Criteria plants. While substantial submittal in this database were that provided a lot of information. This may be information from 4 sites provides a complete data set of provided by a sampling of significantly misleading if the data spread doesn't those designs, even partial data from another site that four (4) of the responding contain minimum targets of barrier types or design represents different design basis eras would more NPPs that provided basis. Additional NPPs have augmented appropriately represent an industry cross section, and significant installation inspections programs for barriers and seal. actual seal conditions might be significantly better than details and are expected to portrayed in this data, due to continuing inspections be representative of typical covered by structural monitoring programs that are plants." typically driven by Maintenance Rule condition monitoring and License Renewal aging management.

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Attachment Affected Section Comment/Basis Recommendation

5. Page 7 Identifies and discusses "parameters that must be Understanding of the scope is to identify seal design considered for each candidate penetration seal parameters that will impact the pressure resistance of a assembly; the size and configuration of the penetration seal to support evaluation and qualification penetration and the material selection for the seal testing.

assembly."

Some bounding parameters are intuitive and most have been identified by previous industry testing. From these, tests can be performed to validate these bounding parameters. In general, the parameters will be generic and not material dependent (demonstrated testing a few materials and varying these parameters in lieu of testing a large number of materials). For example; size of the seal in important regardless of material type because as the area of the seal increases the force acting on seal also increases while the perimeter of the seal works to resist this pressure and keep the seal in place.

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Attachment Affected Section Comment/Basis Recommendation

6. Page 7. "Silicone foam is The statement is only partially correct and the The testing methodology proposed should include most recommended for inclusion material has been used in some NPPs, but not all of materials used and not be developed specifically as a candidate material in NPPs. toward Silicone foam material. Seal materials used to seal assemblies during the protect safety related systems should have the greatest testing .... due to its priority for new testing methodologies.

extensive use and operating history" Silicone foam was extensively used for sealing fire barrier penetration seals within the Nuclear Industry - not certain that it has been extensively used and credited for flood barrier penetration seals.

The original" ... objective for this research project is to develop a test methodology to be used to evaluate the

• effectiveness and performance of the various types of seal assemblies that are installed in barriers designed to prevent the intrusion of water." This seems to be moving to the testing of specific seal materials and away from the objective.

7. Page 8 Task recommends "testing of some of the This inclusion does not seem to be consistent with the "repaired" configurations that have been applied original objective of this project as noted in the previous to silicone foam seals may also be considered for comment. The overall objective for this research project is to inclusion in the research test plan to assess any develop a test methodology that could be used to evaluate potential improvements in the seal's ability to the effectiveness and performance of the various types of support specific flood mitigation requirements." seal assemblies that are installed in barriers designed to prevent the intrusion of water 4

Attachment Affected Section Comment/Basis Recommendation

8. Page 8 The task notes the" ... inclusion of seal Recommend identifying the test methodologies that are assemblies that have been specifically important to pressure resistance of a penetration seal.

(commercially) marketed for flood mitigation will These parameters should be generic and not specific or also be included in the testing program, regardless different for each type of seal material.

of whether or not they have been previously identified as being installed at existing NPPs. The proposed test procedures must be demonstrated as being appropriated to support the testing of all types offlood penetration seal assemblies. It is anticipated that the research program will include testing of the above listed penetration/ seal configurations using a wide range of materials, including elastomers and epoxies, caulking materials, along with mechanical type seals (boot, link, etc.)

9. Page 9. "An important Reference to the ASTM and similar guidance Ensure where referencing any fire barrier testing standard to consider in the documents of fire barrier testing is being used in methodology comparison to the flood barrier testing to development of the draft the context as if they were current "inservice" distinguish if the comparative testing is "field" or flood test methodology is inspection methodologies whereas many and most "inservice" testing as opposed to "factory" testing.

ASTM E814 - Standard are actually vendor testing methodologies used to Test Method for Fire Tests qualify an installation configuration generically of Penetration Firestop before it is installed with no field test other than Systems" the appropriate Quality Assurance assigned by the original manufacturer. Inappropriate referencing of factory testing where comparing to field testing is misleading.

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Attachment Affected Section Comment/Basis Recommendation

10. Page A-2, Information The Relevant Information shown in the table for Correct the table as indicated with the published version Notice Data IN 2002-12 appears to be a duplication of the of IN 2002-12.  :

Relevant Information listed for IN 2007-01. The events documented in the Table for IN 2002-12 are not the same as contained in the published version of IN 2002-12.

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Attachment Comments on Draft Methodology for Testing and Evaluating the Performance of Flood Penetration Seals, Task 1.2 (ML180438093):

Affected Section Comment/Basis Recommendation

1. General It is unclear of the testing goals if the Do not develop testing acceptance criteria like the methodology is trying to establish a set of 10CFR50 appendix J program which will tend to be labor generically tested and accepted configurations intensive and costly.

similar to what was done by the Joint Owners Group (JOG) for Motor Operated Valves or if is to establish at test to be implemented in the field.

The test apparatus development appears to be more aligned with the JOG project as it is grouping testing development based on "common" penetrations as opposed to "most difficult to test." Similar to comments from Task 1.1, this supports a "factory testing" plan as opposed to a "field testing" methodology.

Similarly, data analysis provided does not include information on accessibility that would be important to field testing.

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Attachment Affected Section Comment/Basis Recommendation

2. General The test methodology is reasonable. However, Add additional information to the last paragraph on page 5 the depicted test chamber seems to be overly in Flood Seal Testing Methodology Development section to engineered for simple penetration seal acknowledge that the test chamber described and shown configurations. For example, a single pipe or in Enclosure 1 is intended to permit testing of "all types of conduit configuration does not need or warrant seal assemblies/materials" and that a simplified test the test chamber when the same required data configuration for simple seal penetration configurations

~n be obtained by capping the exposed side of should not be excluded from the final edition of the test the seal and then applying a controlled water methodology. An example is in Enclosure 1, Section 3.5 head to the seal. This draft methodology is being implies the required use of a data logging system, when in developed in support of the Phase 2 activity to many cases a manual log may be realistic and practical.

"test the test methodology" followed by an update to the test methodology prior to the end of the research program. The risk from only including the highly engineered test chamber in this draft methodology is that the option for a simpler test configuration will not be included in the subsequent phases of the research program.

3. Page 6. "5.1 Flood tests Guidance for testing methodologies needsto Ensure testing conditions including EQ, dose, and other should be performed replicate actual NP_P's service conditions to allow parameters typical of NPPs applications, and particularly within an environmentally for accurate prediction of seal performance". safety related systems are developed in the new controlled area to methodologies.

minimize variables .... "

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Attachment Affected Section Comment/Basis Recommendation

4. Page 9. "An important Reference to the ASTM and similar guidance Ensure where referencing any fire barrier testing standard to consider in the documents of fire barrier testing is being used in methodology comparison to the flood barrier testing to development of the draft the context as if they were current "inservice" distinguish if the comparative testing is "field" or flood test methodology is inspection methodologies whereas many and "inservice" testing as opposed to "factory" testing.

ASTM E814 - Standard most are actually vendor testing methodologies Test Method for Fire Tests used to qualify an installation configuration of Penetration Firestop generically before it is installed with no field test Systems" other than the appropriate Quality Assurance assigned by the original manufacturer.

Inappropriate referencing of factory testing where comparing to field testing is misleading.

5.

• Enclosure 1, Section 1 The scope of the testing methodology is Was any attempt made to develop a method to test actual limited to the laboratory setting. flood penetration seals in situ? The results of such a test would be useful to demonstrate the capability of actual installed and aged flood penetrations. One possibility would be to pressurize a control volume on the upstream side of the penetration with nitrogen, and correlate the measured leakage to equivalent water leakage. The problem to overcome, of course, is how to build the control volume and seal it around all the various penetrants in very tight spaces. It would be difficult, but if we could do it, we'd have a much more informative and useful method than a laJJoratory test.

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6. Enclosure 1 - Section 1.4.3 Section identifies that ... evaluation of each Pressure test methodology presented does not evaluate through-penetration flood seal assembly will be proposed environment or provide specific provisions.

based on; Compatibility of assembly to the proposed environment, which can include aging Recommend removal from this section (Scope of Test characteristics of assembly materials. Methodology) and identify aging as a consideration. This would be an alternate evaluation.

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Attachment Affected Section Comment/Basis Recommendation

7. Enclosure 1 - Section 1.5 Section identifies that testing is a stated For events postulated to be of significantly long duration pressure for "duration to mimic flooding or testing of seals that may have constant and continuous conditions to which the assembly may be exposure (below grade), consider establishment of a exposed." maximum exposure duration representative of continuous.

8. Enclosure 1, Section 1.8 Section identifies the standard units for Gallons per minute is a considerable volume and most volumetric flow (leakage) to be stated in existing seal tests have reported leakage in much smaller gallons per minute (gpm). units (ounces and drips per minute). Reduce prescriptive requirement or provide alternatives for reporting leakage of test results.

9. Enclosure 1, Section 1.11 Section identifies that penetration seal Revise to acknowledge and allow consideration and use of assemblies and penetrants are to be reflective bounding configurations.

of their intended as-built (or planned) configuration.

10. Enclosure 1, Section Section discusses membrane penetration as a Suggest providing an example or examples as this can be r-2.2.3.2 "penetration that passes through part of the confusing (if barrier is not breeched there is no barrier." penetration to test).

11. Enclosure 1, Section 3.2 Section note identifies; "Note: For consistency Provide caution noting that while horizontal mounting and ease of (head) pressure measurement at provides conservative results that these may not be the level of each penetration, the horizontal representative of results that would be achieved by the mounting is typically preferred." ' same seal if installed and tested in a vertical plane.

12. Enclosure 1, Section 3.3 Section requires test assembly to have "a Require means of providing for make-up water and water fill connection." eliminate the prescriptive requirement for a water fill connection. Makeup water can be provided manually, particularly when acceptance criteria is determined to be

- leaktight.

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Attachment Affected Section Comment/Basis Recommendation

13. Enclosure 1, Section 3.3 Section requires water level indicator to be In the case of testing a horizontal seal on a horizontal plan, and 3.5 included in the pressure chamber design. pressure can be determined (and often more accurately) based on the level of water above the plane of the barrier/seal.

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14. Enclosure 1, Section 3.4

• As written, this implies the test conditions Add clarification that the 'specified water pressure' is a must be held at a specified, constant pressure specified pressure band/range.

without allowance for a control band or range which maintains the "minimum test condition". Under zero seal leakage test '

conditions this may be adequate, however for -

conditions which allow a specific seal leakage rate a control band is more appropriate.

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15. Enclosure 1, Section 3.7 As written states that leakage must be Allowance to monitor the exposed side for loss of water collected from the unexposed side. This volume, which should be conservative for a single simple collected requirement may not always be penetration seal configuration, should be included.

practical.

16. Enclosure 1, Section 3.8 The test chamber could be designed with Provide clarification in Section 3.8 description or on sufficient water inventory to alleviate the need Appendix A Schematic that the water input supply piping to provide a hard-piped make-up source. *does not require hard piping.

Water inventory loss during the duration of.

the test sequence could be compensated by increasing the overpressure in the test chamber, providing the required test pressure at the seal itself is maintained.

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Attachment Affected Section Comment/Basis Recommendation

17. Enclosure 1, Section 4 This section lacks additional useful detail on Provide additional detail on how to configure the test how the test sample is to be configured. sample. For example, the placement of the penetrants is important. If the penetrants are close to the center of the penetration, it creates an uns*upported span between the penetrant and the wall for the sealing material to bear the load. This would be a bounding case for penetrations where the unsupported span is shorter.

18. Enclosure 1, Section 4.4 Section requires penetrating items containing Revise to allow for sealing of one side. Sealing on a single hollow spaces, such as pipes and conduit, to be side should be sufficient to prevent leakage through the sealed on both "the exposed and unexposed penetrating item and is typical of some testing performed sides to prevent any water leakage ... " previously.

19. Enclosure 1, Section 4.5 Section requires testing representative of an Revise to allow consideration of bounding configuration as-built configuration, including all pipes, parameters. For example, a larger percent of cable fill may conduits, cables (percent fill), required be bounding and an acceptable representation of a smaller supports, etc... percentage of cable fill and less pipes may be bounding and may acceptably represent a test configuration with less pipes, etc.

20. Enclosure 1, Section 4.6 Section requires that through-penetrating items Revise to require sufficient support but eliminating the extend a minimum of 12 inches (305 requirement for 12 inch extension, particularly on the mm) on both the exposed and unexposed exposed side of the assembly. Requirement for extending sides of the test sample. may impact testing, field representation and require more tests. Particularly when testing on a horizontal plan. For example, a conduit sealed with a flood barrier penetration seal could be tested in and with the larger seal but

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extension on the exposed side of the conduit would impact the test pressure (exposure).

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Attachment Affected Section Comment/Basis Recommendation

21. Enclosure 1, Section 4.8 Section requires conditioning of the test Revise to eliminate this requirement for penetration seal sample, including all installed penetration seal assemblies/materials. Conditioning parameters appear assemblies/materials, to provide a moisture appropriate for cementitious materials but not materials content that is representative of that which is such as elastomers, silicone caulks, epoxies, etc.

anticipated for field construction ...

22. Enclosure 1, Section 4.8 This discusses conditioning of the test sample Aging could be very important, especially for silicone f9am for moisture content, but not for aging. seals. Consider aging the test samples - perhaps using a method similar to the aging of instruments for Environmental Qualification testing.

23. Enclosure 1, Section 5.2 Section identifies requirements for Consider adding the following considerations from previous documenting the test assembly. test protocols;

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• Documentation regarding substrate to which the seal is in contact or installed. Identify if opening is Concrete or a Liner. If liner the material (steel, galvanized steel) and if coated what coating is applied.

• Penetrating items should not only be documented by type and number but size and the location of these within the seal as well. These provide support to the seal and the location can impact pressure resistance. ,

• Cable fill (important when cable is bundled as the intricacies between cables are difficult to close)

• Cable type - some cable types impact the cure of some (elastomeric) materials.

• Clarify use of the term fill density to limit fill to penetrating items that are rigidly supported that penetrate the seal (typically not inclusive of cable).

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Attachment Affected Section Comment/Basis Recommendation

24. Enclosure 1, page 7 Note Note example of determining fill density Definition defines fill density as the "percentage of the 1 indicates that a 2 in pipe in a 4 in sleeve has a available penetration opening area that is occupied by a fill density of approximately 50%. penetrating item."

Area of 4 in pipe is approx. 12.5 sq. in., area of 2 in pipe is approx. 3.14 sq. in so it seems that the fill density would be approximately 25%.

• '

25. Enclosure 1 Appendix B, As written states that the test methodology is For consistency and clarity in wording consider inclusion of Section B-3 not intended to address other potential the "associated effects term" as captured below leakage mechanisms other than the static head of water for a specified duration. The section "This test methodology is not intended to address any then goes on to define other mechanisms such other potential leakage mechanisms for penetration as impact loading from debris. Associated seal assemblies beyond exposure to specified water effects from flooding as defined in other NRC pressures for a specified duration. This includes documents include debris considerations other mechanisms such as impact from float debris, vibration than impact loa_ding from debris. due to seismic activity or attached machinery, or aging.

Although it is anticipated that some seal assemblies could be exposed to additional loading as a result of the flooding associated effects inc/uding-<<:r"impact" damage from floating debris and seismic activity, there are too many variables associated with such an event to develop a realistic simulation for inclusion in a "standardized" testing methodology. Where such events need to be evaluated, those evaluations should be separate from this test methodology .... "

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26. General Editorial Inconsistency in use of Attachment, & Enclosure Comments Page 5 includes "A draft of the test methodology is provided as Attachment 1 to this report."

Page E-1 labels it as "Enclosure 1" for the Draft

!Test Methodology

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Attachment Affected Section Comment/Basis Recommendation

27. None Materials installed as test specimens should be installed by installers qualified to perform installation as required by manufacture/procedures (as in plant).

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