L-MT-10-014, Request 10 CFR 50.55a Request 17: Extension of Permanent Relief from Volumetric Examination of Reactor Pressure Vessel Circumferential Shell Welds for the Renewed Operating License Term

Request 10 CFR 50.55a Request 17: Extension of Permanent Relief from Volumetric Examination of Reactor Pressure Vessel Circumferential Shell Welds for the Renewed Operating License Term

ML100750661
Person / Time
Site:	Monticello
Issue date:	03/12/2010
From:	O'Connor T Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-MT-10-014
Download: ML100750661 (16)

Text

XcelEnergy@ Monticello Nuclear Generating Plant 2807 W County Road 75 Monticello, MN 55362 March 12, 2010 L-MT-10-014 10 CFR 50.55a U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Monticello Nuclear Generating Plant Docket 50-263 Renewed Facility Operating License No. DPR-22

Subject:

10 CFR 50.55a Request 17: Extension of Permanent Relief from Volumetric Examination of Reactor Pressure Vessel Circumferential Shell Welds for the Renewed Operatingq License Term

References:

1) NRC letter, "Monticello Nuclear Generating Plant - Evaluation of Relief Request Number 12 for the Third 10-Year Interval Inservice Inspection Program (TAC No. MB0261)," dated July 27, 2001.

Pursuant to 10 CFR 50.55a, "Codes and standards," paragraph (a)(3)(i), the Northern States Power Company - Minnesota (NSPM) requests U.S. Nuclear Regulatory Commission (NRC) authorization of an alternative to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl, "Rules for Inservice Inspection of Nuclear Power Plant Components," (ASME Section XI).

On November 8, 2006, the NRC issued Renewed Facility Operating License DPR-22 for the Monticello Nuclear Generating Plant (MNGP). NSPM proposes to continue the current permanent relief (Reference 1) from volumetric examination of the reactor pressure vessel (RPV) shell circumferential welds, as required by 10 CFR 50.55a(g)

(i.e., byASME Section Xl, Table IWB-2500-1, Examination Category B-A, Item B1.11, Circumferential Shell Welds) for the term of the renewed operating license. The proposed alternative is in accordance with the NRC approved technical basis provided in Boiling Water Reactor Vessel and Internals Project (BWRVIP) report, BWRVIP-05:

"BWR Reactor Pressure Vessel Shell Weld Inspection Recommendations," and BWRVIP-74, "BWR Vessel and Internals Project, BWR Reactor Pressure Vessel Inspection and Flaw Evaluation Guidelines for License Renewal." Also it is consistent with NRC Generic Letter 98-05, "Boiling Water Reactor Licensees Use of the BWRVIP-05 Report to Request Relief from Augmented Examination Requirements on Reactor Pressure Vessel Circumferential Shell Welds," as supplemented by BWRVIP-74.

The 10 CFR 50.55a request is provided in Enclosure 1.

Document Control Desk L-MT-10-014 Page 2 As indicated within Section 7.0 of Enclosure 1, the NRC has authorized the same alternative for the renewed operating license terms for the Dresden Nuclear Power Station, Units 2 and 3, the Quad Cities Nuclear Power Station, Units 1 and 2, the Nine Mile Point Nuclear Station, Unit No. 2, and the Oyster Creek Nuclear Generating Station.

NSPM requests authorization of this alternative by October 29, 2010, to support determination of inservice inspection resource requirements needed in support of the March 2011 refueling outage.

If you have any questions or require additional information, please contact Mr. Richard Loeffler at (763) 295-1247.

Summary of Commitments Submittal of this 10 CFR 50.55a request completes the portion of the commitment below to submit a relief request. This commitment is listed as Item No. 5 in Appendix A to NUREG-1865, "Safety Evaluation Report Related to the License Renewal of the Monticello Nuclear Generating Plant."

The procedures and training used to limit RPV [reactor pressure vessel] cold overpressure events will be the same as those approved by the NRC when MNGP qeq sted approval of the BWRVIP-05 technical alternative for the term of the current o rating icense. request for extension for the 60-year extended operating period ill be s mitted t the NRC before the period of extended operation.

imoth onnor Site Vi resident, Monticello Nuclear Generating Plant Norther States Power Company - Minnesota Enclosure cc: Administrator, Region III, USNRC Project Manager, Monticello, USNRC Resident Inspector, Monticello, USNRC Minnesota Department of Commerce

ENCLOSURE1 MONTICELLO NUCLEAR GENERATING PLANT 10 CFR 50.55a REQUEST NO. 17 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

WHICH PROVIDES AN ACCEPTABLE LEVEL OF QUALITY OR SAFETY EXTENSION OF PERMANENT RELIEF FROM VOLUMETRIC EXAMINATION OF REACTOR PRESSURE VESSEL CIRCUMFERENTIAL SHELL WELDS FOR THE RENEWED OPERATING LICENSE TERM

L-MT-10-014 Page 1 of 12 10 CFR 50.55a Request No. 17 Proposed Alternative In Accordance With 10 CFR 50.55a(a)(3)(i)

Extension of Permanent Relief from Volumetric Examination of Reactor Pressure Vessel Circumferential Shell Welds for the Renewed Operating License Term 1.0 ASME Code Component(s) Affected All of the affected reactor pressure vessel (RPV) circumferential shell welds are American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, Class 1.

Weld Examination Item Number Description Category No.

VCBB-1 Circumferential Shell to Bottom Head Weld B-A B1.11 VCBA-2 Circumferential Shell to Shell Weld B-A BI.11 VCBB-3 Circumferential Shell to Shell Weld B-A B1.11 VCBB-4 Circumferential Shell to Shell Weld B-A B1.11 2.0 Applicable ASME Code Edition and Addenda The Monticello Nuclear Generating Plant (MNGP) is currently in the fourth 10-year Inservice Inspection (ISI) Program interval and is committed to the ASME Boiler and Pressure Vessel Code, Section Xl, "Rules for Inservice Inspection of Nuclear Power Plant Components," (ASME Section XI), 1995 Edition through 1996 Addenda. Additionally, for ultrasonic examinations, ASME Section XI, Appendix VIII, "Performance Demonstration for Ultrasonic Examination Systems," of the 1995 Edition through 1996 Addenda is implemented, as required and modified by 10 CFR 50.55a.

3.0 Applicable Code Requirement Table IWB-2500-1, "Examination Category B-A, Pressure Retaining Welds in Reactor Vessel" Examination Category B-A, Item Number B1.11, Circumferential Shell Welds, requires volumetric examination of all circumferential shell welds each interval.

L-MT-10-014 Page 2 of 12 4.0 Reason for the Request On July 27, 2001 (Reference 1) the MNGP received U.S. Nuclear Regulatory Commission (NRC) authorization for a technical alternative that eliminated performance of RPV circumferential shell weld examinations for the duration of the full-term operating license that ends on September 8, 2010. The primary basis was an analysis in accordance with Boiling Water Reactor Vessel and Internals Project (BWRVIP) report, BWRVIP-05, "BWR Reactor Pressure Vessel Shell Weld Inspection Recommendations," (Reference 2) and NRC guidance, which indicated that the limiting conditional failure probability for the circumferential shell welds would be satisfied through the expiration of the current full-term operating license.

Anticipated changes in metallurgical conditions expected over the renewed license period required analysis and further evaluation to demonstrate the continued acceptability for not performing volumetric examinations of these RPV circumferential shell welds over the additional renewed operating license term of 20-years.(1) The analysis was based on BWRVIP-05 and BWRVIP-74, "BWR Vessel and Internals Project, BWR Reactor Pressure Vessel Inspection and Flaw Evaluation Guidelines for License Renewal" (Reference 3). Information on the projected acceptability for continuing permanent deferral of volumetric examinations on RPV circumferential shell welds was provided in Section 4.2.6 of the License Renewal Application (LRA) and within responses to NRC staff requests for additional information.

On November 8, 2006, the NRC issued Renewed Facility Operating License DPR-22 for the MNGP, with an expiration date of midnight on September 8, 2030, (Reference 4). Accompanying the renewed license was NUREG-1865, "Safety Evaluation Report Related to the License Renewal of the Monticello Nuclear Generating Plant" (Reference 5), which provides a summary of the safety basis for the acceptability of various aspects of the license renewal. NUREG-1865 Section 4.2.6, "RPV Circumferential Weld Examination Relief," discusses specifics of the NRC evaluation for this area and indicated the continued acceptability of continuing application of this alternative for the renewed license period of operation. Subsection 4.2.6.4, "Conclusion," of the NUREG states:

The staff concluded that the applicant provided an acceptable demonstration, pursuant to 10 CFR 54.21 (c)(1)(ii), that the analyses of the RPV circumferential weld examination relief have been projected to the end of the period of extended operation. The staff also concluded that the USAR [Updated Safety Analysis Report] supplement contains an

1. Reference 7 indicates that 54 Effective Full Power Years is the realistically expected value at the end of the original full-term (40 year) plus the renewed (20 year) operating license terms.

L-MT-10-014 Page 3 of 12 appropriate summary description of this TLAA [Time-Limited Aging Analysis] evaluation, sufficient to satisfy the requirements of 10 CFR 54.21(d).

Section 4.2.6.2, "Staff Evaluation," and Appendix A to NUREG-1 865, indicate that while relief from performance of RPV circumferential shell weld examinations has been determined acceptable from a license renewal technical standpoint, a separate 10 CFR 50.55a (relief) request is necessary to authorize this alternative for the term of the renewed operating license. Accordingly, this 10 CFR 50.55a request is provided to meet the MNGP license renewal commitment to resubmit a request for authorization of permanent relief from the volumetric examination of RPV circumferential shell welds through the 20-year renewed operating license term. The Northern States Power Company - Minnesota (NSPM) is requesting this alternative in accordance with 10 CFR 50.55a(a)(3)(i) on the basis that this proposed alternative provides an acceptable level of quality and safety.

5.0 Proposed Alternative and Basis for Use Proposed Alternative The projected failure frequency of the subject welds at the MNGP has been determined to be sufficiently low for the duration of the renewed operating license term to justify eliminating the examinations required by 10 CFR 50.55a(g) in accordance with ASME Code Section Xl, Table IWB-2500-1, Examination Category B-A, Item No. B 1.11, Circumferential Shell Welds.

Pursuant to 10 CFR 50.55a(a)(3)(i), and consistent with guidance provided in NRC Generic Letter 98-05, "Boiling Water Reactor Licensees Use of the BWRVIP-05 Report to Request Relief from Augmented Examination Requirements on Reactor Pressure Vessel Circumferential Shell Welds" (Reference 6), and the final license renewal safety evaluation report for proprietary report, BWRVIP-74, "BWR Vessel and Internals Project, BWR Reactor Pressure Vessel Inspection and Flaw Evaluation Guidelines for License Renewal," (Reference 7), NSPM proposes the following alternate provisions for the subject weld examinations for the 20-year renewed operating license term.

• The examination requirements of ASME Code Section Xl, Table IWB-2500-1, Examination Category B-A, Item No B1.12, for the RPV longitudinal shell welds, also known as vertical or axial welds, will be performed as required to the extent possible.

L-MT-10-014 Page 4 of 12

• As a proposed alternative to the requirements of ASME Code Item No. B13.11 for the RPV circumferential shell welds, the longitudinal weld examinations for ASME Code Item No. B1.12 will include examination on the segment of RPV circumferential welds VCBA-2, VCBB-3, and VCBB-4 that intersects with the longitudinal welds, or approximately 2 to 3 percent of the RPV shell circumferential welds.

• As a proposed alternative to the requirements of ASME Code Item No. B13.11 for RPV circumferential weld VCBB-1, NSPM will perform volumetric examination on approximately 2 to 3 percent of the weld at an accessible location, rather than at the associated longitudinal weld intersections as proposed for the previously mentioned circumferential welds.

• The proposed examination alternative for the RPV circumferential shell welds may be performed from either the internal inside diameter (ID) surface, or from the external outside diameter (OD) surface of the RPV as determined by the MNGP.

• Examination of the remaining portions of the RPV circumferential shell welds will be permanently deferred through the renewed operating license term.

• Examination will be completed in accordance with the ASME Section Xl, Appendix VIII, "Performance Demonstration for Ultrasonic Examination Systems," for the interval's applicable Code of Record edition and addenda as required and modified by 10 CFR 50.55a, "Codes and standards."

Basis for Use The BWRVIP-74 report provides generic guidelines for the appropriate inspection and flaw evaluation recommendations to assure safety function integrity of reactor pressure vessel components continuing from the initial operating license term through the renewed operating license term. The NRC final license renewal safety evaluation for BWRVIP-74 concluded that Appendix E of the July 28, 1998, NRC safety evaluation for BWRVIP-05 conservatively evaluated BWR reactor pressure vessels to 64 Effective Full Power Years (EFPY) which is 10 EFPY greater than what is realistically expected at the end of an additional 20-year license renewal period.

L-MT-10-014 Page 5 of 12 The NRC staff analysis provides a technical basis for an alternative from the ASME Code Section Xl requirements for the volumetric examination of RPV circumferential shell welds for the license renewal period. The associated safety evaluation stated that to obtain relief (similar to the conditions promulgated in Generic Letter 98-05 (Reference 6)) each licensee would have to demonstrate that:

(1) At the end of the license renewal period, the circumferential welds will satisfy the limiting conditional failure frequency for circumferential welds in Appendix E of the NRC staffs Final Safety Evaluation Report (FSER) for BWRVIP-05, and (2) That they have implemented operator training and established procedures that limit the frequency of cold over-pressure events to the amount specified in the NRC staff's FSER for BWRVIP-05.

The following discussion describes how each of these criteria will be met during the renewed operating license period.

Demonstrate that Circumferential Welds Will Satisfy the Limiting Conditional Failure Frequency at the End of the License Renewal Period The following discussion is taken from the staff evaluation(2) under Section 4.2.6, "RPV Circumferential Weld Examination Relief," within NUREG-1865, the MNGP license renewal safety evaluation report (SER), and summarizes the basis for use and the acceptability of the proposed alternative.

The technical basis for relief is discussed in the staffs final SER concerning the BWRVIP-05 report, "BWR Vessel and Internals Project (BWRVIP), BWR Reactor Pressure Vessel Weld Inspection Requirements," enclosed in the letter dated July 28, 1998, from Mr. G.C.

Laines, NRC, to Mr. C. Terry, the BWRVIP Chairman. In this letter, the staff concluded that, because the failure frequency for circumferential welds in BWR plants is significantly below the criterion specified in RG [Regulatory Guide] 1.154, "Format and Content of Plant-Specific Pressurized Thermal Shock Safety Analysis Reports for Pressurized Water Reactors," and below the core damage frequency of any BWR plant, continued inspection of the RPV circumferential welds will result in a negligible decrease in an already acceptably low rate of RPV failure; therefore, elimination of the inservice inspection (ISI) for RPV circumferential welds is justified. The staffs letter indicated that BWR

2. See Subsection 4.2.6.2, "Staff Evaluation" of NUREG-1865.

L-MT-10-014 Page 6 of 12 applicants may request relief from 10 CFR 50.55a(g) ISI requirements for volumetric examination of circumferential RPV welds by demonstrating that (1) through the expiration of the license period, the circumferential welds satisfy the limiting conditional failure probability for circumferential welds in the NRC staffs July 28, 1998 evaluation, and (2) implementation of operator training and established procedures that limit the frequency of cold overpressure events to the frequency specified in the staffs SER.

The letter indicated that the requirements for inspection of circumferential RPV welds during an additional 20-year license renewal period will be reassessed, on a plant-specific basis, as part of any BWR LRA [license renewal application]; therefore, the applicant must request relief from inspection of circumferential welds during the license renewal period, pursuant to 10 CFR 50.55a.

Section A.4.5 of the BWRVIP-74 report indicates that the staffs SER of the BWRVIP-05 report conservatively evaluated the BWR RPVs to 64 EFPY [effective full power years], which is 10 EFPY greater than realistically expected for the end of the license renewal period. In the July 28, 1998, SER, the staff used the mean [reference temperature of nil-ductility transition] RTNDT value for materials to evaluate failure probability of BWR circumferential welds at 32 and 64 EFPY. The neutron fluence at the clad-weld (inner) interface was used for this evaluation.

Since the staff analysis discussed in the BWRVIP-74 report is generic, the applicant submitted plant-specific information to demonstrate that the MNGP RPV beltline materials meet the criteria specified in the report. To demonstrate that the MNGP RPV has not become embrittled beyond the basis for the relief, the applicant, in LRA Table 4.2.6.1, compared 54 EFPY material data for the limiting MNGP circumferential weld with that of the 64 EFPY reference case in Appendix E to the staffs SER on the BWRVIP-05 report.

Table 4.2.6-1 on the following page, taken from Subsection 4.2.6.2, "Staff Evaluation," of NUREG-1865, has been modified by addition of a fourth column which shows the effects of a 120% increase in thermal power(3)(4) from the original licensed thermal power (OLTP) on the RPV circumferential weld properties at the end of the 20-year renewed operating license period.

3. The current licensed reactor thermal power (CLTP) is 1775 MWt. The maximum projected power level of 2004 MWt is 120% of the OLTP of 1670 MWt.

4. A power increase request (Reference 13) is under review, but on indefinite hold, pending staff resolution to several industry issues. The values in the fourth column correspond to those presented in Table 2.1-2 in Enclosure 5 of Reference 13.

L-MT-10-014 Page 7 of 12 Table 4.2.6-1 Effects of Irradiation on RPV Circumferential Weld Properties for MNGP Chicago Bridge MNGP 54 MNGP Value and Iron (CB&I) EFPY 54 EFPY 64 EFPY (120% OLTP)

Cu (%) 0.10 0.10 0.10 Ni(%) 0.99 0.99 0.99 CF [Chemistry Factor] 134.9 138.5 138.5 Fluence x 10"9 (n/cm2 ) [at 1.02 0.52 0.64 clad/weld interface]

ARTNDT ("F) 135.6 113 121 RTNDT (OF) - 65 - 65.6 - 65.6 Mean RTNDT ('F) 70.6 47.4 55.8 Probability of a failure 1.78 x - (1) (1) event (NRC)

Notes: 1: If the plant-specific mean ARTNDT is less than the mean ARTNDT associated with the limiting case study, the staff concludes that the probability of failure for the plant-specific circumferential weld under review will be less than the conditional probability of failure value for the limiting circumferential weld in the limiting case study.

Analysis indicates that assuming 120% of OLTP through the renewed operating license term, that the Fluence, ARTNDT and Mean RTNDT all increase but that the results (see fourth column) are still well within the CB&I 64 EFPY NRC staff acceptance criteria (second column above).

The Monticello Updated Safety Analysis Report [USAR], Appendix K, Renewed Operating License - USAR Supplement, provides background and summarizes the bases and results of the license renewal analyses and evaluations. The USAR section on RPV circumferential weld examination relief discusses and compares the MNGP limiting weld parameters to those used in the NRC analysis. Under the Disposition section it states:

For MNGP, the chemistry values are the same as those used in the NRC analysis, however, the chemistry factor is higher due to an adjustment to reflect the results from two surveillance capsules. The value of fluence is lower than that used in the NRC analysis. As a result, the shift in reference temperature is lower than the 64 EFPY shift from the NRC analysis. In addition, the unirradiated reference temperature is essentially the same. The combination of unirradiated reference temperature (RTNDT(U)) and shift (ARTNDTW/O margin) yields an Adjusted Reference Temperature (ART) that is lower than the"NRC mean analysis value.

L-MT-10-014 Page 8 of 12 Therefore, the RPV shell weld embrittlement due to fluence has a negligible effect on the probabilities of RPV shell weld failure. The Mean RTNDT value at 54 EFPY is bounded by the 64 EFPY Mean RTNDT provided by the NRC. Although a conditional failure probability has not been calculated, the fact that the MNGP values at the end of license are less than the 64 EFPY value provided by the NRC leads to the conclusion that the MNGP RPV conditional failure probability is bounded by the NRC analysis.

Based on analysis assuming 120% of the OLTP through the renewed license term, the Mean RTNDT increases to 55.8 0 F, but remains bounded by the 64 EFPY Mean RTNDT staff acceptance criteria of 70.6 0 F for CB&I vessels. The fact that this value at the end of the renewed operating license term for 120% of OLTP conditions is less than the 64 EFPY staff acceptance criteria demonstrates that the MNGP conditional failure probability remains bounded by the NRC analysis.

This conclusion is supported by the following discussion from Section 4.2.6.2, "Staff Evaluation," of NUREG-1865 which discusses the effects of irradiation on RPV circumferential shell weld properties for the MNGP for the renewed operating license term. The NUREG states:

The MNGP material data included amounts of copper and nickel, chemistry factor, the neutron fluence, ARTNDT, initial RTNDT, and mean RTNDT of the limiting circumferential weld at the end of the renewal period.

The staff has verified the data for the copper and nickel contents and the initial RTNDT values for the MNGP circumferential beltline weld material by comparing them with the corresponding data in RVID [Reactor Vessel Integrity Database]. The 54 EFPY mean RTNDT value for the MNGP circumferential beltline weld is 47.4 0 F. The staff checked the applicant's calculations for the 54 EFPY mean RTNDT values for the limiting MNGP circumferential welds using the data presented in LRA Table 4.2.6.1 and found them to be accurate. This 54 EFPY mean RTNDT value for MNGP is bounded by the 64 EFPY mean RTNDT value of 70.6°F used by the NRC to determine conditional failure probability of a circumferential weld in a Chicago Bridge and Iron (CB&I) fabricated RPV. The 64 EFPY mean RTNDT value from the staff SER dated July 28, 1998, is for a CB&I weld because CB&I welded the circumferential welds in the [MNGP] RPV.

Because the 54 EFPY mean RTNDT value is less than the 64 EFPY value from the staff SER dated July 28, 1998, the staff concluded that the NRC analysis bounds the MNGP RPV conditional failure probability.

Since the 54 EFPY analysis results, assuming 120% of OLTP, increase for the Fluence, ARTNDT and Mean RTNDT at the end of the renewed operating license term but are still below the 64 EFPY acceptance criteria specified in the NRC

L-MT-10-014 Page 9 of 12 staff SER dated July 28, 1998, it is concluded that the NRC analysis bounds the MNGP RPV conditional failure probability for these parameters at the end of the renewed operating license term.

Implement Operator Training and Establish Procedures that Limit the Frequency of Cold Over-Pressure Events to the Amount Specified in the NRC Staff Safety Evaluation for BWRVIP-05 Section 4.2.6.2, "Staff Evaluation, of NUREG-1865 also indicates that to be acceptable the proposed alternative has to include "implementation of operator training and established procedures that limit the frequency of cold overpressure events to the frequency specified in the staff's SER." The NSPM committed to, and revised and upgraded operator training and plant procedures (References 8 and 9) to minimize the frequency for potential cold overpressure events (consistent with the NRC specified frequency) in conjunction with receiving the current relief (Reference 1) from performing RPV circumferential shell weld examinations for the duration of the full-term operating license.

Going forward, NSPM proposes to continue these commitments to limit the potential for cold overpressure events for the renewed operating license term.

Section 4.2.6.2, "Staff Evaluation," of NUREG-1865 states:

The applicant stated that the procedures and training used to limit cold overpressure events will be the same as those approved by the NRC when MNGP requested relief for the current license period. A request for relief during the period of extended operation will be submitted to the NRC before the period of extended operation.

Submittal of this 10 CFR 50.55a request satisfies the following commitment, referred to as Item No. 5 in Appendix A to NUREG-1 865, and serves to enforce NSPM's ongoing commitment to implement and maintain operator training and procedural content to preclude cold overpressure events, as prescribed in our present authorized relief for the full-term operating license.

The procedures and training used to limit RPV cold overpressure events will be the same as those approved by the NRC when MNGP requested approval of the BWRVIP-05 technical alternative for the term of the current operating license. A request for extension for the 60-year extended operating period will be submitted to the NRC before the period of extended operation.

L-MT-10-014 Page 10 of 12 NSPM has reviewed the above conclusions and has confirmed they are valid for the renewed operating license term of operation. Therefore, the proposed alternative as discussed herein, and as previously evaluated in the NRC safety evaluation for the MNGP for the full-term operating license (Reference 1),

provides an acceptable level of quality and safety for the term of the renewed operating license.

6.0 Duration of Proposed Alternative The proposed alternative will be applied for the 20-year term of the renewed operating license.

7.0 Precedent The NRC has authorized similar requests to adopt an alternative to the ASME Section XI, Table IWB-2500-1, Examination Category B-A, Item. No. B1.11 criteria for permanent relief from the volumetric examination of RPV circumferential shell welds for the Dresden Nuclear Power Station, Units 2 and 3 and the Quad Cities Nuclear Power Station, Units 1 and 2 (Reference 10), the Nine Mile Point Nuclear Station, Unit No. 2 (Reference 11), and the Oyster Creek Nuclear Generating Station (Reference 12).

L-MT-10-014 Page 11 of 12

8.0 REFERENCES

1. NRC letter, "Monticello Nuclear Generating Plant - Evaluation of Relief Request Number 12 for the Third 10-Year Interval Inservice Inspection Program (TAC No. MB0261)," dated July 27, 2001.

2. Electric Power Research Institute (EPRI) Report TR-105697, "BWR Reactor Pressure Vessel Shell Weld Inspection Recommendations (BWRVIP-05)," dated September 1995.

3. BWRVIP-74-A Report, "BWR Vessel and Internals Project, BWR Reactor Pressure Vessel Inspection and Flaw Evaluation Guidelines for License Renewal," dated June 2003.

4. NRC letter, "Issuance of Renewed Facility Operating License No. DPR-22 for Monticello Nuclear Generating Plant," dated November 8, 2006.

5. NUREG-1865, "Safety Evaluation Report Related to the License Renewal of the Monticello Nuclear Generating Plant."

6. NRC Generic Letter 98-05, "Boiling Water Reactor Licensees Use of the BWRVIP-05 Report to Request Relief from Augmented Examination Requirements on Reactor Pressure Vessel Circumferential Shell Welds," dated November 10, 1998.

7, NRC letter, 'Acceptance for Referencing of EPRI Proprietary Report TR-1 13596, "BWR Vessel and Internals Project, BWR Reactor Pressure Vessel Inspection and Flaw Evaluation Guidelines (BWRVIP-74)," and Appendix A, "Demonstration of Compliance with the Technical Information Requirements of the License Renewal Rule (10 CFR 54.21)."' dated October 18, 2001.

8, NMC letter, "Request for Relief No. 12 for the Third 10-Year Interval Inservice Inspection Program," dated October 10, 2000.

9. NMC letter, "Response to NRC Request for Additional Information for Request for Relief No. 12 for the Third 10-Year Interval Inservice Inspection Program,"

dated May 3, 2001.

10. NRC letter, "Dresden Nuclear Power Station, Units 2 and 3 and Quad Cities Nuclear Power Station, Units 1 and 2 - Authorization for Proposed Alternative Reactor Pressure Vessel Circumferential Shell Weld Examinations (TAC Nos.

L-MT-10-014 Page 12 of 12 MC2190, MC2191, MC2192 and MC2193)," dated March 23, 2005. (ADAMS Package Accession No. ML[050620359)

11. NRC letter, "Nine Mile Point Nuclear Station, Unit No. 2 - Authorization Under 10 CFR 50.55a(a)(3)(i) for Proposed Alternative Reactor Pressure Vessel Circumferential Shell Weld Volumetric Examinations (TAC No. MD3696)," dated November 5, 2007. (ADAMS Accession No. ML072830047)

12. NRC letter, "Oyster Creek Nuclear Generating Station - Relief Request for Alternative Examination for Reactor Pressure Vessel Circumferential Shell Welds (TAC No.: ME0890)," dated September 15, 2009. (ADAMS Accession No. ML092520039)

13. NSPM letter, "License Amendment Request: Extended Power Uprate (TAC MD9990)," letter number L-MT-08-052, dated November 5, 2008.

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