Letter Sequence RAI |
---|
TAC:MB7842, Steam Generator Tube Integrity (Approved, Closed) TAC:MB7843, Steam Generator Tube Integrity (Approved, Closed) |
|
MONTHYEARML0312100452002-04-30030 April 2002 Request for Additional Information Project stage: RAI ML0306900292003-02-25025 February 2003 Application for Amendment to Licenses NPF-35 & NPF-52, to Change & Add Technical Specifications Project stage: Request ML0308302972003-03-24024 March 2003 Ltr, Steam Generator Program Guidelines Project stage: Other ML0313407572003-04-24024 April 2003 Request for Additional Information - Catawba, Unit 1 and 2 - Tech Spec Amendment - Steam Generators Project stage: RAI ML0312105682003-04-30030 April 2003 Enclosure 3, Tech Spec Base Changes for Catawba, Units 1 and 2 Project stage: Other ML0313403232003-05-14014 May 2003 Informal Transmittal of Request for Additional Information Project stage: RAI ML0315005992003-05-29029 May 2003 Ltr, Position on Technical Specifications for Steam Generators Project stage: Other ML0316713472003-06-0909 June 2003 Proposed Technical Specifications (TS) Amendments Revision to Steam Generator TS Project stage: Other ML0320200852003-07-21021 July 2003 Regarding Further Request for Additional Information Project stage: RAI ML0321806302003-07-30030 July 2003 Duke Energy Corporation Catawba Nuclear Station, Units 1 and 2 Proposed Technical Specifications (TS) Amendments Revision to Steam Generator TS Project stage: Other ML0326009902003-09-17017 September 2003 Request for Additonal Information Resulting from Licensee Letter Dated July 30, 2003 Project stage: Other ML0328301532003-10-10010 October 2003 Revised Request for Additional Information Resulting from Licensee Letter Dated July 30, 2003 Project stage: RAI ML0407001772004-03-11011 March 2004 Memo to J. Nakoski Transmittal of Request for Additional Information Project stage: RAI ML0407204072004-03-24024 March 2004 RAI, Steam Generator Tube Integrity Criteria Project stage: RAI ML0416103812004-06-0909 June 2004 Withdrawal of Requests for Additional Information Ltr, Steam Generator Tube Integrity Criteria Project stage: Withdrawal ML0426602802004-09-13013 September 2004 Proposed Technical Specifications (TS) Amendments Revision to Steam Generator TS Project stage: Other ML0433500632005-01-13013 January 2005 Catabwa, Units 1 & 2, Issuance of License Amendments 218 and 212 Steam Generator Tube Integrity Project stage: Approval ML0501901302005-01-13013 January 2005 Enclosure, Amendment, TS for SG Tube Integrity (Tac No. MB7842, MB7843) Project stage: Acceptance Review 2003-06-09
[Table View] |
|
---|
Category:Memoranda
MONTHYEARML23118A2852023-05-0202 May 2023 Public Meeting Summary - 2022 Annual Assessment Meeting Regarding Catawba Nuclear Station, McGuire Nuclear and Oconee Nuclear Station ML22300A0742023-01-11011 January 2023 Final Environmental Assessment and Finding of No Significant Impact for the Duke Energy'S Updated Decommissioning Funding Plans Submitted in Accordance with 10 CFR 72.30(C) for Catawba Nuclear Station Independent Spent Fuel Storage Installa ML21099A0932021-04-0909 April 2021 Public Meeting Summary - 2020 Annual Assessment Meeting Regarding Catawba, McGuire, and Oconee Nuclear Stations ML20141L4172020-05-20020 May 2020 EOC Public Meeting Summary ML19098B4482019-04-0808 April 2019 Public Meeting Summary ML18117A2212018-04-27027 April 2018 Summary of Public Meeting with Catawba Nuclear Station Concerning Annual Assessment of Units 1 and 2 for Period of January 01, 2017 - December 21, 2017 ML17107A0642017-04-17017 April 2017 Summary of Public Meeting with Catawba, Units 1 and 2 ML16111B2472016-04-28028 April 2016 Request for Additional Information Re. License Amendment Request to Revise TS 5.5.2 Containment Leakage Rate Testing Program ML16088A2042016-03-28028 March 2016 Memo T Bowers from s Ruffin, Technical Assistance Requests - Review 2015 Tri-Annual Decommissioning Funding Plans for Multiple Independent Spent Fuel Storage Installations W/ Encl 2 (Template) ML16088A2052016-03-28028 March 2016 Enclosure 1 - (72.30 DFP Reviews to Be Completed 2015) - Memo T Bowers from s Ruffin, Technial Assistance Requests - Review 2015 Tri-Annual Decommissioning Funding Plans for Multiple Independent Spent Fuel Storage Installations ML16081A3352016-03-17017 March 2016 Summary of Meeting with Public Concerning Annual Assessment of Catawba Nuclear Station, Units 1 and 2 ML15253A4032016-03-11011 March 2016 Recommendation for Dispositioning Proposed Generic Issue on the Effects of Downstream Dam Failures on Nuclear Power Plants ML15244B2522015-08-31031 August 2015 Report on Trip to Catawba on August 26-27, 2015 ML15106A0302015-04-15015 April 2015 Meeting Summary with Public to Discuss the Annual Assessment of Catawba Nuclear Station, Units 1 and 2 ML14126A6792014-05-0606 May 2014 Summary of Public Meeting with Catawba, Units 1 & 2 to Discuss Annual Assessment ML14077A1312014-03-18018 March 2014 Special Inspection Charter to Evaluate the Abnormal Rotation of the Piston Crankshaft Bearings on the Catawba Unit 1 Diesel Generators ML13295A3062013-10-22022 October 2013 Meeting Notice with Duke Energy Carolinas, LLC Discuss the Planned Modifications Related to the Fukushima Flood Hazard Reevaluations for the Sites Operated by Duke Energy Carolinas, LLC ML13135A5962013-05-16016 May 2013 Cancelled 05/23/2013 Notice of Forthcoming Pre-Application Meeting with Duke Energy Carolinas, Llc. to Discuss a Proposed License Amendment Request Concerning Methodology Report DPC-NE-3001-P for Catawba and McGuire Nuclear Stations ML13127A4352013-05-0909 May 2013 Notice of Forthcoming Pre-Application Meeting with Duke Energy Carolinas, Llc. to Discuss a Proposed License Amendment Request Concerning Methodology Report DPC-NE-3001-P for Catawba and McGuire Nuclear Stations ML13072B2022013-03-19019 March 2013 Meeting Notice with Duke Energy Concerning NFPA-805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants License Amendment Request for Catawba, McGuire, and H. B. Robinson ML12300A4032012-10-26026 October 2012 11/8/2012 Meeting Notice with Duke Energy to Discuss NRC Order on Mitigation Strategies for Beyond-design-Basis External Events ML12284A4612012-10-12012 October 2012 Forthcoming Meeting Notice with Duke Energy to Discuss NRC Order on Mitigation Strategies for Beyond-Design-Basis External Events ML12103A3522012-04-10010 April 2012 Special Inspection Charter to Evaluate Catawba Loss of Offsite Power ML1106603302011-03-0707 March 2011 Notice of Meeting with Duke Energy to Present Status of Licensing Submittals Regarding Implementation of National Fire Protection Association Standard 805, Requirements at Catawba Nuclear Station, Units 1 and 2 and McGuire Nuclear Station ML1029306502010-10-20020 October 2010 Notice of Forthcoming Conference Call with Duke Energy Carolinas, LLC Regarding McGuire Nuclear Station, Units 1 and 2 and Catawba Nuclear Station, Units 1 and 2, ML1021400692010-08-0404 August 2010 Notice of Meeting with Duke Energy to Discuss Duke Energy'S Assessment of the Results of the Catawba Baseline Inspection Conducted by the NRC ML1015900402010-06-0808 June 2010 the Nuclear Regulatory Commission Staff Spot-Check Review of Piedmont Municipal Power Agency'S Ownership Interest of Catawba Nuclear Station Units 1 and 2 on May 19, 2010 - Finding of No Potential Issues in Bank Statements ML1015804682010-06-0808 June 2010 the Nuclear Regulatory Commission Staff Spot Check Review of North Carolina Electric Membership Corporation'S Ownership Interest of Catawba Nuclear Station Units 1 and 2 on May 20, 2010 - Finding of No Potential Issues in Bank Statements ML1015804072010-06-0808 June 2010 the Nuclear Regulatory Commission Staff Spot-Check Review of Duke Energy'S Ownership Interest of Catawba, Units 1 and 2, McGuire, Units 1 and 2, and Oconee, Units 1, 2 and 3 on May 20, 2010 - Finding of No Potential Issues in Bank Statement ML1012604632010-05-0707 May 2010 Notice of Forthcoming Conference Call with Duke Energy Carolinas, LLC (Duke) to Discuss Duke'S Responses to Generic Letter 2004-02 at Catawba 1 and 2 and McGuire 1 and 2 ML0926700202009-10-0707 October 2009 Summary of Conference Call with Duke Regarding Responses to Generic Letter (GL) 2004-02 ML0925404602009-09-10010 September 2009 Summary of Phone Call with Industry to Issues Related to Eccentricity of the Steam Generator Tube-to-Tubesheet Joints in the Finite Element Model Used for the Technical Basis of the Permanent Alternate Repair Criteria License Amendment Requ ML0922908922009-08-18018 August 2009 Notice of Conference Call with Duke Energy Carolinas, LLC (Duke), Regarding Catawba Nuclear Station, Units 1 and 2 (Catawba 1 and 2) and McGuire Nuclear Station Units 1 and 2 ML0831009482008-11-10010 November 2008 Notice of Meeting with Duke Energy Carolinas, LLC, (Duke), Catawba, Units 1 and 2, and McGuire, Units 1 and 2 ML0831107952008-11-0606 November 2008 Cancellation of Meeting with Duke Energy Carolinas, LLC, to Discuss the Request for Additional Information Generic Letter 2004-04, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents. ML0829701832008-10-30030 October 2008 Notice of Meeting with Duke Energy Carolinas, LLC, to Discuss the Request for Additional Information Generic Letter 2004-04, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents ... ML0818301542008-07-0101 July 2008 Notice of Meeting with Duke Energy Carolinas, LLC to Discuss Transition to ASME NQA-1-1994 ML0817903662008-06-27027 June 2008 Safety Evaluation by the Office of Nuclear Reactor Regulation Application for Direct Transfer of Facility Operating License Catawaba Nuclear Station, Unit 1 ML0807400842008-03-14014 March 2008 Draft Regulatory Guide for Comment ML0800201632008-01-0303 January 2008 Cancelled - Meeting with Duke Power Company ML0800202162008-01-0303 January 2008 Forthcoming Meeting with Duke Power Company LLC Catawba Nuclear Station to Discuss the Relief Request Dated October 26, 2006 (Agencywide Documents Access and Management System Accession No. ML063120211) ML0733711662007-12-0303 December 2007 Notice of Meeting with Progress Energy & Duke Energy Regarding Fire Probabilistic Risk Assessment for the Pilot Plants Transitioning to the National Fire Protection Association Standard NFPA 805 ML0628401062006-10-18018 October 2006 Staff'S Review of CLIIP Amendment to Adopt TSTF-372 ML0614505462006-05-25025 May 2006 Revised Augmented Inspection Team Charter ML0614303612006-05-23023 May 2006 Augmented Inspection Team Charter for Catawba, Units 1 and 2 ML0533900722005-12-0707 December 2005 Notice of Forthcoming Meeting with Duke Energy Corporation, to Discuss Reload Design and Safety Analysis Methodology Report Submittals ML0524103052005-09-0606 September 2005 08/18/05 - Summary of Public Meeting on Mspi/Rop Topics for August 17/18, 2005 ML0524503412005-09-0202 September 2005 Notice of Meeting with Duke Energy Corp, Regarding RAIs on Nuclear Service Water System for Catawba, Units 1 and 2 ML0520707942005-08-0303 August 2005 Closeout Letter for Bulletin 2003-01, Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized-Water Reactors. ML0515806402005-06-0808 June 2005 Meeting Notice with Duke Energy Corp, Catawba, Units 1 & 2, Service Water System Carbon Steel Piping with Polyethylene Piping 2023-05-02
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML23271A1792023-09-28028 September 2023 Request for Confirmation License Amendment Application to Revise Control Room Cooling TS 3.7.11 ML23151A3482023-05-30030 May 2023 Duke Fleet - Request for Additional Information Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1) ML23142A2732023-05-22022 May 2023 Duke Fleet - Request for Additional Information Proposed Alternative for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1) ML22336A0692022-11-28028 November 2022 Final 2023 Catawba Nuclear Station (CNS) Commercial Grade Dedication (CGD) Inspection Information Request ML22154A1312022-06-0303 June 2022 NRR E-mail Capture - Catawba Nuclear Station, Units 1 and 2 - Request for Additional Information Environmentally-Assisted Fatigue License Renewal Commitment ML22115A1412022-04-25025 April 2022 NRR E-mail Capture - Duke Common EOF Relocation - Request for Addition Information ML22102A2962022-04-13013 April 2022 Request for Withholding Information from Public Disclosure Response to Request for Additional Information ML22063B1782022-03-0909 March 2022 Request for Additional Information Regarding LAR for Revision to the Conditional Exemption of the End of Cycle Moderator Temperature Coefficient Measurement Methodology (EPID L-2021-LLA-0198) NON-PROPRIETARY ML22024A1122022-01-24024 January 2022 2022 CNS POV Inspection Information Request ML21354A8612021-12-15015 December 2021 NRR E-mail Capture - Request for Additional Information - Duke Fleet Request RA-19-0352 - Alternative for RPV Closure Stud Exams (L-2020-LLR-0156) ML21335A2252021-12-0101 December 2021 NRR E-mail Capture - Catawba Nuclear Station, Unit 2 - Request for Additional Information Spring 2021 Steam Generator Tube Inspection Report (L-2021-LRO-0043) ML21117A1232021-04-23023 April 2021 NRR E-mail Capture - Catawba Verbal Relief Request Request for Additional Information ML21075A0032021-03-12012 March 2021 Emergency Preparedness Exercise Inspection Request for Information for - Brunswick, Catawba, North Anna, Oconee, Vogtle 1 & 2 ML21049A2632021-02-0404 February 2021 NRR E-mail Capture - Request for Additional Information - Duke Energy Fleet License Amendment Request to Revise Emergency Plan ML20346A0212020-12-10010 December 2020 NRR E-mail Capture - Formal Release of RAIs - License Amendment to Change TS 3.8.1 Due Jan. 29, 2021 ML20338A3932020-12-0303 December 2020 Notification of Inspection and Request for Information ML20323A4072020-11-18018 November 2020 NRR E-mail Capture - Request for Additional Information - Brunswick License Exemption Request from 10CFR73 Annual Force on Force Exercise Requirements (EPIC L-2020-LLE-0180) ML20244A0462020-08-31031 August 2020 Notification of Inspection and Request for Information for NRC Problem Identification and Resolution Inspection ML20073F3832020-03-13013 March 2020 NRR E-mail Capture - Request for Additional Information - Catawba Nuclear Station - SG Report (RA-19-0391) - C2R23 ML20052E4282020-02-21021 February 2020 Notification of NRC Fire Protection Team Inspection (Fpti) (NRC Inspection Report 05000412/2020013 and 05000414/2020013) and Request for Information ML20050D3382020-02-21021 February 2020 Letter RAI 1 MAGNASTOR-Catawba and McGuire Exemptions with Enclosure ML20003E5372020-01-0303 January 2020 NRR E-mail Capture - Catawba PT Limits LAR - RAIs ML19032A5842019-01-31031 January 2019 Emergency Preparedness Program Inspection Request for Information ML19011A1372019-01-10010 January 2019 NRR E-mail Capture - Duke Energy Fleet RAIs - Relief Request 18-GO-001 - Proposed Alternative for Depth Sizing Qualification Examination of Welds (L-2018-LLR-0117) ML19009A5412019-01-0909 January 2019 NRR E-mail Capture - Request for Additional Information - Catawba Nuclear Station, Units 1 and 2 - Esps LAR ML19007A3422018-12-21021 December 2018 NRR E-mail Capture - Duke Energy Fleet Draft RAIs - Relief Request 18-GO-001 - Proposed Alternative for Depth Sizing Qualification Examination of Welds (L-2018-LLR-0117) ML18068A5052018-03-0909 March 2018 NRR E-mail Capture - Request for Additional Information - Catawba Nuclear Station, Units 1 and 2 - Nsws Return Pond Header LAR (CACs MG0245 and MG0246, EPID L-2017-LLA-0297) ML18058B2062018-02-27027 February 2018 Notification of Inspection and Request for Information ML18057A2182018-02-23023 February 2018 Enclosurequest for Additional Information (Letter to A. Zaremba Request for Additional Information for Review of Duke Energy'S Decommissioning Funding Plan Update) ML17335A0972017-11-29029 November 2017 NRR E-mail Capture - Request for Additional Information - Catawba Nuclear Station, Units 1 and 2 - Relief Request 17-CN-001 (CACs MF9807 and MF9808, EPID L-2017-LLR-0032) ML17135A0302017-05-12012 May 2017 NRR E-mail Capture - Request for Additional Information - Catawba TSTF-197 ML17115A1422017-04-25025 April 2017 NRR E-mail Capture - Request for Additional Information - Catawba SG Report - RFO 21 ML16337A3322017-01-12012 January 2017 Request for Additional Information Regarding License Amendment Request for Electrical Power System Alignments for Shared Systems ML16355A3922016-12-29029 December 2016 Request for Additional Information Regarding License Amendment Request to Implement a Risk-Informed, Performance-Based Fire Protection Program ML16292A2252016-10-14014 October 2016 Emergency Preparedness Inspection and Request for Information ML16271A0752016-10-12012 October 2016 Request for Additional Information Regarding License Amendment Request for Electrical Power System Alignments for Shared Systems ML16222A7472016-08-0909 August 2016 Notification of Inspection and Request for Information for NRC Problem Identification and Resolution Inspection ML16205A0022016-07-21021 July 2016 Notification of Inspection and Request for Information ML16187A0662016-07-0707 July 2016 Catawba Nuclear Station, Units 1 and 2 - Request for Additional Information Regarding License Amendment Request to Implement a Risk-Informed, Performance-Based Fire Protection Program (CAC Nos. MF2936 and MF2937) ML16111B2472016-04-28028 April 2016 Request for Additional Information Re. License Amendment Request to Revise TS 5.5.2 Containment Leakage Rate Testing Program ML16120A0872016-04-27027 April 2016 Notification of Inspection and Request for Information ML16113A0732016-04-22022 April 2016 Draft RAIs License Amendment Request to Revise TS Section 5.5.2 for Permanent Extension of Type a and Type C Leak Rate Test Frequencies ML16014A7102016-01-20020 January 2016 Request for Additional Information Regarding License Amendment Request to Revise Emergency Action Level Scheme ML16007A1902016-01-20020 January 2016 Request for Additional Information Regarding License Amendment Request to Change the RCS Minimum Required Flow Rates ML15348A2602015-12-17017 December 2015 Request for Additional Information Regarding License Amendment Request to Use an Alternative Fission Gas Gap Release Fraction ML15320A3862015-11-19019 November 2015 RAI LAR to Adopt TSTF-523 ML15314A3592015-11-10010 November 2015 Duke Energy Draft RAIs Request to Adopt TSTF-523 (CAC Nos. MF6413-MF6422) ML15314A3562015-11-10010 November 2015 E-mail from J. Whited to A. Zaremba Duke Energy Draft RAIs License Amendment Request to Adopt TSTF-523 (CAC Nos. MF6413-MF6422) ML15252A4012015-09-17017 September 2015 License Amendment Request Regarding Non-Conservative Technical Specification Allowable Value ML15201A5122015-08-13013 August 2015 Request for Additional Information Regarding License Amendment Request to Support a Measurement Uncertainty Recapture Power Uprate for Catawba, Unit 1 2023-09-28
[Table view] |
Text
March 11, 2004 MEMORANDUM TO: John A. Nakoski, Chief, Section 1 Project Directorate II Division of Licensing Project Management, NRR FROM: Leonard N. Olshan, Project Manager, Section 1 /RA/
Project Directorate II Division of Licensing Project Management, NRR
SUBJECT:
CATAWBA NUCLEAR STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION INFORMALLY TRANSMITTED ON MARCH 5, 2004 (TAC NOS. MB7842 AND MB7843)
The attached was telefaxed to Duke Energy Corporation (the licensee) on March 5, 2004. The request for additional information concerns the licensees amendment request dated February 25, 2003, and the structural integrity performance criteria.
This memorandum and the attachment do not convey or represent an NRC staff position regarding the licensees amendment request.
Docket Nos. 50-413 and 50-414
Attachment:
As stated CONTACT: Leonard N. Olshan, NRR 301-415-1419
ML040700177 NRR-106 OFFICE LPDII-1/PM LPDII-1/LA LPDII-1/SC NAME LOlshan CHawes JNakoski DATE 3/10/04 3/10/04 3/11/04 Mr. D. M. Jamil Vice President Catawba Nuclear Station Duke Energy Corporation 4800 Concord Road York, South Carolina 29745
SUBJECT:
CATAWBA NUCLEAR STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION CONCERNING STEAM GENERATOR TUBE INTEGRITY CRITERIA (TAC NOS. MB7842 AND MB7843)
Dear Mr. Jamil:
Enclosed is a request for additional information (RAI) concerning the structural integrity performance criteria for Catawba Nuclear Station, Units 1 and 2. This RAI was discussed with Mr. Larry Rudy of your staff.
Attachment
REQUEST FOR ADDITIONAL INFORMATION
Background:
By letter dated February 25, 2003, as revised by letters dated June 9, 2003 and July 30, 2003, Duke Energy Corporation (the licensee) submitted a technical specification (TS) amendment request for Catawba Nuclear Station, Units 1 and 2, concerning the maintaining of steam generator (SG) tube integrity. The July 30, 2003, letter included a revised proposal for the structural integrity performance criteria (SIPC) that was intended to address the influence of non-pressure related loads on tube burst during design basis accidents as follows:
All inservice steam generator tubes shall retain structural integrity over the full range of normal operating conditions (including startup, operation in the power range, hot standby, cooldown, and all anticipated transients included in the design specification) and design basis accidents. This includes maintaining a safety factor of 3.0 against burst under normal steady state full power operation primary-to-secondary pressure differential and a safety factor of 1.4 against burst applied to design basis accident primary to secondary pressure differentials. Apart from the above requirements, additional loading conditions associated with the design basis accidents, or combination of accidents in accordance with the design and licensing basis, shall also be evaluated to determine if the associated loads contribute significantly to burst. In the assessment of tube integrity, those loads that do significantly affect burst shall be determined and assessed in combination with the loads due to primary to secondary pressure differential using safety factors that are consistent with the licensing basis design criteria.
By letter dated September 17, 2003, which was revised by letter dated October 10, 2003, the NRC staff issued a Request for Additional Information (RAI) concerning how the portion of the SIPC relating to non-pressure related loads would actually be implemented.
During a meeting with the NRC staff on January 21, 2004, the Nuclear Energy Institute (NEI) described an industry program that was underway to develop information needed to respond to the RAI which would include new industry guidelines for assessing the influence of non-pressure related loads on burst pressure during design basis accidents. NEI expects to provide this information and to resubmit the necessary versions of the Generic License Change Package (GLCP) by October 2004. The licensee for Catawba expects to submit a revised amendment request at that time.
In the meantime, the NRC staff believes there may be an adequate technical basis to proceed with review and approval of the current Catawba amendment package on an interim basis pending completion of the aforementioned NEI effort. This interim approach would be predicated on the licensee submitting of each of the following:
Requested Information:
1.
Provide an assessment demonstrating that stress corrosion cracking, particularly circumferential cracking, is not expected to occur over the current and next inspection cycle. Absent any significant potential for cracking during this time period, explain why
any non-pressure related loads would not be expected to influence burst pressures during design basis accidents.
- 2. Propose a license condition that commits to submit any necessary revisions to the interim technical specifications within two months following completion of the NEI program described during the January 21, 2004, meeting. Should the NEI program not be completed by December 31, 2004, the licensee shall submit an update to the assessment in item 1 within 60 days of each inspection performed in December 2004 or thereafter until the NEI program is completed.