ML12072A113

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James A. Fitzpatrick Nuclear Power Plant, Relief Request Nos. VRR-07 and VRR-08 for the James A. Fitzpatrick Nuclear Power Plant Fourth Interval In-Service Testing Program Relief from the Requirements of the ASME OM Code
ML12072A113
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 03/16/2012
From: George Wilson
Plant Licensing Branch 1
To: Fitzpatrick J
Entergy Nuclear Operations
Vaidya B, NRR/DORL/LPL1-1, 415-3308
References
TAC ME6686, TAC ME6687
Download: ML12072A113 (11)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 16,2012 Vice President, Operations Entergy Nuclear Operations, Inc.

James A FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 10393

SUBJECT:

JAMES A FITZPATRICK NUCLEAR POWER PLANT - RELIEF REQUEST NOS. VRR-07 AND VRR-08 FOR THE JAMES AFITZPATRICK NUCLEAR POWER PLANT FOURTH INTERVAL II\lSERVICE TESTING PROGRAM RE:

RELIEF FROM THE REQUIREMENTS OF THE ASME OM CODE (TAC NOS.

ME6686 AND ME6687)

Dear Sir or Madam:

By letter dated July 7, 2011 (Accession No. ML111890199), Entergy Nuclear Operations, Inc.

(the licensee), submitted Relief Requests VRR-07 and VRR-08 to the U.S. Nuclear Regulatory Commission (NRC). Requests VRR-07 and VRR-08 requested relief from the requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code).

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 50.55a(a)(3)(i), the licensee requested to use the proposed alternatives in VRR-07 and VRR-08, on the basis that the alternatives provide an acceptable level of quality and safety.

Requests VRR-07 and VRR-08 are applicable to the fourth 1O-year inservice testing (1ST) program interval at the James A FitzPatrick (JAF) Nuclear Power Plant. In VRR-07, the licensee requested authorization to use a performance-based approach to the scheduling of Pressure Isolation Valve (PIV) leakage testing rather than the required frequency per ASME OM Code for several PIVs. In VRR-08, the licensee requested authorization to perform the position verification testing for several solenoid operated valves (SOVs) in conjunction with the Type C valve seat leakage test at a frequency in accordance with 10 CFR Part 50 Appendix J, Option B rather than the required frequency per the ASME OM Code. By letters dated October 20, 2011 (Accession No. ML112930539) and November 14, 2011 (Accession No. ML113190078), the licensee submitted additional information pertaining to requests VRR-07 and VRR-08, respectively.

The NRC staff has reviewed the subject request and concludes as set forth in the enclosed safety evaluation, that, the NRC staff finds that the proposed alternatives in requests VRR-07 and VRR-08 provide an acceptable level of quality and safety for the 10 PIVs noted in Section 3.1.1 and the 33 SOVs noted in Section 3.2.1. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(i), and is in compliance with the ASME OM Code requirements.

All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject request for relief remain applicable.

V. P. Operations -2 Therefore, the NRC staff authorizes the alternatives in requests VRR-07 and VRR-08 for the remainder of the JAF fourth 1O-year 1ST interval, which commenced on October 1,2007.

Please contact me at (301) 415-1711, or the Project Manager, Bhalchandra K. Vaidya at (301) 415-3308, if you have any questions.

Sincerely,

"'"',,----9 ~ ~r eorge A. Wilson, Chief lant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosure:

Safety Evaluation cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST NOS. VRR-07 AND VRR-08 FOR THE FOURTH 10-YEAR INTERVAL INSERVICE TESTING PROGRAM ENTERGY NUCLEAR OPERATIONS. INC.

JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. SO-333

1.0 INTRODUCTION

By letter dated July 7, 2011 (Accession No. ML111890199), Entergy Nuclear Operations, Inc.

(the licensee), submitted Relief Requests VRR-07 and VRR-08 to the U.S. Nuclear Regulatory Commission (NRC). Requests VRR-07 and VRR-08 requested relief from the requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code).

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part SO, Section SO.SSa(a)(3)(i), the licensee requested to use the proposed alternatives in VRR-07 and VRR-08, on the basis that the alternatives provide an acceptable level of quality and safety.

Requests VRR-07 and VRR-08 are applicable to the fourth ten-year inservice testing (1ST) program interval at the James A. FitzPatrick (JAF) nuclear power plant. In VRR-07, the licensee requested authorization to use a performance-based approach to the scheduling of Pressure Isolation Valve (PIV) leakage testing rather than the required frequency per ASME OM Code for several PIVs. In VRR-08, the licensee requested authorization to perform the position verification testing for several solenoid operated valves (SOVs) in conjunction with the Type C valve seat leakage test at a frequency in accordance with 10 CFR Part SO Appendix J, Option B rather than the required frequency per the ASME OM Code. By letters dated October 20, 2011 (Accession No. ML 112930S39) and November 14, 2011 (Accession No. ML113190078), the licensee submitted additional information pertaining to requests VRR-07 and VRR-08, respectively.

2.0 REGULATORY EVALUATION

10 CFR SO.SSa(f), "Inservice testing requirements," requires, in part, that 1ST of certain ASME Code Class 1, 2, and 3 pumps and valves be performed in accordance with the specified ASME OM Code and applicable addenda incorporated by reference in the regulations. Exceptions are allowed where alternatives have been authorized or relief has been requested by the licensee and granted by the NRC pursuant to paragraphs (a)(3)(i), (a)(3)(ii), or (f)(6)(i) of 10 CFR SO.SSa.

Enclosure

-2 In proposing alternatives or requesting relief, the licensee must demonstrate that: (1) the proposed alternative provides an acceptable level of quality and safety (10 CFR SO.SSa(a)(3)(i>>;

(2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety (10 CFR SO.SSa(a)(3)(ii>>; or (3) conformance is impractical for the facility (10 CFR SO.SSa(f)(6)(i>>. Section SO.SSa allows the NRC to authorize alternatives and to grant relief from ASME OM Code requirements upon making necessary findings.

The JAF fourth 10-year 1ST program interval began on October 1,2007. The applicable ASME OM Code edition and addenda for the JAF fourth 1O-year 1ST program interval is the 2001 Edition through the 2003 Addenda.

The NRC's findings with respect to authorizing the alternatives VRR-07 and VRR-08 to the ASME OM Code are given below:

3.0 TECHNICAL EVALUATION

3.1 Licensee's Alternative Request VRR-07 3.1.1 Licensee's Request and Proposed Alternative ISTC-3630, "Leakage Rate for Other Than Containment Isolation Valves," states, in part, that "Category A valves with a leakage requirement not based on an Owner's 10 CFR SO, Nonmandatory Appendix J program, shall be tested to verify their seat leakages within acceptable limits. Valve closure before seat leakage testing shall be by using the valve operator with no additional closing force applied."

ISTC-3630(a), "Frequency," states that, "Tests shall be conducted at least once every 2 years."

The licensee requested to use an alternative testing schedule for the following PIVs:

10AOV-68A Loop A Low Pressure Coolant Injection Testable Check Valve 10MOV-2SA Loop A Low Pressure Coolant Injection Inboard Injection Valve 10AOV-68B Loop B Low Pressure Coolant Injection Testable Check Valve 10MOV-25B Loop B Low Pressure Coolant Injection Inboard Injection Valve 14AOV-13A Loop A Low Pressure Core Spray Testable Check Valve 14MOV-12A Loop A Low Pressure Core Spray Inboard Isolation Valve 14AOV-13B Loop B Low Pressure Core Spray Testable Check Valve 14MOV-12B Loop B Low Pressure Core Spray Inboard Isolation Valve 10MOV-17 Residual Heat Removal Shutdown Cooling Outboard Isolation Valve 10MOV-18 Residual Heat Removal Shutdown Cooling Inboard Isolation Valve All of the PIVs listed above are Category A valves within the scope of ISTC-3630. Valves 10MOV-2SA, 10MOV-25B, 14MOV-12A, 14MOV-12B, and 10MOV-17 are also containment isolation valves (CIVs) and are air tested in accordance with 10 CFR Part SO, Appendix J, Option B. The licensee proposed to apply performance-based scheduling of PIV tests in an identical manner as performance-based Type C tested components. Testing of Type C components is described in Nuclear Energy Institute (NEI) Topical Report (TR) 94-01

-3 "Industry Guidance for Implementing Performance Based Option of 10 CFR 50, Appendix J",

and as modified by the positions in Regulatory Guide (RG) 1.163 "Performance Based Containment Leak Test Program." JAF proposes to perform PIV testing at the intervals specified in NEI 94-01. The specific interval for each valve would be a function of its performance and would be established in a manner consistent with the CIV process under 10 CFR Part 50 Appendix J, Option B. This program permits the extension of Appendix J seat leakage testing to a frequency based on specific valve performance.

Program guidance will be established such that if any of the valves fail either the CIV test or PIV test, the test interval for both tests will be reduced to once every 24 months until they can be re-classified as good performers per the performance evaluation requirements of Appendix J, Option B. JAF will perform CIV (if applicable) or PIV testing on each poor performing valve during every refueling outage interval (24 months) until good performance is established. The test intervals for the valves with a PIV-only function will be determined in the same manner as is done for CIV testing under Option B. That is, the test interval may be extended up to a 60-month interval upon completion of two consecutive periodic PIV tests with results within prescribed acceptance criteria.

The performance of PIV leak rate testing provides assurance of acceptable seat leakage with the valve in a closed condition. Typical PIV testing does not identify functional problems which may inhibit the valve's ability to re-position from open to close. For check valves, such functional testing is accomplished per ASME OM Code ISTC-3522 and ISTC-3520. Power operated valves are routinely full-stroke tested per the ASME OM Code to ensure their functional capabilities. The functional tests for PIVs are performed only at Refueling Outage (RFO) frequency. Such testing is not performed online in order to prevent any possibility of an inadvertent Interfacing System Loss of Coolant Accident (ISLOCA) condition. The functional testing of the PIVs is adequate to identify any abnormal conditions that might affect closure capability. Performance of the separate PIV leak rate testing does not contribute any additional assurance of functional capability; it only verifies the seat tightness of the closed valves.

The PIVs listed in this section have an excellent performance history in terms of seat leakage testing. Since the receipt of Technical Specification Amendment No, 234, which approved the implementation of 10 CFR Part 50 Appendix J, Option B, 91 PIV leakage tests have been performed on the subject valves, with only three failures. All three of the failures were on the same valve during a 1-month period, and were attributed to improper valve operation and mechanical cycling. Since November of 2000, no PIV leakage test failures have occurred on the subject valves. The basis for this alternative request is the historically good performance of the PIVs. This alternative will also provide significant reductions in radiation dose. The last RFO radiation exposure was used to identify that PIV testing incurs a total dose of approximately 800 millirem in each RFO.

3.1.2 NRC Staff Evaluation The licensee has proposed an alternative test in lieu of the requirements found in the 2001 Edition of the ASME OM Code Section ISTC-3630 for PIVs 10AOV-68A, 10MOV-25A, 10AOV 68B, 10MOV-25B, 14AOV-13A, 14MOV-12A, 14AOV-13B, 14MOV-12B, 10MOV-17, and 10MOV-18. Specifically, the licensee proposes to verify the leakage rate of the 10 PIVs using

-4 the 10 CFR Part SO Appendix J, Option B performance-based schedule. Valves would initially be tested at the required interval schedule, which is currently every RFO or 2 years as specified by ASME OM Code Section ISTC-3630(a). Valves that have demonstrated good performance for 2 consecutive cycles may have their test interval extended for up to 60 months. Any PIV leakage test failure would require the component to return to the initial testing interval of every RFO or 2 years until they can be re-classified as good performers per the performance evaluation requirements of Appendix J, Option B.

PIVs are defined as two valves in series within the reactor coolant pressure boundary which separate the high pressure reactor coolant system from an attached lower pressure system.

Failure of a PIV could result in an over-pressurization event which could lead to a system rupture and possible release of fission products to the environment. This type of failure event was analyzed under NUREG/CR-S928, "ISLOCA Research Program" (Accession No. ML072430731). The purpose of NUREG/CR-S928 was to quantify the risk associated with an ISLOCA event. NUREG/CR-S928 analyzed Boiling-Water Reactor (BWR) and Pressurized Water Reactor (PWR) designs. Specifically, NUREG/CR-S928 reviewed the BWR-4 design, which included JAF. The conclusion of the analysis showed that an ISLOCA was not a risk concern for the BWR-4 design.

The licensee proposed to initiate a performance-based program consistent with 10 CFR Part SO Appendix J, Option B. The licensee stated that the 10 PIVs would be placed into a performance-based program where each valve would have to complete two consecutive leakage tests within the acceptance criteria. Upon completion of two successful tests, the component leakage test interval can be extended for up to 60 months. The specific interval for each valve would be a function of its performance and would be established in a manner consistent with the CIV process under 10 CFR Part 50 Appendix J, Option B. The specific guidance concerning a performance-based leakage test program, acceptable leakage rate test methods, procedures, and analyses that may be used to implement these requirements and criteria is provided in NEI TR 94-01, Revision O. RG 1.163 endorsed NEI TR 94-01, Revision 0 with the limitation that Type C components' test interval cannot extend greater than 60 months. In addition, NEI 94-01, Revision 2 was reviewed by the NRC staff and a safety evaluation (SE) was issued on June 2S, 2008 (Accession No. ML08114010S).

The 10 PIVs are currently being leak tested every RFO or 2 years. The valves have maintained a history of good performance. Extending the leakage test interval based on good performance and the low risk factor as noted in NUREG/CR-S928 is a logical progression to a performance based program. In addition, JAF routinely functionally tests these check valves and full stroke tests these power operated valves in accordance with ASME Code requirements to ensure their functional capabilities. Based on the excellent valve maintenance history, coupled with valve stroking every RFO and low risk factor, the proposed alternative provides an acceptable level of quality and safety and is acceptable for use.

-5 3.2 Licensee's Alternative Request VRR-08 3.2.1 Licensee's Request and Proposed Alternative ISTC-3700, "Position Verification Testing," states, in part, that "Valves with remote position indicators shall be observed locally at least once every 2 years to verify that valve operation is accurately indicated. Where local observation is not possible, other indications shall be used for verification of valve operation."

ISTC-3530, "Valve Obturator Movement," states that, "The necessary valve obturator movement shall be determined by exercising the valve while observing an appropriate indicator, such as indicating lights that signal the required changes of obturator position, or by observing other evidence, such as changes in system pressure, flow rate, level, or temperature, that reflects change of obturator position."

The licensee requested to use an alternative testing method for the following valves:

07S0V-104A TIP Channel A Guide Tube Ball Valve 07S0V-104B TIP Channel B Guide Tube Ball Valve 07S0V-104C TIP Channel C Guide Tube Ball Valve 27S0V-119E1 Containment Analyzer A Torus Sample Outer Isolation Valve 27S0V-119E2 Containment Analyzer A Torus Sample Inner Isolation Valve 27S0V-119F1 Containment Analyzer B Torus Sample Inner Isolation Valve 27S0V-119F2 Containment Analyzer B Torus Sample Outer Isolation Valve 27S0V-120E1 Containment Analyzer A Drywell310 Ft Elevation Sample Outer Isolation Valve 27S0V-120E2 Containment Analyzer A Drywell 310Ft Elevation Sample Inner Isolation Valve 27S0V-120F1 Containment Analyzer B Drywell 310 Ft Elevation Sample Outer Isolation Valve 27S0V-120F2 Containment Analyzer B Drywell310 Ft Elevation Sample Inner Isolation Valve 27S0V-122E1 Containment Analyzer A Drywell 343 Ft Elevation Sample Outer Isolation Valve 27S0V-122E2 Containment Analyzer A Drywell 343 Ft Elevation Sample Inner Isolation Valve 27S0V-122F1 Containment Analyzer B Drywell 343 Ft Elevation Sample Outer Isolation Valve 27S0V-122F2 Containment Analyzer B Drywell343 Ft Elevation Sample Inner Isolation Valve 27S0V-123E1 Containment Analyzer A Drywell276 Ft t Elevation Sample Outer Isolation Valve 27S0V-123E2 Containment Analyzer A Drywell 276 Ft Elevation Sample Inner Isolation Valve 27S0V-123F1 Containment Analyzer B Drywell276 Ft Elevation Sample Outer Isolation Valve 27S0V-123F2 Containment Analyzer B Drywell276 Ft Elevation Sample Inner Isolation Valve

-6 27S0V-124E 1 Containment Analyzer A Post Accident Sampling Return Header Outer Isolation Valve 27S0V-124E2 Containment Analyzer A Post Accident Sampling Return Header Inner Isolation Valve 27S0V-124F1 Containment Analyzer B Post Accident Sampling Return Header Outer Isolation Valve 27S0V-124F2 Containment Analyzer B Post Accident Sampling Return Header Inner Isolation Valve 27S0V-12SA Drywell Radiation Monitor 17-04-1 Sample Return Inner Isolation Valve 27S0V-12SB Drywell Radiation Monitor 17-04-2 Sample Return Inner Isolation Valve 27S0V-12SC Drywell Radiation Monitor 17-04-1 Sample Return Outer Isolation Valve 27S0V-12SD Drywell Radiation Monitor 17-04-2 Sample Return Outer Isolation Valve 27S0V-135A Drywell Radiation Monitor 17-04-1 Sample Supply Outer Isolation Valve 27S0V-135B Drywell Radiation Monitor 17-04-2 Sample Supply Outer Isolation Valve 27S0V-135C Drywell Radiation Monitor 17-04-1 Sample Supply Inner Isolation Valve 27S0V-135D Drywell Radiation Monitor 17-04-2 Sample Supply Inner Isolation Valve 27S0V-141 Drywell PCV and Instrument Air or Normal N2 Cross-Tie Valve 2 A 27S0V-145 Drywell Instrument Nitrogen Backup Supply Isolation Valve The subject valves are all Category A valves and are all CIVs. All of the subject valves have a safety function to close in order to isolate containment during a loss-of-coolant accident. Each of these valves is a SOV designed in a way that the position of the valve is not locally observable. The coil position is internal to the valve body and not observable in either the energized or de-energized state.

The method used at JAF to verify valve position is a pressure test using local leakage rate testing equipment. This method involves pressurizing the containment penetration volume between 45 and 48 psig, and verifying the penetration remains pressurized while the valve is indicating closed on the main control room board. The valve is then opened using the control switch in the main control room and the penetration is verified to depressurize and the local leak rate testing equipment is verified to have high flow. This method satisfies the position verification testing requirement and ensures that the indicating system accurately reflects the valve position. This method also verifies that both the valve stem and obturator are moving acceptably, and there is no separation of the two.

Since these valves are CIVs, they are each individually seat leakage tested in accordance with 10 CFR Part SO Appendix J, Option B. JAF proposes to perform the position verification testing in conjunction with the Type C valve seat leakage test at a frequency in accordance with 10 CFR Part SO Appendix J, Option B. Based on seat leakage test results, the testing frequency may be adjusted to a maximum of 60 months in accordance 10 CFR Part SO Appendix J, Option B.

Radiation exposure and OperationslTest personnel time involved will be significantly reduced by performing the position verification testing at the same interval as the Appendix J seat leakage test.

The JAF program, which implements 10 CFR Part 50 Appendix J, Option B, requires individual CIVs to pass two consecutive successful seat leakage tests before they can be placed on extended seat leakage testing frequency. All of the subject valves are currently in "good performer" status, requiring a seat leakage test every 60 months. The licensee states that the

-7 ability to detect degradation and ensure the operational readiness of the subject valves to perform their intended function is not adversely affected by performing the position verification testing at the same frequency as specified by 10 CFR Part 50 Appendix J, Option B. This frequency of testing provides assurance of the operational readiness of the subject valves and provides an acceptable level of quality and safety.

In addition, each of these subject valves is exercised on a quarterly frequency and their stroke times are measured and compared to the ASME OM Code acceptance criteria. During the quarterly exercise testing, each valve's stroke time is measured and recorded. The newest test values are compared to the previous six test values by the 1ST coordinator. If there is a significant change or an upward trend between the new test and the previous tests, it alerts the 1ST coordinator to perform a more detailed analysis. Also, the 1ST database automatically compares the test value with both the applicable ISTC-5152 acceptance criteria as well as the ISTC-5151 (b) owner-identified limiting criteria. If either of the criteria levels is exceeded, the 1ST database displays a warning. This allows for tracking and trending of degrading performance over time. During the quarterly exercise testing, the valves are remote manually operated from the control room. Valve obturator position is verified using position indication lights in accordance with ISTC-3530. By continuing this valve exercising, and performance of the position verification testing and seat leakage test in accordance with 10 CFR Part 50 Appendix J, Option B, an adequate assessment of valve health may be determined.

The subject valves are also subject to Preventive Maintenance tasks. Many of these SOVs are periodically replaced to satisfy Environmental Qualification program requirements. Any maintenance that is performed on these valves which might affect position indication will be followed by applicable post-work testing, including a position verification test.

3.2.2 NRC Staff Evaluation The licensee has proposed an alternative test in lieu of the requirements found in ISTC-3700 for the 33 SOVs listed in Section 3.2.1. Specifically, the licensee proposes to perform the valve position verification test in conjunction with the type C valve seat leakage test at a frequency in accordance with the 10 CFR Part 50 Appendix J, Option B schedule. Valves would initially be tested at the required interval schedule, which is currently every RFO or 2 years, as speCified by ISTC-3700. Valves that have demonstrated good performance for two consecutive cycles may have their test interval extended to a maximum of 60 months. Any position indication verification test failure would require the component to return to the initial interval of every RFO or 2 years until good performance can again be established.

The 33 SOVs are Category A CIVs and are required to be leak tested in accordance with the 10 CFR Part 50 Appendix J program. The licensee has implemented Option B of the 10 CFR Part 50 Appendix J program. This places the leakage testing requirements for the 33 SOVs into a performance-based program. Valves that have demonstrated a history of good performance may have their leakage test interval extended beyond the normal test interval requirement.

Extension intervals are not allowed to exceed 60 months. The licensee proposes to synchronize the position indication verification test requirements of ISTC-3700 with the Appendix J leakage rate test requirements. Both tests will be performed together on a 10 CFR Part 50, Appendix J, Option B performance-based schedule. Based on the results of a comprehensive risk analysis presented in NEI TR 94-01, the aggregate risk associated with relaxing the interval for position

- 8 indication verification testing to as long as 60 months is very small. Also, only valves 27S0V 141 and 27S0V-145 are in the JAF Probabilistic Safety Assessment model. Failure of either of these valves will not impact core damage frequency or large early release frequency.

Performance data compiled from the 1ST and maintenance programs for the 33 SOVs show that the valves have been relatively maintenance free. Quarterly valve exercise coupled with a 10 CFR Part 50 Appendix J, Option B performance-based program to test for leakage and verify valve position indication provides an acceptable level of quality and safety.

4.0 CONCLUSION

As set forth above, the NRC staff finds that the proposed alternatives in requests VRR-07 and VRR-08 provide an acceptable level of quality and safety for the 10 PIVs noted in Section 3.1.1 and the 33 SOVs noted in Section 3.2.1. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(i),

and is in compliance with the ASME OM Code requirements. All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject request for relief remain applicable.

Therefore, the NRC staff authorizes the alternatives in requests VRR-07 and VRR-08 for the remainder of the JAF fourth 10-year 1ST interval, which commenced on October 1, 2007.

Principal Contributors: B. Lin, RES/DE/MEEB R. Wolfgang, NRRIDE/EPTB Date: March 16,2012

V. P. Operations -2 Therefore, the NRC staff authorizes the alternatives in requests VRR-07 and VRR-08 for the remainder of the JAF fourth 10-year 1ST interval, which commenced on October 1,2007.

Please contact me at (301) 415-1711, or the Project Manager, Bhalchandra K. Vaidya at (301) 415-3308, if you have any questions.

Sincerely, Ira! (John Boska for)

George A. Wilson, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosure:

Safety Evaluation cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsNrrDorlLPL1-1 RidsNrrPMFitzPatrick RidsOGCMailCenter LPL1-1 Reading File RidsNrrLASLittle RidsAcrsAcnwMailCenter RidsNrrDeEptb DORL DPR MGray, RI L. Chang, EDO Region 1 Contact B. Lin, RES/DE/MEEB R. Wolfgang, NRR/DE/EPTB ADAMS ACCESSION NUMBER: ML12072A113 " No substantial chan OFFICE LPL 1-1/PM LPL1-1/LA NAME BVaidya SLittle McMurtray DATE 03/15/12 03/15/12 03/09/12 03/16/12 03/16/12 OFFICIAL RECORD COpy