ML12319A367

Relief Request ANO2-ISI-007, Alternative to Use ASME Code Case N-770-1 Baseline Examination, Fourth 10-Year Inservice Inspection Interval

ML12319A367
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/27/2012
From:	Markley M Plant Licensing Branch IV
To:	Entergy Operations
Kalyanam N
References
TAC ME7646
Download: ML12319A367 (11)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 27, 2012 Vice President, Operations Arkansas Nuclear One Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802

SUBJECT:

ARKANSAS NUCLEAR ONE, UNIT 2 - REQUEST FOR ALTERNATIVE AN02-ISI-007, USE OF ALTERNATE ASME CODE CASE N-770-1 BASELINE EXAMINATION (TAC NO. ME7646)

Dear Sir or Madam:

By letter dated November 30, 2011, as supplemented by letters dated April 13, May 21, and September 10, 2012 (two letters), pursuant to paragraph 50.55a(a)(3)(ii) of Title 10 of the Code of Federal Regulations (10 CFR), Entergy Operations, Inc. (Entergy, the licensee), submitted request for alternative AN02-ISI-007 for Arkansas Nuclear One, Unit 2 (ANO-2), for U.S. Nuclear Regulatory Commission (NRC) review and authorization. Portions of the two letters dated September 10, 2012, contain proprietary information and have been withheld from public disclosure. On October 2, 2012, the NRC staff granted verbal authorization of this request for a period of 3 months, until January 1, 2013.

The request pertained to relief from achieving the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code-required coverage when performing volumetric examinations of certain reactor coolant pump (RCP) welds, and is associated with the use of an alternative to the requirements of ASME Code Case N-770-1, "Alternative Examination Requirements and Acceptance Standards for Class 1 PWR [Pressurized-Water Reactor] Piping and Vessel Nozzle Butt Welds Fabricated With UNS N06082 or UNS W86182 Weld Filler Material With or Without Application of Listed Mitigation Activities," as conditioned in the Final Rule for 10 CFR 50.55a(g)(6)(ii)(F)(3) dated June 21, 2011 (76 FR 36232). Entergy requested the relief for the fourth 1a-year inservice inspection (lSI) interval, which began on March 26, 2010, and is scheduled to end on March 25, 2020.

The licensee has proposed to credit the ultrasonic (UT) examination performed at ANO-2 in 2009 to fulfill the dissimilar metal butt weld (DMBW) baseline examination. The licensee stated that the previous UT examination of the subject welds was performed within the required re-inspection period using ASME Code,Section XI, Appendix VIII, requirements but did not obtain essentially 100 percent coverage of the required examination volume. The licensee further stated that fulfilling the essentially 100 percent examination requirements would necessitate modification and/or replacement of the component which would constitute a hardship.

Based on its examination of the pipe/weld/surface configuration drawings submitted by the licensee, the NRC staff concludes that obtaining the required examination coverage is not

-2 possible without modification or replacement of the subject welds and that modification of the subject welds would constitute a hardship.

Based on the enclosed safety evaluation, the NRC staff concludes that the proposed alternative will provide reasonable assurance of structural integrity and leak-tightness of the subject RCP pump DMBWs until January 1, 2013. In addition, the NRC concludes that the licensee has demonstrated that performing a Code-compliant examination will result in a hardship without a compensating increase in quality and safety. The NRC, therefore, concludes that the regulatory requirements of 10 CFR 50.55a(a)(3)(ii) have been fulfilled and recommends that the baseline examination of the subject welds be accepted until January 1, 2013.

A" other ASME Code,Section XI requirements for which relief was not specifically requested and approved in this relief request remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.

Sincerely, Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-368

Enclosure:

As stated 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 REQUEST FOR ALTERNATIVE AN02-ISI-007 USE OF ALTERNATE ASME CODE CASE N-770-1 BASELINE EXAMINATION FOR THE FOURTH 10-YEAR INSERVICE INSPECTION INTERVAL ENTERGY OPERATIONS, INC.

ARKANSAS NUCLEAR ONE, UNIT 2 DOCKET NO. 50-368

1.0 INTRODUCTION

By letter dated November 30, 2011 (Reference 1), as supplemented by letters dated April 13, May 21, and September 10, 2012 (two letters) (References 2,3,4, and 5, respectively), Entergy Operations, Inc. (Entergy, the licensee), submitted request for alternative AN02-ISI-007 for Arkansas Nuclear One, Unit 2 (ANO-2), for U.S. Nuclear Regulatory Commission (NRC) review and authorization. Portions of the two letters dated September 10, 2012, contain proprietary information and have been withheld from public disclosure.

Pursuant to paragraph 50.55a(a)(3)(ii) of Title 10 of the Code of Federal Regulations (10 CFR),

the licensee requested relief from the requirements of American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code to permit acceptance of previous examination coverage of dissimilar metal butt welds (DMBW). Specifically, the licensee requested relief from ASME Code Case N-770-1, "Alternative Examination Requirements and Acceptance Standards for Class 1 PWR [Pressurized-Water Reactor] Piping and Vessel Nozzle Butt Welds Fabricated With UNS N06082 or UNS W86182 Weld Filler Material With or Without Application of Listed Mitigation Activities," as conditioned in the Final Rule for 10 CFR 50.55a(g)(6)(ii)(F)(3) dated June 21, 2011 (76 FR 36232), to permit the use of results from a prior ultrasonic examination in which less than Code-compliant coverage was obtained to fulfill the DMBW baseline inspection requirement on the basis that complying with the specified requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Entergy requested the relief for the fourth 10-year inservice inspection (lSI) interval, which began on March 26, 2010, and is scheduled to end on March 25, 2020.

The NRC staff granted verbal authorization of this request on October 2, 2012 (Reference 6) authorizing the alternative until January 1! 2013.

Enclosure

-2

2.0 REGULATORY EVALUATION

The regulations in 10 CFR 50.55a(g)(6)(ii)(F) require that licensees of existing operating pressurized-water reactors (PWRs) implement the requirements of ASME Code Case N-770-1, subject to the conditions specified in 10 CFR 50.55a(g)(6)(ii)(F)(2)-(10), by the first refueling outage after August 22, 2011.

Paragraph 10 CFR 50.55a(a)(3) states, in part, that alternatives to the requirements of 10 CFR 50.55a(g) may be used when authorized by the NRC if the applicant demonstrates that:

(i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Based on analysis of the regulatory requirements, the NRC staff concludes that the NRC has the regulatory authority to authorize the proposed alternative under 10 CFR 50.55a(a)(3)(ii).

3.0 TECHNICAL EVALUATION

3.1 Licensee's Request for Alternative 3.1.1 Components Affected Reactor coolant pump (RCP) suction nozzle elbow-to-safe-end welds08-014, 10-014,12-014, and 14-014 RCP discharge nozzle safe-end-to-pipe welds09-008, 11-008,13-008, and 15-008 3.1.2 Inservice Inspection Code of Record The lSI Code of record for ANO-2, for the fourth 1O-year lSI interval, which began on March 26, 2010, and is scheduled to end on March 25,2020, isSection XI of the ASME Code, 2001 Edition through the 2003 Addenda.

3.1.3 Code Requirements The regulations in 10 CFR 50.55a(g)(6)(ii)(F)(3) state:

Baseline examinations for welds in Table 1, Inspection Items A-1, A-2, and B, shall be completed by the end of the next refueling outage after January 20, 2012. Previous examinations of these welds can be credited for baseline examinations if they were performed within the re-inspection period for the weld item in Table 1 using Section XI, Appendix VIII requirements and met the Code required examination volume of essentially 100 percent. Other previous examinations that do not meet these requirements can be used to meet the baseline examination requirement, provided NRC approval of alternative inspection requirements in accordance with paragraphs (a)(3)(i) or (a)(3)(ii) of this section is granted prior to the end of the next refueling outage after January 20, 2012.

-3 The subject welds are classified as Inspection Item "B", "Unmitigated butt weld at Cold Leg 0 0 operating temperature :<:! 525 F and < 580 F" for which visual and essentially 100 percent volumetric examinations are required.

3.1.4 Licensee's Reason for Request The licensee stated that the UT examination of the subject welds in the fall of 2009 did not obtain greater than 90 percent coverage of the required examination volume and to obtain additional coverage would necessitate modification and/or replacement of the component.

3.1.5 Licensee's Proposed Alternative and Basis for Use The licensee proposed that the scan coverage attained during the UT examination performed in the fall of 2009 in accordance with the Electric Power Research Institute (EPRI) Materials Reliability Program (MRP) technical report MRP-139, Revision 1, "Materials Reliability Program:

Primary System Piping Butt Weld Inspection and Evaluation Guideline" (Reference 7), be credited for the 10 CFR 50.55a(g)(6){ii){F){3) required baseline examination. The licensee stated that the manually delivered ultrasonic phased-array examination was performed using ASME Code,Section XI, Appendix VIII requirements, employing the best available technology for maximizing examination coverage of these types of welds and that examinations performed on the subject areas would demonstrate an acceptable level of integrity, Furthermore, the licensee stated that actions required to obtain the required degree of coverage would result in hardship without a compensating increase in the level of quality and safety.

3.2 NRC Staff Evaluation Primary water stress-corrosion cracking (PWSCC) of Nickel (NO-based pressure retaining boundary materials is a safety concern. Operational experience has shown that PWSCC can occur as the result of the combination of susceptible material, corrosive environment and tensile stresses, resulting in leakage and the potential for loss of structural integrity. The subject DMBWs meet these conditions thus may be susceptible to PWSCC. The examination requirements of ASME Code Case N-770-1, as required and conditioned by 10 CFR

50. 55a(g)(6)(ii)(F), are intended to ensure the structural integrity and leak-tightness of DMBWs through nondestructive examination.

The licensee stated that the surface configuration of the subject DMBWs does not allow full coverage in the circumferential scan direction to detect axially-oriented flaws. The NRC staff has examined the drawings submitted by the licensee (Reference 1) and concludes that the external weld taper or weld shape (convexity or concavity) of the RCP suction nozzle elbow-to safe-end and RCP discharge nozzle safe-end-to-pipe welds does not permit essentially 100 percent interrogation of the susceptible weld material in the ASME Code Case N-770-1 required inspection volume in the circumferential scanning direction.

3.2.1 Hardship Evaluation The licensee stated that attaining essentially 100 percent examination coverage of the subject DMBWs would necessitate modification and/or replacement of the components, The licensee

-4 also stated that the weld crown has already been contoured to the extent possible to maximize examination coverage while maintaining minimum wall thickness. The NRC staff has examined the drawings submitted by the licensee and agrees with the licensee's assertion that the geometry of the outside diameter (00) surface of the weld would have to be re-contouredby deposition of weld metal and subsequent machining in order to examine the susceptible material at the inside diameter (10) of the weld. The staff recognizes that the re-contoured weld would then require radiographic examination after the deposition of weld metal and machining, and concludes that this sequence would present a hardship. The staff also recognizes that the weld could be examined from the 10 but acknowledges that 10 interrogation would be accompanied by a significant radiological dose, thus would constitute a hardship. The staff is not aware of other options for attaining the required examination of the subject welds and, therefore, concludes that attaining the required ASME Code Case N-770-1 examination coverage would present a hardship.

3.2.2 Proposed Alternative Evaluation The licensee stated that the subject nozzle-to-safe-end welds were examined in accordance with MRP-139, Revision 1, during the refueling outage in the fall of 2009 (Reference 2) using a UT procedure that met the requirements of ASME Code,Section XI, Appendix VIII, Supplement 10. For the ferritic nozzle material, the 2009 examination achieved 100 percent coverage of the required ASME Code Case N-770-1 volume for scans in both the axial and circumferential scan directions. For the Ni-alloy weld material, the 2009 examination achieved 100 percent of the required coverage of the Ni-alloy weld material for scans in the axial direction but could not achieve essentially 100 percent coverage for scans in the circumferential direction for axial flaws. For the cast austenitic stainless steel (CASS) material, the 2009 examination could not be credited for any coverage because the procedure used was not qualified for the CASS material. Due to the fact that CASS is not known to be susceptible to PWSCC or other service-related cracking in the reactor coolant system environment, the NRC staff concludes that the lack of ASME Code,Section XI, Appendix VIII compliant coverage is not a structural integrity concern.

Due to the failure of the 2009 examination to achieve the physical volume examination coverage required. and due to the potential for PWSCC cracking to occur in the Alloy 182 weld metal. the NRC staff determined that further analysis was required prior to authorizing the proposed alternative. The staff selected the two welds,09-008 and 10-014. for further analysis. These welds were selected because they could contain the largest potentially undetected flaws. If present. these flaws would grow to unacceptable size in the shortest period of time and are, therefore, bounding for all of the welds for which relief is sought.

The NRC requested that Pacific Northwest National Laboratory (PNNL) model the UT response in the susceptible material in the axial scan direction. The evaluation modeled the UT sound beam intensity based on the array matrix design dimensions, the actual phased-array design parameters and component geometrical information provided by the licensee (Reference 4).

The phased-array UT examination was modeled with focal laws defined to produce steered beams from 0 to 80 degrees, at 1-degree increments. each focused at approximately 122 centimeters (cm) of metal path after exiting the probe. The PNNL model predicts that the 122 cm focal length is beyond the 10 surface for steered beams at angles less than approximately 20 degrees. The steered beams will have less than -6 decibels (dB) beam

- 5 intensities near the ID of the weld at angles above approximately 30 degrees, and it is generally assumed that adequate volumetric coverage exists for sound field intensity greater than or equal to -6 dB. The PNNL model predicts that the weld surface at the ID could be generally interrogated with a sound field intensity of approximately -6 dB or better for beams at angles of approximately 20-25 degrees. PNNL notes, however, that currently modeled sound field extents and intensities represent only isotropic material (i.e., actual grain sizes and structures, velocity ranges, and other material variables that will affect sound beam attenuation, re-direction, and signal-to-noise values have not been applied).

The PNNL evaluation of the UT scan coverage of weld 09-008 shows that the coverage claimed by the licensee is totally contained within the coverage volume predicted by the PNNL model.

The NRC staff, therefore, concludes that the licensee's stated coverage is acceptable for further use in its evaluation.

PNNL also applied the UT model to the scan coverage of weld 10-014. PNNL determined that a volume exists at the ID that had a UT sound field of less than -6 dB due to the OD taper and slightly increased wall thickness. In order for the lower scan angles to extend to their maximum

-6 dB length, electronic lateral skewing was required. While focal laws were produced to laterally skew the beam by 10 degrees, the modeling showed that the actual array matrix would only produce an approximate 4-degree skew because only two elements exist in the passive direction of the array. However, the 4-degree lateral skew was helpful for extending the sound beams. Although the PNNL model did not indicate an adequate sound field to interrogate the weld material at the ID, the model predicted that the extent of coverage with less than -6dB sound field was contained within the licensee's assumed area of no coverage, thus the NRC staff concludes that the licensee's stated area of coverage is acceptable.

The NRC staff examined the UT coverage maps for welds09-008 and 10-014 and determined that licensee's UT coverage map for weld 10-014 would contain the largest (bounding) potential flaw size; therefore, the staff chose weld 10-014 for further consideration. By letter dated September 10, 2012 (Reference 4), in response to the staff's request for additional information (RAI) dated August 28, 2012 (Reference 8), the licensee evaluated the flaw size that could exist in the unexamined region of the bounding RCP weld, weld 10-014 and estimated that the maximum potential dimension of an elliptical flaw that is connected to the weld ID in contact with primary water is 1.0 inches in length and 0.5 inches in depth.

By letter dated September 10, 2012 (Reference 5), in response to the NRC staff's RAI dated August 28,2012 (Reference 8), the licensee provided the results of a PWSCC flaw growth evaluation. The driving force for axial flaw growth results from hoop stress from operational conditions and weld residual stress (WRS). The WRS consists of the stress resulting directly from the DMBW as well as stress resulting from any potential weld repairs. The licensee's WRS calculations were performed using a finite element two-dimensional axisymmetric model for the DMBW with a 10 percent through wall repair, presented in Westinghouse Electric Company LLC Technical Report, WCAP-17128, Revision 1-NP, "Flaw Evaluation of CE Design RCP Suction and Discharge Nozzle Suction and Discharge Nozzle Dissimilar Metal Welds, Phase III Study,"

May 2010 (Reference 9). In response to the staff's RAI, the licensee stated that a due diligence search of documents pertaining to the subject welds did not locate any documented weld repairs. The staff notes, however, that the welding procedures required that the weld is back chipped and rewelded, resulting in a condition that is similar to a 10 percent weld repair. The

- 6 WRS calculated by the licensee using finite element analysis is presented graphically in Reference 9.

The flaw growth evaluation provided by the licensee (Reference 5) used the equation and constants for Alloy 82 and Alloy 182 weld metal from Reference 9 that correspond to those found in ASME Code,Section XI, Appendix C, paragraph 8511. Thus, the NRC staff concludes that the appropriate flaw growth equation and constants have been employed. The results of the licensee's flaw analysis are presented in Reference 5 as a plot of flaw depth with time. The expected time that the initial flaw size would require to propagate to an ASME Code-allowable depth then can be read directly from the plot. The licensee calculated that, in response to the combined operational and WRS loading, the largest flaw within the unexamined zone, a 14.4 percent through-wall flaw, would propagate to ASME Code-allowable limit of 75 percent of wall thickness in 72 months.

The NRC staff, however, recognizes that the largest potential initial flaw size is bounded by the flaw in the examined area (insonified volume) that can first be detected using the UT examination procedure, not by the largest flaw in the volume that does not have UT coverage.

The staff is unaware of ASME Code guidelines for determining the size-dependent probability of detection of axial flaws in DMBWs but recognizes that the ASME Code,Section XI, Appendix VIII UT examination qualification requires a flaw set with flaw depths within 10-30 percent of the wall thickness in order to pass procedure qualification. I n the absence of further guidelines, the staff assumed that a flaw with a depth of 15 percent of wall thickness should be reliably detected and flaws with lesser depths may not be reliably detected. Based on the above, the staff concludes that further analysis of the potential PWSCC growth of a flaw in weld 10-014 should be based on a flaw which is contained within the region of the weld that has not been insonified (14.4 percent) plus 15 percent of the component wall thickness.

Using a potential initial flaw size of the unexamined zone plus 15 percent of the wall thickness, the NRC staff used the licensee's plot of flaw depth with time to determine that the largest potential initial flaw would reach the ASME Code limit of 75 percent of the wall thickness in 44 months, significantly less than the 72 months proposed by the licensee's analysis. Since the previous examination was performed during the fall 2009 outage, the minimum prOjected time for the largest potential flaw in the unexamined region to reach ASME Code limits would permit operation until at least January 2013.

The NRC staff has independently evaluated flaw growth of a hypothetical semicircular axial flaw which could be detected by UT examination. The analysis used the licensee's weld residual stresses found in Reference 9 for a weld with a 10 percent of wall thickness repair. The results of this calculation confirmed the 44-month time for the initial flaw to reach the ASME Code limit of 75 percent through wall.

In summary, the NRC staff concludes that compliance with the requirements of 10 CFR 50.55a(g)(6)(ii)(F)(3) for performing an ASME Code-compliant baseline examination would result in hardship. The staff further concludes that the PWSCC-susceptible weld material has been adequately examined in the axial scan direction for detection of safety significant circumferential flaws, and that the bounding potential axial flaw in the PWSCC-susceptible material has an expected time to reach ASME Code limits of 44 months. The staff concludes that the UT weld examination which was previously performed in accordance with requirements

-7 of ASME Code,Section XI, Appendix VIII, in the fall of 2009 provides reasonable assurance of structural integrity and leak-tightness until January 1, 2013.

4.0 CONCLUSION

Based on the above, the NRC staff determined that the proposed alternative provides reasonable assurance of structural integrity and leak-tightness of the subject RCP welds and that complying with the specified requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. 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}(ii). Therefore, the NRC staff authorizes crediting the nozzle-to safe-end DMBW examination previously performed in the fall of 2009 for the baseline examination required by 10 CFR 50.55a(g}(6)(ii)(F)(3) at ANO-2 until January 1, 2013.

All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in the subject request for relief remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.

5.0 REFERENCES

1. Pyle, S. l., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Use of Alternate ASME Code Case N-770-1 Baseline Examination, Request for Alternative AN02-ISI-007," dated November 30,2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML113340158).

2. Pyle, S. l., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding Request for Alternative AN02-ISI-007, Code Case N-770-1 Baseline Examination," dated April 13, 2012 (ADAMS Accession No. ML12104A066).

3. Pyle, S. l., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Additional Information Related to Request for Alternative AN02-ISI-007, Code Case N-770-1 Baseline Examination," dated May 21,2012 (ADAMS Accession No. ML12142A319).

4. Pyle, S. l., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Response to Second Request for Additional Information, Request for Alternative AN02*

ISI-007, Code Case N-770-1 Baseline Examination," dated September 10, 2012 (ADAMS Accession No. ML12255A388).

5. Pyle, S. l., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Transmittal of Westinghouse Calculation Note CN-MRCDA-12-27 in Support of Response for Additional Information Related to Request for Alternative AN02-ISI-007,"

dated September 10,2012 (ADAMS Accession No. ML12255A386).

6. Record of telephone conversation, "Arkansas Nuclear One, Unit 2 - Verbal Authorization of Relief Request AN02-ISI-007, Alternative to Use ASME Code Case N-770-1 Baseline

- 8 Examination, Fourth 10-Year Inservice Inspection Interval (TAC No. ME7646)," dated October 2,2012 (non-publicly available).

7. Electric Power Research Institute (EPRI), Materials Reliability Program Technical Report MRP-139 R1, "Materials Reliability Program: Primary System Piping Butt Weld Inspection and Evaluation Guideline," Final Report, December 2008 (ADAMS Accession No. ML100970671).

8. Kalyanam, K., U.S. Nuclear Regulatory Commission, electronic mail to R. Clark, Entergy Operations, Inc., "RAI for the Request to use of Alternate ASME Code Case N-770-1 Baseline Examination, Request for Alternative AN02-ISI-007. (TAC No. ME7646),"

dated August 28, 2012 (ADAMS Accession No. ML12241A296).

9. Westinghouse Electric Company LLC, Technical Report WCAP-17128 Revision 1-NP, "Flaw Evaluation of CE Design RCP Suction and Discharge Nozzle Suction and Discharge Nozzle Dissimilar Metal Welds, Phase III Study," May 2010, submitted via electronic mail from R. Clark, Entergy Operations, Inc., dated November 1, 2012 (ADAMS Accession No. ML12306A291).

Principal Contributor: Jay Wallace, NRR/DE/EPNB Date: November 27,2012

- 2 possible without modification or replacement of the subject welds and that modification of the subject welds would constitute a hardship.

Based on the enclosed safety evaluation, the NRC staff concludes that the proposed alternative will provide reasonable assurance of structural integrity and leak-tightness of the subject RCP pump DMBWs until January 1, 2013. In addition, the NRC concludes that the licensee has demonstrated that performing a Code-compliant examination will result in a hardship without a compensating increase in quality and safety. The NRC, therefore, concludes that the regulatory requirements of 10 CFR 50.55a(a)(3)(ii) have been fulfilled and recommends that the baseline examination of the subject welds be accepted until January 1, 2013.

All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in this relief request remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.

Sincerely, IRA!

Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-368

Enclosure:

As stated cc w/encl: Distribution via Listserv DISTRIBUTION:

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