ML080390223

Relief Request No. 5, Use of Performance Demonstration Initiative in Lieu of ASME Code Section XI, Appendix Viii, Supplement 11 Requirement

ML080390223
Person / Time
Site:	FitzPatrick
Issue date:	03/13/2008
From:	Mark Kowal NRC/NRR/ADRO/DORL/LPLI-1
To:	Entergy Nuclear Operations
tsw1
References
TAC MD4756
Download: ML080390223 (8)

Text

March 13, 2008 Vice President, Operations Entergy Nuclear Operations, Inc James A. FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 13093

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - RELIEF REQUEST NO. 5, USE OF PERFORMANCE DEMONSTRATION INITIATIVE IN LIEU OF ASME CODE, SECTION XI, APPENDIX VIII, SUPPLEMENT 11 REQUIREMENTS (TAC NO. MD4756)

Dear Sir or Madam:

By letter dated February 27, 2007, Entergy Nuclear Operations, Inc. (ENO), submitted Relief Request No. 5 (RR-5) for the Fourth Inservice Inspection (ISI) Interval Inspection Program Plan at the James A. FitzPatrick Nuclear Power Plant (JAFNPP). RR-5 requested relief from requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, related to the examination qualification requirements for full structural overlaid wrought austenitic piping welds. The proposed relief would implement the use of the Performance Demonstration Initiative program as an alternative to the ASME Code,Section XI, Appendix VIII, Supplement 11, requirements for ultrasonic testing examination of structural overlaid wrought austenitic welds during the JAFNPP fourth ISI 10-year interval.

The Nuclear Regulatory Commission (NRC) staff has reviewed your request as documented in the enclosed safety evaluation. Based on its review, the NRC staff concludes that the proposed alternative provides an acceptable level of quality and safety. Therefore, pursuant to Title 10 of the Code of Federal Regulations 50.55a(a)(3)(i), the proposed alternative in RR-5 is authorized for the fourth 10-year ISI Interval which ends on December 31, 2017. Although the current license for JAFNPP expires on October 17, 2014, the licensee has applied for license renewal.

If you have any questions regarding this matter, please contact Adrian Muniz at 301-415-4093.

Sincerely,

/RA/

Mark G. Kowal, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosure:

As stated cc w/encl: See next page

March 13, 2008 Vice President, Operations Entergy Nuclear Operations, Inc James A. FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 13093

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - RELIEF REQUEST NO. 5, USE OF PERFORMANCE DEMONSTRATION INITIATIVE IN LIEU OF ASME CODE, SECTION XI, APPENDIX VIII, SUPPLEMENT 11 REQUIREMENTS (TAC NO. MD4756)

Dear Sir or Madam:

By letter dated February 27, 2007, Entergy Nuclear Operations, Inc. (ENO), submitted Relief Request No. 5 (RR-5) for the Fourth Inservice Inspection (ISI) Interval Inspection Program Plan at the James A. FitzPatrick Nuclear Power Plant (JAFNPP). RR-5 requested relief from requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, related to the examination qualification requirements for full structural overlaid wrought austenitic piping welds. The proposed relief would implement the use of the Performance Demonstration Initiative program as an alternative to the ASME Code,Section XI, Appendix VIII, Supplement 11, requirements for ultrasonic testing examination of structural overlaid wrought austenitic welds during the JAFNPP fourth ISI 10-year interval.

The Nuclear Regulatory Commission (NRC) staff has reviewed your request as documented in the enclosed safety evaluation. Based on its review, the NRC staff concludes that the proposed alternative provides an acceptable level of quality and safety. Therefore, pursuant to Title 10 of the Code of Federal Regulations 50.55a(a)(3)(i), the proposed alternative in RR-5 is authorized for the fourth 10-year ISI Interval which ends on December 31, 2017. Although the current license for JAFNPP expires on October 17, 2014, the licensee has applied for license renewal.

If you have any questions regarding this matter, please contact Adrian Muniz at 301-415-4093.

Sincerely, Mark G. Kowal, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosure:

As stated cc w/encl: See next page Distribution:

PUBLIC RidsNrrLASLittle RidsNrrPMAMuniz DTarantino LPL 1-1 Reading RidsNrrDciCpnb RidsNrrPMJBoska RidsOGCMailCenter RidsAcrsAcnw&mMailCenter RidsNrrDorlLpla Accession Number: ML080390223 OFFICE LPL3-1\PM LPL1-1/PM LPL1-1\LA CPNB/BC OGC LPL1-1\BC NAME AMuniz JBoska SLittle TChan JAdler, NLO MKowal DATE 3/5/08 3/5/08 2/13/08 3/3/08 3/10/08 3/13/08 Official Record Copy

FitzPatrick Nuclear Power Plant New York, NY 10271 cc: Mr. Paul Tonko President and CEO Senior Vice President New York State Energy, Research, and Entergy Nuclear Operations, Inc. Development Authority P.O. Box 31995 17 Columbia Circle Jackson, MS 39286-1995 Albany, NY 12203-6399 Vice President Oversight Mr. John P. Spath Entergy Nuclear Operations, Inc. New York State Energy, Research, P.O. Box 31995 and Development Authority Jackson, MS 39286-1995 17 Columbia Circle/

Albany, NY 12203-6399 Senior Manager, Nuclear Safety & Licensing Entergy Nuclear Operations, Inc. Mr. Paul Eddy P.O. Box 31995 New York State Dept. of Public Service Jackson, MS 39286-1995 3 Empire State Plaza Albany, NY 12223-1350 Senior Vice President and COO Entergy Nuclear Operations, Inc. Oswego County Administrator 440 Hamilton Avenue Mr. Steven Lyman White Plains, NY 10601 46 East Bridge Street Oswego, NY 13126 Assistant General Counsel Entergy Nuclear Operations, Inc. Supervisor 440 Hamilton Avenue Town of Scriba White Plains, NY 10601 Route 8, Box 382 Oswego, NY 13126 Manager, Licensing Entergy Nuclear Operations, Inc. Mr. James H. Sniezek James A. FitzPatrick Nuclear Power Plant BWR SRC Consultant P.O. Box 110 5486 Nithsdale Drive Lycoming, NY 13093 Salisbury, MD 21801-2490 Regional Administrator, Region I Mr. Michael D. Lyster U.S. Nuclear Regulatory Commission BWR SRC Consultant 475 Allendale Road 5931 Barclay Lane King of Prussia, PA 19406 Naples, FL 34110-7306 Resident Inspector's Office Mr. John Doering James A. FitzPatrick Nuclear Power Plant BWR SRC Consultant U. S. Nuclear Regulatory Commission P.O. Box 189 P.O. Box 136 Parker Ford, PA 19457 Lycoming, NY 13093 Mr. Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO RELIEF REQUEST NO. 5 FOR THE FOURTH 10-YEAR INTERVAL OF THE INSERVICE INSPECTION PROGRAM ENTERGY NUCLEAR OPERATIONS, INC.

JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333

1.0 INTRODUCTION

By letter dated February 27, 2007, Entergy Nuclear Operations, Inc. (ENO), submitted Relief Request No. 5 (RR-5) for the Fourth Inservice Inspection (ISI) Interval Inspection Program Plan at the James A. FitzPatrick Nuclear Power Plant (JAFNPP). ENO requested relief from requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, related to the qualification for full structural overlaid wrought austenitic piping welds. The proposed relief would implement the use of the Performance Demonstration Initiative (PDI) Program as an alternative to the ASME Code,Section XI, Appendix VIII, Supplement 11, requirements for ultrasonic testing examination of structural overlaid wrought austenitic welds during the JAFNPP fourth ISI 10-year interval.

2.0 REGULATORY REQUIREMENTS Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) must meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code,Section XI, Rules for ISI of Nuclear Power Plant Components, to the extent practical within the limitations of design, geometry, and materials of construction of the components.

The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The ASME Code of record for the current, fourth 10-year ISI interval at JAFNPP is the 2001 Edition with 2003 Addenda.

In accordance with 10 CFR 50.55a(g)(6)(ii)(C), the implementation of Supplements 1 through 8, 10 and 11 of Appendix VIII to Section XI, 1995 Edition with the 1996 Addenda of the ASME Code is required on a phased schedule ending on November 22, 2002. In accordance with this provision, JAFNP will implement the 1995 Edition with the 1996 Addenda of Supplement 11 as modified by this relief request.

Pursuant to 10 CFR 50.55a(a)(3), alternatives to requirements may be authorized by the Nuclear Regulatory Commission (NRC) if the licensee demonstrates that: (i) the proposed alternatives 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.

3.0 TECHNICAL EVALUATION

3.1 System/Components Affected JAFNPP Class 1 affected system/components are provided in the following table.

JAMES A. FITZPATRICK CLASS 1 SYSTEM/COMPONENTS REFERENCE EXAMINATION CATEGORY DESCRIPTION Pressure Retaining Welds in piping PDI Program shall be used in lieu of ASME Code, subject to examination using ASME Code,Section XI, Appendix VIII,Section XI, procedures, personnel and Supplement 11, Qualification Appendix VIII, equipment qualified to ASME Code, Requirements for Full Structural Supplement 11 Section XI, Appendix VIII, Overlaid Wrought Austenitic Piping Supplement 11. Welds.

3.2 Applicable Code Requirement, Edition and Addenda ASME Code,Section XI, Appendix VIII, Supplement 11 of the 1995 Edition with 1996 Addenda.

The ASME Code requirements for which relief is requested are provided in Table 1, Appendix VIII Supplement 11 Requirements vs. PDI Program Requirements of the licensee submittal.

3.3 Reason for Request Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested to use the PDI Program for implementation of Appendix VIII, Supplement 11, requirements.

3.4 Proposed Alternatives and Basis Paragraph 1.1(d)(1) of the ASME Code,Section XI, Appendix VIII, Supplement 11, requires that all base metal flaws be cracks. ENO states that implanting a crack requires excavation of the base material on at least one side of the flaw (see illustration in RR-5) and while this may be satisfactory for ferritic materials, it does not produce a usable axial flaw in austenitic materials.

An unrealistic flaw response is produced because the sound beam, which normally passes through base material only, must now travel through weld material on at least one side.

The PDI program modified this paragraph to allow use of alternative flaw mechanisms under controlled conditions as follows: 1) alternative flaws shall be limited to when implantation of cracks precludes obtaining an effective ultrasonic response, 2) flaws shall be semielliptical with a tip width of less than or equal to 0.002-inch and 3) at least 70 percent of the flaws in the detection and sizing test shall be cracks and the remainder shall be alternative flaws.

Furthermore, paragraph 1.1(d)(1) includes the statement that intentional overlay fabrication flaws shall not interfere with ultrasonic detection or characterization of the base metal flaws.

ENO requested to allow closer spacing of flaws provided they did not interfere with ultrasonic detection or discrimination. The existing specimens used to-date for qualification to the Tri-party (NRC/Boiling Water Reactor Owners Group/Electric Power Research Institute) agreement have a flaw population density greater than allowed by the current ASME Code,Section XI, Appendix VIII, Supplement 11 requirements and have been used successfully for all previous qualifications under the Tri-party agreement program. The PDI program has merged the Tri-party test specimens into the PDI weld overlay program, in order to facilitate the Tri-party test specimen use and provide continuity.

ENO states that the ASME Code,Section XI, IWA-3300 requirement for proximity flaw evaluation in paragraph 1.1(e)(1) of Section XI, Appendix VIII, Supplement 11, was excluded from the PDI Program as indications will now be evaluated/sized based on individual values.

Paragraph 1.1(e)(2)(a)(1) was modified to require that a base metal grading unit include at least 1 inch of the length of the overlaid weld, in lieu of 3 inches. In addition, the phrase . . .and base metal on both sides. . ., was omitted since some of the qualification specimens include flaws on both sides of the weld.

Paragraph 1.1(e)(2)(a)(3) was modified to require sufficient unflawed overlaid weld and base metal to exist on all sides of the grading unit to preclude interfering reflections from adjacent flaws, rather than the 1-inch requirement of Appendix VIII, Supplement 11.

Paragraph 1.1(e)(2)(b)(1) was modified to define an overlay fabrication grading unit as including the overlay material and the base metal-to-overlay interface for a length of at least 1 inch, rather than for 6-square inches and rectangular with minimum dimensions of 2 inches as stated in Appendix VIII, Supplement 11.

Paragraph 1.1(e)(2)(b)(2) was modified to state that overlay fabrication grading units designed to be unflawed shall be separated by unflawed overlay material and unflawed base metal-to-overlay interface for at least 1 inch at both ends, rather than around its entire perimeter.

Paragraph 3.2(b) requirement for reporting all extensions of cracking into the overlay is omitted from the PDI Program because it is redundant to the root mean square (RMS) calculations performed in paragraph 3.2(c) and its presence adds confusion and ambiguity to depth sizing as required by paragraph 3.2(c). This also makes the weld overlay program consistent with the depth sizing criteria of ASME Code,Section XI, Appendix VIII, Supplement 2.

Additional proposed alternatives to the ASME Code,Section XI, Appendix VIII, Supplement 11 were requested by the licensee and are included in Table 1, Appendix VIII Supplement 11 Requirements vs. PDI Program Requirements of the licensee submittal.

3.5 Duration Relief is requested for the fourth 10-year interval of the JAFNPP Inservice Inspection Program, March 1, 2007 through December 31, 2017. The current JAFNPP operating license expires on October 17, 2014. ENO has applied to the NRC for license renewal.

3.6 NRC Staff Evaluation ENO proposed to use the PDI program as an alternative to the requirements of ASME Code,Section XI, Appendix VIII, Supplement 11, Qualification Requirements for Full Structural Overlaid Wrought Austenitic Piping Welds. ENO stated that to avoid confusion, several instances of the term "cracks" or "cracking" were changed to the term "flaws" because of the use of alternative flaw mechanisms. Further, to avoid confusion, the overlay thickness tolerance contained in paragraph 1.1(b) last sentence, was reworded and the phrase "and the remainder shall be alternative flaws" was added to the next to last sentence in paragraph 1.1(d)(1). ENO stated that various additional editorial changes were made to the PDI program.

PARAGRAPH 1.1(d)(1):

ENO determined that certain ASME Code,Section XI, Appendix VIII, Supplement 11 requirements applicable to location and size of cracks would be exceptionally difficult to achieve.

The PDI program developed a process for fabricating flaws that exhibit crack-like reflective characteristics in an effort to satisfy the Supplement 11 requirements. The PDI program weld overlay performance demonstrations contain at least 70 percent cracks with the remainder being fabricated or alternative flaws exhibiting crack-like reflective characteristics in lieu of all flaws being cracks, as required by Paragraph 1.1(d)(1).

The NRC staff has reviewed the flaw fabrication process, compared the reflective characteristics between cracks and fabricated flaws and found the fabricated flaws in the PDI program to be acceptable for this application.

PARAGRAPH 1.1(e)(1):

The PDI program modifies the Appendix VIII, Supplement 11 requirement as follows: The ASME Code requirements for flaw characterization,Section XI, IWA-3300, were excluded.

The ASME Code requirement for flaw characterization was used in part to determine whether closely spaced flaws should be treated as single or multiple flaws. ENO requested to allow closer spacing of flaws provided they did not interfere with ultrasonic detection or discrimination and that alternative indications will be sized based on their individual merits.

The PDI program treats each flaw as an individual flaw and not as part of a system of closely spaced flaws. In addition, the proposed PDI program controls the flaws going into a test specimen set such that the flaws are free of interfering reflections from adjacent flaws and in some cases, would permit flaws to be closer together than what is permitted by ASME Code requirements, thus producing a more demanding performance demonstration. The NRC staff finds that the proposed PDI application of flaw location (angle orientation) and proximity (closely spaced flaws) is more conservative than Appendix VIII, Supplement 11, and, therefore, is acceptable.

PARAGRAPH 1.1(e)(2)(a)(1):

The PDI program modified the ASME Code,Section XI, Appendix VIII, Supplement 11 requirement as follows: 1) specified base metal grading unit, 2) reduced the base metal grading unit length of the overlaid weld to at least 1 inch extending circumferentially, and 3) defined the base metal grading unit width as starting from the weld centerline and wide enough in the axial direction to encompass one half of the original weld crown with a minimum of 0.50-inch of adjacent base material.

The test specimens from the existing Appendix VIII, Supplement 11, weld overlay program have flaws on both sides of the welds which prevents them from satisfying the PDI Program base grading unit requirements. ENO stated that the PDI Program has merged the Tri-party (NRC/BWROG/EPRI) agreement program test specimens into their weld overlay program and these test specimens have been used successfully for testing the proficiency of all previous qualifications.

The NRC staff finds that the PDI program contains a more arduous test because the individual must locate the flaw on the applicable side of the weld; therefore, the PDI program modifications of base metal grading unit length and width are acceptable.

PARAGRAPH 1.1(e)(2)(a)(3):

The PDI program modified the ASME Code,Section XI, Appendix VIII, Supplement 11 requirement to allow for sufficient unflawed overlaid weld and base metal to exist on all sides of the base metal grading unit to preclude interfering reflections from neighboring flaws. The NRC staff notes this modification would minimize the number of false identifications from extraneous reflectors, which effectively addresses the same concerns as Appendix VIII, Supplement 11.

Therefore, the NRC staff finds that the PDI Program application of the variable flaw free area adjacent to the base metal grading unit is acceptable.

PARAGRAPH 1.1(e)(2)(b)(1):

The ASME Code requires that an overlay grading unit shall include the overlay material and the base metal-to-overlay interface of at least 6 square inches. The overlay grading unit shall be rectangular, with minimum dimensions of 2 inches. The PDI program reduces the base metal-to-overlay interface to at least 1 inch (in lieu of a minimum of 2 inches) and eliminates the minimum rectangular dimension. This criterion is more challenging than the Code because of the variability associated with the shape of the grading unit. Hence, the proposed PDIs application of the grading unit is acceptable.

PARAGRAPH 1.1(e)(2)(b)(2):

The PDI program modified the ASME Code,Section XI, Appendix VIII, Supplement 11 requirement to require that overlay fabrication grading units shall be separated by unflawed overlay material and unflawed base metal-to-overlay interface for at least 1 inch at both ends with sufficient unflawed overlaid weld and base metal on both sides of the overlay fabrication grading unit to preclude interfering reflections from nearby flaws. ENO stated that these test specimens have been used successfully for all previous qualifications under the Tri-party agreement program.

The NRC staff notes that the PDI application is more conservative, has merged the Tri-party test specimens into ENOs weld overlay program, and that the test specimens have been demonstrated service proven. Therefore, the NRC staff finds the PDI application for fabrication grading units acceptable.

PARAGRAPH 1.1(e)(2)(b)(3)

Paragraph 1.1(e)(2)(b)(3) requirements are retained in the PDI program. In addition, the PDI program requires that initial procedure qualification contain three times the number of flaws required for a personnel qualification. To qualify new values of essential variables, the equivalent of at least one personnel qualification set is required. The NRC staff concludes that PDIs additions enhance the ASME Code requirements and are, therefore, acceptable because it provides for a more stringent qualification criteria.

PARAGRAPH 1.1(e)(2)(f)(1)

Paragraph 1.1(f)(1) requirements are retained in the PDI program, with the clarification change of the term flaws for cracks. In addition, the PDI program includes the requirements that sizing sets shall contain a distribution of flaw dimensions to verify sizing capabilities. The PDI program also requires that initial procedure qualification contain three times the number of flaws required for a personnel qualification. To qualify new values of essential variables, the equivalent of at least one personnel qualification set is required. The NRC staff concludes that PDIs additions enhance the ASME Code requirements and are, therefore, acceptable because it provides a more stringent qualification criteria.

PARAGRAPH 2.0 Paragraph 2.0, Conduct of Performance Demonstration, in ASME Code Supplement 11 is clarified in PDI by the addition of the sentence, [T]he overlay fabrication flaw test and the base metal flaw test may be performed separately. The staff concludes that the PDI program did not change the intent of the ASME Code but provided additional clarification. Therefore, this alternative in PDI is acceptable.

PARAGRAPH 2.3 Paragraph 2.3 requires that, for depth sizing tests, 80 percent of the flaws shall be sized at a specific location on the surface of the specimen identified to the candidate. This requires detection and sizing tests to be performed separately. The PDI revised the weld overlay program to allow sizing to be conducted either in conjunction with, or separately from, the flaw detection test. If performed in conjunction with detection and the detected flaws do not meet the ASME Code,Section XI, Appendix VIII, Supplement 11 range criteria, additional specimens will be presented to the candidate with the regions containing flaws identified. Each candidate will be required to determine the maximum depth of flaw in each region. For separate sizing tests, the regions of interest will also be identified and the maximum depth and length of each flaw in the region will similarly be determined. The NRC staff determined that the above clarification provides a basis for implementing sizing tests in a systematic, consistent manner that meets the intent of ASME Code,Section XI, Appendix VIII, Supplement 11. Therefore, the NRC staff concludes that the PDIs method is acceptable.

PARAGRAPH 3.1 Paragraph 3.1 requires that examination procedures, equipment and personnel (as a complete ultrasonic system) are qualified for detection or sizing of flaws, as applicable, when certain criteria are met. The PDI program allows procedure qualification to be performed separately from personnel and equipment qualification. Historical data indicate that, if ultrasonic detection or sizing procedures are thoroughly tested, personnel and equipment using those procedures have a higher probability of successfully passing a qualification test. In an effort to increase this passing rate, PDI has elected to perform procedure qualifications separately in order to assess and modify essential variables that may affect overall system capabilities. For a procedure to be qualified, the PDI program requires that:

1) All flaws within the scope of the procedure are detected and the results of the performance demonstration satisfy the acceptance criteria of Table VIII-S2-1 for false calls.

a) At least one successful personnel demonstration has been performed meeting the acceptance criteria defined in (b).

b) Examination equipment and personnel are qualified for detection when the results of the performance demonstration satisfy the acceptance criteria of Table VIII-S2-1 for both detection and false calls.

c) The criteria in (a), (b) shall be satisfied separately by the demonstration results for base metal grading units and for overlay fabrication grading units.

The personnel and equipment are still required to meet the Supplement 11 requirement.

Therefore, the PDI program criteria exceeds the ASME Code requirements for personnel, procedures, and equipment qualification. The NRC staff concludes that the PDI program criteria is acceptable.

PARAGRAPH 3.2(b):

The ASME Code,Section XI, Appendix VIII, Supplement 11 requires that all extensions of base metal cracking into the overlay material by at least 0.1 inch be reported as intrusions into the overlay material. The PDI program eliminated this requirement for reasons explained below.

The PDI program requires that cracks be sized to the tolerance specified in Appendix VIII, Supplement 11, which is less than or equal to 0.125 inch. In addition, since the PDI Program tolerance is less than or equal to 0.125 inch, any crack extending much beyond 0.1 inch into the overlay material would be identified from its dimensions and that the reporting of an extension in the overlay material is redundant for performance demonstration testing. Therefore, the NRC staff finds that the PDI Program elimination of reporting a crack extending 0.1 inch into the overlay material is acceptable.

4.0 CONCLUSION

The NRC staff has reviewed ENOs submittal and determined that the proposed alternative PDI program will provide an acceptable level of quality and safety. ENO proposed modifications/changes to the ASME Code,Section XI, Appendix VIII, Supplement 11, implemented through the PDI Program as an alternative to the Supplement 11 qualification requirements for UT examination of structural overlaid wrought austenitic welds. Therefore,

pursuant to 10 CFR 50.55a(a)(3)(i), the proposed alternative is authorized for the fourth 10-year ISI Interval which ends on December 31, 2017. Although the current license for JAFNPP expires on October 17, 2014, the licensee has applied for license renewal.

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.

Principal Contributor: D. Tarantino Date: March 13, 2008