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| The NRC staff will proceed with completion of the written safety evaluation for RR-12. The staff may ask additional clarification questions to complete its written safety evaluation, if necessary. | | The NRC staff will proceed with completion of the written safety evaluation for RR-12. The staff may ask additional clarification questions to complete its written safety evaluation, if necessary. |
| The written safety evaluation should be issued within 150 days in accordance with the Office of Nuclear Reactor Regulation office instructions. | | The written safety evaluation should be issued within 150 days in accordance with the Office of Nuclear Reactor Regulation office instructions. |
| NRC Participants: | | NRC |
| M. Markley, NRR/DORL/LPL4, Branch Chief T. Lupold, NRR/DCI/CPNB, Branch Chief J. Collins, NRR/DCI/CPNB, Senior Materials Engineer B. Singal, NRR/DORL/LPL4, Project Manager L. Wilkins, NRR/DORL/LPL4, Project Manager Licensee Participants: | | |
| | ==Participants:== |
| | M. Markley, NRR/DORL/LPL4, Branch Chief T. Lupold, NRR/DCI/CPNB, Branch Chief J. Collins, NRR/DCI/CPNB, Senior Materials Engineer B. Singal, NRR/DORL/LPL4, Project Manager L. Wilkins, NRR/DORL/LPL4, Project Manager Licensee |
| | |
| | ==Participants:== |
| J. Herman, Division Manager - Nuclear Engineering B. Hansher, Supervisor - Nuclear Licensing B. Lisowyj, Project Manager - Materials J. Brandeau, Project Manager - Nuclear Projects M. Edwards, Nuclear Licensing Engineer Docket No. 50-285 | | J. Herman, Division Manager - Nuclear Engineering B. Hansher, Supervisor - Nuclear Licensing B. Lisowyj, Project Manager - Materials J. Brandeau, Project Manager - Nuclear Projects M. Edwards, Nuclear Licensing Engineer Docket No. 50-285 |
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MONTHYEARML1023006412010-08-16016 August 2010 10 CFR 50.55a Request Number RR-12, Request for Relief from Code Case N-722 Visual Examination of the Reactor Vessel Hot Leg Nozzle to Safe End Dissimilar Metal Welds Project stage: Request ML1026500132010-09-21021 September 2010 Acceptance Review E-mail, Relief Request RR-12, from Requirements of ASME Code Case N-722 Visual Examination of Reactor Vessel Hot-Leg Nozzle to Safe End Dissimilar Metal Welds for 4th 10-Year Inservice Inspection Interval (ME4541) Project stage: Acceptance Review ML1027801882010-10-0404 October 2010 Email, Draft Request for Additional Information, Relief Request RR-12, from Requirements of ASME Code Case N-722 for Fourth 10-Year Inservice Inspection Interval (ME4541) Project stage: Draft RAI ML1027801902010-10-0404 October 2010 Draft Request for Additional Information, Relief Request RR-12, from Requirements of ASME Code Case N-722 for Fourth 10-Year Inservice Inspection Interval (ME4541) Project stage: Draft RAI ML1028600872010-10-25025 October 2010 Request for Additional Information, Relief Request RR-12 from ASME Code Case N-722 Visual Examination Requirements for 4th 10-Year Inservice Inspection Interval Project stage: RAI ML1029101312010-10-25025 October 2010 Request for Withholding Information from Public Disclosure, 7/30/10 Affidavit Executed by J. Gresham, Westinghouse Project stage: Withholding Request Acceptance LIC-10-0095, Response to Request for Additional Information (RAI) Regarding Relief from ASME Code Case N-722 Requirements for Visual Examination of Reactor Vessel Hot Leg Nozzle to Safe End Welds2010-11-0404 November 2010 Response to Request for Additional Information (RAI) Regarding Relief from ASME Code Case N-722 Requirements for Visual Examination of Reactor Vessel Hot Leg Nozzle to Safe End Welds Project stage: Response to RAI ML1102001932011-01-14014 January 2011 Withdrawal of Response to Request for Additional Information (RAI) Regarding Request for Relief from ASME Code Case N-722 Requirements for Visual Examination of Reactor Vessel Hot Leg Nozzle-to-Safe End Dissimilar Metal Butt Welds Project stage: Withdrawal ML1104705872011-02-16016 February 2011 Request for Additional Information LAR to Revise Technical Specification to Relocate Operating and Surveillance Requirements for the Power Operated Relief Valve Project stage: RAI ML1104705882011-02-16016 February 2011 Request for Additional Information Project stage: RAI ML1105404412011-02-23023 February 2011 Request for Additional Information, Round 2, Relief Request RR-12 from ASME Code Case N-722 Visual Examination Requirements for 4th 10-Year Inservice Inspection Interval Project stage: RAI ML1105404492011-02-23023 February 2011 Request for Additional Information, Round 2, Relief Request RR-12 from ASME Code Case N-722 Visual Examination Requirements for 4th 10-Year Inservice Inspection Interval Project stage: RAI ML1106102172011-03-0303 March 2011 Request for Additional Information, Round 2, Relief Request RR-12 from ASME Code Case N-722 Visual Examination Requirements for 4th 10-Year Inservice Inspection Interval Project stage: RAI LIC-11-0016, Response to Second NRC Request for Additional Information (RAI) Regarding Request for Relief from ASME Code Case N-722 Requirements for Visual Examination of Reactor Vessel Hot Leg Nozzle-to-Safe End Dissimilar Metal Butt Welds2011-03-0404 March 2011 Response to Second NRC Request for Additional Information (RAI) Regarding Request for Relief from ASME Code Case N-722 Requirements for Visual Examination of Reactor Vessel Hot Leg Nozzle-to-Safe End Dissimilar Metal Butt Welds Project stage: Request ML1109103272011-04-0505 April 2011 Verbal Authorization, Request for Relief from Code Case N-722 Visual Examination of the Reactor Vessel Hot-Leg Nozzle-to-Safe-End Dissimilar Metal Welds, 4th 10-Year Inservice Inspection Interval Project stage: Other ML1108309472011-05-17017 May 2011 Request for Withholding Information from Public Disclosure, Affidavit Dated 7/30/10, Executed by J. Gresham, Westinghouse, Report LTR-PAFM-10-123-P, Revision 0 Project stage: Withholding Request Acceptance ML1122702902011-08-18018 August 2011 Relief Request RR-12 from Code Case N-722, Additional Examinations for PWR Pressure Retaining Welds in Class 1 Components Fabricated with Alloy 600/82/182 Materials, Fourth 10-Year Inservice Inspection Interval Project stage: Other LIC-12-0004, Delay 2012 Refueling Outage and Extend In-service Inspection (ISI) and In-service Test (IST) Intervals2012-01-17017 January 2012 Delay 2012 Refueling Outage and Extend In-service Inspection (ISI) and In-service Test (IST) Intervals Project stage: Other 2011-02-16
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Category:Memoranda
MONTHYEARML24107B1272024-04-22022 April 2024 Ft. Calhoun Meeting Summary of March 27, 2024 Meeting with Omaha Public Power District on Submittal of Phase 1 Final Status Surveys ML22333B0922022-12-21021 December 2022 FY22 Nmss/Duwp Operating Experience Report ML21271A5992021-08-0303 August 2021 License Amendment Request (LAR) 21-01, Chapter 8, 12, Omaha Public Power District, FCS-SAF-103, FCS Deconstruction Health and Safety Plan CAC2 ML21055A4022021-05-14014 May 2021 Memorandum: Final Environmental Assessment and Finding of No Significant Impact of Initial and Updated Decommissioning Funding Plans for the Cooper, Fort Calhoun and Virgil C. Summer Independent Spent Fuel Storage Installations ML21271A1492021-04-13013 April 2021 License Amendment Request (LAR) 21-01, Chapter 1 9 Haley & Aldrich, Inc. Memorandum to Energysolutions, File No. 0127960-006, Fort Calhoun Nuclear Power Statio~1 ML20056E4872020-02-26026 February 2020 Staff Review of Fort Calhoun Independent Spent Fuel Storage Installation Physical Security Plan, Security Training and Qualification Plan, and Safeguard Contingency Plan, Revision 0 and the Verification of Additional Security Measures (ASM) ML18173A0082018-06-20020 June 2018 Cancelling Numerous Inspection Report Numbers ML18108A1212018-04-11011 April 2018 American Nuclear Insurers - Notification of Change in the Number of Power Reactors in the Secondary Financial Protection (SFP) Program ML17275A2642017-11-21021 November 2017 Safety Evaluation Input on Fort Calhoun Station Request for Approval of Permanently Defueled Emergency Plan and Emergency Action Level Scheme, Docket No. 50-285 ML16057A1232016-02-26026 February 2016 Cy 2015 Baseline Completion ML16007A4942016-01-11011 January 2016 Review of the Updated Final Safety Analysis Report for the Period June 14, 2014 Through December 4, 2015 ML14163A0022014-06-16016 June 2014 Summary of Audit Conducted March 5-9, 2012, Request to Adopt National Fire Protection Association (NFPA) 805, Performance-Based Standard for Fire Protection for LWR Electric Generating Plants ML14129A4452014-05-12012 May 2014 5/13/2014 Notice of Forthcoming Closed Meeting to Discuss Dam Failure Analysis for Cooper Nuclear Station and Fort Calhoun Station, Unit 1 ML14114A7012014-04-24024 April 2014 Task Interface Agreement - Concurrence on Fort Calhoun Tornado Missile Protection Licensing Basis (TIA 2013-07) ML14085A1842014-03-28028 March 2014 Final Fort Calhoun Gothic TIA Response ML14016A2602014-01-28028 January 2014 Fc Final Containment Structural TIA ML13351A4762013-12-16016 December 2013 Recommendation for NRC to Close Confirmatory Action Letter EA-13-020 Supporting the Restart of Fort Calhoun Station and Recommendation to Issue Post-Restart Confirmatory Action Letter ML13346A0822013-12-12012 December 2013 Notice of Forthcoming Closed Meeting to Discuss Dam Failure Analysis for Cooper Nuclear Station and Fort Calhoun Station, Unit 1 ML13312A8522013-11-0808 November 2013 Meeting Notice with Public to Discuss Fort Calhoun Station ML13253A3542013-09-27027 September 2013 Letter to R. Morris Information Exchange Pertaining to Health Issues Related to Crow Butte Resources Uranium Mine and Ft. Calhoun Nuclear Generating Station ML13102A1892013-04-15015 April 2013 4/22/12 Notice of Closed Meeting with Omaha Public Power District to Discuss Flooding Issues Associated with Fort Calhoun, Unit 1 ML13101A2232013-04-11011 April 2013 Meeting Notice with Omaha Public Power District - Potential License Amendment Requests for Fort Calhoun, Unit 1 Related to Flood Protection for Raw Water System, Tornado Missile Protection, Piping/Code Use, and Alternate Seismic Criteria ML13066A8772013-03-0707 March 2013 Issuance of Revised U.S. Nuclear Regulatory Commission Manual Chapter 0350 Panel Fort Calhoun Station Restart Checklist Basis Document ML13046A3212013-02-19019 February 2013 Notice of Closed Meeting with Fort Calhoun to Discuss Safeguards Information, Proprietary, or Other Sensitive Information ML12345A2702012-11-30030 November 2012 Revised 12/12/2012 Notice of Forthcoming Meeting with Omaha Public Power District to Discuss Containment Internal Structures Issues to Support Restart of Fort Calhoun Station, Unit 1 ML12335A1652012-11-30030 November 2012 Forthcoming Meeting with Omaha Public Power District to Discuss Containment Internal Structures Issues to Support Restart of Fort Calhoun Station, Unit 1 ML12318A3192012-11-13013 November 2012 Issuance of U.S. Nuclear Regulatory Commission Manual Chapter 0350 Panel Fort Calhoun Station Restart Checklist Basis Document ML12251A3172012-09-0707 September 2012 Manual Chapter 0350 Oversight Panel Charter - Revision ML12066A0302012-03-29029 March 2012 Closure Memorandum: Issue for Resolution 2011-001 Fort Calhoun - Failure to Maintain External Flooding Procedures. ML12229A1842012-03-0606 March 2012 Backfit Panel Regarding Fort Calhoun Flooding ML1134707162011-12-13013 December 2011 Memo to M.S.Virgilio Notification of Change to Regulatory Oversight of Fort Calhoun Station ML11293A1982011-10-19019 October 2011 Charter for Backfit Panel on Postulated Failure of Upstream Dams Affecting Fort Calhoun Station ML1118811312011-07-0707 July 2011 Docketing of Nonproprietary Information Provided by Omaha Public Power District (OPPD) Personnel Following the June 2, 2011, Regulatory Conference ML13106A1702011-07-0101 July 2011 Proposed Adequate Protection Backfit Exception ML11174A2322011-06-21021 June 2011 for the Record-06-21-2011: NRC Ensures Public Safety Through Rigorous Oversight of Nuclear Power Plant Safety Standards ML1113807322011-05-18018 May 2011 Regulatory Conference with Omaha Public Power ML1113306432011-05-16016 May 2011 Notice of Forthcoming Prelicensing Teleconference on 5/26/11 with Omaha Public Power District Related to Fort Calhoun Station, Unit 1's License Amendment Submittal Related to Transition to Risk-Informed NFPA-805 ML1109103272011-04-0505 April 2011 Verbal Authorization, Request for Relief from Code Case N-722 Visual Examination of the Reactor Vessel Hot-Leg Nozzle-to-Safe-End Dissimilar Metal Welds, 4th 10-Year Inservice Inspection Interval ML1108106952011-03-23023 March 2011 Notice of Forthcoming Pre-Licensing Meeting with Omaha Public Power District to Discuss Its Plans to Submit an Extended Power Uprate for Fort Calhoun Station and Issues Related to Equipment Environmental Qualification ML1104808672011-02-18018 February 2011 03/2/2011 Notice of Forthcoming Closed Pre-Licensing Teleconference with Omaha Public Power District to Discuss Its Plans to Submit an Extended Power Uprate for Fort Calhoun Station and Issues Related to Control Rod Withdrawal at Power ML1035605482010-12-23023 December 2010 Notice of Forthcoming Pre-Licensing Meeting with Omaha Public Power District to Discuss Fort Calhoun Station'S Extended Power Uprate, Spent Fuel Pool Criticality, and Proposed License Amendment Request Modeled After TSTF-493 ML1020701262010-08-30030 August 2010 the Nuclear Regulatory Commission Staff Spot-Check Review of Fort Calhoun Station Unit 1, June 30, 2010 - Finding of No Potential Issues in Bank Statements ML1016205062010-06-14014 June 2010 Notice of Forthcoming Teleconference Meeting with Omaha Public Power District to Discuss NRC Staff Request for Additional Information Dated 2/12/2010 on Generic Letter 2004-02 for Fort Calhoun Station, Unit 1 ML1006010322010-03-0101 March 2010 Cy 2009 Baseline Inspection Completion ML1004302742010-02-12012 February 2010 Notice of Forthcoming Teleconference with Omaha Public Power District to Discuss NRC Staff Request for Additional Information on Generic Letter 2004-02 for Fort Calhoun Station, Unit 1 ML0909607752009-04-0606 April 2009 Notice of End-of-Cycle Meeting with Omaha Public Power District - Fort Calhoun Station to Present and Discuss the Performance Results for the Fort Calhoun Station for the Period of January 1 Though December 31, 2008 ML0901504382009-01-16016 January 2009 Notice of Forthcoming Meeting with Omaha Public Power District, to Discuss Oppd'S Plans to Submit an Extended Power Uprate Request for the Fort Calhoun Station, Unit 1 ML0901603362009-01-16016 January 2009 Notice of Forthcoming Meeting with Omaha Public Power District, to Discuss the Fort Calhoun Station'S Transition to National Fire Protection Association (NFPA) 805 ML0814100052008-06-0303 June 2008 Summary of Conference Call with Omaha Public Power District (OPPD) Regarding OPPD Emergency Relief Request Submitted May 15, 2008 for Fort Calhoun Station (Tac No. MD8722) ML0809404512008-04-18018 April 2008 Summary of 12/6/2006 Meeting with Omaha Public Power District, Regarding Water Management Strategies for Resolution of GSI-191 (Tac No MD5780) 2024-04-22
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April 5, 2011 MEMORANDUM TO: Docket File FROM: Lynnea Wilkins, Project Manager /RA/
Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
FORT CALHOUN STATION, UNIT NO. 1 -
SUMMARY
OF CONFERENCE CALL ON MARCH 30, 2011, RE: VERBAL AUTHORIZATION OF RELIEF REQUEST RR-12 FROM CODE CASE N-722 VISUAL EXAMINATION (VE) OF THE REACTOR VESSEL HOT LEG NOZZLE TO SAFE END DISSIMILAR METAL WELDS (TAC NO. ME4541)
By letter dated August 16, 2010, as supplemented by letters dated January 14 and March 4, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML102300679, ML110200205, and ML110670226, respectively), Omaha Public Power District (OPPD, the licensee), requested approval by the U.S. Nuclear Regulatory Commission (NRC) of Relief Request Number RR-12, Request for Relief from Code Case N-722 Visual Examination (VE) of the Reactor Vessel Hot Leg Nozzle to Safe End Dissimilar Metal Welds, for Fort Calhoun Station, Unit 1 (FCS). Pursuant to paragraph 50.55a(a)(3)(i) of Title 10 of the Code of Federal Regulations (10 CFR), OPPD requested NRC approval of an alternative to the visual examination requirements of American Society of Mechanical Engineers (ASME) Code,Section XI, Code Case N-722, Additional Examinations for PWR Pressure Retaining Welds in Class 1 Components Fabricated With Alloy 600/82/182 Materials,Section XI, Division 1.
The licensee requested relief from the 10 CFR 50.55a(g)(6)(ii)(E) requirement to perform a bare metal visual inspection of reactor pressure vessel outlet nozzle to safe end dissimilar metal welds in accordance with ASME Code Case N-722. OPPD requested this relief for the spring 2011 and fall 2012 refueling outages at FCS. The NRC staff found that analyses submitted by the licensee may not support the full 51 calendar months requested under RR-12.
However, the analysis does support relief during the spring 2011 refueling outage for one operating cycle.
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), and is in compliance with the Code requirements. Therefore, in accordance with 10 CFR 50.55a(a)(3)(ii), the NRC staff authorizes the licensees proposed alternative, RR-12 at FCS for the spring 2011 refueling outage, as discussed during a conference call with the licensee on March 30, 2011. A summary of the verbal authorization is enclosed.
The NRC staff will proceed with completion of the written safety evaluation for RR-12. The staff may ask additional clarification questions to complete its written safety evaluation, if necessary.
The written safety evaluation should be issued within 150 days in accordance with the Office of Nuclear Reactor Regulation office instructions.
NRC
Participants:
M. Markley, NRR/DORL/LPL4, Branch Chief T. Lupold, NRR/DCI/CPNB, Branch Chief J. Collins, NRR/DCI/CPNB, Senior Materials Engineer B. Singal, NRR/DORL/LPL4, Project Manager L. Wilkins, NRR/DORL/LPL4, Project Manager Licensee
Participants:
J. Herman, Division Manager - Nuclear Engineering B. Hansher, Supervisor - Nuclear Licensing B. Lisowyj, Project Manager - Materials J. Brandeau, Project Manager - Nuclear Projects M. Edwards, Nuclear Licensing Engineer Docket No. 50-285
Enclosure:
As stated
ML110910327 *via email dated OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/DCI/CPNB/BC NRR/LPL4/BC NRR/LPL4/PM MMarkley (BSingal NAME LWilkins JBurkhardt TLupold* for) LWilkins DATE 4/1/11 4/1/11 3/31/11 4/1/11 4/5/11
SUMMARY
OF CONFERENCE CALL ON MARCH 30, 2011 VERBAL AUTHORIZATION FROM ASME CODE CASE N-722 VISUAL EXAMINATION OF THE REACTOR VESSEL HOT LEG NOZZLE TO SAFE END DISSIMILAR METAL WELDS OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION, UNIT 1 DOCKET NO. 50-285 By letter dated August 16, 2010, as supplemented by letters dated January 14 and March 4, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML102300679, ML110200205, and ML110670226, respectively), Omaha Public Power District (OPPD, the licensee), requested relief (RR-12) from the 10 CFR 50.55a(g)(6)(ii)(E) requirement to perform a bare metal visual inspection of reactor pressure vessel outlet nozzle to safe end dissimilar metal welds in accordance with ASME Code Case N-722.
OPPD requested this relief for the spring 2011 and fall 2012 refueling outages (RFO) at Fort Calhoun Station, Unit 1 (FCS). OPPD stated that a best effort visual examination performed during each RFO coupled with favorable inspection data from the 2003, 2008, and 2009 weld examinations, use of zinc addition, and a supporting deterministic crack growth analysis would provide an acceptable level of quality and safety in lieu of the required bare metal visual examination.
The bare metal visual examination requirements for dissimilar metal butt welds provide defense-in-depth non-destructive examination. Plant-specific analysis can be used to provide a basis for inspection relief if the bare metal visual inspection presents a significant hardship on a licensee.
In 2010, the NRC and industry groups worked on the development of MRP-287, Materials Reliability Program: Primary Water Stress Corrosion Cracking (PWSCC) Flaw Evaluation Guidance, to develop an acceptable standard methodology for deterministic flaw analysis.
While the report was not complete by the time of the issuance of OPPDs relief request, OPPD did use the report to support its basis for this relief request. The staff reviewed OPPDs deterministic assessment as well as supporting inspection results, zinc mitigation and best effort visual examination alternative for authorization of RR-12.
By letter dated January 14, 2011, OPPD provided information on the hardship involved with performing the required bare metal visual examination, additional details on zinc addition, several references for the flaw evaluation, and clarification on previous examination data. As the hot-leg dissimilar metal welds are in sandboxes, the NRC staff concluded that OPPD had a sufficient basis for hardship. However, the staff found insufficient time available to evaluate the effectiveness and credit the zinc benefit for stress-corrosion cracking to support this relief request. Additionally, the staff concluded that OPPDs plant-specific stress analysis used the incorrect safe-end length in the model, which is a critical part of the flaw evaluation. The NRC Enclosure
staff then reviewed OPPDs stress analysis without the effect of a safe end and used OPPDs methodology to develop a new flaw analysis. The staff found this analysis may not support the full 51 calendar months requested under RR-12. However, the analysis does support relief during the spring 2011 RFO for one operating cycle.
In order to validate OPPDs flaw analysis and support relief through to the spring 2014 RFO, the NRC staff would need OPPD to use the as-build dimensions, in accordance with Item 1, Geometry and Materials, of Section 3.6, Attributes of an Acceptable Residual Stress Analysis, of MRP-287 to develop a robust flaw analysis under RR-12. Completion of this analysis would be expected to go beyond the upcoming spring 2011 refueling outage at FCS.
However, since the NRC staffs review of OPPDs current analysis shows reasonable assurance of leak tightness for the reactor pressure vessel outlet nozzle to safe end dissimilar metal welds until the fall 2012 RFO, the staff finds sufficient basis to authorize RR-12 for the spring 2011 RFO.
Therefore, given the hardship of the location of both reactor pressure vessel outlet nozzle to safe end dissimilar metal welds being in sandboxes, OPPDs best effort visual inspection during the spring 2011 RFO, and the flaw analysis performed to date, the NRC staff concludes that OPPD has provided sufficient technical basis to find that compliance with the current requirements of 10 CFR 50.55a(g)(6)(ii)(E) for a bare metal visual examination of the reactor pressure vessel outlet nozzle to safe end dissimilar metal welds at FCS during the spring 2011 RFO would cause an unnecessary hardship or unusual difficulty on the licensee 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), and is in compliance with the Codes requirements. Therefore, in accordance with 10 CFR 50.55a(a)(3)(ii), the NRC staff authorizes the licensees proposed alternative, RR-12 as supplemented by letters dated January 14 and March 4, 2011, at FCS for the spring 2011 RFO for one operating cycle.
The NRC staff asked if the licensee intended to supplement the existing application in order for the staff to complete its review. The licensee stated that it does not plan to supplement the existing application and will address the NRC staffs concerns in new application for the fall 2012 RFO.
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.