palisades nuclear plant - response to request for

• ·~Entergy Entergy Nuclear Operations, Inc. Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043·9530 Tel 269 764 2000

Jeffery A. Hardy Regulatory Assurance Manager

PNP 2017-020

April 5, 2017

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Reference:

Response to Request for Additional Information - Relief Request Number RR 4-25 Impracticality - Limited Coverage Examinations During the Fourth 10-year Inservice Inspection Interval

Palisades Nuclear Plant Docket 50-255 Renewed Facility Operating License No. DPR-20

1. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2016-052, Relief Request Number RR 4-25 Impracticality - Limited Coverage Examinations During the Fourth 1 a-year Inservice Inspection Interval, dated November 30, 2016 (ADAMS Accession Number ML 16335A032)

2. NRC e-mail to Entergy Nuclear Operations, Inc., Palisades Nuclear Plant-Final Request for Additional Information regarding Relief Request Number RR 4-25 (CAe No. MF8886), dated March 10, 2017 (ADAMS Accession Number ML 17072A275)

Dear Sir or Madam:

Entergy Nuclear Operations, Inc. (ENO) submitted Reference 1 to the Nuclear Regulatory Commission (NRC) requesting authorization of Palisades Nuclear Plant (PNP) relief request number RR 4-25 for limited coverage examinations during the fourth 10-year inservice inspection (lSI) interval. ENO received an electronic request for additional information (RAI) from the NRC in Reference 2.

Attached is the ENO response to the RAI.

Summary of Commitments

This letter contains no new commitments and no revised commitments.

Sincerely,

9As~.IJ. JAH/jpm

PNP 2017-020 of 2

Attachment: Response to Request for Additional Information - Relief Request Number RR 4-25 Impracticality - Limited Coverage Examinations During the Fourth 10-year Inservice Inspection Interval

cc: Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC

PNP 2017-020

ATTACHMENT

Response to Request for Additional Information -

Relief Request Number RR 4-25 Impracticality -

Limited Coverage Examinations

During the Fourth 10-year Inservice Inspection Interval

4 pages follow

PNP 2017-020 ATTACHMENT

Response to Request for Additional Information -Relief Request Number RR 4-25 Impracticality - Limited Coverage Examinations

During the Fourth 1O-year Inservice Inspection Interval

Entergy Nuclear Operations, Inc. (ENO) received, by electronic mail on March 10,2017, a request for additional information (RAI) regarding Palisades Nuclear Plant (PNP) relief request number RR 4-25 impracticality for limited coverage examinations during the fourth 10-year inservice inspection (lSI) interval. The request stated:

"By letter dated November 30, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 16335A032), Entergy Nuclear Operations, Inc. (Entergy, the licensee) submitted relief request number RR 4-25 to the U.S. Nuclear Regulatory Commission (NRC) for the fourth 10-year inservice inspection interval (lSI) at Palisades Nuclear Plant. In RR 4-25, the licensee requested relief from the examination requirements of Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) applicable to ASME Code Class 1 welds and components as listed in Table 1 of the licensee's enclosure. The licensee determined that conformance with the examination requirements of Section XI of the ASME Code for the welds and components is impractical. Title 1 0 of the Code of Federal Regulations, Part 50, Paragraph 50.55a(g)(5)(iii) requires the licensee to submit information to the NRC to support the determination of impracticality.

The NRC staff has reviewed the application and determined that additional information is needed for the staff to complete its review."

NRC REQUEST (RAI-1)

Table 1 of Attachment 1, "Examination Limitation Details" in the application states that two indications were recorded in RPV Circumferential Weld 10-112 (Examination Category B-A, Item No. B1.11).

Clarify whether the two indications were determined to be fabrication flaws or service-induced flaws. If they are fabrication flaws, state whether the two flaws were recorded in previous lSI intervals. If they were not recorded, please explain why they were not recorded.

If they are service-induced flaws, state whether the two flaws were recorded in previous lSI intervals. If they were not recorded, please explain why they were not recorded. In addition, please state whether the indications have grown, and discuss how the two indications were dispositioned including the plans for re-inspecting the indications.

The NRC staff requests this information to determine whether these two indications present a challenge to the structural integrity of RPV Circumferential Weld 10-112.

ENO RESPONSE (RAI-1)

This RAI is associated with information ENO provided in relief request number RR 4-25 (Reference 1) on reactor pressure vessel (RPV) weld 10-112. The component information provided in Reference 1, Enclosure, Attachment 1, Examination Limitation Details, Table 1, was as follows:

Component ID: RPV Circumferential Weld 10-112

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Item Description:

Exam Cat:

Item No.:

Material 1 and Product Form:

Material 2 and Product Form:

Examination Code Coverage Obtained:

Examination Limitations and Results:

Reactor Pressure Vessel shell Circ weld to bottom head (Fig. A and B)

B-A

B1.11

SA-302-B Plate

SA-302-B Plate

UT = 77.72%

RPV Circumferential Weld 10-112 is a Class 1, pressure retaining reactor vessel lower shell to lower head circ weld. Exam is limited due to interference with the core stabilizing lugs, core stop lugs and flow skirt. The 45L and 45S degree axial scans recorded 2 indications.

The NRC RAI consists of several questions. For clarity, each question is repeated below along with the ENO response to the question.

NRC Question 1:

Clarify whether the two indications were determined to be fabrication flaws or service-induced flaws.

ENO Response to Question 1:

The two indications in Weld 10-112 were determined to be fabrication flaws. The indications were characterized in inspection reports as follows:

Indication #1:

Indication #2:

Fabrication discontinuity. Indication #1 is characterized as an embedded sub-surface discontinuity that has been evaluated to meet the acceptance standard of ASME Code Section XI 2001 Edition through 2003 Addenda, Subparagraph IWB-351 0.1, Allowable Planar Flaws.

Fabrication discontinuity. Indication #2 is characterized as a surface discontinuity on the vessel outside diameter (0 0) that has been evaluated to meet the acceptance standard of ASME Code Section XI 2001 Edition through 2003 Addenda, Subparagraph IWB-351 0.1 , Allowable Planar Flaws.

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During the Fourth 10-year In service Inspection Interval

NRC Question 2:

If they are fabrication flaws, state whether the two flaws were recorded in previous lSI intervals.

ENe Response to Question 2:

Indication #1 was previously recorded in PNP's first 10-year inservice inspection (lSI) interval examinations that were performed in 1983 and again in the second 10-year lSI interval examinations that were performed in 1995.

Indication #2 was not previously recorded in either the first or second 10-year lSI interval examinations.

Note: ENO was authorized to extend PNP's third 10-year lSI interval examinations of reactor vessel welds (Category 8-A) to the end of the fourth 10-year lSI interval (Reference 2). Therefore the second 10-year lSI interval examination of Weld 10-112 was the most recent examination previous to the fourth 10-year lSI interval examination.

NRC Question 3:

If they were not recorded, please explain why they were not recorded.


Revisions to examination techniques and procedures mandated by ASME Code Section XI, Appendix VIII, Performance Demonstration for Ultrasonic Examination Systems, was the reason Indication #2 was identified during the most recent 10-year lSI Interval examinations and had not been identified in previous 10-year lSI interval examinations.

NRC Question 4:

If they are service-induced flaws, state whether the two flaws were recorded in previous lSI intervals. If they were not recorded, please explain why they were not recorded. In addition, please state whether the indications have grown, and discuss how the two indications were dispositioned including the plans for re-inspecting the indications.


The two indications in Weld 10-112 are not service-induced flaws and therefore this question is not applicable.

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REFERENCES

1. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2016-052, Relief Request Number RR 4-25 Impracticality- Limited Coverage Examinations During the Fourth 10-year Inservice Inspection Interval, dated November 30, 2016 (ADAMS Accession Number ML 16335A032)

2. NRC letter to Entergy Nuclear Operations, Inc., Palisades Plant - Evaluation of Relief Request to Extend the Third 10-year Inservice Inspection Interval for Reactor Vessel Weld Examination (TAC No. MD9265), dated February 11 ,2009 (ADAMS Accession Number ML090120896)

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