ML061210140

Request for Additional Information Regarding Relief Request PRR-10, Fourth 10-Year Inservice Inspection Program Plan

ML061210140
Person / Time
Site:	Pilgrim
Issue date:	05/11/2006
From:	James Shea Plant Licensing Branch III-2
To:	Kansler M Entergy Nuclear Operations
SHea J, NRR/DLPM, 415-1388
References
TAC MC8293
Download: ML061210140 (7)

Text

May 11, 2006 Mr. Michael R. Kansler President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

PILGRIM NUCLEAR POWER STATION - REQUEST FOR ADDITIONAL INFORMATION REGARDING RELIEF REQUEST PRR-10, FOURTH 10-YEAR INSERVICE INSPECTION PROGRAM PLAN (TAC NO. MC8293)

Dear Mr. Kansler:

By letter dated June 29, 2005, Entergy Nuclear Operations, Inc. (the licensee) requested relief from requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, for Pilgrim Nuclear Power Station (Pilgrim). You requested approval to apply the Pilgrim risk informed inservice inspection evaluation procedure as an alternative for specific categories of Class 1 piping for the fourth 10-year inservice inspection interval at Pilgrim.

The Nuclear Regulatory Commission staff has reviewed your submittal and has determined that additional information is needed to complete its review. The specific questions are found in the enclosed request for additional information (RAI). A response to this RAI is requested to be provided within 45 days.

Sincerely,

/RA/

James J. Shea, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293

Enclosure:

As stated cc w/encl: See next page

May 11, 2006 Mr. Michael R. Kansler President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

PILGRIM NUCLEAR POWER STATION - REQUEST FOR ADDITIONAL INFORMATION REGARDING RELIEF REQUEST PRR-10, FOURTH 10-YEAR INSERVICE INSPECTION PROGRAM PLAN (TAC NO. MC8293)

Dear Mr. Kansler:

By letter dated June 29, 2005, Entergy Nuclear Operations, Inc. (the licensee) requested relief from requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, for Pilgrim Nuclear Power Station (Pilgrim). You requested approval to apply the Pilgrim risk informed inservice inspection evaluation procedure as an alternative for specific categories of Class 1 piping for the fourth 10-year inservice inspection interval at Pilgrim.

The Nuclear Regulatory Commission staff has reviewed your submittal and has determined that additional information is needed to complete its review. The specific questions are found in the enclosed request for additional information (RAI). A response to this RAI is requested to be provided within 45 days.

Sincerely,

/RA/

James J. Shea, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293

Enclosure:

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

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REQUEST FOR ADDITIONAL INFORMATION (RAI)

PILGRIM RELIEF REQUEST NO. PRR-10 ENTERGY NUCLEAR OPERATIONS, INC.

PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293 By letter dated June 29, 2005, Entergy Nuclear Operations, Inc. (the licensee) requested relief from requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, for Pilgrim Nuclear Power Station (Pilgrim). You requested approval to apply the Pilgrim risk informed (RI) inservice inspection (ISI) evaluation procedure as an alternative for specific categories of Class 1 piping for the fourth 10-year ISI interval at Pilgrim.

The Nuclear Regulatory Commission (NRC) staff has reviewed your submittal and has determined that additional information is needed to complete its review.

1. Your original RI-ISI program submittal (letter, dated December 27, 2000, J.F. Alexander (Director, Nuclear Assessment) to U.S. NRC) states on page 3 of 30, The Pilgrim PSA is presently being refined in order to address the findings of the NRC SER, the BWROG Peer Certification, and to bring the model to the state of the art. These improvements have been considered and will not have an unconservative impact on the conclusions from the RI-ISI evaluation of Class 1 piping.

This implies that changes have been made to the Pilgrim probabilistic safety analysis (PSA) model subsequent to the development of the original RI-ISI program, some of which may have been significant in scope.

a. Please summarize the enhancements and refinements from the NRC safety evaluation and from the Boiling Water Reactor Owners Group (BWROG) Peer Certification (in response to Level A and B Facts and Observations) that have been implemented.

b. Also, please indicate if the Pilgrim PSA has received any subsequent peer reviews, and what, if any, significant issues (e.g. - Level A and B Facts and Observations) emerged as a result of these reviews. If there remains any significant issues with the Pilgrim PSA model that was used to support PRR-10, please summarize your assessment of the impact of resolving these issues on the RI-ISI application for the fourth ISI interval.

2. Page B-55 of the Pilgrim Fourth 10-Year Interval Program Plan (the first page of Relief Request PRR-10) states the Pilgrim-specific RI-ISI program is summarized in Table 1.

However, Table 1 is only partially provided (page B-57). Also, a Table 2 is provided, but the first page of that table is apparently missing. And the second page of Table 2 has the same title as Table 1's title. Please provide a complete set of Tables 1 and 2, and/or otherwise clarify what you had intended to supply as part of PRR-10.

Enclosure

3. Based on the composite of the partial tables provided, it appears that the fourth ISI interval and third interval RI-ISI programs are identical. However, there are two aspects of the fourth interval program that the staff is unable to discern from what was provided:

a. Have there been any changes to the 71 locations selected for non destructive Examination (NDE) for the fourth interval relative to the 71 locations selected during the original RI-ISI program evaluation (within a given system and risk category)? If so, please identify them and give the rationale for those changes.

b. Page B-55 of the Pilgrim Fourth 10-Year Interval Program Plan states The RI-ISI program has been updated consistent with the intent of NEI-04-05 (Reference 3) and continues to meet EPRI [Electric Power Research Institute]

TR-112657 and Regulatory Guide 1.174 risk acceptance criteria.

Please provide a summary of the reviews and other processes that you performed which led to your conclusion that, aside from any location changes (if any) that you describe in your response to RAI 3(a) above, no changes to your RI-ISI program are needed for the fourth 10-year interval, despite changes made to the plant and to your procedures since the original RI-ISI program was implemented.

(Please note that the staff has not reviewed, let alone endorsed, NEI-04-05, as a methodology for performing an evaluation of an RI-ISI program for update.)

4. Page 2-37 of the licensees ISI program plan submitted by letter dated June 29, 2005, states, "RI-ISI socket welds shall receive both a VT-2 and PT examination, at a minimum, each refueling outage. What is meant by PT (pressure test or penetrant test)?

5. Of the items selected for RI-ISI in Table 1(2) how many are socket welds? Provide a breakdown of the examination technique to be performed on the items selected for examination, include the frequency of examination. (UT-Appendix VIII, UT-FAC, VT-2/pressure test, etc.)

6. Page 2-38 of the licensees inservice inspection program plan states the following:

"Extent" includes 100% of the examination location. When the required examination volume or area cannot be examined due to interference by another component or part geometry, limited examinations shall be evaluated for acceptability. Acceptance of limited examinations or volumes shall not invalidate the results of the risk-informed evaluation. Areas with acceptable limited examinations, and their bases, shall be documented.

It is not clear what is meant by "acceptable limited examinations," in addition, limited examinations will still need to have a relief request submitted and approved. The paragraph needs to be modified to include, the need to request relief for limited examinations.

7. Page B-55, "Code Requirement," states that "...100% of Category B-F welds and 25%

of B-J welds for the ASME Class 1 piping greater than 4" NPS be selected for volumetric and/or surface examination." However code changes have changed the requirement to ASME Class 1 piping greater than 1" NPS be selected for volumetric and/or surface examination. The licensee needs to evaluate the effects of the change in scope on its RI-ISI program. Describe how Class 1 piping less than 4" NPS and greater than 1" NPS will be treated.

Pilgrim Nuclear Power Station cc:

Regional Administrator, Region I Secretary of Public Safety U. S. Nuclear Regulatory Commission Executive Office of Public Safety 475 Allendale Road One Ashburton Place King of Prussia, PA 19406-1415 Boston, MA 02108 Senior Resident Inspector Director, Massachusetts Emergency U. S. Nuclear Regulatory Commission Management Agency Pilgrim Nuclear Power Station Attn: James Muckerheide Post Office Box 867 400 Worcester Road Plymouth, MA 02360 Framingham, MA 01702-5399 Chairman, Board of Selectmen Mr. William D. Meinert 11 Lincoln Street Nuclear Engineer Plymouth, MA 02360 Massachusetts Municipal Wholesale Electric Company Chairman P.O. Box 426 Nuclear Matters Committee Ludlow, MA 01056-0426 Town Hall 11 Lincoln Street Mr. Michael A. Balduzzi Plymouth, MA 02360 Site Vice President Entergy Nuclear Operations, Inc.

Chairman, Duxbury Board of Selectmen Pilgrim Nuclear Power Station Town Hall 600 Rocky Hill Road 878 Tremont Street Plymouth, MA 02360-5508 Duxbury, MA 02332 Mr. Stephen J. Bethay Office of the Commissioner Director, Nuclear Safety Assurance Massachusetts Department of Entergy Nuclear Operations, Inc.

Environmental Protection Pilgrim Nuclear Power Station One Winter Street 600 Rocky Hill Road Boston, MA 02108 Plymouth, MA 02360-5508 Office of the Attorney General Mr. Bryan S. Ford One Ashburton Place Manager, Licensing 20th Floor Entergy Nuclear Operations, Inc.

Boston, MA 02108 Pilgrim Nuclear Power Station 600 Rocky Hill Road Director, Radiation Control Program Plymouth, MA 02360-5508 Commonwealth of Massachusetts Executive Offices of Health and Mr. Kevin H. Bronson Human Services General Manager, Plant Operations 174 Portland Street Entergy Nuclear Operations, Inc.

Boston, MA 02114 Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508

Pilgrim Nuclear Power Station cc:

Ms. Charlene D. Faison Mr. Michael J. Colomb Manager, Licensing Director of Oversight Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.

440 Hamilton Avenue 440 Hamilton Avenue White Plains, NY 10601 White Plains, NY 10601 Mr. Gary J. Taylor Mr. Travis C. McCullough Chief Executive Officer Assistant General Counsel Entergy Operations Entergy Nuclear Operations, Inc.

1340 Echelon Parkway 440 Hamilton Avenue Jackson, MS 39213 White Plains, NY 10601 Mr. John T. Herron Ms. Stacey Lousteau Sr. VP and Chief Operating Officer Treasury Department Entergy Nuclear Operations, Inc. Entergy Services, Inc.

440 Hamilton Avenue 639 Loyola Avenue White Plains, NY 10601 New Orleans, LA 70113 Mr. Oscar Limpias Mr. James Sniezek Vice President, Engineering 5486 Nithsdale Drive Entergy Nuclear Operations, Inc. Salisbury, MD 21801-2490 440 Hamilton Avenue White Plains, NY 10601 Mr. Michael D. Lyster 5931 Barclay Lane Mr. Christopher Schwarz Naples, FL 34110-7306 Vice President, Operations Support Entergy Nuclear Operations, Inc. Mr. Garrett D. Edwards 440 Hamilton Avenue 814 Waverly Road White Plains, NY 10601 Kennett Square, PA 19348 Mr. John F. McCann Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601