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MONTHYEARML0903708402009-02-0606 February 2009 Request for NRC Relief from Code Case N-729-1 as Conditioned by 10 CFR 50,55a(g)(6)(ii)(D)(3) Regarding Demonstrated Leak Path Assessment of Reactor Head Penetration Nozzles Project stage: Request ML0907700342009-04-0707 April 2009 Safety Evaluation, Relief Request to Perform Volumetric Leak Path Assessment of Reactor Pressure Vessel Upper Head Penetration Nozzle Project stage: Approval 2009-02-06
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Category:Letter
MONTHYEARML24022A1172024-01-23023 January 2024 Acceptance of Requested Licensing Action Amendment Request to Revise Renewed Facility Operating License and Permanently Defueled Technical Specifications to Support Resumption of Power Operations ML24012A2422024-01-16016 January 2024 Acceptance of Requested Licensing Action License Transfer Request ML23236A0042023-12-27027 December 2023 Issuance of Amendment 274 Re Changes to Perm Defueled Emergency Plan and Perm Defueled Emergency Action Level Scheme ML23355A1242023-12-26026 December 2023 Withdrawal of an Amendment Request Re License Amendment Request to Revise License Condition to Eliminate Cyber Security Plan Requirements ML23192A0772023-12-26026 December 2023 Letter Exemption from the Requirements of 10 CFR 140.11(a)(4) Concerning Offsite Primary and Secondary Liability Insurance ML23191A5222023-12-22022 December 2023 Exemption Letter from the Requirements of 10 CFR 50.54(W)(1) Concerning Onsite Property Damage Insurance (EPID - L-2022-LLE-0032) ML23263A9772023-12-22022 December 2023 Exemption from Certain Emergency Planning Requirements and Related Safety Evaluation ML23354A2602023-12-21021 December 2023 Reference Simulator Inspection Request for Information L-23-019, Proof of Financial Protection 10 CFR 140.152023-12-18018 December 2023 Proof of Financial Protection 10 CFR 140.15 PNP 2023-030, License Amendment Request to Revise Renewed Facility Operating License and Permanently Defueled Technical Specifications to Support Resumption of Power Operations2023-12-14014 December 2023 License Amendment Request to Revise Renewed Facility Operating License and Permanently Defueled Technical Specifications to Support Resumption of Power Operations PNP 2023-035, Withdrawal of License Amendment Request - Revise License Condition to Eliminate Cyber Security Plan Requirements2023-12-12012 December 2023 Withdrawal of License Amendment Request - Revise License Condition to Eliminate Cyber Security Plan Requirements PNP 2023-028, Application for Order Consenting to Transfer of Control of License and Approving Conforming License Amendments2023-12-0606 December 2023 Application for Order Consenting to Transfer of Control of License and Approving Conforming License Amendments L-23-012, Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point2023-11-13013 November 2023 Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point ML23291A4402023-11-0303 November 2023 Acceptance of Requested Licensing Action Request for Exemption from 10 CFR 50.82(a)(2) to Support Reauthorization of Power Operations IR 05000255/20230032023-10-0404 October 2023 NRC Inspection Report No. 05000255/2023003(DRSS)-Holtec Decommissioning International, LLC, Palisades Nuclear Plant ML23275A0012023-10-0202 October 2023 Request for Withholding Information from Public Disclosure for Palisades Nuclear Plant PNP 2023-025, Request for Exemption from Certain Termination of License Requirements of 10 CFR 50.822023-09-28028 September 2023 Request for Exemption from Certain Termination of License Requirements of 10 CFR 50.82 PNP 2023-026, Pre-Submittal Meeting Presentation - Palisades Nuclear Plant License Transfer Application to Support Resumption of Power Operations2023-09-28028 September 2023 Pre-Submittal Meeting Presentation - Palisades Nuclear Plant License Transfer Application to Support Resumption of Power Operations PNP 2023-023, Special Report High Range Noble Gas Monitor Inoperable2023-08-0909 August 2023 Special Report High Range Noble Gas Monitor Inoperable ML23215A2302023-08-0303 August 2023 Notice of Organization Change - Chief Nuclear Officer IR 05000255/20230022023-07-19019 July 2023 NRC Inspection Report 05000255/2023002 DRSS-Holtec Decommissioning International, LLC, Palisades Nuclear Plant ML23087A0362023-05-0202 May 2023 PSDAR Review Letter ML23117A2172023-05-0101 May 2023 Safety Evaluation for Quality Assurance Program Manual Reduction in Commitment PNP 2023-018, 2022 Annual Non-Radiological Environmental Operating Report2023-04-25025 April 2023 2022 Annual Non-Radiological Environmental Operating Report L-23-004, HDI Annual Occupational Radiation Exposure Data Reports - 20222023-04-24024 April 2023 HDI Annual Occupational Radiation Exposure Data Reports - 2022 PNP 2023-007, and Big Rock Point, 2022 Annual Radioactive Effluent Release and Waste Disposal Reports2023-04-19019 April 2023 and Big Rock Point, 2022 Annual Radioactive Effluent Release and Waste Disposal Reports PNP 2023-008, 2022 Radiological Environmental Operating Report2023-04-18018 April 2023 2022 Radiological Environmental Operating Report L-23-003, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2023-03-31031 March 2023 Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations PNP 2023-002, 6 to Updated Final Safety Analysis Report2023-03-31031 March 2023 6 to Updated Final Safety Analysis Report ML23088A0382023-03-29029 March 2023 Stations 1, 2, & 3, Palisades Nuclear Plant, and Big Rock Point - Nuclear Onsite Property Damage Insurance PNP 2023-006, Report of Changes to Security Plan, Revision 202023-03-29029 March 2023 Report of Changes to Security Plan, Revision 20 PNP 2023-012, Presentation on Regulatory Path to Reauthorize Power Operations2023-03-16016 March 2023 Presentation on Regulatory Path to Reauthorize Power Operations ML23038A0982023-03-15015 March 2023 Request for Withholding Information from Public Disclosure ML23095A0642023-03-14014 March 2023 American Nuclear Insurers, Notice of Cancellation Rescinded PNP 2023-001, Regulatory Path to Reauthorize Power Operations2023-03-13013 March 2023 Regulatory Path to Reauthorize Power Operations PNP 2023-004, Report of Changes to Palisades Nuclear Plant Technical Specification Bases2023-03-0808 March 2023 Report of Changes to Palisades Nuclear Plant Technical Specification Bases PNP 2023-005, Response to Palisades Nuclear Plant - Request for Additional Information Related to the Post-Shutdown Decommissioning Activities Report2023-03-0101 March 2023 Response to Palisades Nuclear Plant - Request for Additional Information Related to the Post-Shutdown Decommissioning Activities Report ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities ML23052A1092023-02-17017 February 2023 FEMA Letter to NRC, Proposed Commission Paper Language for Palisades Nuclear Plant Emergency Plan Decommissioning Exemption Request ML23032A3992023-02-0101 February 2023 Regulatory Path to Reauthorize Power Operations IR 05000255/20220032022-12-28028 December 2022 NRC Inspection Report No. 05000255/2022003(DRSS); 07200007/2022001 (Drss) Holtec Decommissioning International, LLC, Palisades Nuclear Plant L-22-042, Oyster, Pilgrim, Indian Point, Palisades and Big Rock Point - Proof of Financial Protection 10 CFR 140.152022-12-14014 December 2022 Oyster, Pilgrim, Indian Point, Palisades and Big Rock Point - Proof of Financial Protection 10 CFR 140.15 PNP 2022-037, Report of Changes to Security Plan, Revision 192022-12-14014 December 2022 Report of Changes to Security Plan, Revision 19 ML22321A2852022-11-17017 November 2022 LLC Master Decommissioning Trust Agreement for Palisades Nuclear Plant IR 05000255/20224012022-11-0909 November 2022 Decommissioning Palisades Nuclear Plant - Decommissioning Security Inspection Report 05000255/2022401 PNP 2022-036, Response to Request for Additional Information Regarding License Amendment Request for Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme2022-11-0808 November 2022 Response to Request for Additional Information Regarding License Amendment Request for Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme PNP 2022-035, International - Notification of Commitment Cancellations for Remaining Activities Related to Beyond-Design-Basis Seismic Hazard Reevaluations2022-11-0202 November 2022 International - Notification of Commitment Cancellations for Remaining Activities Related to Beyond-Design-Basis Seismic Hazard Reevaluations PNP 2022-024, Request for Exemption from 10 CFR 140.11(a)(4) Concerning Primary and Secondary Liability Insurance2022-10-26026 October 2022 Request for Exemption from 10 CFR 140.11(a)(4) Concerning Primary and Secondary Liability Insurance PNP 2022-026, Request for Exemption from 10 CFR 50.54(w)(1) Concerning Onsite Property Damage Insurance2022-10-26026 October 2022 Request for Exemption from 10 CFR 50.54(w)(1) Concerning Onsite Property Damage Insurance ML22292A2572022-10-25025 October 2022 Permanently Defueled Emergency Plan License Amendment RAI Letter 2024-01-23
[Table view] Category:Safety Evaluation
MONTHYEARML23263A9772023-12-22022 December 2023 Exemption from Certain Emergency Planning Requirements and Related Safety Evaluation ML23117A2172023-05-0101 May 2023 Safety Evaluation for Quality Assurance Program Manual Reduction in Commitment ML22039A1982022-05-13013 May 2022 Issuance of Amendment No. 272 Permanently Defueled Technical Specifications ML21292A1482021-12-13013 December 2021 Safety Evaluation Related to Request for Direct and Indirect Transfers of Control of Facility Operating License DPR-6 for Big Rock Point and Renewed Facility Operating License DPR-20 for Palisades Nuclear Plant and ISFSI (EPID L-2020-LLM-00 ML21292A1472021-12-13013 December 2021 Draft Conforming License Amendments - Palisades Nuclear Plant Renewed Facility Operating License DPR-20 and ISFSI and Big Rock Point Facility Operating License DPR-6 and ISFSI (EPID L-2020-LLM-0003) (Enclosure 2) ML20365A0012021-01-19019 January 2021 Relief Request 5-8 Related to ASME Code Case N-729-4 Supplemental Examination Requirements of Reactor Vessel Closure Head Penetration Nozzles ML20226A2722020-08-18018 August 2020 Request to Use a Provision of a Later Edition of the ASME BPV Code, Section XI ML19317D8552019-12-30030 December 2019 Issuance of Amendment No. 271 Regarding Adoption of TSTF-425, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B ML19318E3942019-12-0202 December 2019 Reactor Vessel Material Surveillance Capsule Withdrawal Schedule ML19254A6032019-09-19019 September 2019 Units 2 and 3; Palisades Nuclear Plant; River Bend; and Waterford Steam Electric Station, Unit 3 - Relief Request No. EN-19-RR-1, Use of ASME Code Case N-831-1 ML19175A0422019-09-11011 September 2019 Arkansas Units 1 and 2; Grand Gulf, Unit 1; Indian Point 2 and 3; Palisades; River Bend, Unit 1; Waterford Unit 3 - Issuance of Amendments to Adopt TSTF-529, Clarify Use and Application Rules ML19198A0802019-08-20020 August 2019 Issuance of Amendments No. 269 Regarding Changes to NFPA 805 Modifications and Change to Full Compliance Implementation Date for the Fire Protection Program (Epids L-2018-LLA-0296 and L-2019-LLA-0049) ML19135A0502019-05-21021 May 2019 Correction to Safety Evaluation for Amendment No.268 Regarding Revision to Diesel Generator Undervoltage Start Surveillance Requirement ML19107A0532019-05-13013 May 2019 Issuance of Amendment No. 268 Regarding Revision to Diesel Generator Undervoltage Start Surveillance Requirement ML19112A3172019-04-26026 April 2019 Approval of Alternative for Repair of Reactor Pressure Vessel Head Penetrations ML18170A2192018-09-24024 September 2018 Issuance of Amendment Changes to the Emergency Plan for Permanently Defueled Condition (CAC No. MG0198; EPID L-2017-LLA-0305) ML18128A0672018-06-0808 June 2018 Arkansas, Units 1 and 2; Grand Gulf, Unit 1; Indian Point Unit Nos. 2 and 3; Palisades; Pilgrim; River Bend Station, Unit 1; and Waterford, Unit-3 Relief Request No. EN-17-RR-1, Alternative to Use ASME Code Case N-513-4 ML18114A4102018-06-0404 June 2018 Issuance of Amendment Regarding Administrative Controls for Permanently Defueled Condition (CAC No. MG0021; EPID L-2017-LLA-0266) ML18135A2632018-05-21021 May 2018 Relief Request No. RR 5-6 Alternate to the Reexamination Frequency for a Relevant Condition ML18039A2442018-02-27027 February 2018 Issuance of Amendment License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications ML17328B0332017-12-15015 December 2017 Issuance of Amendment Cyber Security Plan Implementation Schedule (CAC No. MF9523; EPID L-2017-LLA-0199) ML21067A4982017-09-0707 September 2017 Relief Request No. RR 5-4 Proposed Alternative, Weld Reference System ML17151A3502017-08-21021 August 2017 Approval of Certified Fuel Handler Training and Retraining Program ML17194A8072017-08-14014 August 2017 Relief Request No. RR 4-25 Limited Coverage Examinations During the Fourth 10-Year Inservice Inspection Interval ML17137A0282017-06-29029 June 2017 Relief Request Number RR 5; 5 Proposed Alternative, Under-Vessel Leakage Examination ML17121A5102017-06-0808 June 2017 Issuance of Amendment License Amendment Request for Editorial and Administrative Changes to Technical Specifications ML17082A4652017-05-30030 May 2017 Issuance of Amendment Application to Revise Technical Specifications to Adopt TSTF 545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing ML16300A0302016-12-19019 December 2016 Issuance of Amendment Revision to the Requirements for Steam Generator Tube Inspections and Repair Criteria in the Cold Leg Tube Sheet Region ML16281A4982016-10-28028 October 2016 Issuance of Amendment No. 260, Revise License Condition 2.C.(4) and Technical Specifications Related to Control Rod Drive Exercise Surveillance ML16251A6202016-09-13013 September 2016 Entergy Fleet Request for Approval of Change to the Entergy Quality Assurance Program Manual (CAC Nos. MF7086 - MF7097) ML16014A3182016-08-22022 August 2016 Safety Evaluation Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 ML16096A2692016-06-0606 June 2016 Arkansas; Grand Gulf; James A. Fitzpatrick; Indian Point; Palisades; Pilgrim; River Bend; and Waterford - Relief Request RR-EN-15-2, Proposed Alternative to Use ASME Boiler and Pressure Vessel Code Case N-786-1 ML16093A0282016-05-31031 May 2016 Entergy Services, Inc., Proposed Alternative to Utilize ASME Code Case N-789-1, Relief Request RR-EN-15-1, Revision 1 ML16078A0682016-05-0202 May 2016 Issuance of Amendment Cyber Security Plan Implementation Schedule ML16043A4852016-03-14014 March 2016 Relief Request Number RR 4-24 - Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination ML16022A1072016-02-0101 February 2016 Relief Request Number RR 4-23- Proposed Alternative Concerning ASME Code Depth Sizing Requirement ML15334A3072015-12-22022 December 2015 Relief Request Numbers RR 5-2 and 5-3, Proposed Alternative to the Requirements of the ASME OM Code for the Fifth 10-Year Inservice Test Interval ML15320A2442015-11-25025 November 2015 Relief Request Number 5-1, Proposed Alternative, Extend the Current ASME Code of Record Into the Fifth 10-Year ISI Interval for ISI Related Activities ML15103A0592015-05-18018 May 2015 Issuance of Amendment Adoption of TSTF-426, Revision 5, Revise or Add Actions to Preclude Entry Into Limiting Condition for Operation 3.0.3 - RITSTF Initiatives 6B and 6C. ML15055A1062015-04-22022 April 2015 Issuance of Amendment License Amendment Request to Revise Emergency Response Organization Staff Augmentation Response Times ML15007A1912015-02-27027 February 2015 Issuance of Amendment Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance with 10 CFR 50.48(c) ML14237A1442014-12-0808 December 2014 Issuance of Amendment Cyber Security Plan Implementation Schedule ML14283A2872014-10-22022 October 2014 Issuance of Amendment Application for Technical Specification Change (TSTF-427) to Add Limiting Condition for Operation 3.0.9 Regarding the Unavailability of Barriers Using the Consolidated Line Item Improvement Process ML14223B2262014-09-0404 September 2014 Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination ML14199A5572014-08-13013 August 2014 Relief Request Number RR-4-19, Proposed Alternative to the Requirements of ASME Code Case N-638-4 ML14210A2662014-08-0808 August 2014 Arkansas, Units 1 & 2, Big Rock Point, James A. Fitzpatrick, Grand Gulf, Unit 1, Indian Point, Units 1, 2 & 3, Palisades, Pilgrim, River Bend, Unit 1, Vermont Yankee, Waterford, Safety Evaluation Quality Assurance Program Manual, Rev. 24 & ML13312A4232013-11-26026 November 2013 Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation ML13129A2192013-05-29029 May 2013 Staff Assessment in Response to Recommendation 9.3 of the Near-Term Task Force Related to the Fukushima Dai-Ichi Nuclear Power Plant Accident ML13025A3062013-03-14014 March 2013 ANO 1 & 2, Big Rock, FitzPatrick, GGNS, Indian Point 1, 2 & 3, Palisades, Pilgrim, RBS, Vermont Yankee, and Waterford - Correction to Amendments Issued on 12/28/12, Revise QA Program Manual and Staff Qualification Technical Specifications ML13056A5142013-02-28028 February 2013 Non-Proprietary Issuance of Amendment Regarding Replacement of Spent Fuel Pool Region 1 Storage Racks 2023-05-01
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Apri 1 7, 2009 Vice President, Operations Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530
SUBJECT:
PALISADES NUCLEAR PLANT - EVALUATION OF RELIEF REQUEST TO PERFORM VOLUMETRIC LEAK PATH ASSESSMENT OF REACTOR PRESSURE VESSEL UPPER HEAD PENETRATION NOZZLE (TAC NO. ME0606)
Dear Sir or Madam:
By letter dated February 6, 2009 (Agencywide Document Access and Management System (ADAMS) Accession No. ML090370840), Entergy Nuclear Operations, Inc. (the licensee),
requested U.S. Nuclear Regulatory Commission (NRC) authorization for relief from the requirements of Title 10 of the Code of Federal Regulations (CFR) 50.55a(g)(6)(ii)(D)(3) for the 2009 spring refueling outage at Palisades Nuclear Plant (PNP). The submittal requests relief from the requirement to perform an NRC approved demonstrated volumetric leak path assessment of each reactor pressure vessel (RPV) upper head penetration nozzle. The relief request proposes an alternative to use a previously NRC authorized volumetric leak path technique used under the requirements of the First Revised NRC Order EA-03-009, dated February 20, 2004, which was revoked by rulemaking dated September 10, 2008 (73 FR 52742).
The NRC staff has reviewed the licensee's relief request Nondestructive Examination-Leak Path. On the basis of the information submitted, the staff concludes that the proposed alternative provides reasonable assurance of structural integrity of the RPV upper head and implementation of additional requirements would result in hardship without a compensating increase in the level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(ii), the staff authorizes this alternative for the 2009 spring refueling outage at PNP.
~~;m~;:~
Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-255
Enclosure:
Safety Evaluation 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 VOLUMETRIC LEAK PATH ASSESSMENT ENTERGY NUCLEAR OPERATIONS, INC.
RELIEF REQUEST FOR PALISADES NUCLEAR PLANT DOCKET NUMBER 50-255
1.0 INTRODUCTION
By letter dated February 6,2009, Entergy Nuclear Operations, Inc. (the licensee), requested U.S. Nuclear Regulatory Commission (NRC) authorization for relief from the requirements of Title 10 of the Code of Federal Regulations (CFR) 50.55a(g)(6)(ii)(D)(3) for the 2009 spring refueling outage at Palisades Nuclear Plant (PI'JP). The submittal requests relief from the requirement to perform an NRC approved demonstrated volumetric leak path assessment of each reactor pressure vessel (RPV) upper head penetration nozzle. The relief request proposes an alternative to use a previously NRC authorized volumetric leak path technique used under the requirements of the First Revised NRC Order EA-03-009, dated February 20, 2004, which was revoked by rulemaking dated September 10, 2008 (73 FR 52742).
2.0 REGULATORY EVALUATION
Title 10 of the CFR 50.55a(g)(6)(ii) states that the Commission may require the licensee to follow an augmented inservice inspection program for systems and components for which the Commission deems that added assurance of structural reliability is necessary. Under this section, 10 CFR 50.55a(g)(6)(ii)(D) defines the requirements for reactor vessel head inspections. Title 10 of the CFR 50.55a(a)(3) states that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC if: (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. The licensee, in accordance with 10 CFR 50.55a(a)(3)(ii), has requested relief from the demonstrated volumetric leak path inspection requirements of 10 CFR 50.55a(g)(6)(ii)(D)(3).
3.0 TECHNICAL EVALUATION
3.1 Component for Which Relief Was Requested There are 53 American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1 vessel head penetration nozzles and associated welds identified by item number B4.20 of Code Case N-729-1 , Table 1.
Enclosure
-2 3.2 Regulatory Requirement Title 10 of the CFR 50.55a(g)(6)(ii)(D)(3) requires, in part, a licensee to perform a demonstrated volumetric or surface leak path assessment through all vessel head penetration nozzle J-groove welds.
3.3 Proposed Alternative The licensee's proposed alternative is to perform a vOlumetric leak path inspection using the same techniques used to satisfy the requirements of the First Revised NRC Order EA-03-009, dated February 20, 2004.
3.4 Licensee's Basis The licensee notes that while industry has initiated efforts to accomplish a generic demonstration of the volumetric leak path assessment technique, the extent of remaining tasks will likely preclude successful completion in time to support the upcoming spring 2009 refueling outage at PNP. The licensee also states that performance of alternative surface examinations of each J-groove weld would be a significant hardship due to the personnel exposure associated with the inspections in a locked high radiation area and high contamination area without a compensating increase in the level of quality and safety. The licensee provided details on several enhancements to the volumetric leak path inspection technique which have been developed over the past five years, including the previously completed baseline inspection data available for assessment comparison.
3.5 Staff Evaluation ASME Code Case N-729-1 did not include a vOlumetric leak path assessment as part of the long term re-inspection plans for reactor pressure vessel upper head penetration nozzles and their associated welds. The NRC staff believed this omission was, in part, due to the difficulty for ASME members to establish qualification requirements for this inspection technique. The NRC staff determined that surface examination of all associated penetration J-groove welds was necessary as a defense-in-depth approach to detect leakage through the J-groove weld. The NRC staff presented this position in the proposed rule to mandate upper head inspections in accordance with ASME Code Case N-729-1. During the public comment period, several stakeholders noted hardships in performing this examination, and some stakeholders requested the option of performing a vOlumetric leak path assessment which would provide a similar defense-in-depth inspection to detect leakage through the J-groove weld. The staff found the stakeholder's request had merit and amended the final rule. However, due to the question regarding the effectiveness of the examination technique raised during the development of ASME Code Case N-729-1, the NRC staff included the requirement for a demonstrated volumetric leak path assessment in the final rule.
On November 24,2008, the NRC staff held a public meeting with representatives from Nuclear Energy Institute and industry to discuss generic activities going forward to demonstrate the volumetric leak path inspection technique. A meeting summary with presentation slides is available in ADAMS under document accession number ML090560434. During the meeting industry representatives provided a presentation on advances in the volumetric leak path
- 3 assessment technique over the past five years. The industry described a living program being run by both major inspection vendors to ensure effective examinations were being performed.
The industry representatives noted that recent concerns raised by the Office of Nuclear Reactor Research contractors, including questions regarding the interpretation of signal data, were being incorporated into a generic standards document for use by inspectors in the field. The industry representatives explained that since baseline examinations have been performed on all RPV upper head penetration nozzles throughout the United States pressurized water reactor fleet, that there would be significant enhancement in analyzing future inspection results. The industry representatives also stated their intention to provide details of each of these enhancements to the NRC in a guideline in the spring of 2009, but that this information was already being put into use by vendors in the field. Further, industry representatives discussed activities to complete an industry generic demonstration of the volumetric leak path technique, but they did not expect to complete the project in time to support the spring 2009 outage at PNP.
Surface examination of the entire wetted surface of each J-groove weld is an option for the licensee under the requirements of 10 CFR 50.55a(g)(6)(ii)(D)(3). However, the licensee has noted that these inspections would be required in a high radiation area of nearly 3 rem/hour and a contact dose rate of 5 rem/hour. Further the design of the nozzles prevents easy access and limits the ability to deploy remote tooling. This would require additional manual activity within these high radiation areas. The NRC staff finds that the licensee has provided sufficient plant specific information regarding the weld surface condition and personnel radiological dose exposure that the NRC staff concludes that compliance with these provisions would constitute a hardship upon the licensee.
Given this hardship and the delay in implementation of a generic demonstration of the volumetric leak path technique, the licensee's alternative is to implement a volumetric leak path assessment of each penetration nozzle and associated weld in accordance with the previous requirements of the First Revised NRC Order EA-03-009, additionally being informed by the current activities to perform a generic demonstration of the inspection technique. The NRC staff finds that given the licensee's hardship to perform a surface leak path assessment, this volumetric leak path assessment technique, as described in the licensee's proposed alternative, currently provides a best effort defense-in-depth inspection beyond the required bare metal visual inspection to identify leakage through each J-groove weld. Further, the NRC staff concludes that the licensee's proposed alternative provides reasonable assurance of public health and safety, and compliance with the additional requirements would result in hardship without a compensating increase in the level of quality and safety.
4.0 CONCLUSION
The NRC staff has reviewed the licensee's basis and concludes that the licensee's proposed alternative provides reasonable assurance of public health and safety, and compliance with the additional requirements would result in a hardship without a compensating increase in the level of quality and safety. Therefore, in accordance with 10 CFR 50.55a(a)(3)(ii) the NRC authorizes the licensee's proposed alternative for the spring 2009 refueling outage at PNP.
All other 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.
ML090770034 *Memo dated 3/16/09 OFFICE LPL3-1/PM LPL3-1/LA BC:CPNB OGC NLO LPL3-1/BC NAME MChawla BTuily TChan* AJones ** LJames DATE 03/20/09 04/03/09 03/16/09 03/31/09 04/07/09
- w/ comments that should be addressed