PNP 2013-082, Relief Request Number 4-17, Proposed Alternative, Request for Relief from Immediate ASME Code Flaw Repair of Service Water System Manual Valve MV-SW135

Relief Request Number 4-17, Proposed Alternative, Request for Relief from Immediate ASME Code Flaw Repair of Service Water System Manual Valve MV-SW135

ML13339A740
Person / Time
Site:	Palisades
Issue date:	12/03/2013
From:	Vitale A Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PNP 2013-082
Download: ML13339A740 (61)

Text

Entergy Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 Tel 269 764 2000 Anthony J. Vitale Site Vice President PNP 2013-082 December 3, 2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Relief Request Number 4-17, Proposed Alternative, Request for Relief from Immediate ASME Code Flaw Repair of Service Water System Manual Valve MV-SW135 Palisades Nuclear Plant Docket 50-255 License No. DPR-20

Dear Sir or Madam:

Pursuant to 10 CFR 50.55a(a)(3)(ii), Entergy Nuclear Operations, Inc. (ENO) hereby requests NRC approval of the Request for Relief for a Proposed Alternative for the Palisades Nuclear Plant (PNP). This alternative is for the current fourth 10-year inservice inspection interval.

This Request for Relief is submitted because a through-wall flaw was discovered in a service water system, 4-inch cast carbon steel valve body within an ASME Class 3 system. ENO has performed an operability evaluation of the through-wall flaw and determined that the valve continues to be capable of performing its required safety functions and is not susceptible to sudden or catastrophic failure. Immediate repair or replacement of the valve would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Summary of Commitments This letter identifies four new commitments and no revisions to existing commitments.

Refer to Attachment 2.

-ýo047

PNP 2013-082 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on December 3, 2013.

Sincerely, ajv/jse Attachments:

1. Relief Request Number RR 4-17 Proposed Alternative

2. List of Regulatory Commitments

3. Operability Evaluation No. CR-PLP-2013-04613 cc:

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

ATTACHMENT 1 ENTERGY NUCLEAR OPERATIONS, INC.

PALISADES NUCLEAR PLANT Relief Request Number RR 4-17 Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(ii)

Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality and Safety

1. ASME Code Component(s) Affected / Applicable Code Edition Components / Numbers:

Code of Record:

==

Description:==

Service water system manual valve MV-SW135, American Society of Mechanical Engineers (ASME) Class 3, manually operated gate valve manufactured by Anchor/Darling, SA-216 Grade WCB cast carbon steel material ASME Section Xl, 2001 Edition through 2003 Addenda as amended by 10 CFR 50.55a Service water manual valve MV-SW135, located on the discharge side of component cooling water (CCW) heat exchanger E-54A Unit / Inspection Interval:

Palisades Nuclear Plant / Fourth 10-Year Interval

2. Applicable Code Requirements

The ASME Boiler and Pressure Vessel Code, Rules for Inservice Inspection of Nuclear Power Plant Components, Section Xl, 2001 Edition through 2003 Addenda, as amended by 10 CFR 50.55a.

A pin hole leak has developed in the body of valve MV-SW135. Valve MV-SW135 is part of the ASME Code Class 3 portion of the service water system. The request for relief applies to the requirements of ASME Code Section Xl, 2001 Edition through 2003 Addenda, Article IWD-3000, which establishes flaw size acceptance standards (IWD-3500) and provides analytical evaluation criteria (IWD-3600) for flaws identified during performance of inservice inspections and tests. In the 2001 Edition through 2003 addenda, IWD-3500 and IWD-361 0 default to IWC-3500 and IWC-361 0, respectively. IWC-361 0 defaults to IWB-361 0. IWB-361 0 does not include analytical evaluation criteria for acceptance of through-wall valve body flaws.

Code Case N-513-3, "Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping, Section Xl, Division I," which has been conditionally approved by the NRC in Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability, ASME Section Xl, Division 1,," provides analytical evaluation Page 1 of 5

rules for temporary acceptance of flaws in piping. However, Code Case N-513-3 does not apply to through-wall flaws located in the pressure retaining base material of a valve. Paragraph 1(a) and 1(a)(1) of Code Case N-513-3 state:

"These requirements apply to the ASME Section III, ANSI B31.1, and ANSI B31.7 piping, classified by the Owner as Class 2 or 3. The provisions of this Case do not apply to the following: pumps, valves, expansion joints and heat exchangers;"

3. Reason for Request

On October 25, 2013, a pin hole leak was identified in the valve body of four inch manual valve MV-SW135, "Component Cooling Water Heat Exchanger E-54A Service Water Outlet CV-0823 Bypass." The leak was located on the inlet side near the weld connecting the valve to the upstream tapered flange, and was measured to be 3.5 mL/min.

During extent of condition investigation efforts, volumetric ultrasonic testing was conducted on the valve body, the upstream tapered flange, the weld between the valve body and the upstream tapered flange, and the downstream piping. Ultrasonic testing of the valve body was completed in the inlet and outlet areas of the valve, including the area surrounding the pin hole leak. No significant thinning was detected.

Ultrasonic testing of the weld connecting the valve and the upstream tapered flange identified wall thinning, with the thickness of the remaining material measuring as thin as 0.102 inches. Ultrasonic testing of the tapered flange and downstream piping did not uncover material thinning.

No other leakage was visually observed elsewhere in the service water system discharge piping from CCW heat exchangers E-54A and E-54B.

NRC Inspection Manual Part 9900: Technical Guidance, "Operability Determinations &

Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality of Safety," Appendix C, "Specific Operability Issues," Item C.1 1, "Flaw Evaluation" (dated April 16, 2008), addresses evaluations of ASME Class 2 and Class 3 system components with through-wall flaws. When ASME Class 2 or Class 3 components do not meet ASME Code acceptance standards, the requirements of a NRC-endorsed ASME Code Case, or NRC approved alternative, then a determination of whether the degraded or nonconforming condition results in a Technical Specification required system, structure, or component being inoperable is required.

This section of the manual also states that whenever a flaw does not meet ASME Code or construction code acceptance standards or the requirements of an NRC endorsed ASME code case, a relief request needs to be submitted in a timely manner after completing the operability determination process documentation.

An operability evaluation for MV-SW135 was performed (see Attachment 3). The operability evaluation is based on the approach given in ASME Boiler and Pressure Page 2 of 5

Vessel Code, Code Case N-513-3, "Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section Xl, Division 1," January 26, 2009. Code Case N-513-3 was conditionally approved by the NRC in Regulatory Guide 1.147. This Code Case contains requirements that may be used for the evaluation of through-wall flaws in Class 2 or 3 piping only, but is not intended for the evaluation of flaws in valve bodies.

The pin hole leak is located on the upstream side of MV-SW135, near the welded connection to a tapered flange. The valve is on a four inch diameter bypass line that connects upstream to a 16 inch diameter service water discharge line from the CCW heat exchanger E-54A and connects downstream to a 24 inch service water line that flows directly to Lake Michigan. The bypass line contains CCW heat exchanger E-54A temperature control valve CV-0821, which is maintained in a throttled position to regulate flow through the CCW heat exchanger E-54A during normal operation.

Valve MV-SW135 provides an isolation function for the upstream CV-0821. Since MV-SW135 discharges directly to Lake Michigan, leakage from the valve has no effect on the supply of service water to required loads. The valve is not part of the containment isolation system and is not part of the primary coolant system pressure boundary. The valve does not have a safety function to close. It is normally open and is closed only to support maintenance activities involving CV-0821.

The system design pressure is 100 pounds per square inch gage (psig) and design temperature is 300 degrees F. System maximum operating pressure is 125 psig and maximum operating temperature is 170 degrees F.

Valve MV-SW135 is located in the CCW room, outside of the containment building.

The flooding analysis for the CCW room postulates failure of an 18 inch pipeline within the room, and concludes that no equipment required for safe plant shutdown would be affected by the maximum flood levels within the room from the piping failure. Any leakage from the four-inch MV-SW135 would be bounded by the discharge from the postulated 18 inch pipe break.

Valve MV-SW135 is not isolable. The valve can be isolated from the upstream portion of the service water system but not from the downstream portion of the system, which discharges to Lake Michigan. Performing a Code repair/replacement activity now to correct the flaw discovered in MV-SW135 would create a hardship based on the potential risks associated with unit cycling and emergent equipment issues incurred during shutdown and startup evolutions.

No compensating increase in the level of quality and safety would be gained by immediate repair of the flaw. The operability evaluation of the through-wall flaw determined that the affected manual valve continues to be capable of performing its required safety functions and is not susceptible to sudden or catastrophic failure.

Attached to the operability evaluation is an evaluation that addresses the through-wall flaw in the manual valve and the thinning of the weld between the valve body and the upstream tapered flange.

Page 3 of 5

4. Proposed Alternative and Basis for Use

The request for relief applies to the requirements of ASME Code Section Xl, 2001 Edition through 2003 Addenda. As noted in Section 2 of this request, Article IWD-3000, establishes flaw size acceptance standards (IWD-3500) and provides analytical evaluation criteria (IWD-3600) for flaws identified during performance of inservice inspections and tests. However, these Code revisions do not include analytical evaluation criteria for acceptance of through-wall flaws in pressure retaining base material of ferritic valves. While Code Case N-513-3 provides analytical evaluation criteria to accept through-wall flaws in low energy Class 2 and 3 piping, the Code Case does not apply to through-wall flaws in valves. Pursuant to 10CFR50.55a(3)(ii), ENO proposes an alternative to the scope restriction of paragraph 1 (a)(1) that would allow application of Code Case N-513-3 to valves. More specifically, ENO proposes to use Code Case N-513-3 to temporarily accept a through-wall flaw in a moderate energy Class 3 valve.

ENO evaluated the as-found condition of the valve and proposes to temporarily accept the condition of the valve to allow continued operation instead of performing a repair/replacement activity (see Attachment 3). The as-found condition was evaluated using the provisions of the approved alternative Code Case N-513-3, except that paragraph 1 (a)(1) of the Code Case states that the provisions of the Code Case do not apply specifically to valves. The through-wall flaw in the valve body is located near the weld to the upstream tapered flange, and this section of the valve body is similar to a pipe. The evaluation concluded, in part, that the through-wall flaw is stable and the valve will not fail catastrophically under design loading conditions.

This proposed alternative to use Code Case N-513-3 is based on ENO performing the following actions.

1. ENO will perform a daily visual walkdown of manual valve MV-SW135, with the insulation removed, to confirm that the analysis from ultrasonic testing (UT) examinations remains valid (i.e., no new significant leakage) in accordance with Section 2(f) of Code Case N-513-3.

2. ENO will perform a monthly measurement of the MV-SW135 leak rate.

3. ENO will perform a monthly UT examination that bounds the two thinned locations (i.e., the valve body pin hole leak and the weld between the MV-SW135 valve body and the upstream tapered flange) to validate the flaw analysis completed in support of the operability evaluation in accordance with Section 2(e) of ASME Code Case N-513-3.

4. ENO will repair or replace manual valve MV-SW135 no later than when either (1) the predicted flaw size from either periodic inspection or by flaw growth analysis exceeds the acceptance criteria, in accordance with Section 2(h) of Code Case N-513-3, or Page 4 of 5

(2) during the next scheduled outage, in accordance with Section 2(h) of Code Case N-513-3, whichever occurs first.

The next scheduled outage is the refueling outage planned to begin in January 2014.

5. ENO performed an extent of condition UT examination at a minimum of five of the most susceptible and accessible locations within 30 days in accordance with Section 5(a) of Code Case N-513-3.

The following five service water system valve bodies were examined:

" MV-SW136 (Component Cooling Water Heat Exchanger E-54B Service Water Outlet CV-0826 Bypass)

" MV-SW278 (Diesel Generator 1-1 Service Water Outlet)

" CV-0823 (Component Cooling Water Heat Exchanger E-54A Service Water Outlet)

CV-0826 (Component Cooling Water Heat Exchanger E-54B Service Water Outlet)

" CV-0836 (Lube Oil Cooler E-15B Control Valve)

The UT examinations did not identify any evidence of wall thinning at the locations examined.

Basis: Attachment 3, "Operability Evaluation No. CR-PLP-2013-04613," contains the basis for considering the valve operable but degraded/non-conforming with compensatory measures. The operability evaluation and its attached documentation provide the basis for the requested relief from Code Case requirements.

5. Duration of Proposed Alternative

The requested Code relief shall be used until Code repair/replacement activities are performed on the valve body either during the next scheduled outage or when the predicted flaw size exceeds acceptance criteria. The next scheduled outage is the refueling outage planned to begin in January 2014.

6. Precedent This relief request is similar in nature to the relief request listed below, which was authorized by the NRC and involved a through-wall flaw in an ASME Class valve that was evaluated using guidance in Code Case N-513.

McGuire Nuclear Station, Unit 1, March 26, 2008, Accession Number ML080580577.

Page 5 of 5

ATTACHMENT 2 LIST OF REGULATORY COMMITMENTS Two pages follow

List of Regulatory Commitments The following table identifies those actions committed to by Entergy Nuclear Operations, Inc.

(ENO) in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check One)

SCHEDULED COMMITMENT ONE-COMPLETION DATE TIME CONTINUING (If Required)

ACTION COMPLIANCE ENO will perform a daily visual walkdown The next refueling of manual valve MV-SW135 to confirm that outage, or upon repair the analysis from ultrasonic testing (UT)

X or replacement of the examinations remains valid (i.e., no new valve, whichever significant leakage) in accordance with occurs first. The next Section 2(f) of Code Case N-513-3.

refueling outage is scheduled to begin in January 2014.

ENO will perform a monthly measurement The next refueling of the MV-SW135 leak rate.

outage, or upon repair X

or replacement of the valve, whichever occurs first. The next refueling outage is scheduled to begin in January 2014.

ENO will perform a monthly UT The next refueling examination that bounds the two thinned outage, or upon repair locations (i.e., the valve body pin hole leak X

or replacement of the and the weld between the MV-SW 135 valve, whichever valve body and the upstream tapered occurs first. The next flange) to validate the flaw analysis refueling outage is completed in support of the operability scheduled to begin in evaluation in accordance with Section 2(e)

January 2014.

of ASME Code Case N-513-3.

1 of 2

ENO will repair or replace manual valve MV-SW135 no later than when either (1) the predicted flaw size from either periodic inspection or by flaw growth analysis exceeds the acceptance criteria, in accordance with Section 2(h) of Code Case N-513-3, or (2) during the next scheduled outage, in accordance with Section 2(h) of Code Case N-513-3, whichever occurs first.

The next scheduled outage is the refueling outage planned to begin in January 2014.

X The next refueling outage, or upon repair or replacement of the valve, whichever occurs first. The next refueling outage is scheduled to begin in January 2014.

2 of 2

ATTACHMENT 3 OPERABILITY EVALUATION NO.

CR-PLP-2013-04613 50 pages follow

Operability Evaluation Page 1 of 50

1.

Condition Report NoiOperability Evaluation No. CR-PLP-2013-04613

2.

Summary of Operability Evaluation; On October 25, 2013, a Nuclear Plant Operator on rounds discovered a pinhole leak on the inlet side of the valve body of MV-SW 135, E-54A SW OUTLET CV-0823 BYPASS, leaking at a rate of 3.5 mlfmin. The leak was not spraying on any equipment. Based on the amount of water found under the valve it was believed that the leak had developed recently.

The Service Water System, while degraded, continues to be able to fulfill its Safety Function to remove heat loads from the Plant under all conditions, and is not expected to suddenly or catastrophically fail and/or jeopardize other Safety Related Equipment in the Component Cooling Water Room as a result of the pinhole leak and wall thinning in MV-SW135.

This evaluation is based upon NRC Inspection manual 9900 guidance, significant operating experience, and flaw evaluations using guidance from ASME Code Case N-513-3. Because the code case is not applicable to valves, a Relief Request will be submitted to the NRC (CR-PLP-2013-04613 CA-6).

Structural evaluations concluded that the through wall leak was determined to be less than the allowable flaw length. While conducting UT examinations on the MV-SW135 valve body, upstream piping, downstream piping, and the weld between the MV-SW135 valve body and tapered flange, wall thinning was identified on the weld between the MV-SW135 valve body and the tapered flange. However, the wall thickness at the thinnest location was still greater than the calculated minimum wall thickness and therefore acceptable. Therefore, there is no concern with the valve catastrophically failing.

Since the through-wall flaw of MV-SW135 was found structurally acceptable by UT examinations and subsequent analysis, immediate repair of the flaw is not required. Additionally, since Code Case N-513-3 is not applicable to valves, a relief request must be granted from the NRC.

Because compensatory measures to confirm the analysis conditions used in the evaluation have been developed, the operability status of MV-SW1 35 is recommended to be OPERABLE-COMP MEAS.

3.

Basis for Operability Evaluation attached. []

4.

Are there any other affected SSCs? N No EL Yes

5.

Validity of the Immediate Operability Determination: (valid or invalid and why)

The Immediate Operability Determination of the Service Water System states:

The Service Water System is required per Technical Specification LCO 3.7.8 "Service Water System."

Applicable in Modes 1,2,3 and 4. The current leak location from MV-SW135, E-54A SW OUTLET CV-0823 BYPASS, is small (< 4 ml/min) and does not affect the ability of the system to perform its designated Safety Functions.

Per EN-OP-104, Operability Determination Process, Reasonable Expectation of Operability exists based on knowing the degradation mechanism from previous operating experience with the SW System and the insignificant size of the leak.

Based on current information and the ability of the system to still perform its designated Safety Functions it is being classified as OPERABLE-OP EVAL with Corrective Actions being assigned to perform an Operability Evaluation.

Operability Determination is based on Engineering Input in EC 47464. See attachment 9.2 and EC 47464 Compensatory actions are in place to monitor the leakage from MV-SW135 E-54A SW OUTLET CV-0823 BYPASS, and any further degradation will have a new CR written and Operability Re-evaluated.CA#1 has been issued to Engineering to provide an Operability Evaluation of this condition in accordance with procedure EN-OP-104. Due Date = 11/01/2013 @ 1300.

The Immediate Operability Determination of the Service Water System is accurate. A leak in MV-SW135 in the Component Cooling Water Room has no impact on the operation of the Service Water System discharge, since this is the section of open-ended pipe that discharges to the Make-up Basin. It is only an issue from a Code Compliance standpoint The greater potential impact from a leak in this portion of piping has to do with the potential flooding In the Component Cooling Water Room, and thus the operability of the Component Cooling Water (CCW) pumps.

Calculation EA-C-PAL-95-1526-01, "Internal Flooding Evaluation for Plant Areas Outside of Containment" evaluates the Component Cooling Water room for postulated internal flooding events. The bounding pipe break for the CCW room is not the 4" Service Water line, but rather the EB-9-18" Feedwater line. The water level will reach a maximum level of 20" within the CCW room based on the bounding conditions. No equipment required for safe shutdown will be affected by this flood level. The CCW pumps are considered to be flooded at 20.5". The "Jail House" door between the CCW room and the Turbine Building is configured in way that a hinged swing gate to relieve potential flooding in the CCW room. There is minimal threat with respect to room flooding should a leak suddenly propagate to an unmanageable volume.

6.

Recommendation:

EL ADMIN-NA El OPERABLE-DNC El INOPERABLE El EQUIPMENT NON-FUNCTIONAL El OPERABLE

[

OPERABLE-COMP MEAS El EQUIPMENT FUNCTIONAL El NOT REQUIRED

7.

Identify any Limitations, Long Term Actions and/or Compensatory Measures to maintain Operability:

El N/A 0 Yes (List WO, CA, tracking no., etc.)

1. Until MV-SW135 is replaced, perform UT examinations (not to exceed 30 days within each other) bounding the two thinned locations (the pinhole leak and the weld between the MV-SW135 valve body and the tapered flange on the inlet side) to validate the flaw analysis completed in the Structural Integrity Reports. WR 322581

2.

Perform a daily visual walkdown to confirm analysis from NDE examinations remain valid (i.e.

No new significant leakage in accordance with Section 2(f) of N-513-3). Operations to verify during rounds of the Component Cooling Water Room, the Service Water leakage is contained and not leaking on other equipment. Quantitative analysis not needed. An ODMI will be developed to establish quantitative trigger points. This action can be closed once MV-SW135 Is replaced. (CR-PLP-2013-04613 CA-3).

3. Submit relief request to the Nuclear Regulatory Commission in accordance with NRC Inspection Manual Part 9900: Technical Guidance "Operability Determinations & Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety." (CR-PLP-2013-04613 CA-6).

4. Perform extent of condition NDE examination at a minimum of five susceptible locations within 30 days in accordance with ASME Code Case N-513-3. Owners: Programs Engineering. Due Date: 11/24/2013 (CR-PLP-2013-04613 CA-7). WR 322424, WR 322425, WR 322426, WR 322428, WR 322430 Process Applicability Determination and subsequent reviews have been completed for Compensatory Measures required to maintain or restore Operability.

[ Yes ElNo El N/A Approvals:

Preparer (Name/Date):

//dd0JrfA:~ 10rio el#vr7;~i..~?

~r Independent Reviewer (Name/Date):

Lt'...,,

/

Additional Reviews (Assign thru CA Process)lgy (Name/Date):

CA No.

Additional Reviews (Assign thru CA Process) By (Name/Date):

CA No.

Engineering Manager Approval By (Complete only if not entered in PCRS) (Print/Sign/Date):

Shift Manager (Complete only if not entered in PCRS) (Print/Sign/Date):

Send a copy of the Operability Evaluation to the System Engineer for use in the System Health Report.

(Attach additional pages as necessary)

ATTACHMENT 9.6 OPERABluTy EVALUATION BASis FORMAT Sheet I of 11 Use the following format for documenting the basis of the Operability Evaluation.

1.

Summary Statements Succinctly state the Degraded or Nonconforming Condition in clear, concise terminology. Summarize the results of the evaluation, succinctly stating the Operability recommendation.

On October 25, 2013, a Nuclear Plant Operator on rounds discovered a pinhole leak on the inlet side of the valve body of MV-SW 135, E-54A SW OUTLET CV-0823 BYPASS, leaking at a rate of 3.5 mL/min. The leak was not spraying on any equipment. Based on the amount of water found under the valve it was believed that the leak had developed recently.

During extent of condition efforts, Ultrasonic Testing (UT) examinations on the MV-SW135 valve body, upstream piping, downstream piping, and the weld between the valve body and the tapered flange were completed. Wall thinning was identified on the weld between the MV-SW135 and the tapered flange with the remaining material thickness as low as 0.102". Nominal pipe thickness is 0.237".

Identify the safety function of the system being reviewed.

The Service Water System (SWS) provides a heat sink for the removal of process and operating heat from safety related components during a Design Basis Accident (DBA) or transient. During normal operation or a normal shutdown, the SWS provides this function for various safety related and non-safety related components. The segment under consideration discharges into the open-ended Service Water return line to Lake Michigan.

There are two SWS trains, each associated with a Safeguards Electrical Train which are described in Technical Specification 3.8.9, "Distribution Systems - Operating." The SWS train associated with the Left Safeguards Train consists of one SWS pump (P-7B), associated piping, valves, and controls for the equipment to perform their safety function. The SWS train associated with the Right Safeguards Train consists of two SWS pumps (P-7A, P-7C), associated piping, valves, and controls for the equipment to perform their safety function.

Per TS 3.7.8, Service Water System (SWS), LCO 3.7.8, Two SWS trains shall be OPERABLE in Modes 1, 2, 3, and 4.

In Modes 1, 2, 3, and 4, the SWS System is a normally operating system, which is required to support the OPERABILITY of the equipment serviced by the SWS and required to be OPERABLE in these Modes. In Modes 5 and 6, the OPERABILITY requirements of the SWS are determined by the systems it supports.

The basis for determination of Operability.

NRC Inspection Manual 9900: Technical Guidance, "Operability Determinations & Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality of Safety,"

Appendix C, "Specific Operability Issues," Item C.1 1, "Flaw Evaluation" addresses evaluations of ASME Class 2 and Class 3 SSCs with through-wall flaws. When ASME Class 2 or Class 3 components do not meet ASME Code acceptance standards, the requirements of an NRC endorsed ASME Code Case, or NRC approved alternative, then a determination of whether the degraded or nonconforming condition results In a TS required SSC being inoperable is required. In order to determine the operability of the SSC, the degradation mechanism must be visually discernible or there must be substantial operating experience with the identified degradation mechanism in the affected system.

In addition, the NRC issued Generic Letter (GL) 90-05, "Guidance for Performing Temporary Non-Code Repair of ASME Code Class 1, 2, and 3 Piping," permits licensees to consider either the "through-wall flaw" or the "wall thinning" flaw evaluation approach when assessing the structural integrity of moderate energy piping with identified flaws. Whenever a flaw does not meet ASME Code or construction code acceptance standards or the requirements of an NRC endorsed ASME code case, a relief request needs to be submitted in a timely manner after completing the operability determination process documentation.

Palisades has significant Operating Experience with MV-SW1 35. In October 2000, while removing CV-0821, CCW HEAT EXCH E-54A TEMP CONTROL, cavitation/corrosion damage was identified on the flange between CV-0821 and MV-SW135 (CR-PLP-2000-05261). The flange face area was cleaned, a new valve body for CV-0821 was installed, and the system was returned to operation.

In April 2006, while performing work to replace CV-0821, minor cavitation/corrosion damage was again found on MV-SW135 (CR-PLP-2006-01759). The cavitation was located on the Interior of the valve and on the outlet flange face.

In October 2010, during planned maintenance, maintenance workers noted excessive corrosion/pitting on valve MV-SW1135, E-54A SW OUTLET CV-0823 BYPASS (CR-PLP-2010-04738).

Microbiologically Influenced Corrosion (MIC) Program owner was contacted via Operations to perform walkdown and disposition damage. Severe water/droplet impingement damage was noted on flanged surface and interior surfaces of valve. The flange was replaced during 1 R21 under WO 253009.

In December 2011, minimal temperature differential was identified across E-54A CCW Hx (CR-PLP-2011-07085). The apparent cause and radiography of the valve confirmed that MV-SW1135, the outlet isolation of CV-0821, was damaged causing a failure of the gate valve. This failure mechanism damaged the internals of the manual valve causing it to close, thereby reducing flow. It was attributed to the cavitation due to being downstream of the constantly throttled valve, CV-0821. MV-SW1 35 was replaced in March 2012 under WO 305504.

Therefore, Palisades has substantial operating experience with the identified degradation mechanism affecting MV-SW135.

Palisades also has substantial operating experience with cavitation throughout the Service Water System. On July 22, 2013, the NRC proposed a self-revealed green finding associated with the history of Service Water System leaks since 1993 (CR-PLP-2013-03184). Specifically, the site failed to implement monitoring/preventative maintenance process/program corrective actions to mitigate leakage from the service water system caused by cavitation induced erosion.

The finding is a green NCV of 10 CFR 50 App B Criterion V, Procedures. The finding has a cross-cutting aspect of P.2(b), Implements OE. The NRC provided the following condition reports that were reviewed as part of their inspection: CR-PLP-1993-00072, CR-PLP-1 999-00690, CR-PLP-2006-03743, CR-PLP-2007-00376, CR-PLP-2011-03207, CR-PLP-2012-05813 and CR-PLP-2012-06323.

As a result of this Condition Report, a plan to detect cavitation through UT examinations and replace components with identified wall thinning as necessary is being developed.

A structural evaluation (PLP-RPT-13-00047 issued under EC47483) was performed using the guidance from Generic Letter (GL) 90-05, "Guidance for Performing Temporary Non-Code Repair of ASME Code Class 1, 2, and 3 Piping," which permits licensees to consider either the "through-wall flaw" or the "wall thinning" flaw evaluation approach when assessing the structural integrity of moderate energy piping with identified through-wall flaws.

Although ASME Code Case N-513-3, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or Class 3 Piping Section XI, Division 1," does not apply to valves, the guidance and calculations provided in the code case were used to bound the flaws.

The through wall evaluation Code Case N-513-3 utilized section 3.2 "Nonplanar Flaws" subsection C for a branch reinforcement method as well as subsection D which provides an alternative calculation method. Section 3.2(d) provides guidance on bounding the nonplanar flaw by using two independent flaws, one axial and one circumferential. The two independent planar flaw evaluations were determined to be more conservative than the branch reinforcement method of section 3.2(c). The calculations stemming from section 3.2(d), as such, was used as the acceptance criteria. However both calculations show the MV-SW135 through-wall flaw is stable and will not fail catastrophically under design loading including FSAR Chapter 14 conditions.

Additionally, Code Case N-513-3 was used to bound the wall thinning regions identified on the weld between the valve body of MV-SW1 35 and the tapered flange. Section 3.2(b) was utilized to determine a minimum wall thickness. The calculation concludes that the current thinnest wall region (0.102") is acceptable per the code case N-513-3 Section 3.2(b) as long as it remains above the calculated minimum wall of 0.020".

Compensatory measures were devised with guidance from Code Case N-51 3-3. Reference Section 6 of this Operability Evaluation.

Since the through-wall flaw of MV-SW135 was found structurally acceptable by UT examinations and subsequent analysis, immediate repair of the flaw is not required. Additionally because Code Case N-513-3 is not applicable to valves, relief request must be granted from the NRC. A relief request Is being developed for not meeting ASME Code or construction code acceptance standards or the requirements of an NRC endorsed ASME code case and will be submitted in a timely manner. (CR-PLP-2013-04613 CA-6)

Because compensatory measures to confirm the analysis conditions used in the evaluation have been developed, the operability status of MV-SW135 is recommended to be OPERABLE-COMP MEAS.

Replacement of MV-SW135 shall be performed no later than when the predicted flaw size from either periodic inspection or by flaw growth analysis exceeds the acceptance criteria or the next scheduled Refueling Outage (1R23) whichever occurs first. Refer to the section 6 for more information.

If so, a definitive statement that the system is capable of performing its Specified Safety Function.

The Service Water System, while degraded, continues to be able to fulfill its Safety Function to removed heat loads from the Plant under all conditions, and it will not suddenly or catastrophically fail and/or jeopardize other Safety Related Equipment In the Component Cooling Water Room as a result of the pinhole leak in MV-SW135.

The structural evaluation concluded that ASME Code margins with regards to wall thicknesses around the pinhole leak are still being met. Therefore, there is no concern with the valve catastrophically failing.

2.

References List all procedures, specifications, standards, codes, calculations, drawings, regulatory documents, etc.,

including revision numbers that were used in the evaluation.

1. FSAR Section 9.1, Rev. 25

2. Technical Specification LCO 3.7.8, Amend 199

3. Piping and Instrument Diagram - Service Water System, M-208, Sheet 1A, Revision 62

4. Piping Isometric Drawing M-101, Sheet 2744, Revision 11

5. Piping Class Sheet, Class HB, Drawing M-260, Sheet 1I/HB, Revision 36

6.

Piping Class Summary, Class HB-23, Drawing-259, Page 24, Revision 24

7. Condition Report CR-PLP-2000-05261

8. Condition Report CR-PLP-2006-01759

9. Condition Report CR-PLP-2010-04738

10. Condition Report CR-PLP-2011-03207

11. Condition Report CR-PLP-2011-07058

12. Condition Report CR-PLP-2012-05813

13. Condition Report CR-PLP-2013-03184

14. Condition Report CR-PLP-2013-04613

15. Work Order 365955, "MV-SW135; PINHOLE LEAK ON INLET BODY WELD"

16. EC 47464 "Immediate Operability Recommendation for CR-PLP-2013-04613, MV-SW135 leak in valve body"

17. Report PAL-UT-1 3-053, Work Order 365955 task 2, 'UT Erosion/Corrosion Examination', MV-SW135

18. Report PAL-UT-13-054, Work Order 365955 task 2, 'UT Erosion/Corrosion Examination', Tapered Flange to MV-SW135

19. Report PAL-UT-1 3-055, Work Order 365955 task 2, 'UT Erosion/Corrosion Examination',

Downstream Pipe from MV-SW 135

20. Report PAL-UT-1 3-056, Work Order 365955 task 2, 'UT Erosion/Corrosion Examination', Weld Between 4" Cast Valve Body (MV-SW 135) and Tapered Flange

21. EA-C-PAL-95-1526-01, "Internal Flooding Evaluation for Plant Areas Outside of Containment"

22. PLP-RPT-13-00047, SIA Report No. 1301385.401.RA "Flaw Tolerance Evaluation of Leaking MV-SW135 Service Water Valve Body" issued under EC47483

23. ASME Code Case N-513-3, "Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, Division I"

24. NRC Inspection Manual Part 9900: Technical Guidance "Operability Determinations &

Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety."

25. PAD13-0333

3.

Detailed Problem Statements Clearly identify and discuss each item of Degraded or Nonconforming Condition.

On October 25, 2013, a Nuclear Plant Operator on rounds discovered a pinhole leak on the inlet side of the valve body of MV-SW1 35, E-54A SW OUTLET CV-0823 BYPASS, leaking at a rate of 3.5 mL/min. The leak was not spraying on any equipment Based on the amount of water found under the valve it was believed that the leak had developed recently.

During extent of condition efforts, Ultrasonic Testing (UT) examinations on the MV-SW135 valve body, upstream piping, downstream piping, and the weld between the valve body and the tapered flange were completed. Wall thinning was identified on the weld between the MV-SW135 and the tapered flange with the remaining material thickness as low as 0.102". Nominal pipe thickness is 0.237".

Describe the Specified Safety Function performed by the equipment The Service Water System is designed to supply lake water as the cooling medium (Ultimate Heat Sink) for removal of waste heat from the nuclear plant and steam plant auxiliary systems during normal, shutdown or emergency conditions. The Critical Service Water piping system consists of two main supply lines; one serving the Component Cooling heat exchangers, one serving the Containment Air Coolers.

The discharge piping system consists primarily of a 16-inch line from the Containment Air Coolers and a 16-inch line from the Component Cooling heat exchangers. These two discharge lines are joined Into a single 24-inch discharge line that routes water through the West Engineered Safeguards room, thereby preventing flooding of the below-grade room by the Service Water discharge line. After the single 24-inch discharge line receives the service water from the engineered safeguards pumps seal coolers and the engineering safeguards room air coolers, the line is run underground to the discharge structure.

The remaining service water loads, including the emergency diesel generator lube oil and jacket water coolers, control room HVAC, instrument air compressor aftercoolers, auxiliary building air-conditioning condensers and noncritical equipment return headers are discharged into a common 16-inch header.

This header runs underground from the lube oil room to join the common 24-inch discharge return line that is routed to the cooling tower makeup basin.

The observed leak is on the inlet side of MV-SW135's valve body. The valve Is flanged to a spool piece which connects to the 24" discharge header which flows to Lake Michigan. The function of the valve is to provide isolation of CV-0821. CV-0821 is in a throttled position to regulate flow through the CCW Hx during normal operation. In an accident scenario, CV-0821 is designed to close thus closing the supply of water to MV-SW135. The leak is located on the discharge line and therefore would not impact the supply of Service Water to required loads. Because all applicable heat loads have been applied, this condition is primarily a code compliance issue rather than a nuclear safety issue.

Describe any background of events leading to the Degraded or Nonconforming Condition, include times, dates, documents, personnel, etc. involved with related circumstances.

Palisades has significant Operating Experience with MV-SW135. In October 2000, while removing CV-0821, CCW HEAT EXCH E-54A TEMP CONTROL, cavitation/corrosion damage was identified on the flange between CV-0821 and MV-SW 135 (CR-PLP-2000-05261). The flange face area was cleaned, a new valve body for CV-0821 was installed, and the system was returned to operation.

In April 2006, while performing work to replace CV-0821, minor cavitation/corrosion damage was again found on MV-SW1 35 (CR-PLP-2006-01759). The cavitation was located on the interior of the valve and on the outlet flange face.

In October 2010, during planned maintenance, maintenance workers noted excessive corrosion/pitting on valve MV-SW135, E-54A SW OUTLET CV-0823 BYPASS (CR-PLP-2010-04738).

Microbiologically Influenced Corrosion (MIC) Program owner was contacted via Operations to perform walkdown and disposition damage. Severe water/droplet impingement damage was noted on flanged surface and interior surfaces of valve. The flange was replaced during 1 R21 under WO 253009.

In December 2011, a minimal temperature differential was identified across E-54A CCW Hx (CR-PLP-2011-07085). The apparent cause and radiography of the valve confirmed that MV-SW135, the outlet isolation of CV-0821, was damaged causing a failure of the gate valve. This failure mechanism damaged the internals of the manual valve causing it to close, thereby reducing flow. It was attributed to the cavitation due to being downstream of the constantly throttled valve, CV-0821. MV-SW135 was replaced in March 2012 under WO 305504.

Additionally, piping downstream of throttled valves has contributed to Palisades' Operating Experience. The piping downstream of CV-0824, SW from Containment, and CV-0823, CCW Hx E-54A SW Outlet, have recently shown pinhole leaks. During 1 R22, the piping downstream of CV-0824 was replaced with cavitation resistant material under WO 282307 (CR-PLP-2011-03207). During the forced outage for CRD-24 repairs (August 2012), the piping downstream of CV-0823 was temporarily repaired under WO 324812 per code case N-661 and will be returned to OPERABLE status in 1 R23 (CR-PLP-2012-05813). Both through wall leak sites were attributed to cavitation downstream of throttled valves, similar to MV-SWI 36 which is directly downstream of the throttled CV-0822.

Describe by what means and when the potential Degraded or Nonconforming Condition was discovered.

On October 25, 2013, a Nuclear Plant Operator on rounds discovered a pinhole leak on the inlet side of the valve body of MV-SW135, E-54A SW OUTLET CV-0823 BYPASS, leaking at a rate of 3.5 mLlmin. The leak was not spraying on any equipment. Based on the amount of water found under the valve it was believed that the leak had developed recently.

During extent of condition efforts, Ultrasonic Testing (UT) examinations on the MV-SW135 valve body, upstream piping, downstream piping, and the weld between the valve body and the tapered flange were completed. Wall thinning was identified on the weld between the MV-SW135 and the tapered flange with the remaining material thickness as low as 0.102". Nominal pipe thickness is 0.237".

Describe the failure mechanism.

Cavitation induced erosion is a known problem in the Service Water System at Palisades. In 2011, cavitation induced erosion caused pinhole leaks downstream of CV-0824, Service Water From Containment, near the heat affected zone of a downstream weld (CR-PLP-2011-03207). Several examples of cavitation induced erosion are documented in the background section.

For the present occurrence, NDE data indicated localized corrosionlerosion on the weld between the MV-SW135 valve body on the inlet side and the tapered flange.

In 2011, MV-SW135, was identified as failed due to cavitation induced erosion (CR-PLP-2011-07085).

This current event associated with MV-SW135 appears similar to the 2011 event. Similarly in 1999, caviation induced erosion caused a small pinhole leak to develop within the valve body of MV-SW136.

From the ACE performed under CR-PLP-2011-03207:

"Cavitation involves the formation of entrained gas in a process fluid due to a sudden pressure reduction; such as, may occur downstream of a throttled valve. The entrained gas bubbles collapse as fluid pressure increases. The dissipation of energy caused by the gas bubble collapse causes an erosive effect on system piping material."

CV-0821, CCW HEAT EXCH E-54A TEMP CONTROL, is designed as a throttled valve. CV-0821 has two main functions, throttled for flow, and closed. The temperature control valves regulate Service Water flow through the CCW Hx during normal Operations. This provides a constant throttled condition, and as such, cavitation downstream of the valve. Immediately downstream of the valve is MV-SW 135. This throttled flow passes through CV-0821 and produces the corrosionlerosion leading to the bounded locations.

4.

Assumptions Specifically state all assumptions made in the engineering evaluation.

1)

The current event is similar to past events and as such has similar causes

2)

A relief request will be submitted in a timely manner in accordance with NRC Inspection Manual 9900 for not meeting ASME Code or construction code acceptance standards or the requirements of an NRC endorsed ASME code case.

3)

A 125 psig value was used for the calculations performed. This is conservative as the maximum pressure this valve would experience is substantially less.

5.

Engineering Evaluation Provide an evaluation for each item in the detailed problem statements.

The evaluation summary should clearly indicate if the component can perform its specified TS function and the basis thereof.

As shown in the Structural integrity Reports (Reference 18), there is no current structural concern with the valve. There are no indications that the valve may catastrophically fail. The safety function of MV-SW1 35 is to act as a class boundary of the Service Water System. The valve has no active function.

Similar area of degradation in the valve body has been identified. Thus, the Service Water System, while degraded, continues to be able to fulfill its Safety Function to remove heat loads from the Plant under all conditions, and it will not fail and/or jeopardize other Safety Related Equipment.

If walk downs or inspections were conducted, details should be provided here or referenced in the attachment section, including names, dates, criteria and specific results.

During extent of condition efforts, Ultrasonic Testing (UT) examinations on the MV-SW135 valve body, upstream piping, downstream piping, and the weld between the valve body and the tapered flange were completed. Wall thinning was identified on the weld between the MV-SW135 and the tapered flange with the remaining material thickness as low as 0.102". Nominal pipe thickness is 0.237".

Describe the basis for recommending the systems OPERABLE (i.e., analysis, test or partial test, operator experience or technical judgment).

Operability is based upon the guidance from NRC Inspection Manual 9900, significant operating experience, and the analysis of the structural integrity of the valve using code case N-51 3-3 as guidance.

Inspection Manual 9900 Per 9900, "While ASME Section XI does not specifically provide flaw acceptance standards for components other than those specified in Table IWX-2500-1, its methods and standards may be applied to other components when appropriate as determined by the licensee."

In response to declaring a Class 2 or 3 components operable: "the degradation mechanism must be discernible from visual examination, or there must be substantial operating experience with the identified degradation mechanism in the affected system."

Operating Experience Palisades has significant Operating Experience with cavitation induced erosion in the Service Water System. EC 47464 was provided as Input into the Immediate Operability determination for CR-PLP-2013-04613 with information regarding several class 3 piping sections and specific operating experience with cavitation induced leaks.

Per Section 0.11 and C.12 of Inspection Manual 9900: "In performing the prompt operability determination, the licensee must evaluate the structural integrity of the leaking component using actual geometry of the through wall flaw characterized or bounded with volumetric examination methods."

Ultrasonic Testing measured wall thickness Indicative of cavitation Induced erosions based on Palisades significant operating experience.

ASME Code Case N-513-3 Because the valve body leakage is not within the bounds of a specific ASME or NRC approved code, a relief request must be submitted in a timely manner per Inspection Manual 9900. In order to provide a basis of Operability, the flaw location must be monitored. NRC approved ASME Code Case N-513-3 was used as guidance flaw evaluations.

Per the UT testing completed per WO 365955, MV-SW135 had two locations with significant wall thinning, one being a through wall leak and another on the weld between the MV-SW135 valve body on the inlet side and the tapered flanged.

In order to determine structural integrity of MV-SW135, Code Case N-513-3 was used. Both conditions represent non-planar flaws and such were analyzed using section 3.2 of Code Case N-513-3.

Per section 3.2(b) the minimum wall thickness (tmin) to maintain design requirements was calculated to be 0.020 inches. Using UT, the minimum wall thickness on the weld between the MV-SW135 valve body on the inlet side and the tapered flange was found to be 0.102". In accordance with Section 3.2(b) of N-513-3, a nonplanar flaw is acceptable as long as the remaining wall thickness is greater than or equal to tmln-Two methods of evaluation, both acceptable per Code Case N-513-3, were chosen to evaluate the through wall leak on the outlet of the valve body.

The through wall leak was evaluated using section 3.2(c) using the branch reinforcement method for a through wall leak in a thinning area. Alternatively, Section 3.2(d) was originally chosen to bound the condition using two planar flaws in conjunction.

The results of the branch reinforcement evaluation per section 3.2(c) was conservative by assuming uniform thinning across the valve body of the predicted minimum thickness surrounding the thinned through wall area. The resulting allowable through wall circular opening using the branch reinforcement methodology is 1.5 inches.

Two Independent planar evaluations were conducted as directed by section 3.2(d), one axial and one circumferential. The allowable flaw lengths were calculated using the predicted thinnest wall of 0.051",

which is based on the wear rate of the valve while in service. The circumferential allowable flaw length Is 0.41" while the allowable axial flaw length is 0.96" Based on UT measurements, the metal loss for the through wall leak was estimated to be 0.051 inches from now until approximately January 24, 2014. Periodic monitoring will ensure that the metal loss at the wall thinning region does not go below tW.

It should be noted that even if the metal loss rate were to exceed the predicted rate, the ASME Code margins for the MV-SW1 35 valve are maintained as long

as the degraded area with thickness below 0.102 inch is bounded by the corresponding allowable through-wall flaw lengths.

Structural integrity of the valve is shown through the flaw evaluation completed in PLP-RPT-13-00047.

This report shows the localized corrosion/erosion of the valve is not significant to the point at which a catastrophic failure would occur.

Since the degraded condition also involves compensatory measures to maintain operability this condition is recommended as OPERABLE-COMP MEAS.

Evaluate the Immediate Operability Determination for this condition and confirm or refute its validity.

Per EN-OP-1 04, "To determine if an ASME Class 2 or 3 SSC with a flaw is OPERABLE in an Immediate Determination, the degradation mechanism must be readily apparent. To be readily apparent, the degradation mechanism must be discernable from visual examination (as external corrosion or wear) or there must be substantial operating experience with the identified degradation mechanism in the affected SSC."

The Operability Determination for CR-PLP-2013-04316 declared the Service Water System OPERABLE-OP EVAL. The immediate Operability states:

The Service Water System is required per Technical Specification LCO 3.7.8 "Service Water System." Applicable in Modes 1,2,3 and 4. The current leak location from MV-SW135, E-54A SW OUTLET CV-0823 BYPASS, is small (< 4 mYmin) and does not affect the ability of the system to perform its designated Safety Functions.

Per EN-OP-104, Operability Determination Process, Reasonable Expectation of Operability exists based on knowing the degradation mechanism from previous operating experience with the SW System and the insignificant size of the leak.

Based on current information and the ability of the system to still perform its designated Safety Functions it is being classified as OPERABLE-OP EVAL with CA being assigned to perform an Operability Evaluation.

Operability Determination is based on Engineering Input in EC 47464. See attachment 9.2 and EC 47464 Compensatory actions are in place to monitor the leakage from MV-SW135 E-54A SW OUTLET CV-0823 BYPASS, and any further degradation will have a new CR written and Operability Re-evaluated. CA#1 has been issued to Engineering to provide an Operability Evaluation of this condition in accordance with procedure EN-OP-104. Due Date = 11/01/2013 @ 1300.

The overall assessment of the Service Water System is accurate.

A leak in MV-SW135 in the Component Cooling Water Room has no Impact on the operation of the Service Water System discharge, since this is the section of open-ended pipe that discharges to the Make-up Basin. It is only an issue from a Code Compliance standpoint. The greater potential impact from a leak in this portion of the piping has to do with the potential flooding in the Component Cooling Water Room, and thus the operability of the Component Cooling Water (CCW) pumps.

Calculation EA-C-PAL-95-1526-01, "Internal Flooding Evaluation for Plant Areas Outside of Containment" evaluates the Component Cooling Water room for postulated internal flooding events.

The bounding pipe break for the CCW room is not the 4" Service Water line, but rather the EB-9-1 8" Feedwater line. The water level will reach a maximum level of 20" within the CCW room based on the bounding conditions. No equipment required for safe shutdown will be affected by this flood level. The CCW pumps are considered to be flooded at 20.5". The "Jail House" door between the CCW room and

the Turbine Building is configured in way that a hinged swing gate to relieve potential flooding in the CCW room. There is minimal threat with respect to room flooding should a leak suddenly propagate to an unmanageable volume.

6.

Compensatory Measures Describe and recommend any Compensatory Measures needed to:

Maintain or enhance an OPERABLE but Degraded or Nonconforming SSC's capability to perform its Specified Safety Functions. This includes any periodic monitoring or testing to demonstrate continued operability.

While not directly applicable to this condition, because of the valve body leak, the Operability Evaluation and structural analysis is based on the content from ASME Code Case N-513-3. As such the Compensatory Measures were chosen with guidance from the Code Case.

1. Until MV-SW135 is replaced, perform UT examinations (not to exceed 30 days within each other) bounding the two identified thinned locations (the pinhole leak and the weld between the MV-SW135 valve body and the tapered flange on the inlet side) to validate the flaw analysis completed in the Structural Integrity Reports. WR 322581

2.

Perform a daily visual walkdown to confirm analysis from NDE examinations remain valid (i.e.

No new significant leakage in accordance with Section 2(f) of N-513-3). Operations to verify during rounds of the Component Cooling Water Room, the Service Water leakage is contained and not leaking on other equipment. Quantitative analysis not needed. An ODMI will be developed to establish quantitative trigger points. This action can be closed once MV-SW135 is replaced. (CR-PLP-2013-04613 CA-3).

3. Submit relief request to the Nuclear Regulatory Commission in accordance with NRC Inspection Manual Part 9900: Technical Guidance "Operability Determinations & Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety." (CR-PLP-2013-04613 CA-6).

4. Perform extent of condition NDE examination at a minimum of five susceptible locations within 30 days in accordance with ASME Code Case N-513-3. Owners: Programs Engineering. Due Date: 11/2412013 (CR-PLP-2013-04613 CA-7) WR 322424, WR 322425, WR 322426, WR 322428, WR 322430

" Restore INOPERABLE SSCs to an OPERABLE but Degraded or Nonconforming status.

None Restore operating margins None Compensate for a Degraded or Nonconforming Condition None Allow corrective maintenance to be performed None Provide for a time limit for future Operability based on the results of an Operability Evaluation.

Per Code Case N-513-3, repair or replacement shall be performed no later then when the predicted flaw size from either periodic inspection or by flaw growth analysis exceeds the acceptance criteria or the next scheduled (refueling) outage (1R23), whichever occurs first.

However, a predicted flaw growth rate was completed by Structural Integrity Associates as part of their evaluation. An extrapolation was completed using nominal wall thickness, based upon the months in service. The evaluation dictates that the pressure retention capabilities of the thinned region may be exceeded in approximately 3 months of continuous service. While this evaluation does predict the thinnest location to go through-wall near the end of the evaluation period, it is recognized that the analysis herein is conservative.

Because of the service conditions of this valve, this valve sees varying flow dependent on lake temperature. Therefore, a linear extrapolation, while not completely accurate, provides an estimation of the flaw growth rate. Monthly UT measurements will provide the determination on when the valve may exceed its flaw size criteria.

For the inlet wall thinning, if the thickness of the thinnest location does become less than tw, or even through-wall, the evaluation performed for the leaking pin hole on the outlet side of the valve (Reference 18) may be used to make an immediate operability decision. This could then be followed by a similar evaluation to justify continued operation.

Confer with the SM and persons in other departments to determine any procedures that may be needed to be created or modified to perform the Compensatory Measures.

Shift Manager and Engineering departments were consulted on the need to create or modify procedures and no additional procedures or changes were identified.

7.

Long Term Actions In some cases it may be possible to identify the appropriate long-term corrective action or LTCA (as defined in EN-LI-102, Corrective Action Process). If so, describe this and provide the status or schedule if available. As with all 10 CFR 50 Appendix B conditions adverse to quality, the schedule for corrective actions should be commensurate with importance to safety of the Degraded or Nonconforming Condition.

Also, identify if any further detailed engineering evaluation is required. Describe the aspects that need further investigation. If possible, provide an estimated completion date. If Long Term Corrective Action was previously planned for other reason(s), then revise the action (WR, CA, etc.) to reference this CR.

Such revision provides linkage to prevent cancellation or deferral without proper review. If a new Long Term Corrective Action Item is created record the work order, work request or other plant specific tracking number(s). In addition, record the CR Number (and due date as applicable) in the work order, work request or other plant specific tracking system "Description Field" to provide a link in order to prevent cancellation or deferral without proper review and revision (if necessary) of the actions from this Operability Evaluation.

1. Work Order 365955-01 will replace MV-SW135 in the next refueling outage (1R23).

8.

Attachments

1) PLP-RPT-1 3-00047, Structural Integrity Report on the Flaw Tolerance Evaluation of Leaking MV-SW1 35 Service Water Valve Body

2) WO 365955-02, PAL-UT-1 3-053, UT Erosion/Corrosion Examination of MV-SW135 Valve Body

3) WO 365955-02, PAL-UT-1 3-054, UT Erosion/Corrosion Examination of Tapered Flange to MV-SW1 35 Valve Body

4) WO 365955-02, PAL-UT-13-055, UT Erosion/Corrosion Examination of Inlet Piping to MV-SW135

5) WO 365955-02, PAL-UT-13-056, UT Erosion Corrosion Examination of Weld Between MV-SW135 Valve Body and Tapered Flange

6)

PAD 13-0333

ATTACHMENT 9.1 ENGINEERING REPORT COVER SHEET & INSTRUCTIONS ATTAcHmEmT 9.1 ENGINEERING REPORT COVER SHEET & INSTRUCTIONS SHEET I OF 2 Engineering Report No.

PLP-RPT-13-OOD47 Rev 0

Page 1

of 14

'VEntergy ENTERGY NUCLEAR Engineering Report Cover Sheet Engineering Report

Title:

Engineering Report Type:

New 0

Revision D]

Cancelled El Superseded Superseded by:

El Applicable Site(s)

IPI El ANO I EC No. 47483 1P2 El ANO2 C]

jP3 0l ECH El AN [El GONS 0l PNPS El RBS El VY C WF3CE wPo El PLP 0 Report Origin:

El Entergy 0

Vendor Vendor Document No.: 1301385.401.RO Quality-Related:

0 Yes Structural Integrity Associates, Inc.

El No Prepared by.

Design Verified:

Reviewed by:

Approved by:

Responsible Engineer (Print Name/Sign)

Structural Integrity Associates, Inc.

Design Verifier (if required) (Print Name/Sign)

Adam Bono K-C/X--1 Reviewergrint Name/Sign)

Dave MacMaster

?

z Supervisor / Manager (Print Name/Sign)

Date:

10/28/13 Date:

10/28/13 Date:

10/29/13 Date:

10/29/13 EN-DC-147 REV 6

ATTACHMENT 9.1 VENDOR DOCUMENT REVIEW STATus Sheet I of I

• EnrteW ENTERGY NUCLEAR MANAGEMENT MANUAL EN-DC.149 VENDOR DOCUMENT REVIEW STATUS SFOR ACCEPTANCE FOR INFORMATION IPEC 0

JAF 0 PLP 0

PNPS [I VY 0

ANO

[] GGNS

] RBS

[0 W3 NP Document No.: 1301385.401 Rev. No. Draft A Document

Title:

Flaw Tolerance Evaluation of Leaking MV-SW135 Service Water Valve Body

'EC No.:47483 Purchase Order No. N/A (W/A for lfý STATUS NO:

1. 0 ACCEPTED, WORK MAY PROCEED

2. 0] ACCEPTED AS NOTED RESUBMITTAL NOT REQUIRED, WORK MAY PROCEED

3.

El ACCEPTED AS NOTED RESUBMITTAL REQUIRED

4. E3 NOT ACCEPTED Acceptance does not constitute approval of design details, calculations, analyses, test methods, or materials developed or selected by the supplier and does not relieve the supplier from full compliance with contractual negotiations.

Responsible Engineer Adam Bono

/

6

,o/-9'4S Print Name

/9o/

/t Date Engineering Supervisor Dave MacMaster

/

Print Name Signature Date EN-DC-149 REV 6

ATTACHMENT 9.2 VENDOR DocUMENT COMMENT RESOLUTION SHEET Sheet I of I VENDOR DOCUMENT COMMENT RESOLUTION Document No: 1301385.401 Rev. No: Draft EC No: 47483 (KA kor NP)

Document

Title:

Flaw Tolerance Evaluation of Leaking MV-SW 135 Service Water Valve Body Reviewer: Adam Bono Ext. 269.764.3342 Print Namel Signature Date Comment Page Section Comment:

Disposition Resolution:

No:

No:

No:

_/0*

1 1

Update reference 8 to state I

Incorporated.

"EC47483" in lieu of "TBD".

4 3.4 MX, MY, MZ values improperly I

Incorporated.

referenced as coming from Reference [9]. Please add the below reference:

Calculation EA-SP-03316-01, Rev 6, "Piping Stress Analysis for Service Water from Engineering Safeguards Coolers V-27A and B East and V-27C and D West"

• 1 = Included, 0 = Omitted RE: Ak4/' &-o/

Print Name/ Signature Date EN-DC-149 REV 6

10731 E. Easter Ave.,

Suite 100 Centennial, CO 80112 Phone: 303-792-0077 Fax:

303-792-2158 www.structnt.com ehouston@structintcom October 28, 2013 Report No. 1301385.401.RO Quality Program: E Nuclear F] Commercial Mr. Jacob Milliken Entergy Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Hwy Covert, MI 49043-9505

Subject:

Flaw Tolerance Evaluation of Leaking MV-SW 135 Service Water Valve Body

Reference:

1. ASME Boiler and Pressure Vessel Code,Section XI, 2001 Edition with Addenda through 2003.

2. ASME Boiler and Pressure Vessel Code, Code Case N-513-3, "Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, Division 1," January 26, 2009.

3. Power Piping ANSI B31.1 - 1973 with Addenda through Summer 1973.

4. Anchor Darling Drawing No. 93-14272, "4"-150 Flex Wedge Gate Valve, Carbon Steel, Weld Ends, Bolted Bonnet, With 8" Dia Handwheel," SI File No. 1301385.201.

5. Entergy UT Erosion/Corrosion Examination, Report No. PAL-UT-13-053, SI File No.

1301385.201.

6. Entergy UT Erosion/Corrosion Examination, Report No. PAL-UT-13-054, SI File No.

1301385.201.

7. Entergy UT Erosion/Corrosion Examination, Report No. PAL-UT-13-056, SI File No.

1301385.201.

8. Design Input Record No. EC47483, Revision 0, SI File No. 1301385.201.

9. Calculation EA-SP-03316-01, Rev 6, "Piping Stress Analysis for Service Water from Engineering Safeguards Coolers V-27A and B East and V-27C and D West," SI File No.

1201055.201.

10. Entergy Drawing No. VEN-M101, Sheet 2744, Revision 11, "Service Water From Eng.

Safeguards," SI File No. 1301385.201.

11. Consumers Power Document No. EA-SP-03316-02, "Palisades - Service Water from Engineered Safeguards - Stress Package 03316-MV-135-SW Replacement," SI File No.

1301385.201.

12. pc-CRACKIM, Version 4.0.1.0, Structural Integrity Associates, December 14, 2011.

Toll-Free 877-474-7693 Akron,OH Albuquerque, NM AuStin,TX Claiotte. KC Chattanooga,TN Chicago, IL 330-899-9753 505-872-0123 512-533-9191 704-597-5554 423-553-1180 815-648-2519

Donver, CO

Mystic, CT Poughkeepsie, NY San Diego, CA San Jose, CA Stab College, PA Toronto, Canada 303-792-0077 860-536-3982 845-454-"100 858-455-6350 408-978-8200 814-954-7776 905-829-9817

Mr. Jacob Milliken, Palisades Nuclear Plant Report No. 1301385.401.RO Flaw Tolerance Evaluation of Leaking MV-SW 135 Service Water Valve Body October 28, 2013 Page 2 of 11

Dear Jake:

This summary report documents the flaw tolerance evaluation of the MV-SW 135 Service Water valve body (inlet side) at the Palisades Nuclear Plant to determine the allowable through-wall flaws that would meet ASME B&PV Code,Section XI stability requirements. It is understood that Section XI does not specifically address through-wall flaws. The evaluation results summarized herein are based on verified analyses which utilize many conservative assumptions.

1.0 INTRODUCTION

Leakage was recently discovered on the inlet side of the MV-SW 135 Service Water valve body at Palisades Nuclear Plant. The leak emanates from a pin hole flaw assumed, based on past history, to be due to cavitation induced erosion at the inside surface of the carbon steel valve.

The location of the pin hole leak is shown in Figure 1.

The objective of this calculation is to perform fracture mechanics analyses to determine the maximum through-wall flaw sizes that meet the ASME B&PV Code,Section XI allowable flaw criteria in terms of structural stability.

Figure 1: Photograph of Leak at MV-SW135 Valve CStructural Integrity Associates, Inc!

Mr. Jacob Milliken, Palisades Nuclear Plant October 28, 2013 Report No. 1301385.401.RO Page 3 of 11 Flaw Tolerance Evaluation of Leaking MV-SW 135 Service Water Valve Body 2.0 TECHNICAL APPROACH The evaluation is performed using the procedures of Section XI of the ASME Code [1] and the general approach given in Code Case N-513-3 [2] for a nonplanar through-wall flaw. The MV-SW 135 Service Water valve is a Class 3 component design per ANSI B31.1 [3] (built to the ANSI B 16.34 standard). Following the recommendations of Section 3.2(d) in Code Case N-513-3, to evaluate a through-wall nonplanar flaw, two independent planar flaws, one in the axial direction and the other oriented in the circumferential direction are postulated. Critical (structural factor of one) and allowable flaw sizes are calculated for the postulated through-wall axial and circumferential flaws in the valve body to assess the structural integrity of the valve.

Alternatively, a nonplanar through-wall flaw may be evaluated using a branch reinforcement approach as described in Section 3.2(c) of Code Case N-513-3. The approach results in an allowable through-wall circular opening of diameter, dadj. This evaluation is performed in addition to the planar characterization method.

3.0 FLAW EVALUATION 3.1 Component Dimensions The location of the leak in the MV-SW 135 Service Water valve is adjacent to a flange neck weld. Therefore, the nominal dimensions of the valve at the weld prep are used in this evaluation:

" Outside Diameter at Weld Prep: 4 17/32" [4]

" Inside Diameter at Weld Prep:

4.026" [4]

" Wall Thickness at Weld Prep, t,,: 0.25" (calculated)

Since the leak is located in the valve body, the wall thickness at the thinned location is nominally larger than the calculated 0.25" thickness, as shown by the UT results [5, 6, 7]. In order to assess the effects of the remaining wall thickness surrounding the pin hole, the analyses are performed with the thickness of the valve set to:

• tp = 0.051" which corresponds to the predicted end-of-evaluation period minimum thickness (see Section 3.7)

• tmeas = 0.102" which corresponds to the minimum measured thickness [7], and tavg = 0.245" which corresponds to the mean thickness in the thinned region

[7]

3.2 Design and Operating Conditions The design and operating conditions of the Service Water piping system containing the MV-SW 135 valve are as follows [8]:

Design Conditions:

0 Design pressure =

100 psig C

Structural Integrity Associates, IncM

Mr. Jacob Milliken, Palisades Nuclear Plant Report No. 1301385.401.RO Flaw Tolerance Evaluation of Leaking MV-SW 135 Service Water Valve Body October 28, 2013 Page 4 of 11 Design temperature =

Operating Conditions:

0 Maximum operating pressure 300°F 125 psig 170°F 0 Maximum operating temperature =

The bounding maximum pressure of 125 psig is used in this evaluation.

3.3 Materials and Material Properties The material of the MV-SW135 Service Water valve body is specified as SA-216 Grade WCB

[4]. The allowable stress for this material at the operating temperature is 14 ksi [3].

For the fracture mechanics evaluation, the modulus of elasticity is conservatively taken at 200'F: E=27,700 ksi, which is near the maximum operating temperature of 170°F [3].

3.4 Applied Stresses The stress report of the Service Water piping line containing the MV-SW 135 valve considered Pressure, Deadweight, OBE, SSE and Accident Mode Thermal loading for two cases labeled "Active Supports" and "Inactive Supports" and an enveloping case labeled "Active and Inactive Supports" [9]. The loads from the bounding enveloping case were selected at node 75, which represents the MV-SW 135 valve for this evaluation [10]. The loads are presented in Table 1 along with the calculated resultant axial stresses for several wall thicknesses. Note that SSE loading is twice OBE loads [11, Sheet 10].

Table 1: Applied Axial Stresses t = 0.051 "

t = 0.102" t = 0.245" P

MX MY MZ O'm Cyb eym Cyb am Cb Load (psig)

(in-lb)

(in-lb)

(in-lb)

(ksi)

(ksi)

(ksi)

(ksi)

(ksi)

(ksi)

Pressure 125 2.777 1.388 0.578 DW 4,836 240 5,460 9.179 4.748 2.175 Thermal 192 276 1,200 1.567 0.811 0.371 OBE 2,184 2,256 1,116 4.191 2.168 0.993 SSE 4,368 4,512 2,232 8.383 4.336 1.987 Since an axial flaw is also postulated, the hoop stress is needed for the fracture mechanics evaluation. The hoop stress due to the internal pressure is calculated as follows:

p

.(roMside2 + rinside2)

(Th°°P

-ý (routside 2 rinside 2 )

1Structural Integrity Associates, Inc.0

Mr. Jacob Milliken, Palisades Nuclear Plant Report No. 1301385.401.RO Flaw Tolerance Evaluation of Leaking MV-SW 135 Service Water Valve Body October 28, 2013 Page 5 of 11

where, P = internal pressure rinside = inside radius of the cylinder routside = outside radius of the cylinder Thus, using the maximum operating pressure of 125 psig, Table 2 shows the hoop stresses applied in the axial flaw analyses.

Table 2: Applied Hoop Stresses 3.5 Stress Intensity Factors Stress intensity factors are calculated for the postulated axial and circumferential through-wall flaws using fracture mechanics crack models of an axial or circumferential flaw in a pressurized cylinder.

The stress intensity factors are determined using the pc-CRACKTM [12] fracture mechanics software. The flaw models are shown in Figure 2 for an axial through-wall flaw and in Figure 3 for a circumferential through-wall flaw. The stress results derived in Section 3.4 are input to the program to determine the stress intensity factors for each of the postulated flaws.

Crack Model: 310 - Through-Wall Axial Crack in Pressurized Cylinder Stress/Load Input Stress Coefficients V/

Coeffs. from Stress Table Stress Table Stress Intensity Factors (ID)

Stress Intensity Factors (2D))

Co = Internal pressure Crack Dimensions:

a Component Dimensions:

t R.,

Range: a/(Rt)1/2 <_ 10 4-Figure 2: Fracture Mechanics Model for Axial Through-Wall Flaw VStructural Integrity Associates, Inc!

Mr. Jacob Milliken, Palisades Nuclear Plant Report No. 1301385.401.R0 Flaw Tolerance Evaluation of Leaking MV-SW 135 Service Water Valve Body October 28, 2013 Page 6 of I 1 Crack Model: 311 - Through-Wal Circumferential Crack in Cylinder Under Tension And Bending Stress/Load Input C

0-a,--K- (maxo~

.eft Awz)

I 1

6.-

I mu baddwom I

At......p Stress Coefficients

/

Coeffs. from Stress Table Stress Table Stress Intensity Factors (ID)

I Stress Intensity Factors (2D)

X Co = Membrane Stress C1 = Max. Bending Stress Crack Dimensions:

a Component Dimensions:

t R.

Range:

1.5 < Rm/t < 100 a/(it R,,) < 0.611 Figure 3: Fracture Mechanics Model for Circumferential Through-Wall Flaw 3.6 Fracture Toughness For the ferritic material of the MV-SW 135 Service Water valve, the fracture toughness can be obtained using the guidelines in Appendix C of Section XI of the ASME Code [1]. The material toughness, J1c, values for ferritic steel base metals and weldments for axial and circumferential flaws are provided in Table C-8322-1 and Table C-8321-1 of ASME Code,Section XI, Appendix C, respectively. Since the maximum operating temperature of the system is less than 2000 F, it is conservatively assumed to be below the upper-shelf temperature of the ferritic material. The J1, for lower-shelf temperature of ferritic steel base metal is:

J1, = 45 in-lb/in 2 Thus, using this fracture toughness, the stress intensity factor can be calculated as:

K1, = (J1cE'/1000) 0.5 = 37.0 ksi4in

where, E'

E/(1 -v2)

E = Young's modulus = 27,700 ksi v = Poisson ratio = 0.3 Applying the bounding structural factors for the different service levels specified in Appendix C of Section XI [1], yields the allowable stress intensity factor, Kallow, for each service level. For example, with a 2.7 structural factor, Kaiio1w of 13.7 ksi4in is obtained for Service Level A.

VStructural Integrity Associates, Inc.

Mr. Jacob Milliken, Palisades Nuclear Plant Report No. 1301385.401.RO Flaw Tolerance Evaluation of Leaking MV-SW 135 Service Water Valve Body October 28, 2013 Page 7 of 11 3.7 Predicted End-of-Evaluation Thickness The MV-SW135 valve was replaced in March 2012 [8], approximately 19 months ago. If the maximum thickness of 0.426" [7] is assumed to be representative of the as-installed thickness, then the apparent metal loss rate, using the minimum thickness of 0.102" [7], is 17 mils per month. Based on this rate, the minimum measured thickness in the weld is predicted to be reduced to 0.051" for the 3-month evaluation period ending in January 2014.

3.8 Branch Reinforcement Evaluation As an alternative to the planar characterization approach used above to evaluate the nonplanar through-wall flaw, a branch reinforcement method as described in Section 3.2(c) of Code Case N-513-3 may be employed. Figure 4 illustrates the overall approach. The values Of tadj and dadj (defined in Figure 4), must satisfy Equation 8 of N-513-3:

1.5 td (tadj - tni,,)

tm'1n tm 2(S +0.4p)

where, R

tmin

=

mean radius

= minimum wall thickness required for pressure loading

= 0.020" [2, Equation 4]

Note that R is based on the OD of 4 17/32" and the evaluated thickness. For example, a thickness of 0.051" yields R = (4 17/32 - 0.051)/2 = 2.24".

The value Of tadj is taken as 0.102" - the minimum thickness surrounding the localized thinning (i.e., the valve body is assumed uniformly thinned at 0.102"). Solving for N-513-3 Equation 8 gives the following limit on dadj:

dadJ <2.9" VStructural Integrity Associates, Inc!0

Mr. Jacob Milliken, Palisades Nuclear Plant Report No. 1301385.401.RO Flaw Tolerance Evaluation of Leaking MV-SW 135 Service Water Valve Body October 28, 2013 Page 8 of 11 Through-wall f opening (a) Adjusted Wall Thickness train (b) Equivalent Hole Representation Figure 4: Illustration of Branch Reinforcement Approach In addition, the remaining ligament average thickness, tcavg, over the degraded area bounded by dadj must satisfy Equation 9 of N-513-3:

t,.a,,g >! 0.353dad J-P

where, P = operating pressure S = allowable stress Typically, the determination of tc,avg is limiting when calculating dadj. Thus, tc,avg will be established and dadj will be backed out of N-513-3 Equation 9 and then checked against the N-513-3 Equation 8 limit. It is conservative to use the minimum predicted thickness in the localized thinned region as tcavg. From Section 3.7, tc,avg = 0.051 ". Using Equation 9 and solving for a maximum dadj:

tcg 0.051 14000 = 1.

d~d, cav 4

125__

0.353 J P 0.353 125 Since dadj also satisfies the N-513-3 Equation 8 limit of 2.9", the resulting allowable through-wall circular opening using the branch reinforcement methodology is 1.5".

C Structural Integrity Associates, Inc.!

Mr. Jacob Milliken, Palisades Nuclear Plant October 28, 2013 Report No. 1301385.401.R0 Page 9 of 11 Flaw Tolerance Evaluation of Leaking MV-SW135 Service Water Valve Body 4.0 RESULTS The allowable and critical flaw sizes are determined by comparing the calculated stress intensity factors to the valve material allowable stress intensity factor, Kaijow, and fracture toughness, K1c, respectively. The resulting allowable and critical through-wall flaw sizes for different wall thicknesses are presented in Table 3.

Table 3: Allowable and Critical Flaw Lengths Circumferential Flaw Axial Flaw Valve Uniform Thickness (in)

(in)

Allowable Critical Allowable Critical 0.051" (predicted thinnest - 2014) 0.41 1.08 0.96 2.16 0.102" (thinnest - 2013) 1.23 2.58 2.11 4.63 0.245" (weld average) 3.43 5.78 5.58 13.0 In addition, an allowable through-wall circular opening of 1.5" resulted from a branch reinforcement evaluation.

5.0 CONCLUSION

S Fracture mechanics analyses are performed to evaluate the flaw tolerance of the MV-SW 135 Service Water valve at Palisades Nuclear Plant with postulated through-wall flaws. The analyses conservatively assume uniformly thinned components, thereby not including the additional strength provided by the remaining wall around the thinned region.

The allowable through-wall circumferential flaw length of the valve was determined to be 0.41 inch and the allowable through-wall axial flaw length was determined to be 0.96 inch based on the conservative minimum predicted thickness (0.051 inch). The corresponding critical through-wall flaw lengths are 1.08 inches for the circumferential flaw and 2.16 inches for the axial flaw.

Considering a uniformly thinned valve with an average thickness of 0.245 inch, the allowable circumferential and axial flaw lengths increase considerably to 3.43 inches and 5.58 inches, respectively. The corresponding critical flaw lengths are 5.78 inches for the circumferential flaw and 13.0 inches for the axial flaw. These results show that the calculated allowable and critical flaw lengths using the predicted minimum thickness as the uniform thickness are very conservative.

In addition, a branch reinforcement methodology was employed resulting in an allowable through-wall circular opening of 1.5 inches assuming a uniformly thinned valve body of 0.102 inch surrounding the localized thinned region.

Based on UT examinations, the metal loss was estimated to be 0.051 inch from now until January 2014. Thus, the region of wall thinning with predicted thickness below 0.102 inch is CStructural Integrity Associates, Inc!

Mr. Jacob Milliken, Palisades Nuclear Plant Report No. 1301385.401.R0 Flaw Tolerance Evaluation of Leaking MV-SW 135 Service Water Valve Body October 28, 2013 Page 10 of I1 less than 1.0 inch. Conservatively assuming a uniform valve thickness of 0.102 inch, the calculated allowable planar through-wall flaws are larger than the dimensions of the predicted wall thinning area. Therefore, the degradation reported in the MV-SWI 35 valve is predicted to show that the ASME Code margins are met until January 2014.

Periodic monitoring will ensure that the metal loss rate at the wall thinning region does not exceed the predicted rate used in this evaluation and that the pin hole does not exceed 1.5 inches in diameter. It should be noted that even if the metal loss rate were to exceed the predicted rate, the ASME Code margins for the MV-SW 135 valve are maintained as long as the degraded area with thickness below 0.102 inch is bounded by the corresponding allowable through-wall flaw lengths.

CStructural Integrity Associates, Inc.!

Mr. Jacob Milliken, Palisades Nuclear Plant Report No. 1301385.401.R0 Flaw Tolerance Evaluation of Leaking MV-SW 135 Service Water Valve Body October 28, 2013 Page 11 of 11 Please contact us if you have any questions. Thank you.

Prepared by:

Verified by:

10/28/2013 Date 10/28/2013 Date Eric Houston, P.E.

Consultant Jagannath Hiremagalur Consultant Approved by:

Robert 0. McGill, P.E.

Senior Associate 10/28/2013 Date CStructural Integrity Associates, Inc.

Entergy UT ErosionlCorrosion Examination Sum WI Site/Unit:

PAL 1 1 mary No.:

N/A orkscope:

BOP Procedure:

Procedure Rev.:

Work Order No.:

CEP-NDE-0505 4

Outage No.:

N/A Report No.:

PAL-UT-13-053 Page:

1 of 4

00365955-02 Code:

NIA Cat.lItem:

NIA Location:

BLDG AB ELEV 0590 CCW ROOM A123 Drawing No.:

NIP

==

Description:==

4" Cast Valve Body System ID:

CSW Component ID: MV-SW135 Size/Length:

N/P Thickness/Diameter:

N/P Limitations:

Valve Body Geometry Component File No.: NIP Start Time:

1505 Finish Time:

1710 Calibration Information Calibration Thickness (in)

Calibration Times / Initials Actual Measured

.250 NIA Start:

1505 MAO

.500 N/A Verify:

N/A N/A

.750 N/A Verify:

N/A N/A 1.000 N/A Verify:

NIA N/A N/A N/A Final:

1710 MAO Partitioning Information Component BeginiCol/Row Ending/Col/Row M. UPST Ext.

N/A NIA Main UPST.

N/A N/A Main AA01 BE18 Main DNST.

NIA N/A M. DNST Ext.

NIA NIA Branch NIA NIA Branch Ext.

N/A NIA Component Information Component Geometry:

Valve Body Outside Diameter N/P Grid Size: 0.5 "x 0.5" Max. Thickness:

0.832" Min. Thickness:

0.576" Nominal Thickness:

NIP Tmin.:

NIP Min. Thickness Location:

AD17 Max. Thickness Location:

AH17 Surface Condition:

Casting/Uneven/Clean IIrnsrumen:

Transducer:

Reference/Simulator Block:

Temp. Tool:

Manufacturer:

Panametrics Manufacturer:

Panametrics Serial No.:

07-4043 Manufacturer:

Traceable Model:

37-DL Plus Serial No.:

655243 Type:

4-Step Block Serial No.:

016697 Serial No.:

071565212 Size:

0.5" Freq.:

5.0 MHz Couplant:

Gain:

55 Db Model:

D790-SM Ref./Simulator Block Temp.:

74

• F Type:

Ultragel 11 Range:

2"

1. of Elements:

Dual Material/Component Temp.:

82

°F Batch No.:

08125 Comments/Obstructions:

Unable to measure readings in various areas due to the valve body geometry. ** This exam Is considerec be5+ P-7V-Results:

Accept []

Reject []

Info W]

Engineering to evaluate inspection results. **Cast Valve Body, Cal Block is CIS-Examiner Level IlL pignature Date Reviewer Sig lture c

Date Olafson, Mark A.

10/25/2013 Deeds Jr., Paul E S12 S-113 Examiner Level NIA Signature Date Site Review Snature Date N/A N/A Other Level N/A Signature Date ANII Review Signature Date N/A NIA

• Enteg Supplemental Report Report No.:

PAL-UT-13-053 Page:

2 of 4

Summary No.: N/A Examiner Olafson, Mark A.

Examiner:

N/A Other:

WA Level:

IlL Level:

WA Level:

WA Reviewer Deeds Jr., Paul E Site Review: WA ANII Review: N/A Date:

Date:

Date:

Comments: Pin hole leak is approximately 0.75" from measurement at point AP02 and approximately 0.875" from measurement at point A002. No readings could be taken on the pin hole leak or the tapered area on the valve body.

Sketch or Photo: J:\\Engineerlng\\NDE\\Pictures\\IM&_0377.jpg

COLOR CODED DATA GRID PANAMETRICS-NDT Ultrasonic Thickness Gage ge Vo)4 9,JAL-U7 -I3 -06S3 The Survey Name:

MV-SW135 Survey Date:

10/25/2013 5:25:15 PM Survey

Description:

VALVE Survey Mode:

THICKNESS Survey Type:

2D GRID Erase Protection:

FALSE Location Note:

590CCW Inspector ID:

MAO Color Legwd!

i I AAI WI AC IAD IAE IAF IAGI MI AlI A3I AK IAL IAM IM I AO IAPI I

AI I nfrml nimO I nimW I armluE m i nuui n finnI n iK I na n Innnni I I inamE arm 0

n-an I flNE l a-aw00 lA I 0.00 uVlA uA~

AJUU tiAP U.UWJ UAW 0.000 0.I00 0.000 0.000 0.00 0.000 0

UAW0 1

.OO g UJW U

gN1 A

UAWUJ I O UAAJU 0.000 0 ~

-4.-I-I-4-4-4-4-4.-4-4--I-4-*-I-4-flAKE O+O00 O+OOO O.J]OO O*

0.000 O.O0O O.O00 0.(W*

O.O00 0AW M I MOOD MOODE 1 0.000 I fu I MOWE MONE I (LOW I 0=0 MO 0.000 0=0 IK I Minm MomK 06~ 0.000 M000 M.0OD 0MOW 0M000 0AW0 0.000 0.00 0M000 0.00 0.000 0.000 0.00 0.000 0.000 0.000 0.000 07 0.000 0.000 0.000 0.000 0000 0,

0.000 0.000 M0000 0.000 0.00 0.000 0

.000 0.000 0.000 0.000 0.000 08 0.000 0.000 0.0 00 0.000 0.000 00000 00 00 0.000 0.000 0.000 0.000 0.000 0O0O0 0.000 0000 0.000 09 0.000 0.000 0.000 0.000 MO0 0.0 0.0 0 0.000 0

0.000 0.000 0M000 0.000 0.000 0.000 0.000 0.0 10 0.000 0.00 0 M0.00 0.000 0.000 0.000 0.0 00 0

00000 0.MW 00 0=000 0.000 0.000 0.00 0w000 11 0.000 0.000 0.000 0.000 0.000 0.000 0.00 0.00 0.W 0O0 0

0.000 0.000 0.000 MW 00 0 M000 0.000 0.000 0.000 0 0.000 00 0.000 0.000 000 0

0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 13 0.000 000000 0000 0.00]0 0.000 0.000 0.000 0.000 0.W00 14 0.00 0.000 0.00 MOW 000

.0 0=00 0.00 0.00 0.00 MO00 0.000 0.000 O

MO 0.000 0.000000 000 15 WAWM OAJJU 0.000J 0.=U fJMl*

U.glJIJ MIM I am 1 0.000 URM I MOOD 0 AWP 0.000 U0IJU Izzmu-I ZZAMIU 44FIOL4)

Page: 1

COLOR CODED DATA GRID PANAMETRICS-NDT Ultrasonic Thickness Gage WjoA. Oee, 00,36 595S-OZ The Survey Name:

MV-SW135 Survey Date:

10/25/2013 5:25:15 PM Survey

Description:

VALVE Survey Mode:

THICKNESS Survey Type:

2D GRID Erase Protection:

FALSE Location Note:

590CCW Inspector ID:

MAO Color Legam.u I ARI1 AS IAT I U AV IAW I X[AY IAZ[~

I U I 8CI W I BE 010.10.0w

.0w 10.0.000 10-m I

000I mm I 0.0wI0.=

I 0101I.0,0W I001 0.000 1 o.000I0.00 0000 0.000 0.000 0.000 0.000 0000 0.000 0.000 0.000 0.000 0=00 0.000 0.000 0.000 07 0.000 0.000 0.000 0.000 0.0 00L 0.000

0.

00 0 0 0.000 0.000 0.000 0.000 0

0.000 0.0 0.000 0.000 0.000 0.000 0.000 O.0W 0.000 0.000 0.00 O.000 0.0 0.000 1

0.000

.0.000 0.=

0=

0 0.000 0.0 0.000 0.000 0.000 0.000 0.00 0.000 0.000 1

0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.o00 0.m0 0.000 o.000 0000 1

0.000 0.000 0.0w0 0.000 0.00 0.0 00 0

00 0.00]0 O0 0 0.000 0.0 00 00 1

0000 0

0.000 00 0.00 000 0.000 0.00 0000 00000 0400 00 00 0.000 0.000 16mmmmmm 17*ooooooooooooom

~o ~ooooooooooooooooooo

~o ZI3 060 LIaiRZ 0.~

0.I700I 0.60 0.5751 EZm --Z 0.000Z Total Sabtlucs:

z IIJ I

Popc 2

• Entergy UT ErosionlCorrosion Examination Site/Unit:

PAL I

Summary No.:

Workscope:

1 N/A BOP Procedure:

Procedure Rev.:

Work Order No.:

CEP-NDE-0505 4

00365955-02 Outage No.:

NIA Report No.:

PAL-UT-13-054 Page:

1 of 4

Code:

NIA Cat./Item:

N/A Location:

BLDG AB ELEV 0590' CCW ROOM Al 23 Drawing No.:

NIP

==

Description:==

Tapered Flange to 4" Cast Valve Body System ID:

CSW Component ID: Tapered Flange to MV-SW135 Size/Length:

NIP Thickness/Diameter:

NIP Limitations:

Tapered Flange Geometry Component File No.: N/P Start Time:

1505 Finish Time:

1710 Calibration Information Partitioning Information Component Information Calibration Thickness (In)

Calibration Times I Initals Component BeginrCol/Row Ending/Co(ow Component Geometry:

Tapered Flange Actual Measured Sa M. UPST Ext.

NIA N/A Outside Diameter:

NIP Grid Size:

0.5 "x 0.5" Start:

1505 MAO

.250 NIA Main UPST.

N/A NIA Max. Thickness:

0.686" Min. Thickness:

0.423" Vify:

NIA N

Main AA01 BE02 Nominal Thickness:

NIP Tmin.:

NIP

.750 N/A Verify:

NIA NIA Main DNST.

N/A NIA 1.000_

N/A

, Verify:

N/A N/A M. DNST Ext.

N/A NIA N/A NIA Final:

1710 MAO Branch NIA NIA Max. Thickness Location:

AP01 Branch Ext.

NIA NIA Surface Condition:

Tapered Flange/Clean Instrument:

Transducer:

Reference/Simulator Block:

Temp. Tool:

Manufacturer:

Panametrics Manufacturer:

Panametrics Serial No.:

07-4043 Manufacturer:

Traceable Model:

37-DL Plus Serial No.:

655243 Type:

4-Step Block Serial No.:

016697 Serial No.:

071565212 Size:

0.5" Freq.:

5.0 MHz Couplart:

Gain:

55 Ob Model:

D790-SM Ref./Simulator Block Temp.:

74

-F Type:

Ultragel 11 Range:

2"

1. of Elements:

Dual Material/Component Temp.:

82

°F Batch No.:

08125 Comments/Obstructions:

Restrictions due to tapered flange, geometry, flange bolting, pipe movement. Grid size is approximate.

Results:

Accept []

Reject []

Info Wj Engineering to evaluate inspection results. **This exam is considered best effort. **

Examiner Level IiL ignature Date Reviewer Rigature

, /Date Olafson, Mark A.

10125/2013 Deeds Jr., Paul E Examiner Level NIA Signature Date Site Review Signature Date N/A NIA Other Level N/A Signature Date ANII Review Signature Date N/A N/A

Enteigy Supplemental Report Report No.:

PAL-UT-13-054 Summary No.: N/A Page:

2 of 4

Sketch or Photo: J:\\Engineedng\\NDE\\Pictures\\IMG_0377.jpg

COLOR CODED DATA GRID PANAMETRICS-NDT Ultrasonic Thickness Gage 00,)c-L ode,.A'p 0 - ev36 5 65-O I0fvbee+

phC I--Cr-3 The Survey Name:

135 Survey Date:

10/25/2013 5:30:46 PM Survey

Description:

FLAGE Survey Mode:

THICKNESS Survey Type:

2D GRID Erase Protection:

ON Location Note:

590CCW Inspector ID:

MAO AA AS M

AD A~

AF AG MI A!

Al AIC AL AN Aid DO AP AQ or 02

0.

0*4 0.41 Color Logw l.

geaalO~s v

)4)0 oz aid,4Q 0 z ct.e

'bo t-Li I

Ij"

&VbM

• kV-10111 Ich l~eak, EIY Lh"RaZ 0.700 0l llil 0.500j soI~

LZo.40 1L 0.000 l

I Row or Column'StaUstics I

Total Statistic

[I*m I'-

I Pagu 1

COLOR CODED DATA GRID PANAMETRICS-NDT Ultrasonic Thickness Gage eot op~~

The Survey Name:

135 Survey Date:

10/25/2013 5:30:46 PM Survey

Description:

FLAGE Survey Mode:

THICKNESS Survey Type:

2D GRID Erase Protection:

ON Location Note:

590CCW Inspector ID:

MAO AR AS AT AU AV AW AX AY AZ BA U

ac U)

BE o1~

or o~

MP COW~eor Nef RdnI*

0.45 1

-&O 0.700 E0.II0 EI.5w 0.400Z 0.000Z i

Row or Col~umn talktsics TOtWl Sbaistim J-

~zI"=

I1 E*-Z1 Page: 2

• Entergy UT ErosionlCorrosion Examination Site/Unit:

PAL I 1 Summary No.:

NIA Workscope:

BOP Procedure:

Procedure Rev.:

Work Order No.:

CEP-NDE-0505 4

00365955-02 Outage No.:

N/A Report No.:

PAL-UT-13-055 Page:

1 of 2

Code:

NIA Cat./Item:

NIA Location:

BLDG AB ELEV 0590' CCW ROOM A123 Drawing No.:

NIP

==

Description:==

Pipe System ID:

CSW Component ID: Downstream Pipe from MV-SW135 Size/Length:

NIP Thickness/Diameter:

NIP Limitations:

Pipe movement Component File No.: NIP Start Time:

1505 Finish Time:

1710 Calibration Information Partitioning Information Component Information Calibration Thickness (In)

Calibration Times I Initials Component Begin/Col/Row Ending/Col/Row Component Geometry:

Pipe Actual Measured M. UPST Ext.

N/A NIA Outside Diameter:

NIP Grid Size:

1" x I"

.250 N/A Stait N/0 N

Main UPST.

N/A N/A Max. Thickness:

0.294" Min. Thickness:

0.264"

.500 NIA Verify:

N/A N

Main AOl NOS Nominal Thickness:

N/P Tmin.:

N/P

.750 N/A Verify:

NIA N/A Main DNST.

N/A N/A Mm. Thickness n:

mi N

1.000 NIA Verify:

N/A N/A M. DNST Ext.

NIA NIA Min. Thickness Location:

M02 NIA N/A Final:

1710 MAO Branch N/A NA Max. Thickness Location:

MOI, M05 BranchExt.

NIA NIA Surface Condition:

Clean Instrument Transducer:

Reference/Simulator Block:

Temp. Tool:

Manufacturer:

Panametrics Manufacturer:

Panametrics Serial No.:

07-4043 Manufacturer:

Traceable Model:

37-DL Plus Serial No.:

655243 Type:

4-Step Block Serial No.:

016697 Serial No.:

071565212 Size:

0.5" Freq.:

5.0 MHz Couplant:

Gain:

53 Db Model:

D790-SM Ref.ISimulator Block Temp.:

74 "F

Type:

Ultragel II Range:

1"

1. of Elements:

Dual Material/Component Temp.:

82

• F Batch No.:

08125 Comments/Obstructions:

Pipe movement, Approximate grid size.

Results:

Accept []

Reject LI Info W Engineering to evaluate inspection results.

Examiner Level IlL Signature Date Reviewer Si nat 're I

/2, Dt Olafson, Mark A.

10/2512013 Deeds Jr., Paul E Examiner Level NIA Signature Date Site Review Sign ure Date N/A NIA Other Level NIA Signature Date ANII Review Signature Date NIA NIA

COLOR CODED DATA GRID PANAMETRICS-NDT Ultrasonic Thickness Gage Wev ýAk 036SIS-Puj.+

4 AVý.P Io~-- r 1 )b The Survey Name:

135P Survey Date:

10/25/2013 5:35:20 PM Survey

Description:

PIPE Survey Mode:

THICKNESS Survey Type:

2D GRID Erase Protection:

FALSE Location Note:

590CCW Inspector ID:

MAO S

A B

C D

EG m X MiLll °T

'I,02 om.

07 l

H I

0.279 0,271 oxg 0.zm 0.2.72 OL.272 0.273 (1.273 K

0,V O7

.274 1;aAd/"

9 LFW RaI1 01I 028 0.30 LII9Z 0I.ZI1 0.270 0.260 0.00 L-06k;ýj 106t--,vv

/ViV-5w j 3-5 IRow orColumn StatisucI Total Statsticst lzzdz~

&27 F1 j. wI Pagm I

• Entergy UT Erosion/Corrosion Examination Site/Unit:

PAL I

I Summary No.:

NIA Procedure:

Procedure Rev.:

Work Order No.:

CEP-NDE-0505 4

00365955-02 Outage No.:

N/A Report No.:

PAL-UT-13-056 Page:

1 of 2

Workscope:

BOP Code:

N/A Cat./Item:

N/A Location:

BLDG AB ELEV 0590' CCW ROOM A123 Drawing No.:

NIP

==

Description:==

Weld Between 4" Cast Valve Body and Tapered Flange System ID:

CSW Component ID: MV-SW135 Size/Length:

NIP Thickness/Diameter:

NIP Limitations:

Unground Weld Component File No.: NIP Start Time:

2030 Finish Time:

2125 Calibration Information Calibration Thickness (In)

Calibration Times / Initials Actual Measured

.040

.500 Start:

2030 MAO

,100 N/A Verify:

NIA N/A

.200 NIA Verify:

N/A N/A

.300 NIA Verify:

N/A N/A

.400

/A Final:

2125 MAO Partitioning Information Component Begin/Col/Row Ending/Col/Row M. UPST Ext.

NIA N/A Main UPST.

NIA N/A Main AA01 BE01 Main DNST.

NIA NIA M. DNST Ext.

NIA N/A Branch NIA NIA Branch Ext.

NIA NIA Component Information Component Geometry:

Valve Body to Flange Outside Diameter:

Varies Grid Size: 0.5 "x 0.5" Max. Thickness:

0.426" Min. Thickness:

0.102" Nominal Thickness:

N/P Tmin.:

NIP Min. Thickness Location:

AO01 Max. Thickness Location:

BA01 Surface Condition:

Cleaned Weld Instrument:

Transducer:

Reference/Simulator Block:

Temp. Tool:

Manufacturer:

Panametrics Manufacturer:

Panametdcs Serial No.:

A25493 Manufacturer:

Traceable Model:

37-DL Plus Serial No.:

607862 Type:

6-Step Block (CS)

Serial No.:

016697 Serial No.:

071565212 Size:

0.283 Freq.:

5.0 MHz Couplant:

Gain:

54Db ModRef./Simulator Block Temp.:

74 TFupn:

an:Model:

D794 Type:

Ultragel II Range:

1"

1. of Elements:

__Material/Component Temp.:

82

°F Batch No.:

08125 Comments/Obstructions:

Unable to measure readings in various areas due to the weld geometry. " This exam is considered beq" e-io,*4-Results:

Accept F]

Reject E]

Info 66 Engineering to evaluate inspection results. **Cast Valve Body, Cal Block is CIS**

Examiner Level IlL re Si Date Reviewer D-(Sig re Date Olafson, Mark A.

10/25/2013 Deeds Jr., Paul E

7te, 2

/I/

Examiner Level NIA Signature Date Site Review Q)inature Date NIA N/A Other Level N/A Signature Date ANII Review Signature Date NIA IN/A

• En/erg Supplemental Report Report No.:

Page:

Summary No.: N/A Examiner: Olaf son,_Mark A.Q Level Examiner:

N/A Level Other: N/A Level PAL-!UT-13-056 2

of 2

Date:

Date:

Date:

IlL

N/A N/A Reviewer: Deeds Jr., Paul E Site Review: NIA ANII Review: N/A Comments:

Drawing not to scale.

66-~toL4-~.

WeiI )

Q U

I e

a

,ALOI :'O.Zl4~p

,A~~~

1 T T

) 3- -

A/A:: Q,3t)5 iSA Of l(ý1 AVQ' 029 4Y'V 0%~4

0. -7 L0 Ct Y'A.'+k 0

V1 A'-

e,ý% 44 VIL LtAk 0 4Qf' 0, qI5 j5o-tto 0-ý

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM 13-0333 I. OVERVIEW PAD Rev.#: 0 Facility: Palisades Proposed Activity / Document: Compensatory Measures to be taken per CR-PLP-2013-04613 Operability Evaluation, "Thin area and through wall leak at valve body to pipe weld of MV-SW135 (E54A SW OUTLER CV-0823 BYPASS)."

ChangelRev. #: 0 Description of Proposed Activity:

The leak and thinned area found on the valve body of MV-SW 135 has been deemed acceptable per the operability evaluation performed under CR-PLP-2013-04613, with an evaluation performed by Structural Integrity. This operability evaluation has classified the Service Water System as Operable-Comp measure. To ensure the evaluation performed remains acceptable, inspections of the piping and leakage are necessary. The inspections will be performed in accordance with approved processes.

11. DOCUMENT REVIEW Provide the requested information for each item below.

1.

For documents available electronically:

a.

List search engine or documents searched, and keywords used:

Searched : FSAR ( Palisades Network L-Drive ), Tech Specs ( Palisades Network L-Drive), ORM (In Merlin), NRC Commitments (Palisades Network, L-Drive)

Keywords : Service Water, E-54, CV-0826, MV-SW-1 36, Ultrasonic, Visual

b.

List relevant sections of controlled electronic documents reviewed:

FSAR Sections: 1.9.1.14, 5.1.5.16, 5.6.7.3, 9.1,9.3, 9.8.13 FSAR Tables: 9-2, 5.2-3, 6-12 Tech Specs LCO 3. 6.6, 3.7.7, 3.7.8 All Commitments 8-13-13 EN-LI-100 REV. 13

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM

2.

Documents reviewed manually (hardcopy):

None.

3.

For those documents that are not reviewed either electronically or manually, use the specific questions provided in Sections III and IV of Attachment 9.2 of EN-LI-100 as needed. Document below the extent to which the Attachment 9.2 questions were used.

The questions provided In Attachment 9.2 were used in addition to the electronic reviews of the documents described above.

EN-LI-100 REV. 13

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM Ill.

PROCESS REVIEW Does the proposed activity affect, invalidate, or render incorrect, OR have the potential to affect, Invalidate, or render incorrect, information contained in any of the following processes?

Associated regulations and procedures are Identified with each process below.

PROCESS (Regulations I Procedures)

YES NO REVIEW RESULTS Chemistry I Effluents 0

ED Radwaste I Process Control Program (PCP)

I0 E

(EN-RW-105 or contact the Radiation Protection Dept.)

Radiation Protection I ALARA 0

0 (10 CFR 20 / EN-RP-110 or contact the Radiation Protection Dept.)

Inservice Inspection Program (10 CFR 50.55a / EN-DC-120, -351) 0 0

Inservice Testing Program (10 CFR 50.55a I EN-DC-332)

E) 0 Maintenance Rule Program (10 CFR 50.65 / EN-DC-203, -204, -205, -206.

0 0

-207)

Containment Leakage Rate Testing (Appendix J) Program (10 CFR 50 0]

Appendix J I EN-DC-334)

IF any box Is checked "Yes," THEN contact the appropriate department to ensure that the proposed change is acceptable and document the results In the REVIEW RESULTS column.

EN-LI-1 00 REV. 13

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM IV.

LICENSING BASIS DOCUMENT REVIEW Does the proposed activity affect, invalidate, or render incorrect, OR have the potential to affect, invalidate, or render incorrect, information contained in any of the following Licensing Basis Document(s)? Associated regulations and procedures are Identified with each Licensing Basis Document below.

LICENSING BASIS DOCUMENTS REVIEW RESULTS OR SECTIONS (Regulations I Procedures)

YES NO AFFECTED OR LBDCR #

Ouality Assurance Program Manual (QAPM)

(10 CFR 50.54(a) / EN-QV-104)

Fire Protection Program (FPP) [includes the Fire Safety Analysis/Fire Hazards Analysis (FSAJFHA)]

[1 0

OL Condition, 10 CFR 50.48 / EN-DC-128)

Emergency Plan (10 CFR 50.54(q) / EN-EP-305) 0 0

Environmental Protection Plan (Appendix B of the OL, Environmental Evaluation / EN-EV-1 15, EN-EV-0 0

117, EN-LI-103)

Security Plan and Cyber Security Plan (10 CFR 50.54(p) / EN-NS-210 or contact the site Security I IT Dept.)

[

0 Operating License (OL) I Technical Specifications (TS)

(10 CFR 50.90/ EN-LI-103)

TS Bases (10 CFR 50.59/ EN-LI-100 / EN-L-lol01) 0 Technical Requirements Manual (TRM) (including TRM Bases)

(10 CFR 50.59 / EN-LI-100 / EN-LI-101)

Core Operating Limits Report (COLR), and Pressure and Temperature Limits Report (PTLR) (TS Administrative Controls, EN-LI-1 13, EN-LI-100, 0

0 EN-LI-)101)

Offsite Dose Calculation Manual (ODCM)

(TS Administrative Controls or 10 CFR 50.59 / EN-LI-1 13 or EN-LI-1 001 0

0 EN-LI-101)

Updated Final Safety Analysis Report (UFSAR)

(10 CFR 50.71(e) / EN-LI-113, EN-LI-100, EN-LI--101)

Storage Cask Certificate of Compliance (10 CFR 72.2441 EN-LI-113) 0'-

0[]

Cask FSAR (CFSAR) (including the CTS Bases)

(10 CFR 72.70 or 72.248 / EN-LI-1 13, EN-LI-100,EN-LI-1 12) 0 0

10 CFR 72.212 Evaluation Report (212 Report)

El 0

(10 CFR 72.48 1 EN-LI-100, EN-LI-112)

NRC Orders (10 CFR 50.90 / EN-LI-103 or as directed by the Order) 0r*

09 NRC Commitments and Obligations (EN-LI-1 10) 0*

0 Site Specific CFR Exemption (10 CFR 50.12, 10 CFR 55.11, 10 CFR 55.13, 10 CFR 72.7)

IT 0

• Contact the site Licensing Department if needed.

IF any box is checked "Yes," THEN ensure that any required regulatory reviews are performed in accordance with the referenced procedures. Prepare an LBDCR per procedure EN-LI-113 If a LBD is to be changed, and document any affected sections or the LBDCR #. Briefly discuss how the LBD is affected in Section VII.A.

EN-LI-100 REV. 13

ATTACHMENT 9.1 PROCESS APPLICABIUTY DETERMINATION FORM V.

10 CFR 50.59110 CFR 72.48 APPLICABILITY Can the proposed activity be dispositioned by one of the following criteria? Check the appropriate box (if any).

[]

An approved, valid 50.59172.48 Evaluation covering associated aspects of the proposed activity already exists. Reference 50.59172.48 Evaluation #

(if applicable) or attach documentation. Verify the previous 50.59/72.48 Evaluation remains valid.

U The NRC has approved the proposed activity or portions thereof or a license amendment being reviewed by the NRC addresses the proposed activity. Reference the approval document:

0 The proposed activity is controlled by one or more specific regulations.

Examples of specific regulations are:

Maintenance Rule (50.65),

Quality Assurance Program (10 CFR 50 Appendix B)

Security Plan (50.54(p))

Emergency Plan (50.54(q))

Fire Protection (operating license condition)

See NEI 96-07 Section 4.1 for additional guidance on specific regulations.

Reference the controlling specific regulation(s):

IF the entire proposed activity can be dispositioned by the criteria in Section V, THEN 50.59 and 72.48 Screenings are not required. Proceed to Section VII and provide basis for conclusion in Section VI.A.

Otherwise, continue to Section VI to perform a 50.59 and/or 72.48 Screening, or perform a 50.59 and/or 72.48 Evaluation in accordance with EN-LI-101 and/or EN-LI-112.

Changes to the IPEC Unit I Decommissioning Plan are to be evaluated in accordance with the 50.59 process, as allowed by the NRC in a letter to IPEC dated January 31, 1996. [IPEC-1 Letter RA9600141 EN-LI-100 REV. 13

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM VI.

50.59172.48 SCREENING REVIEW VI.A 50.59/72.48 SCREENING (Check the appropriate boxes.)

-T 10 CFR 50.59 Screening criteria are met. [10 CFR 50.59(c)(1)]

The proposed activity meets all of the following criteria regarding design function:

Does not adversely affect the design function of an SSC as described in the UFSAR; AND Does not adversely affect a method of performing or controlling a design function of an SSC as described in the UFSAR; AND Does not adversely affect a method of evaluation that demonstrates Intended design function(s) of an SSC will be accomplished as described in the UFSAR; AND Does not Involve a test or experiment not described in the UFSAR.

E The proposed activity does not involve structures, systems, or components controlled by 10 CFR 60.59.

E]

10 CFR 72.48 Screening criteria are met. [10 CFR 72.48(c)(1)] (Applicable to sites with an ISFSI)

The proposed activity meets all of the following criteria regarding design function:

Does not adversely affect the design function of an SSC as described in the CFSAR; AND Does not adversely affect a method of performing or controlling a design function of an SSC as described in the CFSAR; AND Does not adversely affect a method of evaluation that demonstrates intended design function(s) of an SSC will be accomplished as described In the CFSAR; AND Does not involve a test or experiment not described in the CFSAR.

[

The proposed activity does not Involve structures, systems, or components controlled by 10 CFR 72.48.

IF either of the 50.59 or 72.48 Screening criteria are met, THEN complete VI.B below as appropriate and proceed to Section VII.

IF the proposed activity does not meet the applicable criteria, THEN perform a 50.59 or 72.48 Evaluation in accordance with EN-L-1I 01 or EN-LI11-2, as appropriate, attach a copy of the Evaluation to this form, and proceed to Section VII.

IF the activity does not involve systems, structures, or components controlled by 10 CFR 50.59 or by 10 CFR 72.48, THEN a 50.59 or 72.48 Screening is not required, as appropriate, and proceed to Section ViI.

EN-LI-100 REV. 13

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM VI.B BASIS Provide a clear, concise basis for determining the proposed activity may be screened out such that a third-party reviewer can reach the same conclusions. Refer to NEI 96-07 Section 4.2 for guidance. Provide supporting documentation or references as appropriate.

Per fleet procedure EN-OP-104, "Operability Determination Process," Section 5.5 (2], the Process Applicability Determination (PAD), which contains the Entergy 50.59 screening process, is required to be performed on the effect of the compensatory measure(s) on other aspects of the facility, and not on the effectiveness of the compensatory measure with regard to the degraded or nonconforming condition.

This guidance in EN-OP-1 04 Is consistent with the NRC-endorsed NEI 96-07, Revision 1, "Guidelines for 10 CFR 50.59 Implementation," Section 4.4. Per NRC Regulatory Issue Summary 2005-20, the effectiveness of the compensatory measure in mitigating the degraded or nonconforming condition is to be addressed within the corrective action system (i.e., the operability evaluation). Therefore, the scope of this 50.59 screening is to review the effect of the compensatory measures documented in CR-PLP-2013-04613 Corrective Action (CA) 1 on other aspects of the facility.

Compensatory measures have been established for the Service Water System as part of the operability evaluation performed under CR-PLP-2013-04613 CA 1. The compensatory measures are:

1. Until MV-SW135 is replaced, perform UT examinations (not to exceed 30 days within each other) bounding the two thinned locations (the pinhole leak and the weld between the MV-SW135 valve body and the tapered flange on the inlet side) to validate the flaw analysis completed in the Structural Integrity Reports in the operability evaluation (Work Request (WR) 322581).

2.

Perform a daily visual walkdown to confirm analysis from NDE examinations remain valid (i.e. No new significant leakage in accordance with Section 2(f) of N-513-3). Operations to verify during rounds of the Component Cooling Water Room, the Service Water leakage is contained and not leaking on other equipment. An ODMI will be developed to establish quantitative trigger points. This action can be closed once MV-SW135 is replaced. (CR-PLP-2013-04613 CA-3).

3.

Submit relief request to the Nuclear Regulatory Commission in accordance with NRC Inspection Manual Part 9900: Technical Guidance "Operability Determinations & Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety." (CR-PLP-2013-04613 CA-6).

4.

Perform extent of condition NDE examination at a minimum of five susceptible locations within 30 days in accordance with ASME Code Case N-513-3. Owners: Programs Engineering. Due Date: 11/24/2013 (CR-PLP-2013-04613 CA-7) (WR322424, WR322425, WR322426, WR322428, and WR322430)

The compensatory measures were established to ensure that MV-SW 135 (E-54A SW Outlet CV-0823 Bypass) remains operable. This is done by monitoring for significant changes to the leakage and monitoring the flawed area to ensure that the flaw is still within the bounds of Structural Integrity Report PLP-RPT-1 3-00047.

These compensatory measures have no effect on plant structures, systems, or components (SSCs).

The compensatory measures concern only the inspection of the Service Water System and do not affect the ability of other components, or other aspects of the facility, to perform their design functions.

EN-LI-1 00 REV. 13

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM Therefore, with regard to other aspects of the facility, the compensatory measures for ensuring operability of that MV-SW 135 (E-54A SW Outlet CV-0823 Bypass) do not adversely affect the design functions performed by SSCs, the method of performing or controlling a design function of an SSC, or a method of evaluation that demonstrates the intended design functions of an SSC as described in the UFSAR. A test or experiment not described in the UFSAR is not involved.

EN-LI-100 REV. 13

ATFACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM VII. REGULATORY REVIEW

SUMMARY

VII.A GENERAL REVIEW COMMENTS (Provide pertinent review details and basis for conclusions if not addressed elsewhere in form.)

None.

VIi.B CONCLUSIONS

1.

Is a change to an LBD being initiated?

IF "Yes," THEN enter the appropriate change control process and include this form with the change package.

2.

Is a 10 CFR 50.59 Evaluation required?

IF "Yes," THEN complete a 50.59 Evaluation in accordance with EN-LI-101 and attach a copy to the change activity.

3.

Is a 10 CFR 72.48 Evaluation required?

IF "Yes," THEN complete a 72.48 Evaluation in accordance with EN-LI-112 and attach a copy to the change activity.

EL Yes

[

No El Yes Z

No El Yes 0

No VIII.

SIGNATURES' Preparer:

Aaron Verzwyvelt f

M,/"J.

-*/,/o

/3 Name (print) I Signature/

ompany I Department I Dite Co-Prepared for Matthew Kovac /,Ii Ay*,15r

/

, 6A'6/ /0/2 7 O/0 Qualification Name (print) I Signature I Company I 0'rpartment I Date Reviewer:

Jeffrey Erickson/ I fAI0/L-.ldj_. 1/-?_'j Name (print) I Sig rature I Company / Department I Date Process Applicability Exclusion Site Procedure Champion or Owner:

Ame + (r PPitSiguome.

Name (print) I Signaiture / Company / Department I Date Upon completion, forward this PAD form to the appropriate organization for record storage. If the PAD form is part of a process that requires transmittal of documentation, including PAD forms, for record storage, then the PAD form need not be forwarded separately.

The printed name, company, department, and date must be included on the form. Signatures may be obtained via electronic processes (e.g., PCRS, ER processes, Asset Suite signature), manual methods (e.g.,

Ink signature), e-mail, or telecommunication. If using an e-mail, attach It to this form.

EN-LI-100 REV. 13

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM Upon completion, forward this PAD form to the appropriate organization for record storage. If the PAD form is part of a process that requires transmittal of documentation, including PAD forms, for record storage, then the PAD form need not be forwarded separately.

EN-LI-100 REV. 13