ML14064A375

NRR E-mail Capture - Palisades - RR 4-18 - 2nd Set of Rai'S TAC No. MF3508

ML14064A375
Person / Time
Site:	Palisades
Issue date:	02/27/2014
From:	Mahesh Chawla Division of Operating Reactor Licensing
To:	Dotson B Entergy Nuclear Palisades
References
MF3508
Download: ML14064A375 (5)

Text

NRR-PMDAPEm Resource From: Chawla, Mahesh Sent: Thursday, February 27, 2014 5:58 PM To: DOTSON, BARBARA E (bdotson@entergy.com); ERICKSON, JEFFREY S (JERICKS@entergy.com); MIKSA, JAMES P (jmiksa@entergy.com)

Cc: Collins, Jay; Lupold, Timothy; Alley, David; Cumblidge, Stephen; Holmberg, Mel; Hills, David; Sanchez Santiago, Elba; Bilik, Tom; Duncan, Eric; Carlson, Robert; Taylor, Thomas; Sanchez Santiago, Elba; Scarbeary, April; Shah, Swetha

Subject:

Palisades - RR 4 2nd Set of RAI's TAC No. MF3508 Attachments: Palisades N-770-1 MF3508 2ND RAI RIII Edits.docx By letter dated February 25, 2014 Entergy Nuclear Operations, Inc. (the licensee), proposed an alternative to 10 CFR 50.55a(g)(6)(ii)(F)(3) for Palisades Nuclear Plant (Palisades). This regulation defines the inspection requirement for branch connection butt welds at Palisades in accordance with American Society of Mechanical Engineers Boiler and Pressure Vessel Code Case N-770-1, Alternative Examination Requirements and Acceptance Standards for Class 1 PWR Piping and Vessel Nozzle Butt Welds Fabricated With UNS N06082 or UNS W86182 Weld Filler Material With or Without Application of Listed Mitigation Activities, with NRC conditions. The licensee is requesting an extension of the required inspection for at least one cycle of operation.

As per the discussions during the conference call held today with your representatives, the NRC staff has identified the need for additional information, as indicated in the attached request for additional information.

Thanks Mahesh Chawla Project Manager Phone: 301-415-8371 Fax: 301-415-1222 mahesh.chawla@nrc.gov 1

Hearing Identifier: NRR_PMDA Email Number: 1141 Mail Envelope Properties (Mahesh.Chawla@nrc.gov20140227175800)

Subject:

Palisades - RR 4 2nd Set of RAI's TAC No. MF3508 Sent Date: 2/27/2014 5:58:03 PM Received Date: 2/27/2014 5:58:00 PM From: Chawla, Mahesh Created By: Mahesh.Chawla@nrc.gov Recipients:

"Collins, Jay" <Jay.Collins@nrc.gov>

Tracking Status: None "Lupold, Timothy" <Timothy.Lupold@nrc.gov>

Tracking Status: None "Alley, David" <David.Alley@nrc.gov>

Tracking Status: None "Cumblidge, Stephen" <Stephen.Cumblidge@nrc.gov>

Tracking Status: None "Holmberg, Mel" <Mel.Holmberg@nrc.gov>

Tracking Status: None "Hills, David" <David.Hills@nrc.gov>

Tracking Status: None "Sanchez Santiago, Elba" <Elba.SanchezSantiago@nrc.gov>

Tracking Status: None "Bilik, Tom" <Tom.Bilik@nrc.gov>

Tracking Status: None "Duncan, Eric" <Eric.Duncan@nrc.gov>

Tracking Status: None "Carlson, Robert" <Robert.Carlson@nrc.gov>

Tracking Status: None "Taylor, Thomas" <Thomas.Taylor@nrc.gov>

Tracking Status: None "Sanchez Santiago, Elba" <Elba.SanchezSantiago@nrc.gov>

Tracking Status: None "Scarbeary, April" <April.Scarbeary@nrc.gov>

Tracking Status: None "Shah, Swetha" <Swetha.Shah@nrc.gov>

Tracking Status: None "DOTSON, BARBARA E (bdotson@entergy.com)" <bdotson@entergy.com>

Tracking Status: None "ERICKSON, JEFFREY S (JERICKS@entergy.com)" <JERICKS@entergy.com>

Tracking Status: None "MIKSA, JAMES P (jmiksa@entergy.com)" <jmiksa@entergy.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 1114 2/27/2014 5:58:00 PM Palisades N-770-1 MF3508 2ND RAI RIII Edits.docx 27622

Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

REQUEST FOR ADDITIONAL INFORMATION REQUEST FOR RELIEF FROM 10 CFR 50.55a(g)(6)(ii)(F)(3) REQUIREMENTS FOR EXAMINATION OF BRANCH CONNECTION BUTT WELDS ENTERGY NUCLEAR OPTERATIONS INC.,

PALISADES NUCLEAR PLANT DOCKET NO. 50-255 By letter dated February 25, 2014 Entergy Nuclear Operations, Inc. (the licensee), proposed an alternative to 10 CFR 50.55a(g)(6)(ii)(F)(3) for Palisades Nuclear Plant (Palisades). This regulation defines the inspection requirement for branch connection butt welds at Palisades in accordance with American Society of Mechanical Engineers Boiler and Pressure Vessel Code Case N-770-1, Alternative Examination Requirements and Acceptance Standards for Class 1 PWR Piping and Vessel Nozzle Butt Welds Fabricated With UNS N06082 or UNS W86182 Weld Filler Material With or Without Application of Listed Mitigation Activities, with NRC conditions. The licensee is requesting an extension of the required inspection for at least one cycle of operation.

The NRC staff has reviewed and evaluated the information provided by the licensee and has determined that the following additional information is needed in order to complete its review of the relief request.

2.0 Non-destructive Examination RAI-2.1 As part of the hardship associated with performing volumetric inspections this outage, a radiological total dose estimate of 37 REM was provided. However, as volumetric examinations would have been required this outage, the staff requests what portion of that dose is above the exposure to perform the examination, as required by 10 CFR 50.55(a) with appropriate planning and foresight. Please provide the basis for the dose estimates, e.g. a breakdown of doses for each weld for erecting scaffolding, conducting surveys, removing insulation, conducting examinations, re-installing insulation, removing scaffolding, etc. Include the times required for each activity along with the estimates for general area dose rates and dose rates at 12 inches from the nozzles.

RAI-2.2 10 CFR 50.55a(g)(6)(ii)(F) requires a volumetric inspection be performed this outage of the subject butt welds that meets the requirements of Appendix VIII of ASME Code. The proposed alternative would manage the potential for PWSCC cracking by monitoring for reactor coolant pressure boundary unisolable though wall leakage. This is unacceptable without significant hardship or compensating basis for ensuring leaktightness. Provide the basis for why the following nondestructive examinations could not be performed in this outage for each weld:

A. The use of an ASME Code Section XI Appendix VIII Supplement 10 qualified procedure using a manual phased array ultrasonic search unit with a large number of angles to examine the welds. The use of many angles could overcome the difficulties posed by the geometry of the weld. Additionally, if the manual phased array inspection procedure is validated by a later site-

specific mockup demonstration, the inspection could be counted as a fully-qualified inspection.

B. Perform an eddy current or ultrasonic inspection from the inner diameter of the component to search for surface-breaking cracks.

C. Use a high-angle ultrasonic inspection method (e.g. a 70 degree refracted longitudinal search unit) to determine if any crack tips are in the outer 25% of the weld metal.

For A through C above, identify the estimated dose to complete the examination at each of the affected welds.

3.0 Proposed Alternative RAI-3.1 The NRC staffs understanding is that the licensees current proposed alternative is as follows;

1) Perform periodic system leakage tests in accordance with ASME Section Xl Examination Category B-P, Table IWB-2500-1 (Reference 10).

2) Perform visual and dye penetrant surface examinations of the welds in accordance with ASME requirements. During the 2012 (1R22) and 2014 (1R23) refueling outages, visual and external surface examinations of certain welds for which relief is requested identified no evidence of through-wall cracking or leakage for these components, as identified in Enclosure Table 1.

Pursuant to 10 CFR 50.55a(a)(3)(ii), ENO proposes to perform appropriate actions to meet ASME Section Xl Code Case N-770-1 examination requirements, as required, for those dissimilar metal welds identified in Enclosure Table 1 of this request during the first refueling outage after a viable technology is developed to perform these examinations.

The NRC staff does not find the proposed alternative for future inspections by the licensee to be acceptable. At a minimum, the NRC staff would expect the licensee to clearly identify the regulatory requirements and how those regulatory requirements will be met. The NRC staff expects the licensee to comply with 10 CFR 50.55a(G)(6)(ii)(F) during the next scheduled refueling outage.