PNP 2014-031, Response to Fourth Request for Additional Information Dated March 11, 2014, for Relief Request Number RR 4-18 - Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination

Response to Fourth Request for Additional Information Dated March 11, 2014, for Relief Request Number RR 4-18 - Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination

ML14070A477
Person / Time
Site:	Palisades
Issue date:	03/11/2014
From:	Gustafson O Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PNP 2014-031, TAC MF3508
Download: ML14070A477 (5)

Text

Entergy Nuclear Operations, Inc.

Palisade Nuclear Plant ElitE?!

27780 Blue Star Memorial Highway Covert, Ml 49043-9530 Tel 269 764 2000 Otto W. Gustafson Regulatory Assurance Manager PNP 2014-031 March 11,2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Response to Fourth Request for Additional Information dated March 11, 2014, for Relief Request Number RR 4-18 Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination Palisades Nuclear Plant Docket 50-255 License No. DPR-20

References:

1.

Entergy Nuclear Operations, Inc. letter PNP 2014-015, Relief Request Number RR 4 Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination, dated February 25, 2014 2.

NRC Electronic Mail, Request for Additional Information Palisades - RR 4-18

- Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination

- MF3508, dated February 26, 2014 3.

Entergy Nuclear Operations, Inc. letter PNP 2014-021, Response to Request for Additional Information dated February 26, 2014, for Relief Request Number RR 4-18 Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination, dated March 01, 2014 4.

NRC Electronic Mail, Palisades - RR 4-18

- 2nd Set of RAIs TAC No. MF3508, dated February 27, 2014 5.

Entergy Nuclear Operations, Inc. letter PNP 2014-022, Response to Second Request for Additional Information dated February 27, 2014, for Relief Request Number RR 4-18 Proposed PNP 2014-031 March 11,2014 Entergy Nuclear Operations, Inc.

Palisade Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 Tel 269 764 2000 Otto W. Gustafson Regulatory Assurance Manager U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

References:

Response to Fourth Request for Additional Information dated March 11,2014, for Relief Request Number RR 4 Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination Palisades Nuclear Plant Docket 50-255 License No. DPR-20

1.

Entergy Nuclear Operations, Inc. letter PNP 2014-015, Relief Request Number RR 4 Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination, dated February 25,2014

2.

NRC Electronic Mail, Request for Additional Information -

Palisades - RR 4 Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination - MF3508, dated February 26,2014

3.

Entergy Nuclear Operations, Inc. letter PNP 2014-021, Response to Request for Additional Information dated February 26, 2014, for Relief Request Number RR 4 Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination, dated March 01,2014

4.

NRC Electronic Mail, Palisades - RR 4 2nd Set of RAJ's TAC No. MF3508, dated February 27,2014

5.

Entergy Nuclear Operations, Inc. letter PNP 2014-022, Response to Second Request for Additional Information dated February 27, 2014, for Relief Request Number RR 4 Proposed

PNP 2014-031 Page 2 Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination, dated March 4, 2014 6.

NRC Electronic Mail, Request for Additional Information (3rd set)

- RR 4-18

- Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination

- MF3508, dated March 5, 2014 7.

Entergy Nuclear Operations, Inc. letter PNP 2014-028, Supplemental Response to Request for Additional Information dated February 26, 2014, for Relief Request Number RR 4-18

Proposed Alternative, Use of Alternate ASME Code Case N-770-I Baseline Examination, dated March 6, 2014 8.

Entergy Nuclear Operations, Inc. letter PNP 2014-029, Response to Third Request for Additional Information dated March 5, 2014, for Relief Request Number RR 4-18 Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination, dated March 6, 2014 9.

Entergy Nuclear Operations, Inc. letter PNP 2014-030, Second Supplemental Response to Request for Additional Information dated February 26, 2014, for Relief Request Number RR 4-18

Proposed Alternative, Use of Alternate ASME Code Case N-770-I Baseline Examination, dated March 9, 2014 10.

NRC Electronic Mail, Fourth Request forAdditional Information Palisades - Relief Request RR 4-18

- MF3508, dated March 11, 2014 Sir or Madam:

In Reference 1, Entergy Nuclear Operations, Inc. (ENO) requested Nuclear Regulatory Commission (NRC) approval of the Request for Relief for a Proposed Alternative for the Palisades Nuclear Plant (PNP). NRC approval was requested by March 8, 2014.

Reference 1 is associated with the use of an alternative to the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Code Case N-770-1, as conditioned by 10 CFR 50.55a(g)(6)(ii)(F)(1) and 10 CFR 50.55a(g)(6)(ii)(F)(3), dated June 21, 2011.

In Reference 2, the NRC issued a request for additional information (RAI). ENO responded to the RAI in Reference 3.

In Reference 4, the NRC issued a second RAI.

PNP 2014-031 Page 2 Sir or Madam:

Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination, dated March 4, 2014

6.

NRC Electronic Mail, Request for Additional Information (3rd set)

- RR 4 Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination - MF3508, dated March 5, 2014

7.

Entergy Nuclear Operations, Inc. letter PNP 2014-028, Supplemental Response to Request for Additional Information dated February 26, 2014, for Relief Request Number RR 4 Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination, dated March 6, 2014

8.

Entergy Nuclear Operations, Inc. letter PNP 2014-029, Response to Third Request for Additional Information dated March 5, 2014, for Relief Request Number RR 4 Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination, dated March 6, 2014

9.

Entergy Nuclear Operations, Inc. letter PNP 2014-030, Second Supplemental Response to Request for Additional Information dated February 26, 2014, for Relief Request Number RR 4 Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination, dated March 9, 2014

10. NRC Electronic Mail, Fourth Request for Additional Information -

Palisades - Relief Request RR 4 MF3508, dated March 11, 2014 In Reference 1, Entergy Nuclear Operations, Inc. (ENO) requested Nuclear Regulatory Commission (NRC) approval of the Request for Relief for a Proposed Alternative for the Palisades Nuclear Plant (PNP). NRC approval was requested by March 8, 2014.

Reference 1 is associated with the use of an alternative to the requirements of the American Society of Mechanical Engineers (AS ME) Boiler and Pressure Vessel Code, Code Case N-770-1, as conditioned by 10 CFR 50.55a(g)(6)(ii)(F)(1) and 10 CFR 50.55a(g)(6)(ii)(F)(3), dated June 21, 2011.

In Reference 2, the NRC issued a request for additional information (RAI). ENO responded to the RAI in Reference 3. In Reference 4, the NRC issued a second RAI.

PNP 2014-031 Page 3 ENO responded to the RAI in Reference 5, as supplemented in References 7 and 9.

In Reference 6, the NRC issued a third RAI. ENO responded to the RAI in Reference 8.

In Reference 10, the NRC issued a fourth RAI. The ENO response to this fourth RAI is provided in the attachment.

This submittal makes no new commitments or revisions to previous commitments.

Sincerely, owg/jse

Attachment:

Response to Fourth Request for Additional Information dated March 11, 2014, for Relief Request Number RR 4-18 Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination cc:

Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC PNP 2014-031 Page 3 END responded to the RAI in Reference 5, as supplemented in References 7 and 9.

In Reference 6, the NRC issued a third RAI. END responded to the RAI in Reference 8.

In Reference 10, the NRC issued a fourth RAI. The END response to this fourth RAI is provided in the attachment.

This submittal makes no new commitments or revisions to previous commitments.

Sincerely, owg/jse

Attachment:

Response to Fourth Request for Additional Information dated March 11,2014, for Relief Request Number RR 4 Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination cc:

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

ATTACHMENT Response to Fourth Request for Additional Information dated March II, 2014, for Relief Request Number RR 4-18 Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination By letter dated February 25, 2014, Entergy Nuclear Operations (END) requested Nuclear Regulatory Commission (NRC) approval of the Request for Relief for a Proposed Alternative for the Palisades Nuclear Plant (PNP). By electronic mail, dated March 11, 2014, the Nuclear Regulatory Commission (NRC) submitted a fourth request for additional information. The requested information is provided below.

NRC Information Request Response to Question RAI-3.3 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.

3.0 Proposed Alternative RAI-3.3 The NRC requests the licensee change the proposed alternative to include the following items.

A.

A volumetric examination, using ASME Code,Section XI, Appendix VIII, Supplement 10 qualified procedure, equipment and personnel, will be performed on each of the 9 subject welds of this alternative during the next scheduled refueling outage.

B.

If the Tier Two Action Levels of WCAP-16465NP are reached, the Response Guidelines for Tier Two and Tier Three Action Level will be performed.

C.

If the Tier Two or Tier Three Action Levels of WCAP-16465NP are reached, and the source of leakage is not identified in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the licensee will take action to be in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, and perform bare metal visual examinations of the 9 subject welds of this alternative.

ENO Response In lieu of the alternative requested in RAI-3.3, END proposes to replace the alternative documented in END letter PNP 2014-029, Response to Third Request for Additional Information dated March 5, 2014, for Relief Request Number RR 4-18 Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination, dated March 6, 2014, with the following:

I of 2 ATTACHMENT Response to Fourth Request for Additional Information dated March 11, 2014, for Relief Request Number RR 4 Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination By letter dated February 25,2014, Entergy Nuclear Operations (ENO) requested Nuclear Regulatory Commission (NRC) approval of the Request for Relief for a Proposed Alternative for the Palisades Nuclear Plant (PNP). By electronic mail, dated March 11,2014, the Nuclear Regulatory Commission (NRC) submitted a fourth request for additional information. The requested information is provided below.

NRC Information Request - Response to Question RAI-3.3 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.

3.0 Proposed Alternative RAI-3.3 The NRC requests the licensee change the proposed alternative to include the following items.

A.

A volumetric examination, using ASME Code,Section XI, Appendix VIII, Supplement 10 qualified procedure, equipment and personnel, will be performed on each of the 9 subject welds of this alternative during the next scheduled refueling outage.

B. If the Tier Two Action Levels of WCAP-16465NP are reached, the Response Guidelines for Tier Two and Tier Three Action Level will be performed.

C. If the Tier Two or Tier Three Action Levels of WCAP-16465NP are reached, and the source of leakage is not identified in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the licensee will take action to be in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, and perform bare metal visual examinations of the 9 subject welds of this alternative.

ENO Response In lieu of the alternative requested in RAI-3.3, ENO proposes to replace the alternative documented in ENO letter PNP 2014-029, Response to Third Request for Additional Information dated March 5, 2014, for Relief Request Number RR 4 Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination, dated March 6,2014, with the following:

1 of 2

Proposed Alternative 1)

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

2)

Perform visual examinations (per Code Case N-722-1) and dye penetrant surface examinations (per ASME Section Xl Examination Category B-J, Table IWB-2500-l) of the welds in accordance with ASME requirements.

3)

Perform a volumetric examination, using ASME Code, Section Xl, Appendix VIII, Supplement 10 qualified procedures, equipment and personnel, on each of the nine subject welds of this alternative during the next scheduled refueling outage (1 R24).

4)

Until the next scheduled refueling outage, if unidentified PCS leakage increases by 0.15 gpm above the WCAP-16465NP baseline mean, and is sustained for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, ENO will take action to be in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, and perform bare metal visual examinations of the nine subject welds of this alternative, unless it can be confirmed that the leakage is not from these welds.

Regulation 10 CFR 50.55a(g)(6)(ii)(F)(1) states Licensees of existing, operating pressurized water reactors as of July 21, 2011 shall implement the requirements of ASME Code Case N-770-i, subject to the conditions specified in paragraphs (g)(6)(ii)(F)(2) through (g)(6)(ii)(F)(i0) of this section, by the first refueling outage after August 22, 2011.

Regulation 10 CFR 50.55a(g)(6)(ii)(F)(3) states that baseline examinations for welds in Code Case N-770-1, Table I, Inspection Items A-i, A-2, and B, shall be completed by the end of the next refueling outage after January 20, 2012.

Pursuant to 10 CFR 50.55a(3)(ii), ENO will comply with 10 CFR 50.55a(g)(6)(ii)(F) by completing the baseline volumetric examinations as required by Code Case N-770-i, for each of the nine subject welds of this alternative, prior to the end of the next scheduled refueling outage.

2 of 2 Proposed Alternative

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

2)

Perform visual examinations (per Code Case N-722-1) and dye penetrant surface examinations (per ASME Section XI Examination Category B-J, Table IWB-2500-1) of the welds in accordance with ASME requirements.

3) Perform a volumetric examination, using ASME Code,Section XI, Appendix VIII, Supplement 10 qualified procedures, equipment and personnel, on each of the nine subject welds of this alternative during the next scheduled refueling outage (1 R24).

4) Until the next scheduled refueling outage, if unidentified PCS leakage increases by 0.15 gpm above the WCAP-16465NP baseline mean, and is sustained for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, ENO will take action to be in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, and perform bare metal visual examinations of the nine subject welds of this alternative, unless it can be confirmed that the leakage is not from these welds.

Regulation 10 CFR 50.55a(g)(6)(ii)(F)(1) states "Licensees of existing, operating pressurized water reactors as of July 21, 2011 shall implement the requirements of ASME Code Case N-770-1, subject to the conditions specified in paragraphs (g)(6)(ii)(F)(2) through (g)(6)(ii)(F)(10) of this section, by the first refueling outage after August 22, 2011."

Regulation 10 CFR 50.55a(g)(6)(ii)(F)(3) states that baseline examinations for welds in Code Case N-770-1, Table 1, Inspection Items A-1, A-2, and B, shall be completed by the end of the next refueling outage after January 20, 2012.

Pursuant to 10 CFR 50.55a(3)(ii), ENO will comply with 10 CFR 50.55a(g)(6)(ii)(F) by completing the baseline volumetric examinations as required by Code Case N-770-1, for each of the nine subject welds of this alternative, prior to the end of the next scheduled refueling outage.

2 of 2