PNP 2014-081, Response to Fourth Request for Additional Information - Reactor Vessel Internals (ME9569)

Response to Fourth Request for Additional Information - Reactor Vessel Internals (ME9569)

ML14226A807
Person / Time
Site:	Palisades
Issue date:	08/14/2014
From:	Hardy J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PNP 2014-081
Download: ML14226A807 (4)

Text

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~ Entergy tergy Entergy Entergy Nuclear Palisades 27780 Nuclear Operations, Palisades Nuclear 27780 Blue Blue Star Operations, Inc Nuclear Plant Plant Star Memorial Covert, MI 49043-9530 ecv;t Inc.*

Memorial Highway 4:o3953o Tel 269 764 2000 Highway Jeffery Jeffery A. Hardy Hardy Regulatory Assurance Regulatory Assurance Manager Manager PNP 2014-081 PNP 201 4-081 14, 2014 August 14,2014 U. S. Nuclear Regulatory Commission ATTN: Document AnN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Response to Fourth Request for Additional Information - Reactor Vessel Internals (ME9569)

Palisades Nuclear Plant Docket 50-255 License No. DPR-20

REFERENCES:

1. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2012-009, "Revised Revised Program Plan for Aging Management of Reactor Vessel Internals," Internals, September 13, 2012 (ADAMS Accession Number ML ML12257A352) 12257A352)

2. NRC e-mail, Palisades "Palisades - Request for Additional Information - ME9569-ME9569 -

Revised Program Plan for Aging Management of Reactor Vessel Internals, March 04,2013 Internals," 04, 2013 (ADAMS Accession Number ML ML13063A318) 13063A318)

3. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2013-022,

Response

"Response to Request for Additional Information - Revised Program Plan for Aging Management of Reactor Vessel Internals,"Internals, April 04, 2013 (ADAMS Accession Number ML1 3094A41 4)

ML13094A414)

4. NRC e-mail, Palisades "Palisades - Request for Additional Information Information - Reactor Vessel Internals Internals - ME9569

- ME9569 - Email Resend, Resend," December 12, 12, 2013 (ADAMS Accession Number ML13346A644)

ML13346A644)

5. Entergy Nuclear Operations, Operations, Inc.

Inc. letter to NRC, NRC, Summary "Summary of JanuaryJanuary 2, 2014 2014 Teleconference with Nuclear with Nuclear Regulatory Staff Staff onon Palisades Palisades- -

Req uest for Additional Information - Reactor Vessel Internals Request Internals - ME9569 ME9569

Response

Response Schedule, Schedule," January January 07, 07, 2014 (ADAMS (ADAMS Accession Number Number ML1 4007A1 51)

ML14007A151)

6. Entergy

6. Nuclear Operations, Entergy Nuclear Inc. letter Operations, Inc. to NRC, letter to NRC, PNP PNP 2014-001, 2014-001,

Response

"Response to to Second Second Request Request forfor Additional Additional Information Reactor Vessel Information - Reactor

- Vessel Internals Internals - ME9569, ME9569," April 03, 2014 April 03, 2014 (ADAMS (ADAMS Accession Accession NumberNumber ML1 4097A376)

ML 14097 A376)

7. NRC

7. NRC e-mail, e-mail, Request "Request for for Additional Additional Information Information - Palisades

- Palisades - Aging Aging Management Program for Management Program for ReactorReactor Vessel Vessel Internals Internals - ME9569,

- ME9569," JuneJune 09, 09, 2014 (ADAMS 2014 (ADAMS Accession Accession Number Number ML14160B264)

ML14160B264)

PNP 2014-081 PNP 2014-081 Page 22 of Page of 22 Entergy Nuclear

8. Entergy Nuclear Operations, Operations, Inc.

Inc. letter letter to NRC, PNP to NRC, PNP 2014-067, 2014-067, Response to Third Request Information - Reactor "Response to Third Request for Additional Information Reactor Vessel Vessel Internals (ME9569),"

Internals (ME9569), July 01, 2014 2014 (ADAMS Accession Number Number 41 83A01 4)

ML114183A014)

ML

9. NRC

9. NRC e-mail, "Request Request for Additional Information:

Information: Palisades Palisades Aging Management Program Management Program for Reactor Reactor Vessel Internals (ME9569),"

(ME9569),

August 01, 2014 Madam:

Dear Sir or Madam:

In Reference 1, Entergy Nuclear Operations, Inc. (ENO) submitted to the Nuclear Regulatory Commission (NRC) a revised program plan for aging management of reactor vessel internals.

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 with a 30-day required response. In Reference 5, ENO documented a teleconference during which the NRC accepted a request to extend the second RAI response from 30 days to 120 days. ENO responded to the second RAI in Reference 6.

In Reference 7, the NRC issued a third RAI with a 30-day required response. ENO responded to the third RAI in Reference 8.

In Reference 9, the NRC issued a fourth RAI with a 30-day required response.

The response to the fourth RAI RAt is provided in the attachment.

This submittal submittal contains no proprietary information.

This submittal contains no no new or revised commitments.

Sincerely, jah/jse jah/jse

Attachment:

Response

Response to to Fourth Fourth Request Request for for Additional Additional Information Information for for Reactor Reactor Vessel Vessel Internals Internals (ME9569) cc:

cc: Administrator, Administrator, Region Region III, III, USNRC USNRC Project Project Manager, Manager, Palisades, Palisades, USNRC USNRC Resident Inspector, Palisades, Resident Inspector, Palisades, USN RC USNRC

ATTACHMENT Response to Fourth Request for Additional Information for Reactor Vessel Internals (ME9569)

By letter dated September 13, 2012, Entergy Nuclear Operations, Inc. (ENO) submitted to the Nuclear Regulatory Commission (NRC) a revised program plan for aging management of reactor vessel internals at Palisades Nuclear Plant (PNP). By electronic mail, dated August 01, 2014, the NRC issued a fourth request for additional information (RAI) concerning the program plan. The requested information is provided below.

1. NRC Information Request - RAI-4.1 Please confirm that the weld joining the very bottom of the core support barrel to the plate that forms the bottom of the lower core support structure (Figure B), is considered a "Core Core Weld, at PNP and is subject to EVT-1 visual examination as a Support Barrel Lower Girth Weld,"

Primary inspection category component.

"Primary" ENO Response The weld joining the bottom of the core support barrel to the plate that forms the bottom of Core Support Barrel Lower Girth Weld" the lower core support structure is considered a "Core Weld at Primary inspection category PNP, and is subject to EVT-1 visual examination as a "Primary" component.

As discussed in the RAI, Figure 14, "Palisades Palisades Reactor Vessel Internals Inspection Plan,"

Plan, of Reference 11 shows an elevation cross section of the PNP core support barrel and has four circled areas corresponding to portions to be inspected. The figure caption states the following:

EVT-1 Primary: EVT -1 examination of core of upper flange weld and lower cylinder girth welds no later than 2 RFOs [refueling outages] from the beginning of the LR [license renewal]

period (ten year intervals)

Coverage: 100%)

100% of accessible surfaces of upper flange weld and lower cylinder girth welds The lower-most weld circled in the figure is the weld that joins the bottom of the core support barrel to the plate that forms the bottom of the lower core support structure. This weld is considered to be a Core "Core Support Barrel Lower Girth Weld Weld" and is subject to EVT-1 visual examination as a Primary "Primary" inspection category component.

2. NRC NRC Information Information Request - RAI-4.2 Please confirm that Entergy Nuclear Operations, Inc. understands there to be an error in MRP-227-A, Tables 4-2 and 4-5 in in that both both the Core "Core Support Support Barrel Lower Flange Weld, Weld,"

and "Core Support and Core Support Barrel Lower Core Barrel Flange, should have Flange," should been identified have been as not identified as not applicable applicable to PNP.

Page Page 11 of 22

ENO Response Pressurized Water Reactor (PWR)

ENO understands that there is an error in MRP-227-A, "Pressurized Internals Inspection and Evaluation Guidelines" Guidelines (Reference 2), Tables 4-2, "CE CE plants components, and 4-5, "CE Primary components," CE plants Expansion components."

components. In these two tables, Core Support Barrel Assembly, Lower flange weld" the "Core weld and the "Core Core Support Barrel flange should have been identified as not applicable to PNP.

Assembly, Lower core barrel flange" This error has been documented in the PNP corrective action program.

References

1. Revised Program Plan for Aging Management of Reactor Vessel Palisades Nuclear Plant, "Revised Internals, dated September 13, 2012 (ADAMS Accession No. ML Internals," ML12257A352) 12257A352)

2. Electrical Power Research Institute, "Materials Materials Reliability Program: Pressurized Water (MRP-227-A), 1022863, dated Reactor Internals Inspection and Evaluation Guidelines (MRP-227-A),"

December 2011.

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