ML17108A812

Notification for Information Only - Pilgrim Deviation from Inspection Guidelines in EPRI Report 3002000091, Rev. 1

ML17108A812
Person / Time
Site:	Pilgrim
Issue date:	04/10/2017
From:	Perkins E Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.17.028
Download: ML17108A812 (5)

Text

• ~Entergx Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 April 10, 2017 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

Notification for Information Only - Pilgrim Deviation from EPRI Report 3002000091, Rev. 1 Pilgrim Nuclear Power Station Docket No. 50-293 Renewed License No. DPR-35

REFERENCES:

1. EPRI Report 3002000091, Rev. 1, "Nondestructive Evaluation: Guidelines for Conducting Ultrasonic Examinations of Dissimilar Metal Welds, Rev. 1"

2. BWRVIP-94NP, Rev. 2, "BWR Program Implementation Guidelines" LETTER NUMBER: 2.17.028

Dear Sir or Madam:

Entergy hereby informs the U. S. Nuclear Regulatory Commission (NRC) Staff of a specific deviation from the inspection guidelines described in EPRI Report 3002000091, Rev. 1 (Reference 1), in accordance with BWRVIP-94NP Rev. 2 (Reference 2) at Pilgrim Nuclear Power Station (PNPS).

Reference 2 requires notification to the NRG Staff anytime a utility licensee does not implement any portion of an applicable "mandatory" or "needed" Boiling Water Reactor Vessel and Internals Project (BWRVIP) guideline that has been approved by the BWRVIP Executive Committee within 45 days of the licensee executive concurrence with the deviation disposition.

Entergy announced in October 2015 that PNPS will be permanently retired from active service no later than June 1, 2019.

Entergy Nuclear Operation, Inc. Letter No. 2.17.028 Pilgrim Nuclear Power Station Page 2 of 2 The attachment to this letter describes the deviation from the EPRI Report guidance, the justification for the deviation, and any alternative actions in lieu ofthe EPRI Report guidance requirements.

This deviation from the listed EPRI Report guidance has been reviewed and approved in accordance with Entergy procedures and NEI 03-08 "Guideline for the Management of Materials Issues" guidance. The deviation will remain in effect until the end of operating cycle 22 (projected to be June 1, 2019, when PNPS will be retired from active service).

If you have any questions or require additional information, please contact me at 508-830-8323.

This is a notification of deviation only. No action is being requested from the NRC Staff.

There are no regulatory commitments contained in this letter.

Sincerely, E~ns~r~~

Regulatory Assurance Manager EPP/mw/sc

Attachment:

BWRVIP Deviation DD-2016-005 Summary (2 Pages) cc:

Mr. Daniel H. Dorman Mr. John Lamb, Senior Project Manager Regional Administrator, Region I Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd., Suite 100 Mail Stop 8 B1A King of Prussia, PA 19406-2713 Washington, DC 20555 Mr. Joseph Holonich NRC Senior Resident Inspector NRC/NRR BWRVIP Project Manager Pilgrim Nuclear Power Station U.S. Nuclear Regulatory Commission Mail Stop 13 H10 Washington, DC 20555

Attachment Letter Number 2.17.028 BWRVIP Deviation DD-2016-005 Summary (2 Pages)

Entergy Nuclear Operation, Inc. Attachment to Letter No. 2.17.028 Pilgrim Nuclear Power Station Page 1 of 2 BWRVIP Deviation DD-2016-005 Summary Guideline Requirement Pilgrim Nuclear Power Station (PNPS) is required by BWRVIP-75-A to perform required inspections of the Dissimilar Metal Welds (DMW) using Appendix VIII qualified examination techniques.

Deviation PNPS performed an evaluation for the scheduled examination of DMWs and concluded that an automated encoded examination was required for scheduled examinations during Refueling Outage (RFO) 21 at PNPS. The evaluation was based on the fact that the selected/scheduled welds are susceptible to stress corrosion cracking. NRC Generic Letter 88-01 and BWRVIP A classify these DMWs as lntergranular Stress Corrosion Cracking (IGSCC) Category D welds.

This deviation is to perform the selected DMW examinations using a manual phased array Ultrasonic Testing (UT) technique instead of the automated encoded technique.

Justification for Deviation The Electric Power Research Institute (EPRI) enhanced guidance for conducting ultrasonic examinations of dissimilar metal welds provides needec;j guidance in order to be efficient and properly plan the DMW examinations. Utilization of the guidance minimizes the probability of significant human performance errors, improves flaw detection, reduces false calls, and improves the overall quality of the examinations.

All recommendations contained in the EPRI DMW guidance document are being followed with the exception of the recommendation to utilize automated encoded examination techniques.

The examination will be performed utilizing manual phased array UT with qualified American Society of Mechanical EngineersSection XI, Appendix VIII, Supplement 10 procedures as well as utilization of qualified Non-Destructive Examination personnel.

PNPS is working with the selected inspection vendor to ensure multiple qualified personnel are available for live time analyzing and evaluating those welds with identified recordable indications.

In accordance with section 4.4.2 of the DMW guideline, the weld history including any construction repairs is being included into the pre-job briefing paying particular attention to those previously identified areas of interest. Additionally, the examinations being performed in the upcoming outage will be performed using phased array multi-segmented transducer which will increase the ability to interrogate the previously identified indications.

In addition to the heightened awareness of the components that have previously identified indications and using the interaction guidance given in section 4.4.3, PNPS designated NOE Level Ill (UT) will also be engaged with the final disposition of any identified indication which might include additional actions.

Entergy Nuclear Operation, Inc. Attachment to Letter No. 2.17.028 Pilgrim Nuclear Power Station Page 2 of 2 The welds being examined in RF021 were examined using encoded techniques during their last examination. Five welds in 2011 and the other four welds were examined in 2007 also using encoded techniques. While all of the encoded examinations were performed prior to the issuance of the "needed" requirement contained in the 2013 guideline, the data has been reviewed and the intent to acquire encoded data to ensure quality examinations has been satisfied resulting in reasonable assurance that significant flaws would have been identified during the previous exam activities; therefore, the performance of a non-encoded examination of these nine welds being inspected in RF021 is technically justified. None of the encoded examinations performed in 2007 or 2011 identified service related indications indicative of sec.