ML20267A387

Relief Request Number RR 5-8, Proposed Alternative to ASME Section XI Code Requirements for Repair of Reactor Pressure Vessel Head Penetrations

ML20267A387
Person / Time
Site:	Palisades
Issue date:	09/23/2020
From:	Gaston R Entergy Nuclear Operations, Framatome
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML20267A386	List: ML20267A387 ML20267A388 ML20267A391 PNP 2020-031, Attachment 3 - Framatome, Inc. Affidavit Supporting Withholding of Proprietary Information
References
PNP 2020-031
Download: ML20267A387 (3)

Text

PROPRIETARY INFORMATION -WITHHOLD UNDER 10 CFR 2.390

• ~ Entergr.

UPON REMOVAL OF ATTACHMENT 2, THIS LETTER IS UNCONTROLLED Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213-8298 Tel 601-368-5138 Ron Gaston Director, Nuclear Licensing 10 CFR 50.55a PN P 2020-031 September 23, 2020 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Relief Request Number RR 5-8, Proposed Alternative to ASME Section XI Code Requirements for Repair of Reactor Pressure Vessel Head Penetrations Palisades Nuclear Plant N RC Docket 50-255 Renewed Facility Operating License No. DPR-20

Reference:

Entergy Nuclear Operations, Inc. letter PNP 2018-054, Relief Request Number RR 5-7, Proposed Alternative to ASME Section XI Code requirements for Repair of Reactor Pressure Vessel Head Penetrations, (NRC ADAMS Package Accession Number ML18330A141 ), dated November 26, 2018 Pursuant to Title 1O of the Code of Federal Regulations (CFR) 50.55a(z)(1 ), Acceptable level of quality and safety, Entergy Nuclear Operations, Inc. (Entergy) hereby requests Nuclear Regulatory Commission authorization for the Palisades Nuclear Plant (PNP) of relief request number RR 5-8, Proposed Alternative to ASME Section XI Code Requirements for Repair of Reactor Pressure Vessel Head Penetrations.

Entergy has identified two PNP reactor pressure vessel head penetrations that require repair as a result of examinations of the reactor head performed during the current refueling outage. The provisions of this relief are applicable to the fifth ten-year inservice inspection interval, which complies with the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Division 1, 2007 Edition through the 2008 Addenda.

Referenced above is a similar relief request Entergy submitted in 2018. Two (2) differences of note between Relief Request 5-7 submitted in 2018 and what will be included in Relief Request 5-8 are that the revision of Code Case N-638, Similar and Dissimilar Metal Welding Using Ambient Temperature Machine GTAW Temper Bead Technique, has changed and surface

PNP 2020-031 Page 2 of 3 stress improvement will not be performed. A more detailed description of these noted differences follows.

1. Code Case N-638-7 is conditionally acceptable in the current regulatory guide (RG) for Section XI Code Cases (RG 1.147, lnservice Inspection Code Case Acceptability, ASME Section XI, Division 1, Rev. 19), whereas N-638-6 was conditionally acceptable in RG 1.147 Rev. 18 in 2018. Revision 7 of N-638 made two changes:

a. Developed realistic simulated post-weld heat treat (PWHT) requirements for the test plate used for temper bead qualification. N-638-6 specified prior simulated PWHT on the temper bead qualification test plate equivalent to or greater than the time and temperature applied to the component to be welded. This was a non-conservative requirement. Therefore, revision 7 of N-638 neither required nor prohibited simulated PWHT. However, if used, the simulated PWHT is not permitted to exceed the time or temperature already applied to the base material to be welded. In 2018, Relief Request 5-7 included justification for the test plate not having equivalent to or more simulated PWHT time than the reactor vessel head material. With the change incorporated to N-638-7, there is no need to include that justification in Relief Request 5-8.

b. Developed alternative impact test requirements for temper bead qualification.

This change between N-638-6 and N-638-7 does not affect Relief Request 5-8.

2. Surface stress improvement (i.e., rotary peening) will not be performed as part of the repairs performed in 2020. Code Case N-638-7 (and N-638-6) does not permit peening on the final weld layer, therefore, relief was requested in Relief Request 5-7 to permit rotary peening. Since rotary peening will not be performed in 2020, relief from that restriction is no longer needed.

The primary water stress corrosion cracking evaluation was updated to address no surface stress improvement and the life assessment summary document was revised to reflect the reduced life expectancy. describes the proposed alternative. Attachment 2 contains a repair life assessment summary that supports the proposed alternative and contains information considered proprietary to Framatome, Inc. On behalf of Framatome, Inc., Entergy requests that the NRG withhold this information in accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding. Attachment 3 contains an affidavit supporting withholding of the proprietary information. Attachment 4 contains a non-proprietary version of the repair life assessment summary. Upon removal of the proprietary information in Attachment 2, the balance of this submittal is uncontrolled.

Entergy requests verbal authorization of this request by October 1, 2020, to support the current refueling outage schedule.

This letter contains no new commitments and no revised commitments.

Should you have any questions or require additional information, please contact Jim Miksa Regulatory Assurance Engineer at (269) 764-2945.

PNP 2020-031 Page 3 of 3 Should you have any questions associated with the affidavit, please contact Philip A. Opsal at Framatome, OF34, 3315 Old Forest Rd., Lynchburg, VA 24501.

L~

Respectfully, RWG/jpm Attachments: 1. Relief Request Number RR 5-8, Proposed Alternative to ASME Section XI Code Requirements for Repair of Reactor Pressure Vessel Head Penetrations

2. Framatome Document No. 51-5047343-009, Palisades GEOM Nozzle

/OTB Repair- Life Assessment Summary (Proprietary Information -

Withhold Under 10 CFR 2.390)

3. Framatome, Inc. Affidavit Supporting Withholding of Proprietary Information

4. Framatome Document No. 51-9292503-002, Palisades GEOM Nozzle

/OTB Repair- Life Assessment Summary (Non-Proprietary) cc: NRC Region Ill Regional Administrator NRC Senior Resident Inspector -Palisades NRC Project Manager -Palisades