ML071170148

Request for Relief, RR 4-12, Use of Code Case N-513-2

ML071170148
Person / Time
Site:	Palisades
Issue date:	05/16/2007
From:	Raghavan L NRC/NRR/ADRO/DORL/LPLIII-1
To:	Balduzzi M Entergy Nuclear Operations
POOLE, J
References
Code Case N-513-2, RR-4-12, TAC MD2415
Download: ML071170148 (10)

Text

May 16, 2007Mr. Michael Balduzzi Sr. Vice President, Regional Operations NEEntergy Nuclear Operations, Inc.440 Hamilton AvenueWhite Plains, NY 10601

SUBJECT:

PALISADES NUCLEAR PLANT - REQUEST FOR RELIEF, RR 4-12, USE OFCODE CASE N-513-2 (TAC NO. MD2415)

Dear Mr. Balduzzi:

By a letter dated June 12, 2006, Nuclear Management Company, LLC (the licensee, at the timeof the submittal), proposed to use the American Society of Mechanical Engineers (ASME) CodeCase N-513-2, "Evaluation Criteria for Temporary Acceptance of Flaws in Moderate EnergyClass 2 or 3 Piping" to evaluate flaws in piping in lieu of the requirements of Subarticle IWA-4000 of the ASME Boiler and Pressure Vessel Code,Section XI. The transfer of ownership ofPalisades Nuclear Plant from Consumers Energy Company (Consumers) to Entergy NuclearPalisades occurred on April 11, 2007.Based on our review of the submitted information, we conclude that the proposed alternative will provide an acceptable level of quality and safety because Code Case N-513-2 incorporatesthe conditions listed in Regulatory Guide (RG) 1.147, "Inservice Inspection Code CaseAcceptability," Revision 14 imposed by the staff on the implementation of Code Case N-513-1. Pursuant to Title 10 of the Code of the Federal Regulations (10 CFR) Section 50.55a(a)(3)(i), the proposed alternative is authorized for the fourth 10-year interval as noted in the reliefrequest.Use of the Code Case is authorized until such time as the Code Case is published in a futureversion of RG 1.147, and incorporated by reference in 10 CFR 50.55a(b). At that time, ifEntergy Nuclear Operations, Inc. intends to continue implementing this Code Case, it mustfollow all provisions of Code Case N-513-2 with conditions as specified in RG 1.147, andlimitations as specified in Sections 50.55a(b)(4), (b)(5) and (b)(6), if any.Sincerely,

/RA/

L. Raghavan, ChiefPlant Licensing Branch III-1Division of Operating Reactor LicensingOffice of Nuclear Reactor RegulationDocket No. 50-255

Enclosure:

Safety Evaluationcc w/encl: See next page May 16, 2007Mr. Michael Balduzzi Sr. Vice President, Regional Operations NEEntergy Nuclear Operations, Inc.440 Hamilton AvenueWhite Plains, NY 10601

SUBJECT:

PALISADES NUCLEAR PLANT - REQUEST FOR RELIEF, RR 4-12, USE OFCODE CASE N-513-2 (TAC NO. MD2415)

Dear Mr. Balduzzi:

By a letter dated June 12, 2006, Nuclear Management Company, LLC (the licensee, at the timeof the submittal), proposed to use the American Society of Mechanical Engineers (ASME) CodeCase N-513-2, "Evaluation Criteria for Temporary Acceptance of Flaws in Moderate EnergyClass 2 or 3 Piping" to evaluate flaws in piping in lieu of the requirements of Subarticle IWA-4000 of the ASME Boiler and Pressure Vessel Code,Section XI. The transfer of ownership ofPalisades Nuclear Plant from Consumers Energy Company (Consumers) to Entergy NuclearPalisades occurred on April 11, 2007.Based on our review of the submitted information, we conclude that the proposed alternative will provide an acceptable level of quality and safety because Code Case N-513-2 incorporatesthe conditions listed in Regulatory Guide (RG) 1.147, "Inservice Inspection Code CaseAcceptability," Revision 14 imposed by the staff on the implementation of Code Case N-513-1. Pursuant to Title 10 of the Code of the Federal Regulations (10 CFR) Section 50.55a(a)(3)(i), the proposed alternative is authorized for the fourth 10-year interval as noted in the reliefrequest.Use of the Code Case is authorized until such time as the Code Case is published in a futureversion of RG 1.147, and incorporated by reference in 10 CFR 50.55a(b). At that time, ifEntergy Nuclear Operations, Inc. intends to continue implementing this Code Case, it mustfollow all provisions of Code Case N-513-2 with conditions as specified in RG 1.147, andlimitations as specified in Sections 50.55a(b)(4), (b)(5) and (b)(6), if any.Sincerely,

/RA/

L. Raghavan, ChiefPlant Licensing Branch III-1Division of Operating Reactor LicensingOffice of Nuclear Reactor RegulationDocket No. 50-255

Enclosure:

Safety Evaluationcc w/encl: See next pageDistribution:PUBLICLPL3-1 r/fRidsNrrLATHarris RidsNrrPMMChawlaRidsNrrDorlLPL3-1RidsOgcRpRidsAcrsAcnwMailCenterRidsRgn3MailCenterTBloomer, EDO Region 3ADAMS Accession Number: ML071170148OFFICENRR/LPL3-1/PMNRR/LPL3-1/LADCI/CPNBOGCNRR/LPL3-1/BCNAMEMChawlaTHarrisTChanJBonannoLRaghavanDATE05/14/0705/14/0704/10/0705/14/0705/16/07OFFICIAL RECORD COPY Palisades Plant cc:

Regional Administrator, Region IIIU.S. Nuclear Regulatory CommissionSuite 2102443 Warrenville RoadLisle, IL 60532-4351SupervisorCovert TownshipP. O. Box 35Covert, MI 49043Office of the GovernorP. O. Box 30013Lansing, MI 48909U.S. Nuclear Regulatory CommissionResident Inspector's OfficePalisades Plant27782 Blue Star Memorial HighwayCovert, MI 49043Michigan Department of Environmental QualityWaste and Hazardous Materials DivisionHazardous Waste and Radiological Protection SectionNuclear Facilities UnitConstitution Hall, Lower-Level North525 West Allegan StreetP.O. Box 30241Lansing, MI 48909-7741Michigan Department of Attorney GeneralSpecial Litigation Division525 West Ottawa St.Sixth Floor, G. Mennen Williams BuildingLansing, MI 48913Mr. Michael R. KanslerPresident & CEO/CNOEntergy Nuclear Operations, Inc.440 Hamilton AvenueWhite Plains, NY 10601Mr. John T. HerronSr. Vice PresidentEntergy Nuclear Operations, Inc.440 Hamilton AvenueWhite Plains, NY 10601Sr. Vice President,Engineering and Technical ServicesEntergy Nuclear Operations, Inc.1340 Echelon ParkwayJackson, MS 39213Mr. Bruce C. WilliamsVice President, OversightEntergy Nuclear Operations, Inc.1340 Echelon ParkwayJackson, MS 39213Mr. Christopher J. SchwarzSite Vice PresidentEntergy Nuclear Operations, Inc.Palisades Nuclear Plant27780 Blue Star Memorial HighwayCovert, MI 49043General Manager, Plant OperationsEntergy Nuclear Operations, Inc.Palisades Nuclear Plant27780 Blue Star Memorial HighwayCovert, MI 49043Mr. Oscar LimpiasVice President, EngineeringEntergy Nuclear Operations, Inc.440 Hamilton AvenueWhite Plains, NY 10601Mr. John F. McCannDirector, Nuclear Safety & LicensingEntergy Nuclear Operations, Inc.440 Hamilton AvenueWhite Plains, NY 10601 Palisades Plant cc:

Ms. Charlene D. FaisonManager, LicensingEntergy Nuclear Operations, Inc.440 Hamilton AvenueWhite Plains, NY 10601Mr. Ernest J. HarknessDirector of OversightEntergy Nuclear Operations, Inc.440 Hamilton AvenueWhite Plains, NY 10601Mr. William DennisAssistant General CounselEntergy Nuclear Operations, Inc.440 Hamilton AvenueWhite Plains, NY 10601Mr. Joseph DeRoyVice President, Operations SupportEntergy Nuclear Operations, Inc.1340 Echelon ParkwayJackson, MS 39213Laurie A. Lahti, Manager, LicensingRegulatory AffairsEntergy Nuclear Operations, Inc.Palisades Nuclear Plant27780 Blue Star Memorial HighwayCovert, MI 49043 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONUSE OF CODE CASE N-513-2 FOURTH 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NO. RR 4-12PALISADES NUCLEAR PLANTENTERGY NUCLEAR OPERATIONS, INC.DOCKET NO. 50-25

51.0INTRODUCTION

By letter dated June 12, 2006, Nuclear Management Company, LLC (NMC, the licensee, at thetime of submittal) submitted request for relief (RR 4-12). In the request, the licensee proposedto use an alternative to certain requirements of the American Society of Mechanical Engineers(ASME) Code. Specifically, the licensee requested to use Code Case N-513-2, "EvaluationCriteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping" in lieu ofSubarticle IWA-4000 of the ASME Boiler and Pressure Vessel Code (ASME Code),Section XI,"Rules for Inservice Inspection of Nuclear Power Plant Components." The relief proposed issought for the fourth 10-year inservice inspection (ISI) interval of the Palisades Nuclear Plant(Palisades). The Palisades fourth 10-year ISI interval started on December 13, 2006.

2.0 REGULATORY EVALUATION

The ISI of the ASME Code Class 1, Class 2, and Class 3 components is to be performed inaccordance with the ASME Code,Section XI, and applicable edition and addenda as requiredby Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g). Pursuant to paragraph 10CFR 50.55a(a)(3), alternatives to the requirements of paragraph (g) may be used, whenauthorized by the Nuclear Regulatory Commission (NRC), if the applicant demonstrates that: (i)the proposed alternatives would provide an acceptable level of quality and safety, or (ii)compliance with the specified requirements would result in hardship or unusual difficulty withouta compensating increase in the level of quality and safety.Pursuant to paragraph 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components(including supports) will meet t he requirements, except the design and access provisions andthe preservice examination requirements, set forth in the ASME Code,Section XI, to the extentpractical within the limitations of design, geometry, and materials of construction of thecomponents. 10CFR 50.55a(g)(4)(i) requires that the ISI of components and system pressuretests conducted during the initial 10-year inspection interval comply with the requirements in thelatest edition and addenda of Section XI of the ASME Code incorporated by reference in 10CFR50.55a(b) on the date 12 months before the issuance of the operating license. The regulation at10CFR 50.55a(g)(4)(ii) requires that the ISI during successive 10-year inspection intervals comply with the requirements of the latest edition and addenda of Section XI of the ASME Codeincorporated by reference in 10CFR 50.55a(b) 12 months before the start of the 120-monthinspection interval, subject to the limitations and modifications listed therein.

3.0 TECHNICAL EVALUATION

3.1 ASME Code Component(s) AffectedASME Section XI, Moderate Energy Class 2 and Class 3 Piping.

3.2 Applicable ASME,Section XI, Code Edition and Addenda2001 Edition through the 2003 Addenda3.3 Applicable ASME Code RequirementsThe requirements of the 2001 Edition with the 2003 for Class 2 and Class 3 piping are asfollows:Class 2 PipingIWC-3122 provides three ways in which an inservice volumetric and surface examinations maybe accepted.1. IWC-3122.1, "Acceptance by Examination"2. IWC-3122.2, "Acceptance by Repair/Replacement Activity"3. IWC-3122.3, "Acceptance by Analytical Evaluation"IWC-3122.2 states, "A component whose examination detects flaws that exceed the acceptance standards of Table IWC-3410-1 is unacceptable for continued service until theadditional examination requirements of IWC-2430 are satisfied and the component is correctedby a repair/replacement activity to the extent necessary to meet the acceptance standards of IWC-3000."IWC-3132 provides four ways in which inservice visual examinations may be accepted.

1. IWC-3132, "Acceptance"2. IWC-3132.1, "Acceptance by Supplemental Examination"3. IWC-3132.2, "Acceptance by Corrective Measures or Repair/Replacement Activity"4. IWC-3132.3, "Acceptance by Analytical Evaluation"IWC-3132.2 states "A component containing relevant conditions is acceptable for continuedservice if the relevant conditions are corrected by a repair/replacement activity or by correctivemeasures to the extent necessary to meet the acceptance standards of Table IWC-3410-1."Class 3 PipingIWD-3120(a) states, "This Article is in course of preparation. The requirements of IWC-3120may be used." IWD-3120(b) states, "Components whose examination reveals flaws that do not meet thestandards of IWD-3400 shall be subjected to supplemental examination, or to arepair/replacement activity." IWD-3200 Supplemental Examinations states, "In the course of preparation. The requirementsof IWC-3200 may be used."IWD-3400 Standards states, "In the course of preparation. The requirements of IWC-3400 maybe used."3.4 Licensee's Basis for Proposed AlternativeThe licensee stated that relief is requested from replacement or internal weld repair of wallthinning conditions resulting from various wall thinning degradation mechanisms such aserosion, corrosion, cavitation, and pitting in moderate energy Class 2 and 3 piping systems inaccordance with the design specification and the original construction code. The licensee stated that the NRC in Regulatory Guide (RG) 1.147, Revision 14, has acceptedCode Case N-513-1 with the following limitations:1. Specific safety factors in paragraph 4.0 must be satisfied.

2. Code Case N-513 may not be applied to:(a) components other than pipe and tube(b) leakage through a gasket(c) threaded connections employing nonstructural seal welds for leakage prevention(through seal weld leakage is not a structural flaw; thread integrity must be maintained)(d) degraded socket weldsCode Case N-513-1 permits flaws in Class 2 and 3 moderate-energy piping on a temporarybasis until the next outage if it can be demonstrated that adequate pipe integrity and leakagecontainment are maintained. The Code Case currently applies to part-through and through-wallplanar flaws and part-through nonplanar flaws. Service experience has shown that some pipingcan suffer degradation from nonplanar flaws, such as pitting and microbiological attack, whereleakage can occur. The Code Case can be used for nonplanar through-wall flaws, but in arestrictive situation where nonplanar geometry is dominant in one plane.According to the licensee, some plants have used the intent of Code Case N-513 for nonplanarleaking flaws. However, relief requests from code r equirements are still required because of thelimited scope of Code Case N-513. Code Case N-513-2 has expanded the application to coverall types of nonplanar flaws. The analysis procedures were expanded to address the generalcase of through-wall degradation. Code Case N-513-2 incorporates improved flaw evaluationprocedures for piping that are provided in Appendix C to the 2002 Addenda of the ASME Code,Section XI. Code Case N-513-2 addresses the limitations posed in RG 1.147 as follows:1. Paragraph 4.0 was revised to incorporate references to Appendix C for acceptance andeliminated the provision that lower safety factors may be used. 2. 1.0(a) was revised to limit the application of the code case as specified in the limitationapplied in RG 1.147.3.5 Duration of Proposed AlternativeThe licensee requested approval of Code Case N-513-2 to be used for the fourth 10-year ISIinterval at the Palisades.3.6 NRC Staff EvaluationAs indicated in the above ASME Code,Section XI, requirements, flaws detected in Class 2 and3 piping need to be either removed by repair/replacement, or accepted by analysis andacceptance criteria specified by of the ASME Code,Section XI. In the mid-1990's, the industryproposed temporary measures to accept and manage flaws in service for Class 3 piping. On August 14, 1997, the ASME issued the first version of Code Case N-513 which permitted temporary acceptance of flaws in moderate energy Class 3 piping without repair/replacement ofdegraded pipe during operation. On March 28, 2001, the ASME issued Code Case N-513-1 which permits temporary acceptanceof flaws for continued service in Class 2 and Class 3 piping without repair/replacement. Code Case N-513-1 also includes a revised flaw evaluation methodology. As stated in thelicensee's basis above, the NRC staff has accepted Code Case N-513-1 in RG 1.47, Revision14, with conditions. The NRC staff's conditions are related to safety factors and the scope ofapplicability of the code case. On February 20, 2004, the ASME issued Code Case N-513-2 to address the NRC staffconditions imposed on Code Case N-513-1. The NRC staff has reviewed the proposedchanges in Code Case N-513-2 and finds them to be acceptable. However, the NRC staff hasnot yet published the approval of Code Case N-513-2 in RG 1.147, Revision 14, or in 10 CFR50.55a. The NRC staff has reviewed changes between Code Case N-513-1 and Code Case N-513-2and has confirmed that Code Case N-513-2 has incorporated the conditions imposed in RG1.147, Revision 14. As discussed above, Code Case N-513-2 has incorporated the flawevaluation procedures for piping that are specified in Appendix C to the 2002 Addenda of theASME Code,Section XI. The NRC staff has approved the 2002 Addenda of the ASME Code in10 CFR 50.55a. Therefore, the use of the flaw evaluation methodology in Appendix C to the2002 Addenda is acceptable. Although some flaws are allowed to remain in service, Code Case N-513-2 providesrequirements to assure piping integrity. Code Case N-513-2 requires frequent inspections of nolonger than 30-day intervals to determine if the flaw is growing and to establish the time atwhich the flaw will reach the allowable size. Alternatively, a flaw growth evaluation may beperformed to predict the time at which the detected flaw will grow to the allowable size. When aflaw growth analysis is used to establish the allowable time for temporary operation, periodicexaminations of no more than 90 day intervals shall be conducted to verify the flaw growthanalysis predictions. If the inspections show that the flaw growth rate to be unacceptable, theCode Case requires repair or replacement when the predicted flaw size exceeds theacceptance criteria or the next scheduled outage, whichever occurs first. For through-wall leaking flaws, the code case requires daily walkdowns to confirm that theanalysis conditions in the evaluation remain valid. In addition, the Code Case requiresaugmented volumetric examination or physical measurement to assess degradation of theaffected system. The Code Case requires expansion in the inspection scope by increasing thesample size when additional flaws are found. Code Case N-513-2 also provides a rigorousmethodology and acceptance criteria to evaluate the flaw. The licensee is committed to adhereto all of the requirements in Code Case N-513-2.Further, the NRC staff notes that although the degraded pipe is permitted to operate per CodeCase N-513-2, the degraded piping is required to be repaired or replaced during the subsequentrefueling outage in accordance with the appropriate requirements of Section XI of the ASMECode. On the basis of the above evaluation, the NRC staff finds that in lieu of ASME Code,Section XI, IWA-4000, the proposed alternative requirements of Code Case N-513-2 provide an acceptablelevel of quality and safety.

4.0 CONCLUSION

The NRC staff concludes that use of ASME Code,Section XI, Code Case N-513-2, asdiscussed in the request for relief will provide an acceptable level of quality and safety. CodeCase N-513-2 contains requirements to maintain piping structural integrity, and incorporates theconditions listed in RG 1.147, Revision 14. Therefore, use of the Code Case is authorized untilsuch time as the Code Case is published in a future version of RG 1.147, and incorporated byreference in 10 CFR 50.55a(b). At that time, if Entergy Nuclear Operations, Inc. intends tocontinue implementing this Code Case, it must follow all provisions of Code Case N-513-2 withconditions as specified in RG 1.147, and limitations as specified in Sections 50.55a(b)(4), (b)(5),and (b)(6), if any. Pursuant to 10 CFR 50.55a(a)(3)(i), the proposed alternative is authorized for the performanceof piping evaluations to determine whether temporary continued operation of applicable ASMECode Class 2 and 3 piping systems is allowed. This authorization applies to Palisades for theremainder of the fourth10-year ISI interval of Palisades as noted in the relief request.

All other requirements of the ASME Code, Sections III and XI, for which relief has not beenspecifically requested and approved remain applicable, including third party review by theAuthorized Nuclear Inservice Inspector.Principal Contributor: Keith M. Hoffman Date: May 16, 2007