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| issue date = 03/11/2016
| issue date = 03/11/2016
| title = Notification for Information Only - Deviations from BWRVIP-41, Rev. 3, BWRVIP-76, Rev. 1-A, BWRVIP-139-A, and BWRVIP-180, Rev.0 Guidelines
| title = Notification for Information Only - Deviations from BWRVIP-41, Rev. 3, BWRVIP-76, Rev. 1-A, BWRVIP-139-A, and BWRVIP-180, Rev.0 Guidelines
| author name = Perkins E P
| author name = Perkins E
| author affiliation = Entergy Nuclear Operations, Inc
| author affiliation = Entergy Nuclear Operations, Inc
| addressee name =  
| addressee name =  
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=Text=
=Text=
{{#Wiki_filter:i Entergy Nuclear Operations, Inc.-r~lFP-fjv600 Rocky Hill Road Plymouth. 02360 March 11, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
{{#Wiki_filter:i                                                   Entergy Nuclear Operations, Inc.
                    -   r~lFP-fjv600                                   Rocky Hill Road Plymouth. MA* 02360 March 11, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001


==SUBJECT:==
==SUBJECT:==
Notification for Information Only -Pilgrim Deviations from BWRVIP-41, Rev.3, BWRVI P-76, Rev. 1-A, BWRVI P-I139-A, and BWRVIP-1 80, Rev.0 Guidelines Pilgrim Nuclear Power Station Docket No. 50-293 Renewed License No. DPR-35  
Notification for Information Only - Pilgrim Deviations from BWRVIP-41, Rev.3, BWRVI P-76, Rev. 1-A, BWRVI P-I139-A, and BWRVIP-1 80, Rev.0 Guidelines Pilgrim Nuclear Power Station Docket No. 50-293 Renewed License No. DPR-35


==REFERENCES:==
==REFERENCES:==
: 1. BWRVIP-41, Rev.3, "BWR Jet Pump Assembly Inspection and Flaw Evaluation Guidelines" 2. BWRVIP-76, Rev.l-A, "BWR Core Shroud Inspection and Flaw Evaluation Guidelines" 3. BWRVIP-139-A, "BWR Steam Dryer Inspection and Flaw Evaluation Guidelines
: 1. BWRVIP-41, Rev.3, "BWR Jet Pump Assembly Inspection and Flaw Evaluation Guidelines"
: 4. BWRVIP-1 80, Rev.0, "BWR Access Hole Cover- Inspection and Flaw Evaluation Guidelines" 5. BWRVIP-94NP, Rev.2, "BWR Program Implementation Guidelines" 6. U.S. Nuclear Regulatory Commission Letter to Entergy, Supplemental Safety Evaluation Report Related to the License Renewal of Pilgrim Nuclear Power Station (TAC No. MC9669), June 30, 2011. (1.11.076)
: 2. BWRVIP-76, Rev.l-A, "BWR Core Shroud Inspection and Flaw Evaluation Guidelines"
LETTER NUMBER: 2.16.016  
: 3. BWRVIP-139-A, "BWR Steam Dryer Inspection and Flaw Evaluation Guidelines
: 4. BWRVIP-1 80, Rev.0, "BWR Access Hole Cover- Inspection and Flaw Evaluation Guidelines"
: 5. BWRVIP-94NP, Rev.2, "BWR Program Implementation Guidelines"
: 6. U.S. Nuclear Regulatory Commission Letter to Entergy, Supplemental Safety Evaluation Report Related to the License Renewal of Pilgrim Nuclear Power Station (TAC No. MC9669), June 30, 2011. (1.11.076)
LETTER NUMBER: 2.16.016


==Dear Sir or Madam:==
==Dear Sir or Madam:==
Entergy Nuclear Operations, Inc. hereby informs the NRC of specific deviations from the inspection guidelines described in BWRVIP-41, Rev.3 (Reference 1), BWRVIP-76, Rev.l-A (Reference 2), BWRVIP-1 39-A (Reference
 
: 3) and BWRVIP-1 80, Rev.0 (Reference
Entergy Nuclear Operations, Inc. hereby informs the NRC of specific deviations from the inspection guidelines described in BWRVIP-41, Rev.3 (Reference 1), BWRVIP-76, Rev.l-A (Reference 2), BWRVIP-1 39-A (Reference 3) and BWRVIP-1 80, Rev.0 (Reference 4) in accordance with BWRVIP-94NP, Rev.2 (Reference 5) at Pilgrim Nuclear Power Station (PNPS).
: 4) in accordance with BWRVIP-94NP, Rev.2 (Reference
Reference 5 requires notification to the NRC anytime a utility does not implement any portion of an applicable "mandatory"~ or "needed" BWR Vessel and Internals Project (BWRVIP) guideline that has been approved by the BWRVIP Executive Committee within 45 days of the utility executive concurrence with the deviation disposition.
: 5) at Pilgrim Nuclear Power Station (PNPS).Reference 5 requires notification to the NRC anytime a utility does not implement any portion of an applicable "mandatory"~
 
or "needed" BWR Vessel and Internals Project (BWRVIP) guideline that has been approved by the BWRVIP Executive Committee within 45 days of the utility executive concurrence with the deviation disposition.
Entergy Nuclear Operations, Inc.                                       Letter No. 2.16.016 Pilgrim Nuclear Power Station                                                  Page 2 of 2 The deviations listed in Table 1 of the Attachment are all deviations from BWRVIP guidelines that are classified as "needed" elements of the BWRVIP program. The deviations are due to Entergy's recent announcement of plant closure, performance deficiencies with vendor ultrasonic testing tooling and plant configuration interferences to weld examinations.
Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station Letter No. 2.16.016 Page 2 of 2 The deviations listed in Table 1 of the Attachment are all deviations from BWRVIP guidelines that are classified as "needed" elements of the BWRVIP program. The deviations are due to Entergy's recent announcement of plant closure, performance deficiencies with vendor ultrasonic testing tooling and plant configuration interferences to weld examinations.
Entergy announced in October 2015 that Pilgrim Nuclear Power Station will be permanently retired from active service not later than June 1, 2019.
Entergy announced in October 2015 that Pilgrim Nuclear Power Station will be permanently retired from active service not later than June 1, 2019.Table 1 lists the deviation from BWRVIP guidelines, the justification for the deviation and any alternative actions in lieu of the BWRVIP requirements.
Table 1 lists the deviation from BWRVIP guidelines, the justification for the deviation and any alternative actions in lieu of the BWRVIP requirements. Table 1 also lists the Pilgrim Station License Renewal Commitment Number associated with the corresponding BWRVIP guidelines document, if any (Reference 6).
Table 1 also lists the Pilgrim Station License Renewal Commitment Number associated with the corresponding BWRVIP guidelines document, if any (Reference 6).The deviations from the listed BWRVIP guidelines have been reviewed and approved in accordance with Entergy procedures and NEI 03-08 guidance.
The deviations from the listed BWRVIP guidelines have been reviewed and approved in accordance with Entergy procedures and NEI 03-08 guidance. The deviations will remain in effect until the end of cycle 22 (Spring 2019 when Pilgrim will cease commercial operation).
The deviations will remain in effect until the end of cycle 22 (Spring 2019 when Pilgrim will cease commercial operation).
If you have any questions or require additional information, please contact me at (508) 830-8323.
If you have any questions or require additional information, please contact me at (508) 830-8323.This is a notification of deviation only, and no action is being requested from the NRC.There are no regulatory commitments made in this letter.Sincerely, Everett P. Perkins, Jr.' 'Regulatory Assurance Manager EPP/mw  
This is a notification of deviation only, and no action is being requested from the NRC.
There are no regulatory commitments made in this letter.
Sincerely, Everett P. Perkins, Jr.'             '
Regulatory Assurance Manager EPP/mw


==Attachment:==
==Attachment:==
TABLE I      - Deviation Listing cc:
Mr. Daniel H. Dorman                                Ms. Booma Venkataraman, 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 O-8C2A 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 2.16.016 TABLE 1 - Deviation Listing (4 Pages)


TABLE I -Deviation Listing cc: Mr. Daniel H. Dorman Regional Administrator, Region I U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd., Suite 100 King of Prussia, PA 19406-2713 Mr. Joseph Holonich NRC/NRR BWRVIP Project Manager U.S. Nuclear Regulatory Commission Mail Stop 13 H10 Washington, DC 20555 Ms. Booma Venkataraman, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8C2A Washington, DC 20555 NRC Senior Resident Inspector Pilgrim Nuclear Power Station Attachment Letter Number 2.16.016 TABLE 1 -Deviation Listing (4 Pages)
Entergy Nuciear Operations, Inc.                                                                               Attachment to 2.16.016 Pilgrim Nuclear Power Station                                                                                              Page 1 of 4 TABLE 1 - Deviation Listing BWRVIP          Deviation from                                  Justification for Deviation                        Alternative Actions /
Entergy Nuciear Operations, Inc.Pilgrim Nuclear Power Station Attachment to 2.16.016 Page 1 of 4 TABLE 1 -Deviation Listing BWRVIP Deviation from Justification for Deviation Alternative Actions /Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No.,___________________________________
Guidelines      BWRVIP Guidelines                                                                                    License Renewal Document                                                                                                            Regulatory Commitment No.,___________________________________
BWRVIP-41, Rev.3 Pilgrim Station is required to re-inspect all jet pump (JP) beam BB-1 and BB-2 regions by UT methods by 2017; a 10-year re-inspection frequency (There are a total of 20 JPs).Instead, Pilgrim plans to perform an EVT-1 visual examination of all beams during the 2017 (RFO21) last planned refuel outage in lieu of UT re-inspection examination required by BWRVIP-41, Rev.3, Table 2-4.Pilgrim replaced all 20 original JP beams with the improved Group 2 beams in 1984 and has subsequently examined all beams by UT method per BWRVIP guidelines without any relevant indications.
BWRVIP-41,     Pilgrim Station is      Pilgrim replaced all 20 original JP beams with the improved Group 2         Pilgrim plans to perform an Rev.3          required to re-inspect  beams in 1984 and has subsequently examined all beams by UT                EVT-1 visual examination of all jet pump (JP) beam  method per BWRVIP guidelines without any relevant indications. The          all 20 beams during the 2017 BB-1 and BB-2 regions   BWRVIP 10-year re-inspection frequency is based on a normal                (RFO21) refuel outage in lieu by UT methods by        water chemistry environment. However, Pilgrim's superior water              of UT re-inspection 2017; a 10-year re-      chemistry environment should be conducive to a longer re-inspection         examination required by inspection frequency    interval, i.e., no-less than a 12-year interval ending in 2019 when the    BWRVIP-41, Rev.3, Table 2-(There are a total of 20 plant will be retired from active service.                                  4.
The BWRVIP 10-year re-inspection frequency is based on a normal water chemistry environment.
JPs).
However, Pilgrim's superior water chemistry environment should be conducive to a longer re-inspection interval, i.e., no-less than a 12-year interval ending in 2019 when the plant will be retired from active service.The alternative proposed examination of all 20 beams in 2017 will provide additional assurance that sufficient structural integrity exists to justify an additional cycle of operation to 2019. This alternative method is appropriate as the EVT-1 method has the capability to detect lntergranular Stress Corrosion Cracking (IGSCC)initiating from visible areas of the top surface and IGSCC is the only known significant degradation mechanism associated with JP beams.Pilgrim plans to perform an EVT-1 visual examination of all 20 beams during the 2017 (RFO21) refuel outage in lieu of UT re-inspection examination required by BWRVIP-41, Rev.3, Table 2-4.There are no License Renewal Commitments for inspection of jet pump beams.Upon BWRVIP approval, this deviation disposition constitutes an approved plant-specific application of the BWRVIP guidelines.
The alternative proposed EVT*-1 examination of all 20 beams in 2017        There are no License Instead, Pilgrim plans  will provide additional assurance that sufficient structural integrity      Renewal Commitments for to perform an EVT-1      exists to justify an additional cycle of operation to 2019. This            inspection of jet pump visual examination of    alternative method is appropriate as the EVT-1 method has the              beams.
Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station Attachment to 2.16.016 Page 2 of 4 TABLE I -Deviation Listing BWRVIP TDeviation from 1Justification for Deviation Alternative Actions/Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No. j __ _____ __BWRVI P-76, Rev. 1 -A Pilgrim is required to re-inspect core shroud beltline vertical welds V15, V16, V17 and V18 by either a UT volumetric or two-sided EVT-1 visual examination method by 2017.The deviation is a one-time two-year extension over the 10-year re-inspection interval for the UT inspection strategy of the core shroud beltline vertical welds V15, V16, V17 and V18 as required by BWRVIP-76, Rev.l-A, Figure 3-3. The two year extension is from 2017 to 2019, when Pilgrim plans to cease operations.
all beams during the    capability to detect lntergranular Stress Corrosion Cracking (IGSCC) 2017 (RFO21) last        initiating from visible areas of the top surface and IGSCC is the only      Upon BWRVIP approval, this planned refuel outage    known significant degradation mechanism associated with JP                  deviation disposition in lieu of UT re-        beams.                                                                     constitutes an approved inspection examination                                                                              plant-specific application of required by BWRVIP-                                                                                 the BWRVIP guidelines.
Pilgrim is a BWR-3 with a repaired Category C core shroud. The plant installed a pre-emptive shroud repair in 1995 to structurally replace shroud horizontal welds HI through H10. The repair consists of four tie-rods installed at azimuths 450, 1350, 2250 and 3150 which coincide with azimuthal locations of shroud vertical welds V1 5, Vi16, V17 and V18. These tie-rod locations completely prevent inspection access to the welds from the shroud exterior surface and would require peripheral fuel removal for interior access.Pilgrim has an extensive history of shroud inspections with no relevant indications by visual or UT methods. The four vertical welds V1 5, Vi16, V1 7 and VI18 were last inspected in 2007 with a full volumetric UT method from the shroud interior surface achieving>90% coverage of all four welds with no relevant indications noted.These shroud welds are fully mitigated by Hydrogen Water Chemistry (HWC) and Noble Metals Chemical Addition (NMCA) to prevent or reduce the effects of IGSCC.Fleet operating experience shows "very little vertical weld cracking has occurred within the U.S. fleet" as stated in BWRVIP-278, Section 5.3.2.Pilgrim performed plant-specific calculations in accordance with BWRVIP guidelines and conservatively concluded that the 20%extension over the 10-year inspection interval is structurally acceptable to justify an additional cycle of operation.
41, Rev.3, Table 2-4.
Pilgrim performed plant-specific calculations in accordance with BWRVIP guidelines and conservatively concluded that the one-time 20%extension over the 10-year inspection interval is structurally acceptable to justify an additional cycle of operation.
 
There are no License Renewal Commitments for inspection of core shroud welds.Upon BWRVIP approval, this deviation disposition constitutes an approved plant-specific application of the BWRVIP guidelines.
Entergy Nuclear Operations, Inc.                                                                              Attachment to 2.16.016 Pilgrim Nuclear Power Station                                                                                              Page 2 of 4 TABLE I    - Deviation Listing BWRVIP Guidelines    TDeviation    from BWRVIP Guidelines        1Justificationfor Deviation                                                Alternative  Actions/
/Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station TABLE 1 -Deviation Listing Attachment to 2.16.016 Page 3 of 4 BWRVIP Deviation from Justification for Deviation Alternative Actions /Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No.7 BWRVIP-1 39- Pilgrim is required to Pilgrim has complied with the inspection requirements of BWRVIP- Pilgrim plans to visually A re-inspect steam dryer 139-A and previously with GE SIL No.644. PNPS recently examine tie-bars #6, #7 and interior key locations completed the re-inspection of exterior dryer locations required by #8 ini 2017 (RFO21).and a 10% sampling of BWRVIP-1 39-A in 2015. The Pilgrim steam dryer is a non-safety-other dryer interior related component with no history of significant structural License Renewal welds every 10 years degradation.
License Renewal Document No.           j    __                                _____
Seven of a total ten tie-bars were structurally replaced Commitment No.37 (TAO as detailed in BWRVIP- in 2005 per BWRVIP-1 81-A repair guidelines.
Regulatory Commitment BWRVI P-76,    Pilgrim is required to    Pilgrim is a BWR-3 with a repaired Category C core shroud. The            Pilgrim performed plant-Rev. 1-A        re-inspect core shroud    plant installed a pre-emptive shroud repair in 1995 to structurally      specific calculations in beltline vertical welds  replace shroud horizontal welds HI through H10. The repair consists      accordance with BWRVIP V15, V16, V17 and V18    of four tie-rods installed at azimuths 450, 1350, 2250  and 3150 which    guidelines and by either a UT            coincide with azimuthal locations of shroud vertical welds V1 5, Vi16,    conservatively concluded volumetric or two-sided  V17 and V18. These tie-rod locations completely prevent inspection        that the one-time 20%
The interior structure No. MC9669)139-A, Section 5.3.4(D) of the square hood dryer configuration does not have diagonal by the visual VT-1(89) bracings and interior brackets that have caused high stress This is a one-time action.method by 2017. concentrations in some dryer designs. Inspection of this component*is an economic issue directed primarily at preventing the generation Upon BWRVIP approval, this The deviation is a one- of loose parts in the reactor vessel. There have been few indications deviation disposition time two-year in dryer welds or components but these indications have been re- constitutes an approved extension over the 10- inspected repeatedly and have shown to be stable with no evidence plant-specific application of year re-inspection of crack growth or continued degradation.
EVT-1 visual              access to the welds from the shroud exterior surface and would            extension over the 10-year examination method by     require peripheral fuel removal for interior access.                     inspection interval is 2017.                                                                                              structurally acceptable to Pilgrim has an extensive history of shroud inspections with no            justify an additional cycle of The deviation is a one-   relevant indications by visual or UT methods. The four vertical welds     operation.
However, one new the BWRVIP guidelines.
time two-year            V1 5, Vi16, V1 7 and VI18 were last inspected in 2007 with a full extension over the 10-  volumetric UT method from the shroud interior surface achieving            There are no License year re-inspection      >90% coverage of all four welds with no relevant indications noted.       Renewal Commitments for interval for the UT      These shroud welds are fully mitigated by Hydrogen Water                  inspection of core shroud inspection strategy of   Chemistry (HWC) and Noble Metals Chemical Addition (NMCA) to              welds.
interval for selected indication was identified in 2015 when original tie-bar #8 was found interior locations from to be partially cracked. Tie-bar #8 will be re-inspected (and re-10 to 12 years (2017 to evaluated) in 2017 along with adjacent tie-bars #6 and #7. An 2019, when Pilgrim evaluation confirmed that tie-bar #8 does not present a loose-parts plans to cease concern. The structural integrity of the dryer is monitored by operations).
the core shroud beltline  prevent or reduce the effects of IGSCC.
Chemistry during power operations via moisture carryover analysis in accordance with Entergy fleet and plarnt procedures.
vertical welds V15,                                                                                Upon BWRVIP approval, this V16, V17 and V18 as      Fleet operating experience shows "very little vertical weld cracking      deviation disposition required by BWRVIP-      has occurred within the U.S. fleet" as stated in BWRVIP-278, Section      constitutes an approved 76, Rev.l-A, Figure 3-    5.3.2.                                                                    plant-specific application of
Based on moisture carryover trends since 2005, there has been no indication of a reduction in the structural integrity of the steam dryer. Pilgrim has not installed a power uprate other than a thermal power uprate.It is therefore reasonable to conclude that the alternative plans to re-examine tie-bars #6, #7 and #8 in 2017, will provide sufficient assurance to maintain the structural integrity of the dryer for an additional cycle of operation to 2019.
: 3. The two year                                                                                    the BWRVIP guidelines.
Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station Attachment to 2.16.016 Page 4 of 4 TABLE 1 -Deviation Listing BWRVIP Deviation from Justification for Deviation Alternative Actions /Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No.BWRVIP-1 80, Pilgrim is required to Pilgrim has an extensive inspection history regarding the AH~s with Pilgrim plans to perform an Rev.0 complete a UT no service-induced recordable indications since the first UT EVTI-1 visual examination of baseline examination examination in RFO8 (1991). The similarly constructed AHC weld at the 180 degree AHC in 2017 of the access hole azimuth 0° was recently examined with UT in RFO2O (2015) with (RFO2I).cover (AHC) weld at 100% coverage achieved and no service-induced relevant 1800 by 2017. Pilgrim_ indications.
extension is from 2017    Pilgrim performed plant-specific calculations in accordance with to 2019, when Pilgrim    BWRVIP guidelines and conservatively concluded that the 20%
License Renewal successfully completed Commitment No.34 (TAO the baseline UT of the The BWRVIP-180 inspection guidelines allow use of the EVT-1 No. MC9669)00 AHC in 2015 but examination method until such time as a UT technique is deferred examination demonstrated and documented by the BWRVIP. The UT technique This is a one-time action.of the 1800 cover to the was demonstrated by EPRI/GEH however, the UT tooling used at 2017 refuel outage due Pilgrim Station in RFO2O lacked reliability as it could only examine Upon BWRVIP approval, this to adverse inspection the AHC at the 00 but not at the 1800 side as planned. The AHC deviation disposition tooling issues which design at Pilgrim Station is unique to the industry consisting of an constitutes an approved prevented completion "intermediate" thickness configuration that required a hybrid plant-specific application of of the baseline combination of "thin" and "thick" mockups for the EPRI/GEH the BWRVIP guidelines.
plans to cease            extension over the 10-year inspection interval is structurally operations.               acceptable to justify an additional cycle of operation.
examination of the demonstration.
 
1800 AHC in 2015.The AHC welds are highly flaw tolerant.
                                      /
Only a small percentage of Instead, Pilgrim plans the AHC 3600 circumferential seal weld is required to maintain a to perform an EV-I-1 leak-tight barrier. There are no known industry operating experience visual examination of reports of cracking in AHCs since the BWR fleet implemented the 1800 AHC in 2017, improved water chemistry.
Entergy Nuclear Operations, Inc.                                                                             Attachment to 2.16.016 Pilgrim Nuclear Power Station                                                                                              Page 3 of 4 TABLE 1 - Deviation Listing BWRVIP          Deviation from                                Justification for Deviation                          Alternative Actions /
The AH~s at Pilgrim Station are in lieu of UT mitigated by HWC and NMCA.examination required by BWRVIP-1 80, The planned EVT-1 alternative method is appropriate as the EVT-1 Rev.0, Section 9.1. method has the capability to detect IGSCC initiating from visible areas of the AHC top surface and IGSCC is the only known____________________________
Guidelines      BWRVIP Guidelines                                                                                  License Renewal Document                                                                                                            Regulatory Commitment No.7 BWRVIP-1 39-    Pilgrim is required to Pilgrim has complied with the inspection requirements of BWRVIP-           Pilgrim plans to visually A                re-inspect steam dryer  139-A and previously with GE SIL No.644. PNPS recently                      examine tie-bars #6, #7 and interior key locations  completed the re-inspection of exterior dryer locations required by        #8 ini 2017 (RFO21).
degradation mechanism for this weld._____________
and a 10% sampling of  BWRVIP-1 39-A in 2015. The Pilgrim steam dryer is a non-safety-other dryer interior    related component with no history of significant structural                License Renewal welds every 10 years    degradation. Seven of a total ten tie-bars were structurally replaced      Commitment No.37 (TAO as detailed in BWRVIP- in 2005 per BWRVIP-1 81-A repair guidelines. The interior structure        No. MC9669) 139-A, Section 5.3.4(D) of the square hood dryer configuration does not have diagonal by the visual VT-1(89)  bracings and interior brackets that have caused high stress                This is a one-time action.
i Entergy Nuclear Operations, Inc.-r~lFP-fjv600 Rocky Hill Road Plymouth. 02360 March 11, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
method by 2017.         concentrations in some dryer designs. Inspection of this component
                                        *is an economic issue directed primarily at preventing the generation      Upon BWRVIP approval, this The deviation is a one- of loose parts in the reactor vessel. There have been few indications      deviation disposition time two-year          in dryer welds or components but these indications have been re-           constitutes an approved extension over the 10-  inspected repeatedly and have shown to be stable with no evidence          plant-specific application of year re-inspection      of crack growth or continued degradation. However, one new                  the BWRVIP guidelines.
interval for selected  indication was identified in 2015 when original tie-bar #8 was found interior locations from to be partially cracked. Tie-bar #8 will be re-inspected (and re-10 to 12 years (2017 to evaluated) in 2017 along with adjacent tie-bars #6 and #7. An 2019, when Pilgrim      evaluation confirmed that tie-bar #8 does not present a loose-parts plans to cease          concern. The structural integrity of the dryer is monitored by operations).            Chemistry during power operations via moisture carryover analysis in accordance with Entergy fleet and plarnt procedures. Based on moisture carryover trends since 2005, there has been no indication of a reduction in the structural integrity of the steam dryer. Pilgrim has not installed a power uprate other than a thermal power uprate.
It is therefore reasonable to conclude that the alternative plans to re-examine tie-bars #6, #7 and #8 in 2017, will provide sufficient assurance to maintain the structural integrity of the dryer for an additional cycle of operation to 2019.
 
Entergy Nuclear Operations, Inc.                                                                                Attachment to 2.16.016 Pilgrim Nuclear Power Station                                                                                                Page 4 of 4 TABLE 1 - Deviation Listing BWRVIP              Deviation from                                Justification for Deviation                        Alternative Actions /
Guidelines          BWRVIP Guidelines                                                                                License Renewal Document                                                                                                              Regulatory Commitment No.
BWRVIP-1 80,        Pilgrim is required to  Pilgrim has an extensive inspection history regarding the AH~s with       Pilgrim plans to perform an Rev.0                complete a UT          no service-induced recordable indications since the first UT              EVTI-1 visual examination of baseline examination    examination in RFO8 (1991). The similarly constructed AHC weld at        the 180 degree AHC in 2017 of the access hole      azimuth 0° was recently examined with UT in RFO2O (2015) with            (RFO2I).
cover (AHC) weld at      100% coverage achieved and no service-induced relevant 1800 by 2017. Pilgrim_  indications.                                                              License Renewal successfully completed                                                                            Commitment No.34 (TAO the baseline UT of the   The BWRVIP-180 inspection guidelines allow use of the EVT-1              No. MC9669) 00  AHC in 2015 but    examination method until such time as a UT technique is deferred examination    demonstrated and documented by the BWRVIP. The UT technique              This is a one-time action.
of the 1800 cover to the was demonstrated by EPRI/GEH however, the UT tooling used at 2017 refuel outage due  Pilgrim Station in RFO2O lacked reliability as it could only examine      Upon BWRVIP approval, this to adverse inspection   the AHC at the 00 but not at the 1800 side as planned. The AHC            deviation disposition tooling issues which    design at Pilgrim Station is unique to the industry consisting of an      constitutes an approved prevented completion    "intermediate" thickness configuration that required a hybrid            plant-specific application of of the baseline          combination of "thin" and "thick" mockups for the EPRI/GEH                the BWRVIP guidelines.
examination of the      demonstration.
1800 AHC in 2015.
The AHC welds are highly flaw tolerant. Only a small percentage of Instead, Pilgrim plans  the AHC 3600 circumferential seal weld is required to maintain a to perform an EV-I-1    leak-tight barrier. There are no known industry operating experience visual examination of   reports of cracking in AHCs since the BWR fleet implemented the 1800 AHC in 2017,    improved water chemistry. The AH~s at Pilgrim Station are in lieu of UT            mitigated by HWC and NMCA.
examination required by BWRVIP-1 80,          The planned EVT-1 alternative method is appropriate as the EVT-1 Rev.0, Section 9.1.      method has the capability to detect IGSCC initiating from visible areas of the AHC top surface and IGSCC is the only known
____________________________        degradation mechanism for this weld._____________
 
i                                                  Entergy Nuclear Operations, Inc.
                    -    r~lFP-fjv600                                   Rocky Hill Road Plymouth. MA* 02360 March 11, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001


==SUBJECT:==
==SUBJECT:==
Notification for Information Only -Pilgrim Deviations from BWRVIP-41, Rev.3, BWRVI P-76, Rev. 1-A, BWRVI P-I139-A, and BWRVIP-1 80, Rev.0 Guidelines Pilgrim Nuclear Power Station Docket No. 50-293 Renewed License No. DPR-35  
Notification for Information Only - Pilgrim Deviations from BWRVIP-41, Rev.3, BWRVI P-76, Rev. 1-A, BWRVI P-I139-A, and BWRVIP-1 80, Rev.0 Guidelines Pilgrim Nuclear Power Station Docket No. 50-293 Renewed License No. DPR-35


==REFERENCES:==
==REFERENCES:==
: 1. BWRVIP-41, Rev.3, "BWR Jet Pump Assembly Inspection and Flaw Evaluation Guidelines" 2. BWRVIP-76, Rev.l-A, "BWR Core Shroud Inspection and Flaw Evaluation Guidelines" 3. BWRVIP-139-A, "BWR Steam Dryer Inspection and Flaw Evaluation Guidelines
: 1. BWRVIP-41, Rev.3, "BWR Jet Pump Assembly Inspection and Flaw Evaluation Guidelines"
: 4. BWRVIP-1 80, Rev.0, "BWR Access Hole Cover- Inspection and Flaw Evaluation Guidelines" 5. BWRVIP-94NP, Rev.2, "BWR Program Implementation Guidelines" 6. U.S. Nuclear Regulatory Commission Letter to Entergy, Supplemental Safety Evaluation Report Related to the License Renewal of Pilgrim Nuclear Power Station (TAC No. MC9669), June 30, 2011. (1.11.076)
: 2. BWRVIP-76, Rev.l-A, "BWR Core Shroud Inspection and Flaw Evaluation Guidelines"
LETTER NUMBER: 2.16.016  
: 3. BWRVIP-139-A, "BWR Steam Dryer Inspection and Flaw Evaluation Guidelines
: 4. BWRVIP-1 80, Rev.0, "BWR Access Hole Cover- Inspection and Flaw Evaluation Guidelines"
: 5. BWRVIP-94NP, Rev.2, "BWR Program Implementation Guidelines"
: 6. U.S. Nuclear Regulatory Commission Letter to Entergy, Supplemental Safety Evaluation Report Related to the License Renewal of Pilgrim Nuclear Power Station (TAC No. MC9669), June 30, 2011. (1.11.076)
LETTER NUMBER: 2.16.016


==Dear Sir or Madam:==
==Dear Sir or Madam:==
Entergy Nuclear Operations, Inc. hereby informs the NRC of specific deviations from the inspection guidelines described in BWRVIP-41, Rev.3 (Reference 1), BWRVIP-76, Rev.l-A (Reference 2), BWRVIP-1 39-A (Reference
 
: 3) and BWRVIP-1 80, Rev.0 (Reference
Entergy Nuclear Operations, Inc. hereby informs the NRC of specific deviations from the inspection guidelines described in BWRVIP-41, Rev.3 (Reference 1), BWRVIP-76, Rev.l-A (Reference 2), BWRVIP-1 39-A (Reference 3) and BWRVIP-1 80, Rev.0 (Reference 4) in accordance with BWRVIP-94NP, Rev.2 (Reference 5) at Pilgrim Nuclear Power Station (PNPS).
: 4) in accordance with BWRVIP-94NP, Rev.2 (Reference
Reference 5 requires notification to the NRC anytime a utility does not implement any portion of an applicable "mandatory"~ or "needed" BWR Vessel and Internals Project (BWRVIP) guideline that has been approved by the BWRVIP Executive Committee within 45 days of the utility executive concurrence with the deviation disposition.
: 5) at Pilgrim Nuclear Power Station (PNPS).Reference 5 requires notification to the NRC anytime a utility does not implement any portion of an applicable "mandatory"~
 
or "needed" BWR Vessel and Internals Project (BWRVIP) guideline that has been approved by the BWRVIP Executive Committee within 45 days of the utility executive concurrence with the deviation disposition.
Entergy Nuclear Operations, Inc.                                       Letter No. 2.16.016 Pilgrim Nuclear Power Station                                                  Page 2 of 2 The deviations listed in Table 1 of the Attachment are all deviations from BWRVIP guidelines that are classified as "needed" elements of the BWRVIP program. The deviations are due to Entergy's recent announcement of plant closure, performance deficiencies with vendor ultrasonic testing tooling and plant configuration interferences to weld examinations.
Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station Letter No. 2.16.016 Page 2 of 2 The deviations listed in Table 1 of the Attachment are all deviations from BWRVIP guidelines that are classified as "needed" elements of the BWRVIP program. The deviations are due to Entergy's recent announcement of plant closure, performance deficiencies with vendor ultrasonic testing tooling and plant configuration interferences to weld examinations.
Entergy announced in October 2015 that Pilgrim Nuclear Power Station will be permanently retired from active service not later than June 1, 2019.
Entergy announced in October 2015 that Pilgrim Nuclear Power Station will be permanently retired from active service not later than June 1, 2019.Table 1 lists the deviation from BWRVIP guidelines, the justification for the deviation and any alternative actions in lieu of the BWRVIP requirements.
Table 1 lists the deviation from BWRVIP guidelines, the justification for the deviation and any alternative actions in lieu of the BWRVIP requirements. Table 1 also lists the Pilgrim Station License Renewal Commitment Number associated with the corresponding BWRVIP guidelines document, if any (Reference 6).
Table 1 also lists the Pilgrim Station License Renewal Commitment Number associated with the corresponding BWRVIP guidelines document, if any (Reference 6).The deviations from the listed BWRVIP guidelines have been reviewed and approved in accordance with Entergy procedures and NEI 03-08 guidance.
The deviations from the listed BWRVIP guidelines have been reviewed and approved in accordance with Entergy procedures and NEI 03-08 guidance. The deviations will remain in effect until the end of cycle 22 (Spring 2019 when Pilgrim will cease commercial operation).
The deviations will remain in effect until the end of cycle 22 (Spring 2019 when Pilgrim will cease commercial operation).
If you have any questions or require additional information, please contact me at (508) 830-8323.
If you have any questions or require additional information, please contact me at (508) 830-8323.This is a notification of deviation only, and no action is being requested from the NRC.There are no regulatory commitments made in this letter.Sincerely, Everett P. Perkins, Jr.' 'Regulatory Assurance Manager EPP/mw  
This is a notification of deviation only, and no action is being requested from the NRC.
There are no regulatory commitments made in this letter.
Sincerely, Everett P. Perkins, Jr.'             '
Regulatory Assurance Manager EPP/mw


==Attachment:==
==Attachment:==
TABLE I      - Deviation Listing cc:
Mr. Daniel H. Dorman                                Ms. Booma Venkataraman, 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 O-8C2A 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 2.16.016 TABLE 1 - Deviation Listing (4 Pages)
Entergy Nuciear Operations, Inc.                                                                              Attachment to 2.16.016 Pilgrim Nuclear Power Station                                                                                              Page 1 of 4 TABLE 1 - Deviation Listing BWRVIP          Deviation from                                  Justification for Deviation                        Alternative Actions /
Guidelines      BWRVIP Guidelines                                                                                    License Renewal Document                                                                                                            Regulatory Commitment No.,___________________________________
BWRVIP-41,      Pilgrim Station is      Pilgrim replaced all 20 original JP beams with the improved Group 2        Pilgrim plans to perform an Rev.3          required to re-inspect  beams in 1984 and has subsequently examined all beams by UT                EVT-1 visual examination of all jet pump (JP) beam  method per BWRVIP guidelines without any relevant indications. The          all 20 beams during the 2017 BB-1 and BB-2 regions    BWRVIP 10-year re-inspection frequency is based on a normal                (RFO21) refuel outage in lieu by UT methods by        water chemistry environment. However, Pilgrim's superior water              of UT re-inspection 2017; a 10-year re-      chemistry environment should be conducive to a longer re-inspection        examination required by inspection frequency    interval, i.e., no-less than a 12-year interval ending in 2019 when the    BWRVIP-41, Rev.3, Table 2-(There are a total of 20 plant will be retired from active service.                                  4.
JPs).
The alternative proposed EVT*-1 examination of all 20 beams in 2017        There are no License Instead, Pilgrim plans  will provide additional assurance that sufficient structural integrity      Renewal Commitments for to perform an EVT-1      exists to justify an additional cycle of operation to 2019. This            inspection of jet pump visual examination of    alternative method is appropriate as the EVT-1 method has the              beams.
all beams during the    capability to detect lntergranular Stress Corrosion Cracking (IGSCC) 2017 (RFO21) last        initiating from visible areas of the top surface and IGSCC is the only      Upon BWRVIP approval, this planned refuel outage    known significant degradation mechanism associated with JP                  deviation disposition in lieu of UT re-        beams.                                                                      constitutes an approved inspection examination                                                                              plant-specific application of required by BWRVIP-                                                                                  the BWRVIP guidelines.
41, Rev.3, Table 2-4.
Entergy Nuclear Operations, Inc.                                                                              Attachment to 2.16.016 Pilgrim Nuclear Power Station                                                                                              Page 2 of 4 TABLE I    - Deviation Listing BWRVIP Guidelines    TDeviation    from BWRVIP Guidelines        1Justificationfor Deviation                                                Alternative  Actions/
License Renewal Document No.          j    __                                _____
Regulatory Commitment BWRVI P-76,    Pilgrim is required to    Pilgrim is a BWR-3 with a repaired Category C core shroud. The            Pilgrim performed plant-Rev. 1-A        re-inspect core shroud    plant installed a pre-emptive shroud repair in 1995 to structurally      specific calculations in beltline vertical welds  replace shroud horizontal welds HI through H10. The repair consists      accordance with BWRVIP V15, V16, V17 and V18    of four tie-rods installed at azimuths 450, 1350, 2250  and 3150 which    guidelines and by either a UT            coincide with azimuthal locations of shroud vertical welds V1 5, Vi16,    conservatively concluded volumetric or two-sided  V17 and V18. These tie-rod locations completely prevent inspection        that the one-time 20%
EVT-1 visual              access to the welds from the shroud exterior surface and would            extension over the 10-year examination method by    require peripheral fuel removal for interior access.                      inspection interval is 2017.                                                                                              structurally acceptable to Pilgrim has an extensive history of shroud inspections with no            justify an additional cycle of The deviation is a one-  relevant indications by visual or UT methods. The four vertical welds    operation.
time two-year            V1 5, Vi16, V1 7 and VI18 were last inspected in 2007 with a full extension over the 10-  volumetric UT method from the shroud interior surface achieving            There are no License year re-inspection      >90% coverage of all four welds with no relevant indications noted.        Renewal Commitments for interval for the UT      These shroud welds are fully mitigated by Hydrogen Water                  inspection of core shroud inspection strategy of    Chemistry (HWC) and Noble Metals Chemical Addition (NMCA) to              welds.
the core shroud beltline  prevent or reduce the effects of IGSCC.
vertical welds V15,                                                                                Upon BWRVIP approval, this V16, V17 and V18 as      Fleet operating experience shows "very little vertical weld cracking      deviation disposition required by BWRVIP-      has occurred within the U.S. fleet" as stated in BWRVIP-278, Section      constitutes an approved 76, Rev.l-A, Figure 3-    5.3.2.                                                                    plant-specific application of
: 3. The two year                                                                                    the BWRVIP guidelines.
extension is from 2017    Pilgrim performed plant-specific calculations in accordance with to 2019, when Pilgrim    BWRVIP guidelines and conservatively concluded that the 20%
plans to cease            extension over the 10-year inspection interval is structurally operations.              acceptable to justify an additional cycle of operation.
                                      /
Entergy Nuclear Operations, Inc.                                                                              Attachment to 2.16.016 Pilgrim Nuclear Power Station                                                                                              Page 3 of 4 TABLE 1 - Deviation Listing BWRVIP          Deviation from                                Justification for Deviation                          Alternative Actions /
Guidelines      BWRVIP Guidelines                                                                                  License Renewal Document                                                                                                            Regulatory Commitment No.7 BWRVIP-1 39-    Pilgrim is required to  Pilgrim has complied with the inspection requirements of BWRVIP-            Pilgrim plans to visually A                re-inspect steam dryer  139-A and previously with GE SIL No.644. PNPS recently                      examine tie-bars #6, #7 and interior key locations  completed the re-inspection of exterior dryer locations required by        #8 ini 2017 (RFO21).
and a 10% sampling of  BWRVIP-1 39-A in 2015. The Pilgrim steam dryer is a non-safety-other dryer interior    related component with no history of significant structural                License Renewal welds every 10 years    degradation. Seven of a total ten tie-bars were structurally replaced      Commitment No.37 (TAO as detailed in BWRVIP-  in 2005 per BWRVIP-1 81-A repair guidelines. The interior structure        No. MC9669) 139-A, Section 5.3.4(D) of the square hood dryer configuration does not have diagonal by the visual VT-1(89)  bracings and interior brackets that have caused high stress                This is a one-time action.
method by 2017.        concentrations in some dryer designs. Inspection of this component
                                        *is an economic issue directed primarily at preventing the generation      Upon BWRVIP approval, this The deviation is a one- of loose parts in the reactor vessel. There have been few indications      deviation disposition time two-year          in dryer welds or components but these indications have been re-            constitutes an approved extension over the 10-  inspected repeatedly and have shown to be stable with no evidence          plant-specific application of year re-inspection      of crack growth or continued degradation. However, one new                  the BWRVIP guidelines.
interval for selected  indication was identified in 2015 when original tie-bar #8 was found interior locations from to be partially cracked. Tie-bar #8 will be re-inspected (and re-10 to 12 years (2017 to evaluated) in 2017 along with adjacent tie-bars #6 and #7. An 2019, when Pilgrim      evaluation confirmed that tie-bar #8 does not present a loose-parts plans to cease          concern. The structural integrity of the dryer is monitored by operations).            Chemistry during power operations via moisture carryover analysis in accordance with Entergy fleet and plarnt procedures. Based on moisture carryover trends since 2005, there has been no indication of a reduction in the structural integrity of the steam dryer. Pilgrim has not installed a power uprate other than a thermal power uprate.
It is therefore reasonable to conclude that the alternative plans to re-examine tie-bars #6, #7 and #8 in 2017, will provide sufficient assurance to maintain the structural integrity of the dryer for an additional cycle of operation to 2019.


TABLE I -Deviation Listing cc: Mr. Daniel H. Dorman Regional Administrator, Region I U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd., Suite 100 King of Prussia, PA 19406-2713 Mr. Joseph Holonich NRC/NRR BWRVIP Project Manager U.S. Nuclear Regulatory Commission Mail Stop 13 H10 Washington, DC 20555 Ms. Booma Venkataraman, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8C2A Washington, DC 20555 NRC Senior Resident Inspector Pilgrim Nuclear Power Station Attachment Letter Number 2.16.016 TABLE 1 -Deviation Listing (4 Pages)
Entergy Nuclear Operations, Inc.                                                                                 Attachment to 2.16.016 Pilgrim Nuclear Power Station                                                                                                 Page 4 of 4 TABLE 1 - Deviation Listing BWRVIP               Deviation from                               Justification for Deviation                         Alternative Actions /
Entergy Nuciear Operations, Inc.Pilgrim Nuclear Power Station Attachment to 2.16.016 Page 1 of 4 TABLE 1 -Deviation Listing BWRVIP Deviation from Justification for Deviation Alternative Actions /Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No.,___________________________________
Guidelines           BWRVIP Guidelines                                                                                 License Renewal Document                                                                                                               Regulatory Commitment No.
BWRVIP-41, Rev.3 Pilgrim Station is required to re-inspect all jet pump (JP) beam BB-1 and BB-2 regions by UT methods by 2017; a 10-year re-inspection frequency (There are a total of 20 JPs).Instead, Pilgrim plans to perform an EVT-1 visual examination of all beams during the 2017 (RFO21) last planned refuel outage in lieu of UT re-inspection examination required by BWRVIP-41, Rev.3, Table 2-4.Pilgrim replaced all 20 original JP beams with the improved Group 2 beams in 1984 and has subsequently examined all beams by UT method per BWRVIP guidelines without any relevant indications.
BWRVIP-1 80,         Pilgrim is required to Pilgrim has an extensive inspection history regarding the AH~s with       Pilgrim plans to perform an Rev.0               complete a UT           no service-induced recordable indications since the first UT             EVTI-1 visual examination of baseline examination   examination in RFO8 (1991). The similarly constructed AHC weld at         the 180 degree AHC in 2017 of the access hole       azimuth 0° was recently examined with UT in RFO2O (2015) with             (RFO2I).
The BWRVIP 10-year re-inspection frequency is based on a normal water chemistry environment.
cover (AHC) weld at     100% coverage achieved and no service-induced relevant 1800 by 2017. Pilgrim_ indications.                                                             License Renewal successfully completed                                                                             Commitment No.34 (TAO the baseline UT of the   The BWRVIP-180 inspection guidelines allow use of the EVT-1               No. MC9669) 00   AHC in 2015 but     examination method until such time as a UT technique is deferred examination     demonstrated and documented by the BWRVIP. The UT technique               This is a one-time action.
However, Pilgrim's superior water chemistry environment should be conducive to a longer re-inspection interval, i.e., no-less than a 12-year interval ending in 2019 when the plant will be retired from active service.The alternative proposed examination of all 20 beams in 2017 will provide additional assurance that sufficient structural integrity exists to justify an additional cycle of operation to 2019. This alternative method is appropriate as the EVT-1 method has the capability to detect lntergranular Stress Corrosion Cracking (IGSCC)initiating from visible areas of the top surface and IGSCC is the only known significant degradation mechanism associated with JP beams.Pilgrim plans to perform an EVT-1 visual examination of all 20 beams during the 2017 (RFO21) refuel outage in lieu of UT re-inspection examination required by BWRVIP-41, Rev.3, Table 2-4.There are no License Renewal Commitments for inspection of jet pump beams.Upon BWRVIP approval, this deviation disposition constitutes an approved plant-specific application of the BWRVIP guidelines.
of the 1800 cover to the was demonstrated by EPRI/GEH however, the UT tooling used at 2017 refuel outage due   Pilgrim Station in RFO2O lacked reliability as it could only examine     Upon BWRVIP approval, this to adverse inspection   the AHC at the 00 but not at the 1800 side as planned. The AHC           deviation disposition tooling issues which     design at Pilgrim Station is unique to the industry consisting of an     constitutes an approved prevented completion   "intermediate" thickness configuration that required a hybrid             plant-specific application of of the baseline         combination of "thin" and "thick" mockups for the EPRI/GEH               the BWRVIP guidelines.
Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station Attachment to 2.16.016 Page 2 of 4 TABLE I -Deviation Listing BWRVIP TDeviation from 1Justification for Deviation Alternative Actions/Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No. j __ _____ __BWRVI P-76, Rev. 1 -A Pilgrim is required to re-inspect core shroud beltline vertical welds V15, V16, V17 and V18 by either a UT volumetric or two-sided EVT-1 visual examination method by 2017.The deviation is a one-time two-year extension over the 10-year re-inspection interval for the UT inspection strategy of the core shroud beltline vertical welds V15, V16, V17 and V18 as required by BWRVIP-76, Rev.l-A, Figure 3-3. The two year extension is from 2017 to 2019, when Pilgrim plans to cease operations.
examination of the       demonstration.
Pilgrim is a BWR-3 with a repaired Category C core shroud. The plant installed a pre-emptive shroud repair in 1995 to structurally replace shroud horizontal welds HI through H10. The repair consists of four tie-rods installed at azimuths 450, 1350, 2250 and 3150 which coincide with azimuthal locations of shroud vertical welds V1 5, Vi16, V17 and V18. These tie-rod locations completely prevent inspection access to the welds from the shroud exterior surface and would require peripheral fuel removal for interior access.Pilgrim has an extensive history of shroud inspections with no relevant indications by visual or UT methods. The four vertical welds V1 5, Vi16, V1 7 and VI18 were last inspected in 2007 with a full volumetric UT method from the shroud interior surface achieving>90% coverage of all four welds with no relevant indications noted.These shroud welds are fully mitigated by Hydrogen Water Chemistry (HWC) and Noble Metals Chemical Addition (NMCA) to prevent or reduce the effects of IGSCC.Fleet operating experience shows "very little vertical weld cracking has occurred within the U.S. fleet" as stated in BWRVIP-278, Section 5.3.2.Pilgrim performed plant-specific calculations in accordance with BWRVIP guidelines and conservatively concluded that the 20%extension over the 10-year inspection interval is structurally acceptable to justify an additional cycle of operation.
1800 AHC in 2015.
Pilgrim performed plant-specific calculations in accordance with BWRVIP guidelines and conservatively concluded that the one-time 20%extension over the 10-year inspection interval is structurally acceptable to justify an additional cycle of operation.
The AHC welds are highly flaw tolerant. Only a small percentage of Instead, Pilgrim plans the AHC 3600 circumferential seal weld is required to maintain a to perform an EV-I-1     leak-tight barrier. There are no known industry operating experience visual examination of   reports of cracking in AHCs since the BWR fleet implemented the 1800 AHC in 2017,   improved water chemistry. The AH~s at Pilgrim Station are in lieu of UT           mitigated by HWC and NMCA.
There are no License Renewal Commitments for inspection of core shroud welds.Upon BWRVIP approval, this deviation disposition constitutes an approved plant-specific application of the BWRVIP guidelines.
examination required by BWRVIP-1 80,         The planned EVT-1 alternative method is appropriate as the EVT-1 Rev.0, Section 9.1.     method has the capability to detect IGSCC initiating from visible areas of the AHC top surface and IGSCC is the only known
/Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station TABLE 1 -Deviation Listing Attachment to 2.16.016 Page 3 of 4 BWRVIP Deviation from Justification for Deviation Alternative Actions /Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No.7 BWRVIP-1 39- Pilgrim is required to Pilgrim has complied with the inspection requirements of BWRVIP- Pilgrim plans to visually A re-inspect steam dryer 139-A and previously with GE SIL No.644. PNPS recently examine tie-bars #6, #7 and interior key locations completed the re-inspection of exterior dryer locations required by #8 ini 2017 (RFO21).and a 10% sampling of BWRVIP-1 39-A in 2015. The Pilgrim steam dryer is a non-safety-other dryer interior related component with no history of significant structural License Renewal welds every 10 years degradation.
____________________________        degradation mechanism for this weld._____________}}
Seven of a total ten tie-bars were structurally replaced Commitment No.37 (TAO as detailed in BWRVIP- in 2005 per BWRVIP-1 81-A repair guidelines.
The interior structure No. MC9669)139-A, Section 5.3.4(D) of the square hood dryer configuration does not have diagonal by the visual VT-1(89) bracings and interior brackets that have caused high stress This is a one-time action.method by 2017. concentrations in some dryer designs. Inspection of this component*is an economic issue directed primarily at preventing the generation Upon BWRVIP approval, this The deviation is a one- of loose parts in the reactor vessel. There have been few indications deviation disposition time two-year in dryer welds or components but these indications have been re- constitutes an approved extension over the 10- inspected repeatedly and have shown to be stable with no evidence plant-specific application of year re-inspection of crack growth or continued degradation.
However, one new the BWRVIP guidelines.
interval for selected indication was identified in 2015 when original tie-bar #8 was found interior locations from to be partially cracked. Tie-bar #8 will be re-inspected (and re-10 to 12 years (2017 to evaluated) in 2017 along with adjacent tie-bars #6 and #7. An 2019, when Pilgrim evaluation confirmed that tie-bar #8 does not present a loose-parts plans to cease concern. The structural integrity of the dryer is monitored by operations).
Chemistry during power operations via moisture carryover analysis in accordance with Entergy fleet and plarnt procedures.
Based on moisture carryover trends since 2005, there has been no indication of a reduction in the structural integrity of the steam dryer. Pilgrim has not installed a power uprate other than a thermal power uprate.It is therefore reasonable to conclude that the alternative plans to re-examine tie-bars #6, #7 and #8 in 2017, will provide sufficient assurance to maintain the structural integrity of the dryer for an additional cycle of operation to 2019.
Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station Attachment to 2.16.016 Page 4 of 4 TABLE 1 -Deviation Listing BWRVIP Deviation from Justification for Deviation Alternative Actions /Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No.BWRVIP-1 80, Pilgrim is required to Pilgrim has an extensive inspection history regarding the AH~s with Pilgrim plans to perform an Rev.0 complete a UT no service-induced recordable indications since the first UT EVTI-1 visual examination of baseline examination examination in RFO8 (1991). The similarly constructed AHC weld at the 180 degree AHC in 2017 of the access hole azimuth 0° was recently examined with UT in RFO2O (2015) with (RFO2I).cover (AHC) weld at 100% coverage achieved and no service-induced relevant 1800 by 2017. Pilgrim_ indications.
License Renewal successfully completed Commitment No.34 (TAO the baseline UT of the The BWRVIP-180 inspection guidelines allow use of the EVT-1 No. MC9669)00 AHC in 2015 but examination method until such time as a UT technique is deferred examination demonstrated and documented by the BWRVIP. The UT technique This is a one-time action.of the 1800 cover to the was demonstrated by EPRI/GEH however, the UT tooling used at 2017 refuel outage due Pilgrim Station in RFO2O lacked reliability as it could only examine Upon BWRVIP approval, this to adverse inspection the AHC at the 00 but not at the 1800 side as planned. The AHC deviation disposition tooling issues which design at Pilgrim Station is unique to the industry consisting of an constitutes an approved prevented completion "intermediate" thickness configuration that required a hybrid plant-specific application of of the baseline combination of "thin" and "thick" mockups for the EPRI/GEH the BWRVIP guidelines.
examination of the demonstration.
1800 AHC in 2015.The AHC welds are highly flaw tolerant.
Only a small percentage of Instead, Pilgrim plans the AHC 3600 circumferential seal weld is required to maintain a to perform an EV-I-1 leak-tight barrier. There are no known industry operating experience visual examination of reports of cracking in AHCs since the BWR fleet implemented the 1800 AHC in 2017, improved water chemistry.
The AH~s at Pilgrim Station are in lieu of UT mitigated by HWC and NMCA.examination required by BWRVIP-1 80, The planned EVT-1 alternative method is appropriate as the EVT-1 Rev.0, Section 9.1. method has the capability to detect IGSCC initiating from visible areas of the AHC top surface and IGSCC is the only known____________________________
degradation mechanism for this weld._____________}}

Latest revision as of 05:11, 5 February 2020

Notification for Information Only - Deviations from BWRVIP-41, Rev. 3, BWRVIP-76, Rev. 1-A, BWRVIP-139-A, and BWRVIP-180, Rev.0 Guidelines
ML16078A037
Person / Time
Site: Pilgrim
Issue date: 03/11/2016
From: Perkins E
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
2.16.016
Download: ML16078A037 (7)
v • d • e


Text

i Entergy Nuclear Operations, Inc.

- r~lFP-fjv600 Rocky Hill Road Plymouth. MA* 02360 March 11, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Notification for Information Only - Pilgrim Deviations from BWRVIP-41, Rev.3, BWRVI P-76, Rev. 1-A, BWRVI P-I139-A, and BWRVIP-1 80, Rev.0 Guidelines Pilgrim Nuclear Power Station Docket No. 50-293 Renewed License No. DPR-35

REFERENCES:

1. BWRVIP-41, Rev.3, "BWR Jet Pump Assembly Inspection and Flaw Evaluation Guidelines"
2. BWRVIP-76, Rev.l-A, "BWR Core Shroud Inspection and Flaw Evaluation Guidelines"
3. BWRVIP-139-A, "BWR Steam Dryer Inspection and Flaw Evaluation Guidelines
4. BWRVIP-1 80, Rev.0, "BWR Access Hole Cover- Inspection and Flaw Evaluation Guidelines"
5. BWRVIP-94NP, Rev.2, "BWR Program Implementation Guidelines"
6. U.S. Nuclear Regulatory Commission Letter to Entergy, Supplemental Safety Evaluation Report Related to the License Renewal of Pilgrim Nuclear Power Station (TAC No. MC9669), June 30, 2011. (1.11.076)

LETTER NUMBER: 2.16.016

Dear Sir or Madam:

Entergy Nuclear Operations, Inc. hereby informs the NRC of specific deviations from the inspection guidelines described in BWRVIP-41, Rev.3 (Reference 1), BWRVIP-76, Rev.l-A (Reference 2), BWRVIP-1 39-A (Reference 3) and BWRVIP-1 80, Rev.0 (Reference 4) in accordance with BWRVIP-94NP, Rev.2 (Reference 5) at Pilgrim Nuclear Power Station (PNPS).

Reference 5 requires notification to the NRC anytime a utility does not implement any portion of an applicable "mandatory"~ or "needed" BWR Vessel and Internals Project (BWRVIP) guideline that has been approved by the BWRVIP Executive Committee within 45 days of the utility executive concurrence with the deviation disposition.

Entergy Nuclear Operations, Inc. Letter No. 2.16.016 Pilgrim Nuclear Power Station Page 2 of 2 The deviations listed in Table 1 of the Attachment are all deviations from BWRVIP guidelines that are classified as "needed" elements of the BWRVIP program. The deviations are due to Entergy's recent announcement of plant closure, performance deficiencies with vendor ultrasonic testing tooling and plant configuration interferences to weld examinations.

Entergy announced in October 2015 that Pilgrim Nuclear Power Station will be permanently retired from active service not later than June 1, 2019.

Table 1 lists the deviation from BWRVIP guidelines, the justification for the deviation and any alternative actions in lieu of the BWRVIP requirements. Table 1 also lists the Pilgrim Station License Renewal Commitment Number associated with the corresponding BWRVIP guidelines document, if any (Reference 6).

The deviations from the listed BWRVIP guidelines have been reviewed and approved in accordance with Entergy procedures and NEI 03-08 guidance. The deviations will remain in effect until the end of cycle 22 (Spring 2019 when Pilgrim will cease commercial operation).

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

This is a notification of deviation only, and no action is being requested from the NRC.

There are no regulatory commitments made in this letter.

Sincerely, Everett P. Perkins, Jr.' '

Regulatory Assurance Manager EPP/mw

Attachment:

TABLE I - Deviation Listing cc:

Mr. Daniel H. Dorman Ms. Booma Venkataraman, 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 O-8C2A 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 2.16.016 TABLE 1 - Deviation Listing (4 Pages)

Entergy Nuciear Operations, Inc. Attachment to 2.16.016 Pilgrim Nuclear Power Station Page 1 of 4 TABLE 1 - Deviation Listing BWRVIP Deviation from Justification for Deviation Alternative Actions /

Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No.,___________________________________

BWRVIP-41, Pilgrim Station is Pilgrim replaced all 20 original JP beams with the improved Group 2 Pilgrim plans to perform an Rev.3 required to re-inspect beams in 1984 and has subsequently examined all beams by UT EVT-1 visual examination of all jet pump (JP) beam method per BWRVIP guidelines without any relevant indications. The all 20 beams during the 2017 BB-1 and BB-2 regions BWRVIP 10-year re-inspection frequency is based on a normal (RFO21) refuel outage in lieu by UT methods by water chemistry environment. However, Pilgrim's superior water of UT re-inspection 2017; a 10-year re- chemistry environment should be conducive to a longer re-inspection examination required by inspection frequency interval, i.e., no-less than a 12-year interval ending in 2019 when the BWRVIP-41, Rev.3, Table 2-(There are a total of 20 plant will be retired from active service. 4.

JPs).

The alternative proposed EVT*-1 examination of all 20 beams in 2017 There are no License Instead, Pilgrim plans will provide additional assurance that sufficient structural integrity Renewal Commitments for to perform an EVT-1 exists to justify an additional cycle of operation to 2019. This inspection of jet pump visual examination of alternative method is appropriate as the EVT-1 method has the beams.

all beams during the capability to detect lntergranular Stress Corrosion Cracking (IGSCC) 2017 (RFO21) last initiating from visible areas of the top surface and IGSCC is the only Upon BWRVIP approval, this planned refuel outage known significant degradation mechanism associated with JP deviation disposition in lieu of UT re- beams. constitutes an approved inspection examination plant-specific application of required by BWRVIP- the BWRVIP guidelines.

41, Rev.3, Table 2-4.

Entergy Nuclear Operations, Inc. Attachment to 2.16.016 Pilgrim Nuclear Power Station Page 2 of 4 TABLE I - Deviation Listing BWRVIP Guidelines TDeviation from BWRVIP Guidelines 1Justificationfor Deviation Alternative Actions/

License Renewal Document No. j __ _____

Regulatory Commitment BWRVI P-76, Pilgrim is required to Pilgrim is a BWR-3 with a repaired Category C core shroud. The Pilgrim performed plant-Rev. 1-A re-inspect core shroud plant installed a pre-emptive shroud repair in 1995 to structurally specific calculations in beltline vertical welds replace shroud horizontal welds HI through H10. The repair consists accordance with BWRVIP V15, V16, V17 and V18 of four tie-rods installed at azimuths 450, 1350, 2250 and 3150 which guidelines and by either a UT coincide with azimuthal locations of shroud vertical welds V1 5, Vi16, conservatively concluded volumetric or two-sided V17 and V18. These tie-rod locations completely prevent inspection that the one-time 20%

EVT-1 visual access to the welds from the shroud exterior surface and would extension over the 10-year examination method by require peripheral fuel removal for interior access. inspection interval is 2017. structurally acceptable to Pilgrim has an extensive history of shroud inspections with no justify an additional cycle of The deviation is a one- relevant indications by visual or UT methods. The four vertical welds operation.

time two-year V1 5, Vi16, V1 7 and VI18 were last inspected in 2007 with a full extension over the 10- volumetric UT method from the shroud interior surface achieving There are no License year re-inspection >90% coverage of all four welds with no relevant indications noted. Renewal Commitments for interval for the UT These shroud welds are fully mitigated by Hydrogen Water inspection of core shroud inspection strategy of Chemistry (HWC) and Noble Metals Chemical Addition (NMCA) to welds.

the core shroud beltline prevent or reduce the effects of IGSCC.

vertical welds V15, Upon BWRVIP approval, this V16, V17 and V18 as Fleet operating experience shows "very little vertical weld cracking deviation disposition required by BWRVIP- has occurred within the U.S. fleet" as stated in BWRVIP-278, Section constitutes an approved 76, Rev.l-A, Figure 3- 5.3.2. plant-specific application of

3. The two year the BWRVIP guidelines.

extension is from 2017 Pilgrim performed plant-specific calculations in accordance with to 2019, when Pilgrim BWRVIP guidelines and conservatively concluded that the 20%

plans to cease extension over the 10-year inspection interval is structurally operations. acceptable to justify an additional cycle of operation.

/

Entergy Nuclear Operations, Inc. Attachment to 2.16.016 Pilgrim Nuclear Power Station Page 3 of 4 TABLE 1 - Deviation Listing BWRVIP Deviation from Justification for Deviation Alternative Actions /

Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No.7 BWRVIP-1 39- Pilgrim is required to Pilgrim has complied with the inspection requirements of BWRVIP- Pilgrim plans to visually A re-inspect steam dryer 139-A and previously with GE SIL No.644. PNPS recently examine tie-bars #6, #7 and interior key locations completed the re-inspection of exterior dryer locations required by #8 ini 2017 (RFO21).

and a 10% sampling of BWRVIP-1 39-A in 2015. The Pilgrim steam dryer is a non-safety-other dryer interior related component with no history of significant structural License Renewal welds every 10 years degradation. Seven of a total ten tie-bars were structurally replaced Commitment No.37 (TAO as detailed in BWRVIP- in 2005 per BWRVIP-1 81-A repair guidelines. The interior structure No. MC9669) 139-A, Section 5.3.4(D) of the square hood dryer configuration does not have diagonal by the visual VT-1(89) bracings and interior brackets that have caused high stress This is a one-time action.

method by 2017. concentrations in some dryer designs. Inspection of this component

  • is an economic issue directed primarily at preventing the generation Upon BWRVIP approval, this The deviation is a one- of loose parts in the reactor vessel. There have been few indications deviation disposition time two-year in dryer welds or components but these indications have been re- constitutes an approved extension over the 10- inspected repeatedly and have shown to be stable with no evidence plant-specific application of year re-inspection of crack growth or continued degradation. However, one new the BWRVIP guidelines.

interval for selected indication was identified in 2015 when original tie-bar #8 was found interior locations from to be partially cracked. Tie-bar #8 will be re-inspected (and re-10 to 12 years (2017 to evaluated) in 2017 along with adjacent tie-bars #6 and #7. An 2019, when Pilgrim evaluation confirmed that tie-bar #8 does not present a loose-parts plans to cease concern. The structural integrity of the dryer is monitored by operations). Chemistry during power operations via moisture carryover analysis in accordance with Entergy fleet and plarnt procedures. Based on moisture carryover trends since 2005, there has been no indication of a reduction in the structural integrity of the steam dryer. Pilgrim has not installed a power uprate other than a thermal power uprate.

It is therefore reasonable to conclude that the alternative plans to re-examine tie-bars #6, #7 and #8 in 2017, will provide sufficient assurance to maintain the structural integrity of the dryer for an additional cycle of operation to 2019.

Entergy Nuclear Operations, Inc. Attachment to 2.16.016 Pilgrim Nuclear Power Station Page 4 of 4 TABLE 1 - Deviation Listing BWRVIP Deviation from Justification for Deviation Alternative Actions /

Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No.

BWRVIP-1 80, Pilgrim is required to Pilgrim has an extensive inspection history regarding the AH~s with Pilgrim plans to perform an Rev.0 complete a UT no service-induced recordable indications since the first UT EVTI-1 visual examination of baseline examination examination in RFO8 (1991). The similarly constructed AHC weld at the 180 degree AHC in 2017 of the access hole azimuth 0° was recently examined with UT in RFO2O (2015) with (RFO2I).

cover (AHC) weld at 100% coverage achieved and no service-induced relevant 1800 by 2017. Pilgrim_ indications. License Renewal successfully completed Commitment No.34 (TAO the baseline UT of the The BWRVIP-180 inspection guidelines allow use of the EVT-1 No. MC9669) 00 AHC in 2015 but examination method until such time as a UT technique is deferred examination demonstrated and documented by the BWRVIP. The UT technique This is a one-time action.

of the 1800 cover to the was demonstrated by EPRI/GEH however, the UT tooling used at 2017 refuel outage due Pilgrim Station in RFO2O lacked reliability as it could only examine Upon BWRVIP approval, this to adverse inspection the AHC at the 00 but not at the 1800 side as planned. The AHC deviation disposition tooling issues which design at Pilgrim Station is unique to the industry consisting of an constitutes an approved prevented completion "intermediate" thickness configuration that required a hybrid plant-specific application of of the baseline combination of "thin" and "thick" mockups for the EPRI/GEH the BWRVIP guidelines.

examination of the demonstration.

1800 AHC in 2015.

The AHC welds are highly flaw tolerant. Only a small percentage of Instead, Pilgrim plans the AHC 3600 circumferential seal weld is required to maintain a to perform an EV-I-1 leak-tight barrier. There are no known industry operating experience visual examination of reports of cracking in AHCs since the BWR fleet implemented the 1800 AHC in 2017, improved water chemistry. The AH~s at Pilgrim Station are in lieu of UT mitigated by HWC and NMCA.

examination required by BWRVIP-1 80, The planned EVT-1 alternative method is appropriate as the EVT-1 Rev.0, Section 9.1. method has the capability to detect IGSCC initiating from visible areas of the AHC top surface and IGSCC is the only known

____________________________ degradation mechanism for this weld._____________

i Entergy Nuclear Operations, Inc.

- r~lFP-fjv600 Rocky Hill Road Plymouth. MA* 02360 March 11, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Notification for Information Only - Pilgrim Deviations from BWRVIP-41, Rev.3, BWRVI P-76, Rev. 1-A, BWRVI P-I139-A, and BWRVIP-1 80, Rev.0 Guidelines Pilgrim Nuclear Power Station Docket No. 50-293 Renewed License No. DPR-35

REFERENCES:

1. BWRVIP-41, Rev.3, "BWR Jet Pump Assembly Inspection and Flaw Evaluation Guidelines"
2. BWRVIP-76, Rev.l-A, "BWR Core Shroud Inspection and Flaw Evaluation Guidelines"
3. BWRVIP-139-A, "BWR Steam Dryer Inspection and Flaw Evaluation Guidelines
4. BWRVIP-1 80, Rev.0, "BWR Access Hole Cover- Inspection and Flaw Evaluation Guidelines"
5. BWRVIP-94NP, Rev.2, "BWR Program Implementation Guidelines"
6. U.S. Nuclear Regulatory Commission Letter to Entergy, Supplemental Safety Evaluation Report Related to the License Renewal of Pilgrim Nuclear Power Station (TAC No. MC9669), June 30, 2011. (1.11.076)

LETTER NUMBER: 2.16.016

Dear Sir or Madam:

Entergy Nuclear Operations, Inc. hereby informs the NRC of specific deviations from the inspection guidelines described in BWRVIP-41, Rev.3 (Reference 1), BWRVIP-76, Rev.l-A (Reference 2), BWRVIP-1 39-A (Reference 3) and BWRVIP-1 80, Rev.0 (Reference 4) in accordance with BWRVIP-94NP, Rev.2 (Reference 5) at Pilgrim Nuclear Power Station (PNPS).

Reference 5 requires notification to the NRC anytime a utility does not implement any portion of an applicable "mandatory"~ or "needed" BWR Vessel and Internals Project (BWRVIP) guideline that has been approved by the BWRVIP Executive Committee within 45 days of the utility executive concurrence with the deviation disposition.

Entergy Nuclear Operations, Inc. Letter No. 2.16.016 Pilgrim Nuclear Power Station Page 2 of 2 The deviations listed in Table 1 of the Attachment are all deviations from BWRVIP guidelines that are classified as "needed" elements of the BWRVIP program. The deviations are due to Entergy's recent announcement of plant closure, performance deficiencies with vendor ultrasonic testing tooling and plant configuration interferences to weld examinations.

Entergy announced in October 2015 that Pilgrim Nuclear Power Station will be permanently retired from active service not later than June 1, 2019.

Table 1 lists the deviation from BWRVIP guidelines, the justification for the deviation and any alternative actions in lieu of the BWRVIP requirements. Table 1 also lists the Pilgrim Station License Renewal Commitment Number associated with the corresponding BWRVIP guidelines document, if any (Reference 6).

The deviations from the listed BWRVIP guidelines have been reviewed and approved in accordance with Entergy procedures and NEI 03-08 guidance. The deviations will remain in effect until the end of cycle 22 (Spring 2019 when Pilgrim will cease commercial operation).

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

This is a notification of deviation only, and no action is being requested from the NRC.

There are no regulatory commitments made in this letter.

Sincerely, Everett P. Perkins, Jr.' '

Regulatory Assurance Manager EPP/mw

Attachment:

TABLE I - Deviation Listing cc:

Mr. Daniel H. Dorman Ms. Booma Venkataraman, 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 O-8C2A 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 2.16.016 TABLE 1 - Deviation Listing (4 Pages)

Entergy Nuciear Operations, Inc. Attachment to 2.16.016 Pilgrim Nuclear Power Station Page 1 of 4 TABLE 1 - Deviation Listing BWRVIP Deviation from Justification for Deviation Alternative Actions /

Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No.,___________________________________

BWRVIP-41, Pilgrim Station is Pilgrim replaced all 20 original JP beams with the improved Group 2 Pilgrim plans to perform an Rev.3 required to re-inspect beams in 1984 and has subsequently examined all beams by UT EVT-1 visual examination of all jet pump (JP) beam method per BWRVIP guidelines without any relevant indications. The all 20 beams during the 2017 BB-1 and BB-2 regions BWRVIP 10-year re-inspection frequency is based on a normal (RFO21) refuel outage in lieu by UT methods by water chemistry environment. However, Pilgrim's superior water of UT re-inspection 2017; a 10-year re- chemistry environment should be conducive to a longer re-inspection examination required by inspection frequency interval, i.e., no-less than a 12-year interval ending in 2019 when the BWRVIP-41, Rev.3, Table 2-(There are a total of 20 plant will be retired from active service. 4.

JPs).

The alternative proposed EVT*-1 examination of all 20 beams in 2017 There are no License Instead, Pilgrim plans will provide additional assurance that sufficient structural integrity Renewal Commitments for to perform an EVT-1 exists to justify an additional cycle of operation to 2019. This inspection of jet pump visual examination of alternative method is appropriate as the EVT-1 method has the beams.

all beams during the capability to detect lntergranular Stress Corrosion Cracking (IGSCC) 2017 (RFO21) last initiating from visible areas of the top surface and IGSCC is the only Upon BWRVIP approval, this planned refuel outage known significant degradation mechanism associated with JP deviation disposition in lieu of UT re- beams. constitutes an approved inspection examination plant-specific application of required by BWRVIP- the BWRVIP guidelines.

41, Rev.3, Table 2-4.

Entergy Nuclear Operations, Inc. Attachment to 2.16.016 Pilgrim Nuclear Power Station Page 2 of 4 TABLE I - Deviation Listing BWRVIP Guidelines TDeviation from BWRVIP Guidelines 1Justificationfor Deviation Alternative Actions/

License Renewal Document No. j __ _____

Regulatory Commitment BWRVI P-76, Pilgrim is required to Pilgrim is a BWR-3 with a repaired Category C core shroud. The Pilgrim performed plant-Rev. 1-A re-inspect core shroud plant installed a pre-emptive shroud repair in 1995 to structurally specific calculations in beltline vertical welds replace shroud horizontal welds HI through H10. The repair consists accordance with BWRVIP V15, V16, V17 and V18 of four tie-rods installed at azimuths 450, 1350, 2250 and 3150 which guidelines and by either a UT coincide with azimuthal locations of shroud vertical welds V1 5, Vi16, conservatively concluded volumetric or two-sided V17 and V18. These tie-rod locations completely prevent inspection that the one-time 20%

EVT-1 visual access to the welds from the shroud exterior surface and would extension over the 10-year examination method by require peripheral fuel removal for interior access. inspection interval is 2017. structurally acceptable to Pilgrim has an extensive history of shroud inspections with no justify an additional cycle of The deviation is a one- relevant indications by visual or UT methods. The four vertical welds operation.

time two-year V1 5, Vi16, V1 7 and VI18 were last inspected in 2007 with a full extension over the 10- volumetric UT method from the shroud interior surface achieving There are no License year re-inspection >90% coverage of all four welds with no relevant indications noted. Renewal Commitments for interval for the UT These shroud welds are fully mitigated by Hydrogen Water inspection of core shroud inspection strategy of Chemistry (HWC) and Noble Metals Chemical Addition (NMCA) to welds.

the core shroud beltline prevent or reduce the effects of IGSCC.

vertical welds V15, Upon BWRVIP approval, this V16, V17 and V18 as Fleet operating experience shows "very little vertical weld cracking deviation disposition required by BWRVIP- has occurred within the U.S. fleet" as stated in BWRVIP-278, Section constitutes an approved 76, Rev.l-A, Figure 3- 5.3.2. plant-specific application of

3. The two year the BWRVIP guidelines.

extension is from 2017 Pilgrim performed plant-specific calculations in accordance with to 2019, when Pilgrim BWRVIP guidelines and conservatively concluded that the 20%

plans to cease extension over the 10-year inspection interval is structurally operations. acceptable to justify an additional cycle of operation.

/

Entergy Nuclear Operations, Inc. Attachment to 2.16.016 Pilgrim Nuclear Power Station Page 3 of 4 TABLE 1 - Deviation Listing BWRVIP Deviation from Justification for Deviation Alternative Actions /

Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No.7 BWRVIP-1 39- Pilgrim is required to Pilgrim has complied with the inspection requirements of BWRVIP- Pilgrim plans to visually A re-inspect steam dryer 139-A and previously with GE SIL No.644. PNPS recently examine tie-bars #6, #7 and interior key locations completed the re-inspection of exterior dryer locations required by #8 ini 2017 (RFO21).

and a 10% sampling of BWRVIP-1 39-A in 2015. The Pilgrim steam dryer is a non-safety-other dryer interior related component with no history of significant structural License Renewal welds every 10 years degradation. Seven of a total ten tie-bars were structurally replaced Commitment No.37 (TAO as detailed in BWRVIP- in 2005 per BWRVIP-1 81-A repair guidelines. The interior structure No. MC9669) 139-A, Section 5.3.4(D) of the square hood dryer configuration does not have diagonal by the visual VT-1(89) bracings and interior brackets that have caused high stress This is a one-time action.

method by 2017. concentrations in some dryer designs. Inspection of this component

  • is an economic issue directed primarily at preventing the generation Upon BWRVIP approval, this The deviation is a one- of loose parts in the reactor vessel. There have been few indications deviation disposition time two-year in dryer welds or components but these indications have been re- constitutes an approved extension over the 10- inspected repeatedly and have shown to be stable with no evidence plant-specific application of year re-inspection of crack growth or continued degradation. However, one new the BWRVIP guidelines.

interval for selected indication was identified in 2015 when original tie-bar #8 was found interior locations from to be partially cracked. Tie-bar #8 will be re-inspected (and re-10 to 12 years (2017 to evaluated) in 2017 along with adjacent tie-bars #6 and #7. An 2019, when Pilgrim evaluation confirmed that tie-bar #8 does not present a loose-parts plans to cease concern. The structural integrity of the dryer is monitored by operations). Chemistry during power operations via moisture carryover analysis in accordance with Entergy fleet and plarnt procedures. Based on moisture carryover trends since 2005, there has been no indication of a reduction in the structural integrity of the steam dryer. Pilgrim has not installed a power uprate other than a thermal power uprate.

It is therefore reasonable to conclude that the alternative plans to re-examine tie-bars #6, #7 and #8 in 2017, will provide sufficient assurance to maintain the structural integrity of the dryer for an additional cycle of operation to 2019.

Entergy Nuclear Operations, Inc. Attachment to 2.16.016 Pilgrim Nuclear Power Station Page 4 of 4 TABLE 1 - Deviation Listing BWRVIP Deviation from Justification for Deviation Alternative Actions /

Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No.

BWRVIP-1 80, Pilgrim is required to Pilgrim has an extensive inspection history regarding the AH~s with Pilgrim plans to perform an Rev.0 complete a UT no service-induced recordable indications since the first UT EVTI-1 visual examination of baseline examination examination in RFO8 (1991). The similarly constructed AHC weld at the 180 degree AHC in 2017 of the access hole azimuth 0° was recently examined with UT in RFO2O (2015) with (RFO2I).

cover (AHC) weld at 100% coverage achieved and no service-induced relevant 1800 by 2017. Pilgrim_ indications. License Renewal successfully completed Commitment No.34 (TAO the baseline UT of the The BWRVIP-180 inspection guidelines allow use of the EVT-1 No. MC9669) 00 AHC in 2015 but examination method until such time as a UT technique is deferred examination demonstrated and documented by the BWRVIP. The UT technique This is a one-time action.

of the 1800 cover to the was demonstrated by EPRI/GEH however, the UT tooling used at 2017 refuel outage due Pilgrim Station in RFO2O lacked reliability as it could only examine Upon BWRVIP approval, this to adverse inspection the AHC at the 00 but not at the 1800 side as planned. The AHC deviation disposition tooling issues which design at Pilgrim Station is unique to the industry consisting of an constitutes an approved prevented completion "intermediate" thickness configuration that required a hybrid plant-specific application of of the baseline combination of "thin" and "thick" mockups for the EPRI/GEH the BWRVIP guidelines.

examination of the demonstration.

1800 AHC in 2015.

The AHC welds are highly flaw tolerant. Only a small percentage of Instead, Pilgrim plans the AHC 3600 circumferential seal weld is required to maintain a to perform an EV-I-1 leak-tight barrier. There are no known industry operating experience visual examination of reports of cracking in AHCs since the BWR fleet implemented the 1800 AHC in 2017, improved water chemistry. The AH~s at Pilgrim Station are in lieu of UT mitigated by HWC and NMCA.

examination required by BWRVIP-1 80, The planned EVT-1 alternative method is appropriate as the EVT-1 Rev.0, Section 9.1. method has the capability to detect IGSCC initiating from visible areas of the AHC top surface and IGSCC is the only known

____________________________ degradation mechanism for this weld._____________

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