ML18270A451

Ltr. 09/27/18 Palisades Nuclear Plant - Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000255/2018004 (DRS-E.Fernandez)

ML18270A451
Person / Time
Site:	Palisades
Issue date:	09/27/2018
From:	Edison Fernandez NRC/RGN-III/DRS/EB1
To:	Arnone C Entergy Nuclear Operations
References
IR 2018004
Download: ML18270A451 (9)

See also: IR 05000255/2018004

Text

September 27, 2018

Mr. Charles Arnone

Vice President, Operations

Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant

27780 Blue Star Memorial Highway

Covert, MI 49043-9530

SUBJECT: PALISADES NUCLEAR PLANTNOTIFICATION OF NRC BASELINE

INSPECTION AND REQUEST FOR INFORMATION; INSPECTION

REPORT 05000255/2018004

Dear Mr. Arnone:

On October 29, 2018, the U.S. Nuclear Regulatory Commission (NRC) will begin the Baseline

Inservice Inspection Procedure 71111.08. This onsite inspection is scheduled to be performed

October 29, 2018, through November 9, 2018.

Experience has shown that this inspection is resource intensive both for the NRC inspector and

your staff. In order to minimize the impact to your onsite resources, and to ensure a productive

inspection for both sides, we have enclosed a request for documents needed for this inspection.

These documents have been divided into two groups.

The first group identifies information necessary to ensure that the inspector is adequately

prepared. The second group identifies the information the inspector will need upon arrival at

the site. It is important that all of these documents are up-to-date, and complete, in order to

minimize the number of additional documents requested during the preparation and/or the

onsite portions of the inspection.

We have discussed the schedule for inspection activities with your staff and understand that

our regulatory contact for this inspection will be Ms. B. Dotson, of your organization. If there are

any questions about this inspection or the material requested, please contact the lead inspector

Mr. E. Fernandez at 630-829-9754 or via e-mail at Edison.Fernandez@nrc.gov.

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget, Control

Number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to

respond to, a request for information or an information collection requirement unless the

requesting document displays a currently valid Office of Management and Budget Control

Number.

C. Arnone -2-

This letter and its enclosure will be made available for public inspection and copying at

http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in

accordance with Title 10 of the Code of Federal Regulations, Part 2.390, Public Inspections,

Exemptions, Requests for Withholding.

Sincerely,

/RA Vijay Meghani Acting for/

Edison Fernandez, Reactor Inspector

Engineering Branch 1

Division of Reactor Safety

Docket No. 50-255

License No. DPR-20

Enclosure:

Document Request for Baseline Inservice

Inspection

cc: Distribution via LISTSERV

C. Arnone -3-

Letter to Charles Arnone from Edison Fernandez dated September 27, 2018.

SUBJECT: PALISADES NUCLEAR PLANTNOTIFICATION OF NRC BASELINE

INSPECTION AND REQUEST FOR INFORMATION; INSPECTION

REPORT 05000255/2018004

DISTRIBUTION:

Christopher Cook

RidsNrrPMPalisades Resource

RidsNrrDorlLpl3

RidsNrrDirsIrib Resource

Steven West

Darrell Roberts

Richard Skokowski

Allan Barker

DRPIII

DRSIII

ADAMS Accession Number: ML18270A450

OFFICE RIII

NAME EFernandez:cl

DATE 09/27/18

OFFICIAL RECORD COPY

DOCUMENT REQUEST FOR BASELINE INSERVICE INSPECTION

Inspection Report: 05000255/2018004

Inspection Dates: October 29, 2018, through November 9, 2018

Inspection Procedure: Inspection Procedure 71111-08, Inservice Inspection

Lead Inspector: Edison Fernandez, DRS

630-829-9754

Edison.Fernandez@nrc.gov

A. Information for the In-Office Preparation Week

The following information is requested as an (electronic copy CD ROM if possible) by

October 15, 2018, to facilitate the selection of specific items that will be reviewed during

the onsite inspection week. The inspector will select specific items from the information

requested below and a list of additional documents needed onsite from your staff. We

request that the specific items selected from the lists be available and ready for review

on the first day of inspection. If you have any questions regarding this information,

please call the inspector as soon as possible.

1. For the upcoming outage, a detailed schedule and description of:

a. Non-Destructive Examinations (NDEs) planned for Class 1 and 2 Systems

and containment, performed as part of your American Society of Mechanical

Engineers (ASME) Code Inservice Inspection (ISI) Program (include edition

and addenda of Code committed to), and NDEs planned for other systems

performed as part of a Risk-Informed-ISI Program, or other augmented

inspection programs (e.g., ASME Code Case N-770-1 examination of dissimilar

metal welds and examinations to meet an industry initiative). For each weld

examination, include the weld identification number, description of weld

(component name), category, class, type of exam and procedure number,

and date of examination;

b. Reactor vessel upper head examinations required by Title 10 of the Code of

Federal Regulations (CFR), Part 50.55a(g)(6)(ii)(D) and Code Case N-729-1;

c. Steam generator (SG) tube inspection and repair activities for the upcoming

outage or SG secondary side examinations1;

d. Welding on Code Class 1, 2, or 3 components (including contingency repair

welding for dissimilar metal welds); and

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Note 1- If no SG examinations are planned for this outage, please confirm when the next SG examination will occur

and no further information is required for the items identified above requesting SG related information.

Enclosure

DOCUMENT REQUEST FOR BASELINE INSERVICE INSPECTION

e. Inspections required under Nuclear Energy Institute 03-08 such as MRP 227,

146, 192 or other Mandatory, Needed or Good Practice requirements under

the material initiative.

2. A copy of the NDE procedures and welding procedures used to perform the activities

identified in Item A.1 (including NDE calibration and flaw characterization/sizing

procedures and Welding Procedure Qualification Records). For ultrasonic

examination procedures qualified in accordance with Appendix VIII, of Section XI of

the ASME Code, provide documentation supporting the procedure qualification

(e.g., the Electric Power Research Institute (EPRI) performance demonstration

qualification summary sheets).

3. A copy of ASME Section XI, Code Relief Requests applicable to the examinations

identified in Item A.1. This would include the NRC-approved Relief Request for

implementing a risk-informed ISI Program (if applicable).

4. A copy of the 10-year ISI Program showing those required exams scheduled to be

performed this outage, and those which have been completed.

5. A list identifying NDE reports (ultrasonic, radiography, magnetic particle, or dye

penetrant), which have identified relevant indications on Code Class 1 and 2

Systems since the beginning of the last refueling outage.

6. List with short description of the welds in Code Class 1 and 2 Systems, which have

been fabricated due to component repair/replacement activities since the beginning

of the last refueling outage and identify the system, weld number, and reference

applicable documentation (e.g., NIS-2 forms with definitions of system and

component acronyms).

7. If reactor vessel weld examinations required by the ASME Code are scheduled to

occur during the inspection period, provide a detailed description of the welds to be

examined, and the extent of the planned examination.

8. List with description of ISI and SG-related issues such as piping or SG tube

degradation or damage (e.g., cracks, wall thinning, wear, MIC) or errors identified

during piping/SG tube examinations that have been entered into your corrective

action system since the beginning of the last refueling outage. Also, include a list of

corrective action records associated with foreign material introduced/identified in the

reactor vessel, primary coolant system, SG or feed systems since the beginning of

the last refueling outage.

9. Copy of any 10 CFR Part 21 reports applicable to your structures systems or

components within the scope of Section XI of the ASME Code that have been

identified since the beginning of the last refueling outage.

10. Copy of SG history documentation given to vendors performing eddy current (ET)

testing of the SGs during the upcoming outage.

11. Copy of procedure containing screening criteria used for selecting tubes for in-situ

pressure testing and the procedure to be used for in-situ pressure testing.

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DOCUMENT REQUEST FOR BASELINE INSERVICE INSPECTION

12. Copy of previous outage SG tube operational assessment completed following ET of

the SGs (provide this document even if no SG ET is planned for current outage).

13. Copy of most recent SG Degradation Assessment (provide this document even if no

SG ET is planned for current outage).

14. Copy of most recent SG Condition Monitoring Assessments.

15. Copy of the document defining the planned SG ET scope (e.g., 100 percent of

unrepaired tubes with bobbin probe and 20 percent sample of hot leg expansion

transition regions with rotating probe) and identify the scope expansion criteria,

which will be applied. Also identify and describe any deviations in this scope or

expansion criteria from the EPRI Guidelines.

16. Copy of the document describing the ET acquisition equipment to be applied

including ET probe types. Also identify the extent of planned tube examination

coverage with each probe type (e.g., rotating probe - 0.080 inches, 0.115 inches

pancake coils and mid-range + point coil applied at the top-of-tube-sheet plus

3 inches to minus 12 inches).

17. Provide procedures with guidance/instructions for identifying (e.g., physically locating

the tubes that require repair) and plugging SG tubes.

18. Identify and quantify any SG tube leakage experienced during the previous operating

cycle. Also provide documentation identifying which SG was leaking and corrective

actions completed or planned for this condition.

19. Copy of current calculations for EDY, and RIY as defined in Code Case N-729-1 that

establish the volumetric and visual examination frequency for the reactor vessel

head and J-groove welds.

20. Point of contact information (name and site number) for the following activities:

a. ISI-Site and vendor leads;

b. Boric Acid Inspections and Evaluations;

c. Reactor Vessel Head Inspection-Site and vendor leads;

d. SG Inspection-Site and vendor leads;

e. NEI 03-08 Program Owner.

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DOCUMENT REQUEST FOR BASELINE INSERVICE INSPECTION

B. Onsite Information to be Provided to the Inspector on the First Day of the

Inspection (e.g., Following the Entrance Meeting). Please Provide Hard Copies

(e.g., Paper Records) of the Following Documents.

1. For welds selected by the inspector from Item A.1.d and A.6 above, provide copies of

the following documents:

a. Document of the weld number and location (e.g., system, train, branch);

b. Document with a detail of the weld construction (e.g., drawing);

c. Applicable portions of the Design Specification and applicable Code of

construction for the weldment (e.g., B31.1 or ASME Section III);

d. Applicable Code Edition and Addenda for weld procedure qualification;

e. Applicable weld procedures and weld data sheets used to fabricate the welds;

f. Copies of procedure qualification records supporting the weld procedures;

g. Copies of welders performance qualification records;

h. Copies of mechanical test reports identified in the procedure qualification

records above;

i. Copies of the nonconformance reports for the selected welds;

j. Access to radiographs and equipment to view radiographs of the selected welds;

k. ASME Code Section XI repair replacement plan and reconciliation for

replacement components/materials;

l. Certified Material Test Reports for replacement pressure boundary materials; and

m. Copies of the nondestructive examinations required by the construction Code

and the pre-service examination records required by the ASME Code Section XI

for the selected welds.

2. For the ISI-related corrective action issues selected by the inspector from Item A.8

above, provide a copy of the corrective actions and supporting documentation.

3. For the NDE reports with relevant indications on Code Class 1 and 2 Systems

selected by the inspector from Item A.5 above, provide a copy of the examination

records and associated corrective action documents. Updated schedules for

Item A.1 (including schedule showing contingency repair plans if available).

4. Copy of the procedures which govern the scope, equipment used, and

implementation of the inspections required to identify boric acid leakage

from systems and components above the vessel head.

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DOCUMENT REQUEST FOR BASELINE INSERVICE INSPECTION

5. Copy of:

a. Engineering evaluations/assessments of boric acid related deposits and

associated wastage or corrosion for safety significant components; and

b. Corrective action records for coolant leakage including boric acid deposits on

safety-related components identified since the beginning of the last refueling

outage.

6. Copy of the plant procedures used to perform inspections to identify reactor coolant

system leaks or boric acid deposits and the procedures for resolution of leaks or

boric acid deposits.

7. Fabrication Drawings (D size) of the reactor vessel welds (including vessel head

J-groove welds) if any are to be examined during the outage. Also provide any

drawings used by NDE vendors to locate these welds.

8. Copy of the documents which demonstrate that the procedures to be used for

volumetric examination of the reactor vessel head penetration J-groove welds were

qualified by a blind demonstration test in accordance with 10 CFR 50.55a(g)(6)(ii)(D).

9. Copy of volumetric, surface and visual examination records for the prior inspection of

the reactor vessel head and head penetration J-groove welds.

10. Provide a copy of the EPRI Examination Technique Specification Sheets and vendor

Examination Technique Specification Sheets-related documents, which support

qualification of the ET probes to be used during the upcoming SG tube inspections1.

11. Provide a copy of the guidance to be followed if a loose part or foreign material is

identified in the SGs1.

12. Identify the types of SG tube repair processes which will be implemented for

defective SG tubes (including any NRC reviews/evaluation/approval of this repair

process). Provide the flaw depth sizing criteria to be applied for ET indications

identified in the SG tubes1.

13. Copy of document describing actions to be taken if a new SG tube degradation

mechanism is identified1.

14. Provide document which defines the scope of SG secondary side examinations (if

any are planned) and identify site specific operational history related to degradation

of SG secondary side components (if any).

15. Provide procedures with guidance/instructions for identifying (e.g., physically locating

the tubes that require repair) and plugging SG tubes1.

1 Note 1- If no SG examinations are planned for this outage, please confirm when the next SG examination will occur

and no further information is required for the items identified above requesting SG related information.

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DOCUMENT REQUEST FOR BASELINE INSERVICE INSPECTION

16. Provide copies of the following standards at the on-site NRC inspection location for

the duration of the inspection:

a. Sections V, IX, and XI of the ASME Code with Editions applicable to the

ISI Program and the Repair/Replacement Program;

b. Copy of the performance demonstration initiative (PDI) generic procedures

with the latest applicable revisions that support site-qualified ultrasonic

examination of piping welds and components (e.g., PDI-UT-1, PDI-UT-2,

PDI-UT-3, PDI-UT-10 etc.);

c. EPRI and industry standards referenced in the site procedures used to

perform the SG tube eddy current examination, which includes EPRI

documents: TR-107621-R1, Steam Generator Integrity Assessment Guidelines,

TR-107620-R1, Steam Generator In-Situ Pressure Test Guidelines, Steam

Generator Management Program: Steam Generator Integrity Assessment

Guidelines, Part 10, and 1003138, Pressurized Water Reactor Steam Generator

Examination Guidelines1; and

d. Boric Acid Corrosion Guidebook Revision 2 - EPRI Technical Report 1000975.

17. Provide training (e.g., Scaffolding, Fall Protection, FME) if required to access the

NDEs selected by the inspector for observation.

If you have questions regarding the information requested, please contact the lead inspector

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