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IR 05000255/2015012, on 03/23/2015 - 08/19/2015; Palisades Nuclear Plant; Operability Determinations and Functional Assessments. (Msh)
	ML15261A576
Person / Time
Site:	Palisades
Issue date:	09/17/2015
From:	O'Brien K; Division of Reactor Safety III
To:	Vitale A; Entergy Nuclear Operations
References
	EA-15-171 IR 2015012
	Download: ML15261A576 (21)
	v • d • e

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE RD. SUITE 210

LISLE, IL 60532-4352

September 17, 2015

EA-15-171

Mr. Anthony Vitale

Vice President, Operations

Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant

27780 Blue Star Memorial Highway

Covert, MI 49043-9530

SUBJECT: PALISADES NUCLEAR PLANT NRC INSPECTION REPORT 05000255/2015012

Dear Mr. Vitale:

On August 19, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

consisting of an operability determination review at your Palisades Nuclear Plant. The enclosed

report documents the results of this inspection, which were discussed on August 19, 2015, with

members of your staff.

This inspection was an examination of activities conducted under your license as they relate to

operability determinations and compliance with the Commissions rules and regulations and the

conditions of your license. Within this area, the inspection involved examination of selected

procedures, representative records and interviews with personnel.

The enclosed report presents the results of this inspection including an apparent violation

which is being considered for escalated enforcement action in accordance with the NRC

Enforcement Policy, which appears on the NRCs Web site at http://www.nrc.gov/about-

nrc/regulatory/enforcement/enforce-pol.html. As described in Section 1R15 of this report,

the apparent violation of 10 CFR 50.9, Completeness and Accuracy of Information, relates to

your failure to provide information to the NRC that was complete and accurate in all material

respects in letter PNP 2014-015, Relief Request Number 4-18 - Proposed Alternative Use of

Alternate ASME [American Society of Mechanical Engineers] Code Case N-770-1 Baseline

Examination, submitted to the NRC on February 25, 2014. This issue resulted from an error in

a calculation supporting the analysis results provided in your February 25, 2014, letter, and,

once identified by your staff, was promptly reported to the NRC. This apparent violation is not a

current safety concern because your staff demonstrated an adequate basis for continued

operability of the nine affected primary coolant system welds.

Because the NRC has not made a final determination in this matter, no notice of violation is

being issued for the apparent violation at this time. In addition, please be advised that the

number and characterization of the apparent violation may change based on further NRC

review. The NRC requires lasting and effective corrective actions for this issue and your

corrective actions for the apparent violation and associated finding of very low safety

significance were discussed with NRC staff at the inspection exit meeting held on

A. Vitale -2-

August 19, 2015. As a result, it may not be necessary to conduct a pre-decisional enforcement

conference (PEC) in order to enable the NRC to make an enforcement decision. In addition,

since you identified the violation, and based on our understanding of your corrective actions, a

civil penalty may not be warranted in accordance with Section 2.3.4 of the Enforcement Policy.

The final decision will be based on you confirming on the license docket that the corrective

actions previously described to the NRC staff have been or are being taken.

Before the NRC makes a final decision on this matter, you may choose to: (1) attend a PEC,

where you can present to the NRC your point of view on the facts and assumptions used to

arrive at the apparent violation and assess its significance, or (2) submit your position on the

violation to the NRC in writing. If you request a PEC, it should be held within 30 days of your

receipt of this letter. Please contact Mr. David Hills at (630) 829-9733, and in writing, within

10 days from the issue date of this letter to notify the NRC of your intentions. If we have not

heard from you within 10 days, we will continue with our enforcement decision.

If you choose to request a PEC, the conference will afford you the opportunity to provide your

perspective on these matters and any other information that you believe the NRC should take

into consideration before making an enforcement decision. The decision to hold a PEC does

not mean that the NRC has determined that a violation has occurred or that enforcement action

will be taken. This conference would be conducted to obtain information to assist the NRC in

making an enforcement decision. The topics discussed during the conference may include

information to determine whether a violation occurred, information to determine the significance

of a violation, information related to the identification of a violation, and information related to

any corrective actions taken or planned. We encourage you to submit supporting

documentation at least one week prior to the conference in an effort to make the conference

more efficient and effective. If you choose to attend a PEC, it will be open for public

observation. The NRC will issue a public meeting notice and press release to announce the

conference.

If you decide to submit only a written response, it should be sent to the NRC within 30 days of

your receipt of this letter. It should be clearly marked as a Response to An Apparent Violation

in NRC Inspection Report (05000255/2015012; EA-15-171) and should include for the apparent

violation: (1) the reason for the apparent violation or, if contested, the basis for disputing the

apparent violation; (2) the corrective steps that have been taken and the results achieved;

(3) the corrective steps that will be taken; and (4) the date when full compliance will be

achieved. Your response may reference or include previously docketed correspondence, if the

correspondence adequately addresses the required response. If an adequate response is not

received within the time specified or an extension of time has not been granted by the NRC, the

NRC will proceed with its enforcement decision or schedule a PEC.

In addition, based on the results of this inspection, one NRC-identified finding of very low safety

significance was identified. This finding involved a violation of NRC requirements. However,

because of the very low safety significance and because the issue was entered into your

Corrective Action Program, the NRC is treating the violation as a Non-Cited Violation (NCV) in

accordance with Section 2.3.2 of the NRC Enforcement Policy.

A. Vitale -3-

If you contest the subject or severity of the NCV, you should provide a response within 30 days

of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a

copy to the Regional Administrator, Region III; the Director, Office of Enforcement, U.S. Nuclear

Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the

Palisades Nuclear Plant. In addition, if you disagree with the cross-cutting aspect assigned to

any finding in this report, you should provide a response within 30 days of the date of this

inspection report, with the basis for your disagreement, to the Regional Administrator,

Region III, and the NRC resident inspector at the Palisades Nuclear Plant.

In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRC's

"Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be

available electronically for public inspection in the NRC Public Document Room or from the

Publicly Available Records System (PARS) component of NRC's Agencywide Documents

Access and Management System (ADAMS), accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA David Curtis Acting for/

Kenneth G. OBrien, Director

Division of Reactor Safety

Docket No. 50-255

License No. DPR-20

Enclosure:

IR 05000255/2015012

cc w/encl: Distribution via LISTSERV

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket No. 50-255

License No. DPR-20

Report No: 05000255/2015012

Licensee: Entergy Nuclear Operations, Inc.

Facility: Palisades Nuclear Plant

Location: Covert, MI

Dates: March 23 through August 19, 2015

Inspectors: M. Holmberg, Reactor Inspector

A. Nguyen, Senior Resident Inspector

Approved by: David E. Hills, Chief

Engineering Branch 1

Division of Reactor Safety

Enclosure

TABLE OF CONTENTS

SUMMARY .................................................................................................................................2

REPORT DETAILS .....................................................................................................................5

1. REACTOR SAFETY ....................................................................................................... 5

1R15 Operability Determinations and Functional Assessments (71111.15) .................. 5

4. OTHER ACTIVITIES .....................................................................................................13

4OA6 Management Meetings ......................................................................................13

SUPPLEMENTAL INFORMATION .............................................................................................1

Key Points of Contact ............................................................................................................. 1

List of Items Opened, Closed, and Discussed ........................................................................ 1

List of Acronyms Used ............................................................................................................ 2

List of Documents Reviewed .................................................................................................. 2

SUMMARY

Inspection Report (IR) 05000255/2015012, 03/23/2015-08/19/2015; Palisades Nuclear Plant;

Operability Determinations and Functional Assessments.

This report covers a 5-month period of inspection by the senior resident inspector for the

Palisades Nuclear Plant and a regional inspector. An apparent violation was identified by the

licensee. Additionally, one Green finding was identified by the inspectors. The finding was

considered a Non-Cited Violation (NCV) of U.S. Nuclear Regulatory Commission (NRC)

regulations. The significance of inspection findings is indicated by their color (i.e., greater than

Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated April 29, 2015. Cross-cutting

aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated

December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the

NRCs Enforcement Policy dated July 9, 2013. The NRC's program for overseeing the safe

operation of commercial nuclear power reactors is described in NUREG-1649, Reactor

Oversight Process, Revision 5, dated February 2014.

Cornerstone: Initiating Events

TBD. An apparent violation (AV) of Title 10 of the Code of Federal Regulations (CFR)

50.9 was identified by the licensee, related to a failure to provide information that was

complete and accurate in all material respects to the NRC in letter PNP 2014-015,

Relief Request (RR) Number 4-18 - Proposed Alternative Use of Alternate ASME

[American Society of Mechanical Engineers] Code Case N-770-1 Baseline Examination.

Specifically, in this document the licensee stated, In the unlikely case that crack

initiation were to occur, crack growth calculations considering primary water stress

corrosion cracking (PWSCC) as the failure mechanism demonstrate that the hot leg

drain nozzle weldment satisfies ASME Code acceptance criteria for 60 effective full

power years [EFPY] for a circumferential flaw, and more than 34 years for an axial flaw.

However, this statement was not correct or accurate in that, the ASME Code acceptance

criteria were not satisfied for 60 EFPY for a circumferential flaw and 34 years for an axial

flaw, where correct information was 20 EFPY for a circumferential flaw, and 11.3 years

for an axial flaw. This AV was not an immediate safety concern because the licensee

demonstrated an adequate basis for continued operability of the nine affected primary

coolant system (PCS) welds. The licensee corrective actions for this AV included

completion of an operability evaluation, submittal of a corrected analysis to the NRC,

and entering this issue into the Corrective Action Program (CAP) (CR-PLP-2015-03441).

If the NRC was provided with the correct information in letter PNP 2014-015, where the

affected welds satisfied ASME Code acceptance criteria (i.e., 75 percent through-wall)

for only 20 effective full power years for a circumferential flaw, and 11.3 years for an

axial flaw, the NRC would not likely have approved RR 4-18 and, as a minimum, would

have requested additional supporting analysis (e.g., required substantial further inquiry).

Further, the need for substantial further inquiry was illustrated by the licensees

subsequent decision in RR 4-21 to abandon the prior analytical approach used in

RR 4-18. The inspectors evaluated the underlying technical issue in accordance with

the SDP to determine the risk significance of this AV. The issue of concern was of more

than minor significance because it was similar to the not minor if aspect of Example 3j

in IMC 0612, Appendix E, Example of Minor Issues. Specifically, the erroneous

2

information provided in letter PNP 2014-015 resulted in a condition in which there was a

reasonable doubt on the operability of the systems and components that were the

subject of the evaluation and dissimilar from the minor because aspect of this example

since the impact of the error for the operability of nine PCS welds was not minimal. In

addition, the performance deficiency was determined to be more than minor because it

was associated with the Initiating Event Cornerstone attribute of Equipment Performance

and adversely affected the Cornerstone objective to limit the likelihood of events that

upset plant stability and challenge critical safety functions. The inspectors evaluated the

finding in accordance with IMC 0609, Significance Determination Process, Attachment

0609.04, Phase 1 - Initial Screening and Characterization of Findings, Table 3, for the

Initiating Events Cornerstone, and IMC 0609, Appendix A, The SDP for Findings At-

Power. Because the licensee was able to demonstrate operability of the nine PCS

welds susceptible to PWSCC, the inspectors answered No to questions A.1 and A.2,

of Exhibit 1, Initiating Events Screening Questions, identified in Appendix A of IMC 609

and, as a result, the finding screened as having very low safety significance (Green).

No cross-cutting aspect was assigned because this Green finding was identified by the

licensee. (Section 1R15)

Green. An NRC-identified finding of very low safety significance and an associated

NCV of Title 10 of the Code of Federal Regulations (CFR), Part 50, Appendix B,

Criterion V, Instructions, Procedures and Drawings, was identified for the licensees

failure to adhere to the site procedure for performing operability determinations during

the evaluation of a nonconforming condition associated with nine primary coolant system

(PCS) welds susceptible to primary water stress corrosion cracking (PWSCC). The

licensees corrective actions for this finding included completion of an operability

determination in accordance with the site operability procedure to include a new analysis

which demonstrated the AMSE Code acceptance criteria would continue to be met for

the affected welds during the remainder of the operating cycle. The licensee entered the

failure to comply with the operability procedure into the CAP (CR-PLP-2015-03434).

This finding was determined to be more than minor because it was similar to the not

minor if aspect of Example 3j in IMC 0612, Appendix E, Example of Minor Issues,

because the errors in operability evaluation CA-1 of CR-PLP-2015-01239 resulted in a

condition in which there was a reasonable doubt on the operability of the systems and

components that were the subject of the evaluation and dissimilar from the minor

because aspect of this example since the impact of the errors on the operability

evaluation was not minimal. In addition, the performance deficiency was determined to

be more than minor because it was associated with the Initiating Event Cornerstone

attribute of Equipment Performance and adversely affected the Cornerstone objective to

limit the likelihood of events that upset plant stability and challenge critical safety

functions. The inspectors evaluated the finding in accordance with IMC 0609,

Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening

and Characterization of Findings, Table 3, for the Initiating Events Cornerstone and

IMC 0609, Appendix A, The SDP for Findings At-Power. Because the licensee was

able to demonstrate operability of the nine PCS welds susceptible to PWSCC, the

inspectors answered No to questions A.1 and A.2, of Exhibit 1, Initiating Events

Screening Questions, identified in Appendix A of IMC 609 and, as a result, the finding

screened as having very low safety significance (Green). This finding has a cross-

cutting aspect in Evaluation for the Problem Identification and Resolution cross-cutting

area since the licensee failed to thoroughly evaluate the impact on operability of a

3

nonconforming condition associated with nine PCS welds susceptible to PWSCC

[IMC 310, Item P.2]. (Section 1R15)

4

REPORT DETAILS

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R15 Operability Determinations and Functional Assessments (71111.15)

a. Inspection Scope

The inspectors reviewed the following issue:

Calculation error affecting flaw evaluation of nine primary coolant system

(PCS) welds susceptible to primary water stress corrosion cracking

(PWSCC) submitted to the NRC in letter PNP 2014-015, Relief Request

(RR) Number 4-18 - Proposed Alternative Use of Alternate American

Society of Mechanical Engineers (ASME) Code Case N-770-1 Baseline

Examination.

The inspectors selected this operability issue based on the risk significance of the

associated components and systems. The inspectors evaluated the technical adequacy

of the evaluations to ensure that Technical Specification (TS) operability was properly

justified and the subject component or system remained available such that no

unrecognized increase in risk occurred. The inspectors compared the operability and

design criteria in the appropriate sections of the TS and the Updated Final Safety

Analysis Report to the licensees evaluations to determine whether the components or

systems were operable. Where compensatory measures were required to maintain

operability, the inspectors determined whether the measures in place would function as

intended and were properly controlled. The inspectors determined, where appropriate,

compliance with bounding limitations associated with the evaluations. Additionally, the

inspectors reviewed a sample of corrective action documents to verify that the licensee

was identifying and correcting any deficiencies associated with operability evaluation.

Documents reviewed are listed in the Attachment to this report.

This operability inspection constituted one sample as defined in Inspection

Procedure 71111.15-05.

b. Findings

.1 Inaccurate/Incomplete Information Submitted For Relief Request 4-18

Introduction: An apparent violation (AV) of 10 CFR 50.9 was identified by the licensee,

related to an apparent failure to provide information that was complete and accurate in

all material respects to the NRC in letter PNP 2014-015. Specifically, in this document

the licensee stated, In the unlikely case that crack initiation were to occur, crack growth

calculations considering PWSCC as the failure mechanism demonstrate that the hot leg

drain nozzle weldment satisfies ASME Code acceptance criteria for 60 effective full

power years (EFPY) for a circumferential flaw, and more than 34 years for an axial flaw.

However, this statement was not correct or accurate in that, the ASME Code acceptance

criteria were not satisfied for 60 EFPY for a circumferential flaw and 34 years for an axial

flaw, where correct information was 20 EFPY for a circumferential flaw, and 11.3 years

for an axial flaw. This AV was not an immediate safety concern because the licensee

demonstrated an adequate basis for continued operability of the nine affected PCS

welds.

5

Description: In March of 2015, the licensee notified NRC staff, that information provided

to the NRC in letter PNP 2014-015 requesting NRC approval to defer examination of

nine PCS welds was not accurate because of an error made in a calculation used to

support the analysis results documented in this letter. On March 23, 2015, the

inspectors initiated a review of this issue to determine the impact of this error on the

operability of the nine affected PCS welds and to assess the licensees corrective

actions.

On February 25, 2014, the licensee submitted a letter PNP 2014-015 to the NRC

requesting approval to defer volumetric examination of nine PCS welds based in part on

the evaluations of postulated weld cracks that demonstrated ASME Code acceptance

criteria were met. In this letter, the licensee stated that the ASME Code acceptance

criteria would continue to be met for a postulated circumferential flaw for 60 EFPY and

more than 34 EFPY for a postulated axial flaw. On February 26, 2015, the licensee was

notified by its vendor of a nonconservative error in a calculation used to support this

analysis. Specifically, the vendor had erroneously applied the normal operating

pressure load which introduced a bending moment into the hot leg pipe wall rather than

an expected radial and axial expansion loads typical of internally applied pressure in the

piping. In particular, the induced bending moment created a compressive (i.e., less

tensile) stress behavior in and around the inside of the nozzle-to-pipe weld. As a result,

the erroneously applied pressure load reduced the radial and hoop tensile stresses at

the weld inside diameter rather than increasing them. The net effect of this error on the

analysis results was that the ASME Code acceptance criteria were met for only 20 EFPY

for a postulated circumferential and 11.3 EFPY for a postulated axial flaw. Palisades

EFPY of operation had already exceeded both of these values.

The inspectors developed a timeline of activities related to this issue as discussed

below.

During the January 2014 refueling outage, the NRC identified nine PCS welds

susceptible to PWSCC which had not been volumetrically examined by the

licensee as required by NRC regulations (reference NRC Inspection Report 05000255/2014002 - ADAMS Number ML14127A543 and NRC Regulatory

Information Summary 2015-10 - ADAMS Number ML15068A131).

On February 25, 2014, the licensee submitted a letter PNP 2014-015 Relief

Request Number RR 4-18 - Proposed Alternative, Use of Alternate ASME Code

Case N-770-1 Baseline Examination to the NRC. In this letter, the licensee

requested the NRC to approve deferral of volumetric examinations on nine PCS

welds based in part, on evaluations of postulated weld cracks that demonstrated

that ASME Code acceptance criteria would be maintained.

On March 6, 2014, in letter PNP 2014-028, the licensee submitted vendor

calculations to the NRC that were used to support the licensees conclusions

documented in RR 4-18 including calculation 1200895.306, Revision 0.

On March 12, 2014, the NRC granted verbal approval of RR 4-18 until the next

refueling outage scheduled for the fall of 2015.

6

On September 4, 2014, the NRC issued a letter documenting the NRCs basis for

approval of RR 4-18 (e.g., NRC safety evaluation).

On February 26, 2015, the licensee was notified by its vendor that an error was

made in a vendor calculation supporting RR 4-18.

On February 27, 2015, the licensee documented in CR-PLP-2015-0928 that an

error was made in a vendor calculation supporting RR 4-18 and notified the

Palisades Senior Resident Inspector.

On March 3 and March 19, 2015, during routine licensing conference calls with

NRC staff, the licensee notified the NRC Project Manager for Palisades in the

Office of Nuclear Reactor Regulation (NRR) that an error was made in a vendor

calculation supporting RR 4-18.

On March 6, 2015, the licensees vendor provided a letter to the licensee which

described the error in the vendors calculation and the impact on the analysis

results discussed in RR 4-18.

On March 23, 2015, in CA-4 of CR-PLP-2015-0928, the licensee identified five

vendor documents submitted to the NRC that contained errors and assigned an

action to interface with the NRC to determine which of these corrected

documents were to be resubmitted to the NRC.

On March 23, 2015, the inspectors and staff in the Office of NRR conducted a

tele-conference meeting with the licensee to determine the impact of the vendor

calculation error supporting RR 4-18 and to evaluate the licensees planned

corrective actions. The licensee reported that the error in the vendor calculation

was nonconservative because a corrected analysis resulted in a reduction in the

time (by approximately a factor of two) until a postulated PWSCC would reach

75 percent through-wall.

On March 24, 2015, the NRC concerns from the March 23, 2015, call, prompted

the licensee to initiate CA-1 of CR-PLP-2015-1239 to document a basis for

operability of the nine PCS welds affected by the calculation error. The

inspectors identified that the licensee had not previously completed an operability

evaluation for this condition because it was not recognized as a nonconformance

with the license basis (see next report section).

On March 31, 2015, the licensee completed an operability evaluation CA-1 of

CR-PLP-2015-1239 for this issue and determined that the affected welds were

operable.

On May 22, 2015, the licensee submitted a letter PNP 2015-037, Relief Request

Number RR 4-21 - Proposed Alternative, Use of Alternate ASME Code Case

N-770-1 Baseline Examination, to the NRC. In this letter, the licensee identified

that a discrepancy was discovered in a calculation that supported relief request

RR 4-18, requested approval for an alternative analysis/basis as described in

RR 4-21 (superseded RR 4-18) and provided corrections to the calculation and

analysis that supported the original RR 4-18. Specifically, in Enclosure 2 of

7

PNP 2015-037, the licensee stated, The erroneously applied pressure caused

an unbalanced pressure load, which introduced a bending moment into the hot

leg pipe wall rather than an expected radial and axial expansion typical of

internally applied pressure in the piping. In particular, the induced moment

tended to create a compressive (i.e., less tensile) stress behavior in and around

the inside of the nozzle-to-pipe weld. As a result, the erroneously applied

pressure reduced the radial and hoop tensile stresses at the weld inside diameter

rather than increase them. And In the unlikely case that crack initiation were to

occur, crack growth calculations considering PWSCC as the failure mechanism

demonstrate that the hot leg drain nozzle weldment satisfies ASME Code

acceptance criteria (i.e., 75 percent through-wall) for 20 EFPY for a

circumferential flaw, and 11.3 years for an axial flaw.

The licensee entered the failure to provide complete and accurate information to the

NRC as part of RR 4-18 into the Corrective Action Program (CAP) (CR-PLP-2015-

03441) and initiated an apparent cause evaluation. The licensees corrective actions

completed for this issue included an operability evaluation, and submittal of a corrected

analysis to the NRC.

Analysis: The inspectors determined that the failure to provide information to the NRC

that was complete and accurate in all material respects in letter PNP 2014-015

requesting NRC approval to defer examination of nine PCS welds that appears not to

be in accordance with 10 CFR 50.9 and a performance deficiency. Additionally, the

inspectors determined that the licensee had reasonable opportunity to foresee and

correct the inaccurate/incomplete information discussed above during owner acceptance

review of the vendors calculations prior to submitting this information to the NRC.

The inspectors reviewed this issue in accordance with IMC 0612, Appendix B, Issue

Screening, dated September 7, 2012. Because the apparent failure to provide

complete and accurate information to the NRC had the potential to impede or impact

the regulatory process, the finding was evaluated in accordance with NRC Enforcement

Policy for traditional enforcement items and the underlying technical issue was evaluated

using the SDP to determine the risk significance of this issue. Specifically, this AV is

associated with a finding that has been evaluated by the SDP and communicated with

an SDP color reflective of the safety impact of the deficient licensee performance. The

SDP, however, does not specifically consider the regulatory process impact, or actual

consequences. Thus, although related to a common regulatory concern, it is necessary

to address the apparent violation and finding using different processes to correctly reflect

both the regulatory importance of the apparent violation and the safety significance of

the associated finding.

If the NRC was provided with the correct information in letter PNP 2014-015, where the

affected welds satisfied ASME Code acceptance criteria (i.e., 75 percent through-wall)

for only 20 EFPY for a circumferential flaw, and 11.3 years for an axial flaw, the NRC

would not likely have approved RR 4-18 and, as a minimum, would have requested

additional supporting analysis (e.g., required substantial further inquiry). The need for

substantial further inquiry was illustrated by the licensees subsequent decision in RR 4-

21 to abandon the prior analytical approach used in RR 4-18 that relied on a closed form

analysis (e.g., SmartCrack Software Program) and instead changed to a more

sophisticated finite element analysis approach using an ANSYS software program to

model crack growth behavior in evaluation of the structural and leakage integrity at the

limiting weld.

8

The inspectors evaluated the underlying technical issue in accordance with the SDP to

determine the risk significance of this AV. The issue of concern was of more than minor

significance because it was similar to the not minor if aspect of Example 3j in IMC 0612, Appendix E, Example of Minor Issues. Specifically, the erroneous information

provided in letter PNP 2014-015 resulted in a condition in which there was a reasonable

doubt on the operability of the systems and components that were the subject of the

evaluation and dissimilar from the minor because aspect of this example since the

impact of the error for the operability of nine PCS welds was not minimal. In addition,

the performance deficiency was determined to be more than minor because it was

associated with the Initiating Event Cornerstone attribute of Equipment Performance

and adversely affected the Cornerstone objective to limit the likelihood of events that

upset plant stability and challenge critical safety functions. The inspectors evaluated the

finding in accordance with IMC 0609, Significance Determination Process, Attachment

0609.04, Phase 1 - Initial Screening and Characterization of Findings, Table 3, for the

Initiating Events Cornerstone and IMC 0609, Appendix A, The SDP for Findings At-

Power, dated June 19, 2012. Because the licensee was able to demonstrate operability

of the nine PCS welds susceptible to PWSCC, the inspectors answered No to

questions A.1 and A.2, of Exhibit 1, Initiating Events Screening Questions, identified in

Appendix A of IMC 609 and, as a result, the finding screened as having very low safety

significance (Green). No cross-cutting aspect was assigned because this Green finding

was identified by the licensee.

Enforcement: Title 10 of the Code of Federal Regulations (10 CFR) 50.9(a),

Completeness and Accuracy of Information, requires that Information provided to the

Commission by an applicant for a license or by a licensee or information required by

statute or by the Commission's regulations, orders, or license conditions to be

maintained by the applicant or the licensee shall be complete and accurate in all material

respects.

In Attachment 1, Relief Request Number RR 4-18 Proposed Alternative of letter PNP

2014-015 RR Number 4-18 - Proposed Alternative Use of Alternate ASME Code Case

N-770-1 Baseline Examination in the section titled Structural Evaluation, the licensee

stated, in part, ASME Code acceptance criteria are satisfied for 60 EFPY for a

circumferential flaw, and more than 34 years for an axial flaw assuming crack initiates at

day one. Using hot leg crack growth rate and temperature.

In Attachment 3, Structural Integrity Associates, Inc. Memorandum - Evaluation of the

Palisades Nuclear Plant Hot Leg Drain Nozzle for Primary Water Stress Corrosion

Cracking of letter PNP 2014-015 RR Number 4-18 - Proposed Alternative Use of

Alternate ASME Code Case N-770-1 Baseline Examination, in the section titled

Conclusions the licensee stated, in part, In the unlikely case that crack initiation were

to occur, crack growth calculations considering PWSCC as the failure mechanism

demonstrate that the hot leg drain nozzle weldment satisfies ASME Code acceptance

criteria for 60 EFPY for a circumferential flaw, and more than 34 years for an axial flaw.

An AV of Code of Federal Regulations (10 CFR) 50.9(a), Completeness and Accuracy

of Information, has been identified, as it appears that the information in letter PNP 2014-

015 provided to the Commission on February 25, 2014, was not complete and accurate

in all material respects because the ASME Code acceptance criteria would not have

been met for 60 EFPY for a circumferential flaw and 34 years for an axial flaw, where

correct information was 20 EFPY for a circumferential flaw, and 11.3 years for an axial

9

flaw. This change in the analysis results represented a significant reduction in the time

to reach the ASME Code acceptance criteria limits and as such, was information

considered material to the NRC in the review and approval of RR 4-18. This was not an

immediate safety concern because the licensee demonstrated an adequate basis for

continued operability of the affected welds. The licensee corrective actions for this issue

included; completion of an operability evaluation, submittal of a corrected analysis to the

NRC, and entering this issue into the CAP (CR-PLP-2015-03441).

(AV 05000255/2015012-01; Inaccurate/Incomplete Information Provided For Relief

Request 4-18).

.2 Operability Evaluation Not Performed in Accordance with Station Procedure

Introduction: The inspectors identified a finding of very low safety significance (Green)

and associated NCV of 10 CFR 50, Part 50, Appendix B, Criterion V, Instructions,

Procedures and Drawings, for the licensees failure to adhere to the site procedure for

performing operability determinations during the evaluation of a nonconforming condition

associated with nine PCS welds susceptible to PWSCC.

Description: During review of the licensees corrective actions for the AV discussed in

the previous report section, the inspectors identified a separate performance deficiency

and finding associated with the licensees failure to follow the site procedure for

evaluating the operability of nine PCS welds.

On February 27, 2015, the licensee was notified by its vendor of a nonconservative error

in a vendor calculation 1200895.306 which determined the residual stress profile in the

limiting PCS weld susceptible to PWSCC. This calculation had been submitted to the

NRC on March 6, 2014, in support of a RR 4-18 (discussed in the previous section) and

was used to support the licensees conclusion that a postulated axial crack would not

reach 75 percent through-wall until more than 34 EFPY and 60 EFPY for a postulated

circumferential crack. In calculation 1200895.306, the licensees vendor erroneously

applied the normal operating pressure load creating an unbalanced pressure load, which

introduced a bending moment into the hot leg pipe wall model rather than an expected

radial and axial expansion load typical of internally applied pressure in the piping. In

particular, the induced moment tended to create a compressive (i.e., less tensile) stress

behavior in and around the inside of the nozzle-to-pipe weld. As a result, the

erroneously applied pressure reduced the radial and hoop tensile stresses at the weld

inside diameter rather than increasing them. The licensee evaluated the effect of this

non-conservative vendor calculation error in CR-PLP-2015-00928 and documented this

issue as administrative in nature with proposed corrective actions to revise the affected

calculation and update the associated engineering change package. However, the

licensee had not assigned an action to complete an operability evaluation of the nine

PCS welds susceptible to PWSCC that had not been volumetrically examined to

determine the extent of cracking within these welds. Because the corrected flaw growth

evaluation of a postulated PWSCC resulted in a time to reach a through-wall leakage

condition that was less than the current accumulated EFPY of operation, the inspectors

were concerned for the lack of a basis to demonstrate that it was acceptable to continue

operation with the nine PCS welds at risk for leakage or failure induced by PWSCC.

Procedure EN-OP-104 Operability Determination Process defined an operability

evaluation as a Technical analysis and associated conclusions, including a prescriptive

description of any required Compensatory Measures, regarding Operability of a TS SSC

10

[structure system or component]. The operability determination process is an activity

affecting quality and the licensee identified procedure EN-OP-104 as quality related

which is a procedure required by the Entergy Quality Assurance Program Manual

(QAPM). The QAPM is implemented through the use of approved procedures (e.g.

policies, directives, procedures, instructions, or other documents) which provide written

guidance for the control of quality related activities and provide for the development of

documentation to provide objective evidence of compliance. In the QAPM the licensee

stated that Procedures that implement the QAPM are approved by the management

responsible for the applicable quality function. These procedures are to reflect the

QAPM and work is to be accomplished in accordance with them.

Step 5.5.5.f of EN-OP-104 required the licensee to identify the applicable current license

basis (CLB) requirements for the SSC including review of other CLB documents such as

safety evaluations. In CR-PLP-2015-00928 the licensee appropriately identified the CLB

requirement for the nine PCS welds which included the NRC safety evaluation approving

RR 4-18 (reference: NRC Letter dated September 4, 2014, ADAMS Number

ML14223B226). However, the licensee incorrectly assumed that the NRC had not relied

on the results of the vendor calculations submitted in the review and approval of this

safety evaluation. Therefore, the licensee did not identify this issue as a

nonconformance with the CLB and hence did not properly accomplish Step 5.5.6.a of

EN-OP-104 which stated, Evaluate component and system conformance with

applicable requirements of the CLB.

On March 23, 2015, the inspectors reviewed CR-PLP-2015-00928 and identified that the

licensee staff failed to recognize the vendor calculation error as a nonconforming

condition with respect to the CLB for the nine affected PCS welds. Step 3.16 of EN-OP-

104 defined a nonconforming condition as A condition of a SSC that involves a failure to

meet the CLB. In this case, the nonconservative calculation error shortened the time

available until a PWSCC could reach 75 percent through-wall which adversely effected

the CLB for the nine PCS welds as evaluated by the NRC during review of RR 4-18.

Consequently, the licensee had not complied with step 5.3 of EN-OP-104, which stated

that Operability should be determined immediately upon discovery (i.e., Immediate

Determination) without delay and in a controlled manner using the best information

available. The inspectors requested that the licensee identify the basis for operability

of the nine affected PCS welds which did not conform to the CLB as established in

RR 4-18. The inspectors concern prompted the licensee to document this issue in CR-

PLP-2015-01239 and complete an immediate operability evaluation. The licensee also

implemented a corrective action to document additional supporting evaluations/analysis

in a prompt operability evaluation in accordance with procedure EN-OP-104.

On March 31, 2015, the licensee completed the prompt operability evaluation under

CA-1 of CR-PLP-2015-01239. However, the inspectors identified that the licensee had

not established an adequate basis for a prompt operability that would cover the

remaining operating cycle. Specifically, the licensees operability evaluation relied on a

leak-before-break type of analysis without identification of margins to prevent thru-wall

leakage and did not follow the ASME Code Section XI methods (e.g., Article IWB-3600

Analytical Evaluation of Flaws) to quantify factors of safety (e.g., margins) to protect

against a sudden/rapid failure (e.g., structural integrity). Without application of the

ASME Code methods, the operability evaluation was not consistent with procedure EN-

OP-104 step 5.5.6(d) which required evaluation of the SSC against the applicable codes

and standards requirements for operability and step 5.11.17 ASME Class 1, 2, 3 Piping

11

Flaw Evaluation and Resolution, which stated that When Flaws are acceptable per the

ASME Code acceptance standards, then structural integrity is assured and the SSC is

OPERABLE. Additionally, the operability evaluation was not consistent with the NRC

policy for operation with flawed piping as identified in Appendix C.11, Flaw Evaluation

of IMC 0326 Operability Determinations and Functionality Assessments for Conditions

Adverse to Quality or Safety which stated, Satisfaction of Code acceptance standards

is the minimum necessary for operability of Class 1 pressure boundary components

because of the importance of the safety function being performed. The licensee staff

stated that they had not followed the operability procedure for flawed piping welds

because they did not have any known flaws. However, the nine PCS welds were

susceptible to PWSCC and the CLB as established in the NRC safety evaluation of

RR 4-18 required the licensee to presume the presence of flaws (e.g., cracks) because

volumetric examinations had not been completed to identify the extent of cracking

present in these welds.

On June 3, 2015, the licensee completed a revision to operability evaluation CA-1 of

CR-PLP-2015-01239 to correct errors previously identified by the inspectors and

established an adequate basis for prompt operability for the remaining portion of the

operating cycle. Specifically, in the revised operability evaluation, the licensee assumed

PWSCC were present in the affected welds and documented a new analysis which

demonstrated the ASME Code acceptance criteria would continue to be met for the

affected welds during the remainder of the operating cycle. The licensee entered the

failure to comply with the operability procedure into the CAP (CR-PLP-2015-03434).

Analysis: The inspectors determined that the failure to adhere to the site procedure for

performing operability determinations during the evaluation of a nonconforming condition

associated with nine PCS welds susceptible to PWSCC was contrary to 10 CFR 50,

Part 50, Appendix B, Criterion V, and a performance deficiency.

This finding was determined to be more than minor because it was similar to the not

minor if aspect of Example 3j in IMC 0612, Appendix E, Example of Minor Issues,

because the errors in Operability Evaluation CA-1 of CR-PLP-2015-01239 resulted in a

condition in which there was a reasonable doubt on the operability of the systems and

components that were the subject of the evaluation and dissimilar from the minor

because aspect of this example since the impact of the errors on the Operability

Evaluation was not minimal. In addition, the performance deficiency was determined to

be more than minor because it was associated with the Initiating Event Cornerstone

attribute of Equipment Performance and adversely affected the Cornerstone objective to

limit the likelihood of events that upset plant stability and challenge critical safety

functions.

The inspectors evaluated the finding in accordance with IMC 0609, Significance

Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and

Characterization of Findings, Table 3, for the Initiating Events Cornerstone and IMC 0609, Appendix A, The SDP for Findings At-Power, dated June 19, 2012. Because

the licensee was able to demonstrate operability of the nine PCS welds susceptible to

PWSCC, the inspectors answered No to questions A.1 and A.2, of Exhibit 1, Initiating

Events Screening Questions, identified in Appendix A of IMC 609 and, as a result, the

finding screened as having very low safety significance (Green).

12

This finding has a cross-cutting aspect in Evaluation for the Problem Identification and

Resolution cross-cutting area since the licensee failed to thoroughly evaluate the impact

on operability of a nonconforming condition associated with nine PCS welds susceptible

to PWSCC [IMC 310, Item P.2].

Enforcement: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures

and Drawings requires, in part, that activities affecting quality be prescribed and

accomplished by procedures. The operability determination process (an activity

affecting quality) was described in procedure EN OP 104 Operability Determination

Process and the licensee identified this procedure as quality related which is a

procedure required by the QAPM.

Procedure EN-OP-104, Step 5.5.6.a stated, Evaluate component and system

conformance with applicable requirements of the CLB.

Procedure EN-OP-104 Step 5.5.6.d stated, Evaluate the SSC condition against the

applicable codes and standards requirements for operability. And Step 5.11.17, ASME

Class 1, 2, 3 Piping Flaw Evaluation and Resolution, stated, in part, When Flaws are

acceptable per the ASME Code acceptance standards, then structural integrity is

assured and the SSC is OPERABLE.

Contrary to the above, on March 31, 2015, in CA-1 of CR-PLP-2015-01239 the licensee

failed to evaluate these welds (e.g., components) for conformance with the CLB as

described in the NRC safety evaluation approving RR 4-18 (reference ADAMS Number

ML14223B226) and failed to evaluate these welds against the applicable ASME Code

for operability. Corrective actions for this finding included completion of an operability

determination on June 3, 2015 in accordance with the site operability procedure to

include a new analysis which demonstrated the ASME Code acceptance criteria would

continue to be met for the affected welds during the remainder of the operating cycle.

Because this violation was of very low safety significance, was corrected on June 3,

2015, and entered into the CAP (CR-PLP-2015-03434), this violation is being treated as

an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000255/2015012-02; Operability Evaluation Not Performed in Accordance with

Station Procedure).

4. OTHER ACTIVITIES

4OA6 Management Meetings

.1 Exit Meeting Summary

On August 19, 2015, the inspectors presented the inspection results to Mr. R. Craven,

and other members of the licensee staff. The licensee acknowledged the issues

presented. The inspectors confirmed that none of the potential report input discussed

was considered proprietary.

ATTACHMENT: SUPPLEMENTAL INFORMATION

13

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

D. Corbin, Operations Manager

R. Craven, Acting General Manager Plant Operations

T. Davis, Regulatory Assurance

J. Hardy, Regulatory Assurance Manager

D. Mannai, Fleet Regulatory Assurance Senior Manager

D. Nestle, Radiation Protection Manager

K. OConnor, Design Engineering Manager

B. Sova, Engineering Supervisor

U.S. Nuclear Regulatory Commission

E. Duncan, Chief, Reactor Projects Branch 3

J. Collins, Senior Materials Engineer, Division of Engineering, Office of Nuclear Reactor

Regulation

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000255/2015012-01 AV Inaccurate/Incomplete Information Submitted For Relief

Request 4-18 (Section 1R15)05000255/2015012-02 NCV Operability Evaluation Not Performed in Accordance with

Station Procedure (Section 1R15)

Closed

05000255/2015012-02 NCV Operability Evaluation Not Performed in Accordance with

Station Procedure (Section 1R15)

Discussed

None

Attachment

LIST OF ACRONYMS USED

ADAMS Agencywide Documents Access and Management System

ASME American Society of Mechanical Engineers

AV Apparent Violation

CAP Corrective Action Program

CFR Code of Federal Regulations

CLB Current License Basis

EFPY Effective Full Power Years

IMC Inspection Manual Chapter

NCV Non-Cited Violation

NRC U.S. Nuclear Regulatory Commission

NRR Office of New Reactor Regulation

PARS Publicly Available Records System

PCS Primary Coolant System

PEC Pre-Decisional Enforcement Conference

PWSCC Primary Water Stress Corrosion Cracking

RR Relief Request

SDP Significance Determination Process

SSC Structure, System, or Component

TBD To Be Determined

TS Technical Specification

LIST OF DOCUMENTS REVIEWED

The following is a partial list of documents reviewed during the inspection. Inclusion on this list

does not imply that the NRC inspector reviewed the documents in their entirety, but rather that

selected sections or portions of the documents were evaluated as part of the overall inspection

effort. Inclusion of a document on this list does not imply NRC acceptance of the document or

any part of it, unless this is stated in the body of the inspection report.

1R15 Operability Determinations and Functionality Assessments

- CR-PLP-2015-03441, dated August 18, 2015

- CR-PLP-2015-03434, dated August 18, 2015

- CR-PLP-2015- 00928, dated February 27, 2015

- CR-PLP-2015-02427, dated June 11, 2015

- CR-PLP-2015- 01239, Corrective Action 1 Operability Evaluation, dated March 31, 2015

- CR-PLP-2015-01239, Corrective Action 1 Operability Evaluation, dated June 3, 2015

- Letter PNP 2014-015, RR Number 4-18 - Proposed Alternative Use of Alternate ASME Code

Case N-770-1 Baseline Examination, dated February 25, 2014.

- Letter PNP 2015-037, Relief Request Number RR 4-21 - Proposed Alternative, Use of

Alternate ASME Code Case N-770-1 Baseline Examination, dated May 22, 2015.

- Procedure EN-OP-104, Operability Determination Process, Revision 8