ML11347A347

Request for Additional Information - License Renewal Commitment - Nickel Alloy Aging Management Program

ML11347A347
Person / Time
Site:	Palisades
Issue date:	12/13/2011
From:	Heather Jones NRC/NRR/DLR/RPOB
To:	Kuemin J, Gustafson O Entergy Operations
Jones H
References
Download: ML11347A347 (3)

Text

From:Jones, Heather To:KUEMIN, JAMES L; GUSTAFSON, OTTO W Cc:Diaz-Sanabria, Yoira; Pham, Bo; Chawla, Mahesh; Tsao, John; Lupold, Timothy

Subject:

Palisades Nuclear Plant - Request for Additional Information - License Renewal Commitment - Nickel Alloy AgingManagement Program Date:Tuesday, December 13, 2011 11:00:00 AMBy letter dated March 13, 2008 (Agencywide Document Access and Management Systems Accession No. ML080770454), Entergy (the licensee) submitted its proposed Nickel Alloy Program (Procedure No. EM-09-22) to satisfy one of the commitments in its license renewal application for the Palisades Nuclear Plant.

The staff reviewed the proposedNickel Alloy program in accordance with aging management program (AMP) XI.M11B, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components (PWRs Only)"

in theGeneric Aging Lessons Learned (GALL) Report, NUREG-1801, Revision 2.

Specifically,the staff compared the proposed Nickel Alloy Program against the 10 attributes of GALL AMP XI.M11B in NUREG-1801, Revision 2.

To complete its review, the staff requestsadditional information. Please arrange a teleconference to discuss the following

information:

REQUEST FOR ADDITIONAL INFORMATION (RAI)

1. GALL AMP XI.M11B, Program Description, references the following three AmericanSociety of Mechanical Engineers (ASME) Code Cases:

(a) Code Case N-729-1, "Alternative Examination Requirements for PWR Reactor VesselUpper Heads With Nozzles Having Pressure-Retaining Partial-Penetration Welds,Section XI, Division 1," is incorporated with conditions in Title 10, Code of Federal Regulations,Part 50, Paragraph 50.55a(g)(6)(ii)(D).

(b) Code Case N-722, "Additional Examinations for PWR Pressure Retaining Welds in Class 1 Components Fabricated with Alloy 600/82/182 Materials,Section XI, Division 1," is incorporated with conditions in 10 CFR 50.55a(g)(6)(ii)(E).

(c) Code Case N-770-1, "Alternative Examination Requirements and Acceptance Standards for Class 1 PWR Piping and Vessel Nozzle Butt Welds Fabricated With UNS N06082 or UNS W86182 Weld Filler Material With or Without Application of Listed Mitigation Activities,Section XI, Division 1," is incorporated with conditions in 10 CFR

50.55a(g)(6)(ii)(F).

However, the proposed Nickel Alloy program does not reference thesethree code cases or corresponding paragraphs in 10 CFR 50.55a.

Discuss how these code cases and corresponding paragraphs in 10 CFR 50.55a will be implemented under the proposed Nickel Alloy Program to satisfy GALL AMP XI.M11B.

2. GALL AMP XI.M11B, Attribute Item 1, Scope of Program, states that the loss ofmaterial due to boric acid corrosion in susceptible components in the vicinity of nickel-alloy components should also be managed, which is not discussed in the proposed Nickel Alloy

Program. Discuss how the proposed Nickel Alloy Program satisfies GALL AMP XI.M11Bwith regard to the aging management of loss of material due to boric acid corrosion or justify the adequacy of the proposed program.

3. Section 2.1.3 of the Nickel Alloy Program identifies many components in the PalisadesNuclear Plant that are made of nickel alloy.

Clarify whether the weld joining the safe endand the safety injection, shutdown cooling outlet and surge line nozzles in the primary coolant piping is made of Alloy 82/182 material and if the safe end is made of Alloy 600 material. Also, clarify whether the weld joining the safe end and the pressurizer spray,surge line, and relief valve nozzles is made of Alloy 82/182 and if the safe end is made ofAlloy 600 material.

4. GALL AMP XI.M11B, Attribute Item 2, Preventive Actions, provides guidance onpreventive actions to mitigate primary water stress corrosion cracking.

Section 5.2.3 of theproposed Nickel-Alloy Program states that the mechanical stress improvement process has been applied at several nickel alloy locations.

Section 5.2.3 further states that thedetails of the mitigation are contained in the Palisades 10-year Interval Master Inservice Inspection Plan for Class 1, 2, 3, Risk-Informed Defense-In-Depth and Augmented

Examinations.

(a) If this report is submitted to the NRC, provide the date.

If not, submitthe report or provide a list of components that have been applied with the mechanical stress improvement process.

(b) Discuss whether other mitigation methods such as weldoverlay, onlay, or inlay have been applied to nickel alloy components.

(c) Discuss anyrepairs on nickel alloy components that have been completed.

5. GALL AMP XI.M11B, Attribute Item 3, Parameter Monitored/Inspected, specifiesparameters that are to be monitored or inspected.

Discuss the parameters that will bemonitored and inspected under the proposed Nickel-Alloy Program.

6. GALL AMP XI.M11B, Attribute Item 4, Detection of Aging Effects, states that reactorcoolant pressure boundary leakage can be monitored through the use of radiation air monitoring and other general area radiation monitoring, and technical specifications for reactor coolant pressure boundary leakage.

(a) Discuss the capability of the plant's RCSleakage detection systems to address this attribute.

(b) Section 5.2.4 of the proposedNickel Alloy Program discusses detection of cracking through a combination bare-metal visual examination and/or non-visual examination techniques.

Discuss how the proposedinspections will satisfy the requirements of 10 CFR 50.55a(g)(6)(ii)(D), (E) and (F).

Discuss the inspection samples for the components identified in Section 2.1.3 of the proposed program (e.g., how many welds and/or components will be inspected) during each inspection.

Discuss inspection techniques, such as, visual, surface, or volumetricexaminations for each component (components may be grouped for the specific inspection

method).

7. GALL AMP XI.M11B, Attribute Item 5, Monitoring and Trending, states that reactorcoolant pressure boundary leakage is calculated and trended on a routine basis in accordance with technical specification to detect changes in the leakage rates.

Clarify howthe proposed Nickel Alloy Program satisfies Attribute Item 5 of GALL AMP XI.M11B.

8. GALL AMP XI.M11B, Attribute Item 6, Acceptance Criteria, specifies the acceptancecriteria for all indications of cracking and loss of material due to boric acid-induced

corrosion.

Sections 5.3.6 and 5.3.7 of the proposed Nickel Alloy Program provide the acceptance criteria for cracking, but not for loss of material.

(1) Discuss the acceptance criteria for lossof material due to boric acid corrosion in susceptible components in the vicinity of nickel-alloy components. (2) Discuss the acceptance criteria for visual examinations that will be performed under the proposed Nickel Alloy Program.

9. GALL AMP XI.M11B, Attribute Item 7, Corrective Actions, specifies that relevant flawindications of susceptible components found to be unacceptable for further services are corrected through implementation of appropriate repair or replacement as dictated by 10CFR 50.55a and industry guidelines.

In addition, detection of leakage or evidence ofcracking in susceptible components require scope expansion of current inspection andincreased inspection frequencies of some components, as required by 10 CFR 50.55a and industry guidelines.

Repair and replacement procedures and activities must either complywith ASME Section XI, as incorporated in 10 CFR 50.55a or conform to applicable ASME Code Cases that have been endorsed in 10 CFR 50.55a by referencing the latest version of NRC Regulatory Guide 1.147.

Clarify how the proposed Nickel Alloy Program satisfiesAttribute Item 7 of GALL AMP XI.M11B.

10. GALL AMP XI.M11B, Attribute Item 8, Confirmation Process, states that site qualityassurance procedures and review and approval processes are implemented in accordance with the requirements of 10 CFR Part 50, Appendix B.

Discuss how the proposed NickelAlloy Program satisfies Attribute Item 8 of GALL AMP XI.M11B.

11. GALL AMP XI.M11B, Attribute Item 9, Administrative Controls, references 10 CFRPart 50, Appendix B.

Section 4.4 of the proposed Nickel Alloy Program discussesadministrative controls without referencing 10 CFR Part 50, Appendix B.

Clarify how theproposed Nickel Alloy Program satisfies Attribute Item 9 of GALL AMP XI.M11B.

12. GALL AMP XI.M11B, Attribute Item 10, Operating Experience, provides guidance onidentifying, maintaining and addressing operating experience.

Section 4.5 of the proposedNickel Alloy Program discusses briefly how operating experience is identified.

Discuss anyindustry operating experience that is applicable to Palisades.

Discuss in details whether arecord of operating experience has been maintained and how industry operating experience will be addressed under the proposed Nickel Alloy Program.

13. Since the time the proposed Nickel Alloy Program was submitted, several documentshave been revised.

For example, References 3.1.3 and 3.1.5 are cited as NUREG-1801,Revisions 0 and 1, respectively.

However, NUREG-1801, Revision 2, is the latest versionand should be cited in Section 3.0.

Please explain how the proposed Nickel Alloy Programwill be reviewed and maintained current from now to the end of the extended period of

operation.