ML062690435

Relief Request No. PRR-10 Risk-Informed Fourth 10-year Interval Inservice Inspection Program Plan

ML062690435
Person / Time
Site:	Pilgrim
Issue date:	09/28/2006
From:	Richard Laufer NRC/NRR/ADRO/DORL/LPLI-1
To:	Kansler M Entergy Nuclear Operations
Shea J
References
PRR-10, TAC MC8293
Download: ML062690435 (9)

Text

September 28, 2006Mr. Michael KanslerPresident Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

PILGRIM NUCLEAR POWER STATION - RELIEF REQUEST NO. PRR-10, RISK-INFORMED FOURTH 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN (TAC NO. MC8293)

Dear Mr. Kansler:

By letter dated June 29, 2005, as supplemented by letter dated June 21, 2006, Entergy NuclearOperations, Inc. (the licensee), submitted a request to extend the Risk-Informed Inservice Inspection (RI-ISI) Program Plan to the fourth10-year ISI interval applicable to the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, 1998 Edition with the 2000 Addenda, requirements for Class 1 Examination Category B-J and B-F piping welds. The RI-ISI program was approved for use at Pilgrim Nuclear Power Station (Pilgrim) during the second period of the third inspection interval.The Nuclear Regulatory Commission staff has concluded that the proposed alternatives to theASME Code requirements in PRR No.10 are acceptable, and will provide an acceptable level ofquality and safety. The results are provided in the enclosed safety evaluation. Pursuant to 10 CFR 50.55a(a)(3)(i), the proposed alternative is authorized for Pilgrim's fourth 10-year ISI interval, which ends on June 30, 2015.If you have any questions regarding this approval, please contact the Pilgrim Project Manager,James Shea, at 301-415-1388. Sincerely,/RA/Richard J. Laufer, ChiefPlant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-293

Enclosure:

As stated cc w/encl: See next page

ML062690435*No major changes to SE dated 09/28/06OFFICELPLI-1/PELPLI-1/PMLPLI-1/LACPNB/BCAPLB/BCOGCLPL1-1/BCNAMENMorganJShea:osrSLittleTChan*LMrowca*JMartinRLauferDATE9/26/069/26/069/28/069/28/069/28/069/27/069/28/06 Pilgrim Nuclear Power Station cc:

Regional Administrator, Region IU. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415Senior Resident InspectorU. S. Nuclear Regulatory Commission Pilgrim Nuclear Power Station Post Office Box 867 Plymouth, MA 02360Chairman, Board of Selectmen11 Lincoln Street Plymouth, MA 02360ChairmanNuclear Matters Committee Town Hall 11 Lincoln Street Plymouth, MA 02360Chairman, Duxbury Board of SelectmenTown Hall 878 Tremont Street Duxbury, MA 02332Office of the CommissionerMassachusetts Department of Environmental Protection One Winter Street Boston, MA 02108Office of the Attorney GeneralOne Ashburton Place 20th Floor Boston, MA 02108MA Department of Public HealthRadiation Control Program Schrafft Center, Suite 1M2A 529 Main Street Charlestown, MA 02129Secretary of Public SafetyExecutive Office of Public Safety One Ashburton Place Boston, MA 02108 Director, Massachusetts EmergencyManagement Agency Attn: James Muckerheide 400 Worcester Road Framingham, MA 01702-5399Mr. William D. MeinertNuclear Engineer Massachusetts Municipal Wholesale Electric Company

P.O. Box 426 Ludlow, MA 01056-0426Mr. Kevin H. BronsonGeneral Manager, Plant Operations Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill RoadPlymouth, MA 02360-5508Mr. Michael A. BalduzziSite Vice President Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill RoadPlymouth, MA 02360-5508Mr. Stephen J. BethayDirector, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill RoadPlymouth, MA 02360-5508Mr. Bryan S. FordManager, Licensing Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill RoadPlymouth, MA 02360-5508 Pilgrim Nuclear Power Station cc:

Mr. Gary J. Taylor Chief Executive Officer Entergy Operations 1340 Echelon Parkway Jackson, MS 39213Mr. John T. HerronSr. VP and Chief Operating Officer Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. Oscar LimpiasVice President, Engineering Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. Christopher SchwarzVice President, Operations Support Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. Michael KanslerPresident Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. John F. McCannDirector, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

Ms. Charlene D. FaisonManager, Licensing Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. Michael J. ColombDirector of Oversight Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Assistant General CounselEntergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Ms. Stacey LousteauTreasury Department Entergy Services, Inc.

639 Loyola Avenue New Orleans, LA 70113Mr. James Sniezek5486 Nithsdale Drive Salisbury, MD 21801-2490Mr. Michael D. Lyster5931 Barclay Lane Naples, FL 34110-7306Mr. Garrett D. Edwards814 Waverly Road Kennett Square, PA 19348 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRISK-INFORMED INSERVICE INSPECTION PROGRAM FOR FOURTH 10-YEAR INTERVALRELIEF REQUEST NO. PRR-10ENTERGY NUCLEAR OPERATIONS, INC.PILGRIM NUCLEAR POWER STATIONDOCKET NO. 50-293

1.0INTRODUCTION

By letter dated June 29, 2005 (Reference 1), as supplemented by letter dated June 21, 2006 (Reference 2), Entergy Nuclear Operations, Inc. (the licensee) submitted a request to extend the Risk-Informed Inservice Inspection (RI-ISI) Program Plan for Pilgrim Nuclear Power Station (Pilgrim) to the fourth 10-year ISI interval. The Pilgrim RI-ISI program was initially submitted to the Nuclear Regulatory Commission (NRC) staff by letter dated December 27, 2000 (Reference3), during the second period of the third 10-year ISI interval, and supplemented by letters dated January 19, 2001, March 8, 2001, March 27, 2001, and April 11, 2001 (References 4, 5, 6, and7, respectively). The Pilgrim RI-ISI program was reviewed and approved by the NRC for use inthe third 10-year ISI interval in a letter dated May 2, 2001 (Reference 8). The licensee's submittal proposes to extend the same RI-ISI program, as submitted in Reference 3 from the third 10-year ISI interval, to the fourth 10-year ISI interval.

2.0REGULATORY EVALUATION

Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(g) specifies that inserviceinspection of nuclear power plant components shall be performed in accordance with the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). According to 10 CFR 50.55a(a)(3),

alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if(i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.The licensee's RI-ISI program, as outlined in References 3 through 7, was developed inaccordance with the methodology contained in the Electric Power Research Institute's (EPRI)

Report, EPRI TR-112657, Rev. B-A, (Reference 9, the topical) which was reviewed and approved by the NRC staff. The scope of the RI-ISI program is limited to the inspection ofASME Code Class 1 piping (Categories B-F and B-J welds).

3.0TECHNICAL EVALUATION

The licensee is requesting relief to use the proposed RI-ISI program plan in the fourth 10-yearISI interval instead of ASME Code,Section XI requirements for Class 1 piping (Categories B-F and B-J welds). An acceptable RI-ISI program plan is expected to meet the five key principles discussed inRegulatory Guide (RG) 1.178 (Reference 10), Standard Review Plan (SRP) 3.9.8 (Reference

11) and the EPRI TR-112657 (Reference 9), as stated below.1.The proposed change meets the current regulations unless it is explicitly related to arequested exemption or rule change.2.The proposed change is consistent with the defense-in-depth philosophy.

3.The proposed change maintains sufficient safety margins.

4.When proposed changes result in an increase in Core Damage Frequency (CDF) orrisk, the increases should be small and consistent with the intent of the Commission'sSafety Goal Policy Statement.5.The impact of the proposed change should be monitored by using performancemeasurement strategies.The first principle is met in this relief request because an alternative ISI program may beauthorized pursuant to 10 CFR 50.55a(3)(i) and therefore, an exemption request is notrequired. The second and third principles require assurance that the alternative program is consistentwith the defense-in-depth philosophy and that sufficient safety margins are maintained, respectively. Assurance that the second and third principles are met is based on the application of the approved methodology and not on the particular inspection locations selected.

As described in Reference 3 and approved by the NRC staff in Reference 8, the RI-ISI is aliving program that requires periodic updating and that, as a minimum, risk ranking of piping segments will be reviewed on an ASME period basis. The licensee indicates in References 1 and 2 that no changes in the number and location of inspections were required in accordance with the approved methodology in the topical. The NRC staff also reviewed Reference 13 toensure that the methodology used to develop the fourth 10-year RI-ISI interval program was unchanged from the methodology approved for use in the third 10-year RI-ISI interval program.

This information was confirmed by the licensee in a conference call held on September 20, 2006. Therefore, the second and third principles are met. The fourth principle requires an estimate of the change in risk, and the change in risk isdependent on the location of inspections in the proposed ISI program compared to the location of inspections that would be inspected using the requirements of ASME Code,Section XI. The topical provides that a change in risk measurement must consider the discontinuance of ASMECode required inspections, as well as any new inspections resulting from the application of its methodology. Although unlikely, it is possible that the number and/or locations of inspections mandated by the updated ASME Code of record could change if a revised ASME inspection program were to be developed for the new ASME Code of record for the fourth 10-year inspection interval. For example, the licensee states in the submittal that for the fourth intervalit plans to update its ASME Code of record from the 1989 Edition with no Addenda to 1998 Edition with the 2000 Addenda. The updated ASME Code of record, per section IWB-2500-1,reduces the exempted nominal pipe size (NPS) from 4" to 1", which would potentially result in an increase in the number of in-scope welds. However, in Reference 2, the licensee explains that, despite this apparent decrease in the number of welds exempted from ASME Class 1 scope, it had originally, and continues to use the exemption clause from IWB-1220(a), instead of IWB-2500-1 requirements. The application of this provision of the ASME Code results in no change to ASME Class 1 scope of welds from the third interval to the fourth interval.

Considering that estimates of the change in CDF and LERF are calculated in the final phase of the RI-ISI methodology, and are intended only to provide additional assurance that aggregatechanges in risk will be acceptable (Reference 9), the needed accuracy of the change in riskcalculations does not warrant developing a new risk informed program for the latest ASME Code of record simply to be used as a new baseline and then discarded. The licensee states in Reference 2 that all major issues and observations from the BoilingWater Reactors Owners Group (BWROG) Peer Review (i.e., Level A, B, and C observations) and weaknesses in the human reliability analysis area identified in the NRC safety evaluationhas been addressed and incorporated into the current probabilistic safety assessment m odelupdate used for this application, that individual probabilistic risk assessment (PRA) update workpackages were independently reviewed in-house, and that the updated PRA model was independently peer-reviewed. The licensee reports in Reference 1 that the RI-ISI programcontinues to meet EPRI TR-112657 and RG 1.174 risk acceptance criteria. Hence, no deviation from the risk acceptance criteria was identified. Given the above considerations concerning the new ASME Code of record requirements andthe PRA evaluation, the staff finds that the licensee's process provides assurance that thefourth key principle is met.In addition to monitoring industry experience, the licensee states in its relief request that thefourth 10-year RI-ISI interval program was updated in accordance with NEI-04-05, "Living Program Guidance To Maintain RI-ISI Programs For Nuclear Plant Piping Systems" (Reference 12), and thus continues to be a living program. Maintenance of a living program is also unaffected by the relocation of inspections and, therefore, the fifth key principle is met.Based on the above discussion, the NRC staff finds that the five key principles of risk-informeddecision making are ensured by the licensee's proposed fourth 10-year RI-ISI interval program plan, and therefore the proposed program for the fourth 10-year ISI inspection interval is acceptable.

3.0CONCLUSION

Based on the information provided in the licensee's submittals, the NRC staff has determinedthat the proposed alternative provides an acceptable level of quality and safety, and thereforethe proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i) for the fourth 10-yearISI interval at Pilgrim.

4.0REFERENCES

6.Letter from S.J. Bethay, Entergy Nuclear Operations, Inc. to U.S. Nuclear RegulatoryCommission, Pilgrim Fourth Ten-Year Inservice Inspection Program Plan, and theAssociated Relief Requests for NRC Approval, dated June 29, 2005. [ADAMSaccession number ML051920157]7.Letter from S.J. Bethay, Entergy Nuclear Operations, Inc. to U.S. Nuclear RegulatoryCommission, Response to NRC Request for Additional Information Regarding PilgrimRelief Request, PRR-10, Risk-Informed ISI for Class 1, B-F and B-J Welds (TAC NO.

MC8293), dated June 21, 2006. [ADAMS accession number ML061860086]8.Letter from J.F. Alexander, Entergy Nuclear Generation Company to U.S. NuclearRegulatory Commission, Pilgrim Risk-Informed Inservice Inspection Program , datedDecember 27, 2000. [ADAMS accession number ML010080122]9.Letter from J.F. Alexander, Entergy Nuclear Generation Company to U.S. NuclearRegulatory Commission, Additional Information Related to Pilgrim Risk-InformedInservice Inspection Program, dated January 19, 2001. [ADAMS accession numberML010300186]10.Letter from J.F. Alexander, Entergy Nuclear Generation Company to U.S. NuclearRegulatory Commission, Update to the Pilgrim Risk-Informed Inservice InspectionProgram, dated March 8, 2001. [ADAMS accession number ML010790228]11.Letter from J.F. Alexander, Entergy Nuclear Generation Company to U.S. NuclearRegulatory Commission, Clarification Concerning Pilgrim Risk-Informed InserviceInspection Program, dated March 27, 2001. [ADAMS accession number ML010930372]12.Letter from J.F. Alexander, Entergy Nuclear Generation Company to U.S. NuclearRegulatory Commission, Implementation of Interim Thermal Fatigue ManagementGuideline (MRP-24) for Pilgrim Risk-Informed Inservice Inspection Program , dated April 11, 2001. [ADAMS accession number ML011070578]13.Letter from U.S. Nuclear Regulatory Commission to M. Bellamy, Entergy NuclearGeneration Company, Pilgrim Nuclear Power Station - Relief Request RegardingApproval of Alternative Risk-informed Inservice Inspection Program for the Third Inspection Interval (TAC NO. MB0841), dated May 2, 2001. [ADAMS accession numberML011020131]14.EPRI TR-112657, Revision B-A, Revised Risk-Informed Inservice Inspection EvaluationProcedure, Final Report, December 1999.15.NRC Regulatory Guide 1.178, An Approach for Plant-Specific Risk-Informed DecisionMaking: Inservice Inspection of Piping, September 2003.16.NRC NUREG-0800, Chapter 3.9.8, Standard Review Plan for Trial Use for the Reviewof Risk-Informed Inservice Inspection of Piping, September 2003. 17.NEI 04-05, Living Program Guidance To Maintain Risk-Informed Inservice InspectionPrograms For Nuclear Plant Piping Systems, April 2004.18.EPRI - Pat O'Regan, Report # RISI-2, Pilgrim Nuclear Power Station Risk-InformedInservice Inspection (RI-ISI) Periodic Update Review, Revision B, August 30, 2004.Principal Contributors: M. Melnicoff A. KeimDate: September 28, 2006