Text

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

i Entergy Nuclear Operations, Inc.-r~lFP-fjv600 Rocky Hill RoadPlymouth. 02360March 11, 2016U.S. Nuclear Regulatory Commission Attn: Document Control DeskWashington, DC 20555-0001

SUBJECT:

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

REFERENCES:

1. BWRVIP-41, Rev.3, "BWR Jet Pump Assembly Inspection and FlawEvaluation Guidelines"

2. BWRVIP-76, Rev.l-A, "BWR Core Shroud Inspection and FlawEvaluation Guidelines"

3. BWRVIP-139-A, "BWR Steam Dryer Inspection and Flaw Evaluation Guidelines

4. BWRVIP-1 80, Rev.0, "BWR Access Hole Cover- Inspection and FlawEvaluation Guidelines"

5. BWRVIP-94NP, Rev.2, "BWR Program Implementation Guidelines"

6. U.S. Nuclear Regulatory Commission Letter to Entergy, Supplemental Safety Evaluation Report Related to the License Renewal of PilgrimNuclear Power Station (TAC No. MC9669),

June 30, 2011. (1.11.076)

LETTER NUMBER: 2.16.016

Dear Sir or Madam:

Entergy Nuclear Operations, Inc. hereby informs the NRC of specific deviations from theinspection guidelines described in BWRVIP-41, Rev.3 (Reference 1), BWRVIP-76, Rev.l-A(Reference 2), BWRVIP-1 39-A (Reference

3) and BWRVIP-1 80, Rev.0 (Reference

4) inaccordance with BWRVIP-94NP, Rev.2 (Reference

5) at Pilgrim Nuclear Power Station (PNPS).Reference 5 requires notification to the NRC anytime a utility does not implement any portion ofan applicable "mandatory"~

or "needed" BWR Vessel and Internals Project (BWRVIP) guideline that has been approved by the BWRVIP Executive Committee within 45 days of the utilityexecutive concurrence with the deviation disposition.

Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power StationLetter No. 2.16.016Page 2 of 2The deviations listed in Table 1 of the Attachment are all deviations from BWRVIP guidelines thatare classified as "needed" elements of the BWRVIP program.

The deviations are due toEntergy's recent announcement of plant closure, performance deficiencies with vendor ultrasonic testing tooling and plant configuration interferences to weld examinations.

Entergy announced in October 2015 that Pilgrim Nuclear Power Station will be permanently retired from active service not later than June 1, 2019.Table 1 lists the deviation from BWRVIP guidelines, the justification for the deviation and anyalternative actions in lieu of the BWRVIP requirements.

Table 1 also lists the Pilgrim StationLicense Renewal Commitment Number associated with the corresponding BWRVIP guidelines

document, if any (Reference 6).The deviations from the listed BWRVIP guidelines have been reviewed and approved inaccordance with Entergy procedures and NEI 03-08 guidance.

The deviations will remain ineffect until the end of cycle 22 (Spring 2019 when Pilgrim will cease commercial operation).

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

This is a notification of deviation only, and no action is being requested from the NRC.There are no regulatory commitments made in this letter.Sincerely, Everett P. Perkins, Jr.' 'Regulatory Assurance ManagerEPP/mw

Attachment:

TABLE I -Deviation Listingcc:Mr. Daniel H. DormanRegional Administrator, Region IU.S. Nuclear Regulatory Commission 2100 Renaissance Blvd., Suite 100King of Prussia, PA 19406-2713 Mr. Joseph HolonichNRC/NRR BWRVIP Project ManagerU.S. Nuclear Regulatory Commission Mail Stop 13 H10Washington, DC 20555Ms. Booma Venkataraman, Project ManagerOffice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8C2AWashington, DC 20555NRC Senior Resident Inspector Pilgrim Nuclear Power Station Attachment Letter Number 2.16.016TABLE 1 -Deviation Listing(4 Pages)

Entergy Nuciear Operations, Inc.Pilgrim Nuclear Power StationAttachment to 2.16.016Page 1 of 4TABLE 1 -Deviation ListingBWRVIP Deviation from Justification for Deviation Alternative Actions /Guidelines BWRVIP Guidelines License RenewalDocument Regulatory Commitment No.,___________________________________

BWRVIP-41, Rev.3Pilgrim Station isrequired to re-inspect all jet pump (JP) beamBB-1 and BB-2 regionsby UT methods by2017; a 10-year re-inspection frequency (There are a total of 20JPs).Instead, Pilgrim plansto perform an EVT-1visual examination ofall beams during the2017 (RFO21) lastplanned refuel outagein lieu of UT re-inspection examination required by BWRVIP-41, Rev.3, Table 2-4.Pilgrim replaced all 20 original JP beams with the improved Group 2beams in 1984 and has subsequently examined all beams by UTmethod per BWRVIP guidelines without any relevant indications.

TheBWRVIP 10-year re-inspection frequency is based on a normalwater chemistry environment.

However, Pilgrim's superior waterchemistry environment should be conducive to a longer re-inspection

interval, i.e., no-less than a 12-year interval ending in 2019 when theplant will be retired from active service.The alternative proposed examination of all 20 beams in 2017will provide additional assurance that sufficient structural integrity exists to justify an additional cycle of operation to 2019. Thisalternative method is appropriate as the EVT-1 method has thecapability to detect lntergranular Stress Corrosion Cracking (IGSCC)initiating from visible areas of the top surface and IGSCC is the onlyknown significant degradation mechanism associated with JPbeams.Pilgrim plans to perform anEVT-1 visual examination ofall 20 beams during the 2017(RFO21) refuel outage in lieuof UT re-inspection examination required byBWRVIP-41, Rev.3, Table 2-4.There are no LicenseRenewal Commitments forinspection of jet pumpbeams.Upon BWRVIP approval, thisdeviation disposition constitutes an approvedplant-specific application ofthe BWRVIP guidelines.

Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power StationAttachment to 2.16.016Page 2 of 4TABLE I -Deviation ListingBWRVIP TDeviation from 1Justification for Deviation Alternative Actions/Guidelines BWRVIP Guidelines License RenewalDocument Regulatory Commitment No. j __ _____ __BWRVI P-76,Rev. 1 -APilgrim is required tore-inspect core shroudbeltline vertical weldsV15, V16, V17 and V18by either a UTvolumetric or two-sided EVT-1 visualexamination method by2017.The deviation is a one-time two-yearextension over the 10-year re-inspection interval for the UTinspection strategy ofthe core shroud beltlinevertical welds V15,V16, V17 and V18 asrequired by BWRVIP-76, Rev.l-A, Figure 3-3. The two yearextension is from 2017to 2019, when Pilgrimplans to ceaseoperations.

Pilgrim is a BWR-3 with a repaired Category C core shroud. Theplant installed a pre-emptive shroud repair in 1995 to structurally replace shroud horizontal welds HI through H10. The repair consistsof four tie-rods installed at azimuths 450, 1350, 2250 and 3150 whichcoincide with azimuthal locations of shroud vertical welds V1 5, Vi16,V17 and V18. These tie-rod locations completely prevent inspection access to the welds from the shroud exterior surface and wouldrequire peripheral fuel removal for interior access.Pilgrim has an extensive history of shroud inspections with norelevant indications by visual or UT methods.

The four vertical weldsV1 5, Vi16, V1 7 and VI18 were last inspected in 2007 with a fullvolumetric UT method from the shroud interior surface achieving

>90% coverage of all four welds with no relevant indications noted.These shroud welds are fully mitigated by Hydrogen WaterChemistry (HWC) and Noble Metals Chemical Addition (NMCA) toprevent or reduce the effects of IGSCC.Fleet operating experience shows "very little vertical weld crackinghas occurred within the U.S. fleet" as stated in BWRVIP-278, Section5.3.2.Pilgrim performed plant-specific calculations in accordance withBWRVIP guidelines and conservatively concluded that the 20%extension over the 10-year inspection interval is structurally acceptable to justify an additional cycle of operation.

Pilgrim performed plant-specific calculations inaccordance with BWRVIPguidelines andconservatively concluded that the one-time 20%extension over the 10-yearinspection interval isstructurally acceptable tojustify an additional cycle ofoperation.

There are no LicenseRenewal Commitments forinspection of core shroudwelds.Upon BWRVIP approval, thisdeviation disposition constitutes an approvedplant-specific application ofthe BWRVIP guidelines.

/Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power StationTABLE 1 -Deviation ListingAttachment to 2.16.016Page 3 of 4BWRVIP Deviation from Justification for Deviation Alternative Actions /Guidelines BWRVIP Guidelines License RenewalDocument Regulatory Commitment No.7BWRVIP-1 39- Pilgrim is required to Pilgrim has complied with the inspection requirements of BWRVIP- Pilgrim plans to visuallyA re-inspect steam dryer 139-A and previously with GE SIL No.644. PNPS recently examine tie-bars

6, #7 andinterior key locations completed the re-inspection of exterior dryer locations required by #8 ini 2017 (RFO21).and a 10% sampling of BWRVIP-1 39-A in 2015. The Pilgrim steam dryer is a non-safety-other dryer interior related component with no history of significant structural License Renewalwelds every 10 years degradation.

Seven of a total ten tie-bars were structurally replaced Commitment No.37 (TAOas detailed in BWRVIP- in 2005 per BWRVIP-1 81-A repair guidelines.

The interior structure No. MC9669)139-A, Section 5.3.4(D) of the square hood dryer configuration does not have diagonalby the visual VT-1(89) bracings and interior brackets that have caused high stress This is a one-time action.method by 2017. concentrations in some dryer designs.

Inspection of this component

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

However, one new the BWRVIP guidelines.

interval for selected indication was identified in 2015 when original tie-bar #8 was foundinterior locations from to be partially cracked.

Tie-bar #8 will be re-inspected (and re-10 to 12 years (2017 to evaluated) in 2017 along with adjacent tie-bars

6 and #7. An2019, when Pilgrim evaluation confirmed that tie-bar #8 does not present a loose-parts plans to cease concern.

The structural integrity of the dryer is monitored byoperations).

Chemistry during power operations via moisture carryover analysisin accordance with Entergy fleet and plarnt procedures.

Based onmoisture carryover trends since 2005, there has been no indication of a reduction in the structural integrity of the steam dryer. Pilgrimhas not installed a power uprate other than a thermal power uprate.It is therefore reasonable to conclude that the alternative plans to re-examine tie-bars

6, #7 and #8 in 2017, will provide sufficient assurance to maintain the structural integrity of the dryer for anadditional cycle of operation to 2019.

Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power StationAttachment to 2.16.016Page 4 of 4TABLE 1 -Deviation ListingBWRVIP Deviation from Justification for Deviation Alternative Actions /Guidelines BWRVIP Guidelines License RenewalDocument Regulatory Commitment No.BWRVIP-1 80, Pilgrim is required to Pilgrim has an extensive inspection history regarding the AH~s with Pilgrim plans to perform anRev.0 complete a UT no service-induced recordable indications since the first UT EVTI-1 visual examination ofbaseline examination examination in RFO8 (1991). The similarly constructed AHC weld at the 180 degree AHC in 2017of the access hole azimuth 0° was recently examined with UT in RFO2O (2015) with (RFO2I).cover (AHC) weld at 100% coverage achieved and no service-induced relevant1800 by 2017. Pilgrim_

indications.

License Renewalsuccessfully completed Commitment No.34 (TAOthe baseline UT of the The BWRVIP-180 inspection guidelines allow use of the EVT-1 No. MC9669)00 AHC in 2015 but examination method until such time as a UT technique isdeferred examination demonstrated and documented by the BWRVIP. The UT technique This is a one-time action.of the 1800 cover to the was demonstrated by EPRI/GEH

however, the UT tooling used at2017 refuel outage due Pilgrim Station in RFO2O lacked reliability as it could only examine Upon BWRVIP approval, thisto adverse inspection the AHC at the 00 but not at the 1800 side as planned.

The AHC deviation disposition tooling issues which design at Pilgrim Station is unique to the industry consisting of an constitutes an approvedprevented completion "intermediate" thickness configuration that required a hybrid plant-specific application ofof the baseline combination of "thin" and "thick" mockups for the EPRI/GEH the BWRVIP guidelines.

examination of the demonstration.

1800 AHC in 2015.The AHC welds are highly flaw tolerant.

Only a small percentage ofInstead, Pilgrim plans the AHC 3600 circumferential seal weld is required to maintain ato perform an EV-I-1 leak-tight barrier.

There are no known industry operating experience visual examination of reports of cracking in AHCs since the BWR fleet implemented the 1800 AHC in 2017, improved water chemistry.

The AH~s at Pilgrim Station arein lieu of UT mitigated by HWC and NMCA.examination requiredby BWRVIP-1 80, The planned EVT-1 alternative method is appropriate as the EVT-1Rev.0, Section 9.1. method has the capability to detect IGSCC initiating from visibleareas of the AHC top surface and IGSCC is the only known____________________________

degradation mechanism for this weld._____________