ML18270A451
| ML18270A451 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/27/2018 |
| From: | Edison Fernandez NRC/RGN-III/DRS/EB1 |
| To: | Arnone C Entergy Nuclear Operations |
| References | |
| IR 2018004 | |
| Download: ML18270A451 (9) | |
See also: IR 05000255/2018004
Text
September 27, 2018
Mr. Charles Arnone
Vice President, Operations
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant
27780 Blue Star Memorial Highway
Covert, MI 49043-9530
SUBJECT: PALISADES NUCLEAR PLANTNOTIFICATION OF NRC BASELINE
INSPECTION AND REQUEST FOR INFORMATION; INSPECTION
REPORT 05000255/2018004
Dear Mr. Arnone:
On October 29, 2018, the U.S. Nuclear Regulatory Commission (NRC) will begin the Baseline
Inservice Inspection Procedure 71111.08. This onsite inspection is scheduled to be performed
October 29, 2018, through November 9, 2018.
Experience has shown that this inspection is resource intensive both for the NRC inspector and
your staff. In order to minimize the impact to your onsite resources, and to ensure a productive
inspection for both sides, we have enclosed a request for documents needed for this inspection.
These documents have been divided into two groups.
The first group identifies information necessary to ensure that the inspector is adequately
prepared. The second group identifies the information the inspector will need upon arrival at
the site. It is important that all of these documents are up-to-date, and complete, in order to
minimize the number of additional documents requested during the preparation and/or the
onsite portions of the inspection.
We have discussed the schedule for inspection activities with your staff and understand that
our regulatory contact for this inspection will be Ms. B. Dotson, of your organization. If there are
any questions about this inspection or the material requested, please contact the lead inspector
Mr. E. Fernandez at 630-829-9754 or via e-mail at Edison.Fernandez@nrc.gov.
This letter does not contain new or amended information collection requirements subject
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information
collection requirements were approved by the Office of Management and Budget, Control
Number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to
respond to, a request for information or an information collection requirement unless the
requesting document displays a currently valid Office of Management and Budget Control
Number.
C. Arnone -2-
This letter and its enclosure will be made available for public inspection and copying at
http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in
accordance with Title 10 of the Code of Federal Regulations, Part 2.390, Public Inspections,
Exemptions, Requests for Withholding.
Sincerely,
/RA Vijay Meghani Acting for/
Edison Fernandez, Reactor Inspector
Engineering Branch 1
Division of Reactor Safety
Docket No. 50-255
License No. DPR-20
Enclosure:
Document Request for Baseline Inservice
Inspection
cc: Distribution via LISTSERV
C. Arnone -3-
Letter to Charles Arnone from Edison Fernandez dated September 27, 2018.
SUBJECT: PALISADES NUCLEAR PLANTNOTIFICATION OF NRC BASELINE
INSPECTION AND REQUEST FOR INFORMATION; INSPECTION
REPORT 05000255/2018004
DISTRIBUTION:
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ADAMS Accession Number: ML18270A450
OFFICE RIII
NAME EFernandez:cl
DATE 09/27/18
OFFICIAL RECORD COPY
DOCUMENT REQUEST FOR BASELINE INSERVICE INSPECTION
Inspection Report: 05000255/2018004
Inspection Dates: October 29, 2018, through November 9, 2018
Inspection Procedure: Inspection Procedure 71111-08, Inservice Inspection
Lead Inspector: Edison Fernandez, DRS
630-829-9754
Edison.Fernandez@nrc.gov
A. Information for the In-Office Preparation Week
The following information is requested as an (electronic copy CD ROM if possible) by
October 15, 2018, to facilitate the selection of specific items that will be reviewed during
the onsite inspection week. The inspector will select specific items from the information
requested below and a list of additional documents needed onsite from your staff. We
request that the specific items selected from the lists be available and ready for review
on the first day of inspection. If you have any questions regarding this information,
please call the inspector as soon as possible.
1. For the upcoming outage, a detailed schedule and description of:
a. Non-Destructive Examinations (NDEs) planned for Class 1 and 2 Systems
and containment, performed as part of your American Society of Mechanical
Engineers (ASME) Code Inservice Inspection (ISI) Program (include edition
and addenda of Code committed to), and NDEs planned for other systems
performed as part of a Risk-Informed-ISI Program, or other augmented
inspection programs (e.g., ASME Code Case N-770-1 examination of dissimilar
metal welds and examinations to meet an industry initiative). For each weld
examination, include the weld identification number, description of weld
(component name), category, class, type of exam and procedure number,
and date of examination;
b. Reactor vessel upper head examinations required by Title 10 of the Code of
Federal Regulations (CFR), Part 50.55a(g)(6)(ii)(D) and Code Case N-729-1;
c. Steam generator (SG) tube inspection and repair activities for the upcoming
outage or SG secondary side examinations1;
d. Welding on Code Class 1, 2, or 3 components (including contingency repair
welding for dissimilar metal welds); and
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Note 1- If no SG examinations are planned for this outage, please confirm when the next SG examination will occur
and no further information is required for the items identified above requesting SG related information.
Enclosure
DOCUMENT REQUEST FOR BASELINE INSERVICE INSPECTION
e. Inspections required under Nuclear Energy Institute 03-08 such as MRP 227,
146, 192 or other Mandatory, Needed or Good Practice requirements under
the material initiative.
2. A copy of the NDE procedures and welding procedures used to perform the activities
identified in Item A.1 (including NDE calibration and flaw characterization/sizing
procedures and Welding Procedure Qualification Records). For ultrasonic
examination procedures qualified in accordance with Appendix VIII, of Section XI of
the ASME Code, provide documentation supporting the procedure qualification
(e.g., the Electric Power Research Institute (EPRI) performance demonstration
qualification summary sheets).
3. A copy of ASME Section XI, Code Relief Requests applicable to the examinations
identified in Item A.1. This would include the NRC-approved Relief Request for
implementing a risk-informed ISI Program (if applicable).
4. A copy of the 10-year ISI Program showing those required exams scheduled to be
performed this outage, and those which have been completed.
5. A list identifying NDE reports (ultrasonic, radiography, magnetic particle, or dye
penetrant), which have identified relevant indications on Code Class 1 and 2
Systems since the beginning of the last refueling outage.
6. List with short description of the welds in Code Class 1 and 2 Systems, which have
been fabricated due to component repair/replacement activities since the beginning
of the last refueling outage and identify the system, weld number, and reference
applicable documentation (e.g., NIS-2 forms with definitions of system and
component acronyms).
7. If reactor vessel weld examinations required by the ASME Code are scheduled to
occur during the inspection period, provide a detailed description of the welds to be
examined, and the extent of the planned examination.
8. List with description of ISI and SG-related issues such as piping or SG tube
degradation or damage (e.g., cracks, wall thinning, wear, MIC) or errors identified
during piping/SG tube examinations that have been entered into your corrective
action system since the beginning of the last refueling outage. Also, include a list of
corrective action records associated with foreign material introduced/identified in the
reactor vessel, primary coolant system, SG or feed systems since the beginning of
the last refueling outage.
9. Copy of any 10 CFR Part 21 reports applicable to your structures systems or
components within the scope of Section XI of the ASME Code that have been
identified since the beginning of the last refueling outage.
10. Copy of SG history documentation given to vendors performing eddy current (ET)
testing of the SGs during the upcoming outage.
11. Copy of procedure containing screening criteria used for selecting tubes for in-situ
pressure testing and the procedure to be used for in-situ pressure testing.
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DOCUMENT REQUEST FOR BASELINE INSERVICE INSPECTION
12. Copy of previous outage SG tube operational assessment completed following ET of
the SGs (provide this document even if no SG ET is planned for current outage).
13. Copy of most recent SG Degradation Assessment (provide this document even if no
SG ET is planned for current outage).
14. Copy of most recent SG Condition Monitoring Assessments.
15. Copy of the document defining the planned SG ET scope (e.g., 100 percent of
unrepaired tubes with bobbin probe and 20 percent sample of hot leg expansion
transition regions with rotating probe) and identify the scope expansion criteria,
which will be applied. Also identify and describe any deviations in this scope or
expansion criteria from the EPRI Guidelines.
16. Copy of the document describing the ET acquisition equipment to be applied
including ET probe types. Also identify the extent of planned tube examination
coverage with each probe type (e.g., rotating probe - 0.080 inches, 0.115 inches
pancake coils and mid-range + point coil applied at the top-of-tube-sheet plus
3 inches to minus 12 inches).
17. Provide procedures with guidance/instructions for identifying (e.g., physically locating
the tubes that require repair) and plugging SG tubes.
18. Identify and quantify any SG tube leakage experienced during the previous operating
cycle. Also provide documentation identifying which SG was leaking and corrective
actions completed or planned for this condition.
19. Copy of current calculations for EDY, and RIY as defined in Code Case N-729-1 that
establish the volumetric and visual examination frequency for the reactor vessel
head and J-groove welds.
20. Point of contact information (name and site number) for the following activities:
a. ISI-Site and vendor leads;
b. Boric Acid Inspections and Evaluations;
c. Reactor Vessel Head Inspection-Site and vendor leads;
d. SG Inspection-Site and vendor leads;
e. NEI 03-08 Program Owner.
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DOCUMENT REQUEST FOR BASELINE INSERVICE INSPECTION
B. Onsite Information to be Provided to the Inspector on the First Day of the
Inspection (e.g., Following the Entrance Meeting). Please Provide Hard Copies
(e.g., Paper Records) of the Following Documents.
1. For welds selected by the inspector from Item A.1.d and A.6 above, provide copies of
the following documents:
a. Document of the weld number and location (e.g., system, train, branch);
b. Document with a detail of the weld construction (e.g., drawing);
c. Applicable portions of the Design Specification and applicable Code of
construction for the weldment (e.g., B31.1 or ASME Section III);
d. Applicable Code Edition and Addenda for weld procedure qualification;
e. Applicable weld procedures and weld data sheets used to fabricate the welds;
f. Copies of procedure qualification records supporting the weld procedures;
g. Copies of welders performance qualification records;
h. Copies of mechanical test reports identified in the procedure qualification
records above;
i. Copies of the nonconformance reports for the selected welds;
j. Access to radiographs and equipment to view radiographs of the selected welds;
k. ASME Code Section XI repair replacement plan and reconciliation for
replacement components/materials;
l. Certified Material Test Reports for replacement pressure boundary materials; and
m. Copies of the nondestructive examinations required by the construction Code
and the pre-service examination records required by the ASME Code Section XI
for the selected welds.
2. For the ISI-related corrective action issues selected by the inspector from Item A.8
above, provide a copy of the corrective actions and supporting documentation.
3. For the NDE reports with relevant indications on Code Class 1 and 2 Systems
selected by the inspector from Item A.5 above, provide a copy of the examination
records and associated corrective action documents. Updated schedules for
Item A.1 (including schedule showing contingency repair plans if available).
4. Copy of the procedures which govern the scope, equipment used, and
implementation of the inspections required to identify boric acid leakage
from systems and components above the vessel head.
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DOCUMENT REQUEST FOR BASELINE INSERVICE INSPECTION
5. Copy of:
a. Engineering evaluations/assessments of boric acid related deposits and
associated wastage or corrosion for safety significant components; and
b. Corrective action records for coolant leakage including boric acid deposits on
safety-related components identified since the beginning of the last refueling
outage.
6. Copy of the plant procedures used to perform inspections to identify reactor coolant
system leaks or boric acid deposits and the procedures for resolution of leaks or
boric acid deposits.
7. Fabrication Drawings (D size) of the reactor vessel welds (including vessel head
J-groove welds) if any are to be examined during the outage. Also provide any
drawings used by NDE vendors to locate these welds.
8. Copy of the documents which demonstrate that the procedures to be used for
volumetric examination of the reactor vessel head penetration J-groove welds were
qualified by a blind demonstration test in accordance with 10 CFR 50.55a(g)(6)(ii)(D).
9. Copy of volumetric, surface and visual examination records for the prior inspection of
the reactor vessel head and head penetration J-groove welds.
10. Provide a copy of the EPRI Examination Technique Specification Sheets and vendor
Examination Technique Specification Sheets-related documents, which support
qualification of the ET probes to be used during the upcoming SG tube inspections1.
11. Provide a copy of the guidance to be followed if a loose part or foreign material is
identified in the SGs1.
12. Identify the types of SG tube repair processes which will be implemented for
defective SG tubes (including any NRC reviews/evaluation/approval of this repair
process). Provide the flaw depth sizing criteria to be applied for ET indications
identified in the SG tubes1.
13. Copy of document describing actions to be taken if a new SG tube degradation
mechanism is identified1.
14. Provide document which defines the scope of SG secondary side examinations (if
any are planned) and identify site specific operational history related to degradation
of SG secondary side components (if any).
15. Provide procedures with guidance/instructions for identifying (e.g., physically locating
the tubes that require repair) and plugging SG tubes1.
1 Note 1- If no SG examinations are planned for this outage, please confirm when the next SG examination will occur
and no further information is required for the items identified above requesting SG related information.
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DOCUMENT REQUEST FOR BASELINE INSERVICE INSPECTION
16. Provide copies of the following standards at the on-site NRC inspection location for
the duration of the inspection:
a. Sections V, IX, and XI of the ASME Code with Editions applicable to the
ISI Program and the Repair/Replacement Program;
b. Copy of the performance demonstration initiative (PDI) generic procedures
with the latest applicable revisions that support site-qualified ultrasonic
examination of piping welds and components (e.g., PDI-UT-1, PDI-UT-2,
PDI-UT-3, PDI-UT-10 etc.);
c. EPRI and industry standards referenced in the site procedures used to
perform the SG tube eddy current examination, which includes EPRI
documents: TR-107621-R1, Steam Generator Integrity Assessment Guidelines,
TR-107620-R1, Steam Generator In-Situ Pressure Test Guidelines, Steam
Generator Management Program: Steam Generator Integrity Assessment
Guidelines, Part 10, and 1003138, Pressurized Water Reactor Steam Generator
Examination Guidelines1; and
d. Boric Acid Corrosion Guidebook Revision 2 - EPRI Technical Report 1000975.
17. Provide training (e.g., Scaffolding, Fall Protection, FME) if required to access the
NDEs selected by the inspector for observation.
If you have questions regarding the information requested, please contact the lead inspector
6