PNP 2015-089, Inservice Inspection Master Program Fifth 10-Year Interval
| ML15343A090 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/09/2015 |
| From: | Hardy J Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CAC MF6162, PNP 2015-089 | |
| Download: ML15343A090 (127) | |
Text
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Enterg)f Jeffery A. Hardy Regulatory Assurance Manager PNP 201 5-089 December 09, 2015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Inservice Inspection Master Program Fifth 10-year Interval Palisades Nuclear Plant Docket 50-255 Renewed Facility Operating License No. DPR-20
References:
1.
Entergy Nuclear Operations, Inc. leffer to NRC, PNP 2015-022, Relief Request Number RR 5-1, Proposed Alternative, Extend the Current ASME Code of Record into the Fifth 10-year IS! Interval for ISI Related Activities, dated April 29, 2015 (ADAMS Accession Number ML15119A223) 2.
NRC letter to Entergy Nuclear Operations, Inc., Palisades Nuclear Plant
Relief Request Number 5-1, Proposed Alternative, Extend the Current ASME Code of Record into the Fifth 10-year ISI Interval for ISl Related Activities (CAC No. MF6162), dated November 25, 2015 (ADAMS Accession No. ML15320A244)
Dear Sir or Madam:
Pursuant to 10 CFR 50.55a, Codes and Standards, Entergy Nuclear Operations, Inc. (ENO) hereby submits the enclosed Palisades Nuclear Plants (PNP) inservice inspection (ISI) master program for the fifth 10-year interval, which begins on December 13, 2015.
Pursuant to 10 CFR 50.55a(g), Insert/ice inspection requirements, as conditioned by 10 CFR 50.55a(b), Use and conditions on the use of standards, PNPs plan will comply with the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code,Section XI, 2007 Edition through the 2008 Addenda as altered by 10 CFR 50.55a(z),
Alternatives to codes and standards requirements.
In Reference 1, PNP proposed an alternative, relief request RR 5-1, to maintain repair/replacement (R/R), pressure testing (PT), and nondestructive examination (NDE) activities to the fourth 10-year inspection intervals ASME BPV,Section XI, 2001 Edition through 2003 Addenda requirements for the first period of the fifth 10-year interval through December 31, 2017. This was requested to align RIR, PT, and NDE for all Entergy units to the same code of record. The NRC authorized the use of relief request RR 5-1 on November 25, 2015 (Reference 2).
This letter contains no new commitments and no revised commitments.
PNP 201 5-089 Page 2 of 2 Sincerely, JAH/jpm
Enclosure:
Entergy Nuclear Operations, Inc., Palisades Nuclear Plant, Palisades Inservice Inspection Master Program Fifth Interval, ASME Section XI, Division 1 cc:
Administrator, Region III, USNRC Project Manager, Palisades, USN RC Resident Inspector, Palisades, USNRC
ENCLOSURE ENTERGY NUCLEAR OPERATIONS, INC.
PALISADES NUCLEAR PLANT Palisades Inservice Inspection Master Program Fifth Interval, ASME Section XI, Division 1 124 pages follow
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I of 124 PROGRAM SECTION FOR PALISADES INSERVICE INSPECTION MASTER PROGRAM FIFTH INTERVAL, ASME SECTION XI, DIVISION I ENTERGY NUCLEAR ENGINEERING PROGRAMS APPLICABLE SITES ALL SITES: LI Specific Sites:
LIANI LIAN2 LJCNS LIGGN LJIP2 LJIP3 LIJAF LIPLP LIPNP LIRBS LIVTY LIWF3 LIHQN Safety Related:
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2of 124 REVIEW AND CONCURRENCE SHEET Program Section
Title:
ASME SECTION Xl, DIVISION 1, PALISADES INSERVICE INSPECTION PROGRAM Prepared By:
Gary Katt Date:
12/7/15 Checked By:
Keith Schultz Date:
ANII:
CorderoSoto, Date:
1 Z//is Concurred:
Joe Jerz Date: Iz//i5 ResfiibIe isor
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3 of 124 REVISION STATUS SHEET REVISION
SUMMARY
REVISION ISSUE DATE DESCRIPTION 0
Initial Revision Issued For Use. SEP-ISl-PLP-003 replaces Palisades Fourth Ten-Year Interval Inservice Inspection Plan, MERLIN Document No. GENRECS PLP-ISI-20.
Incorporated Risk Informed ISI (RI-ISI) in accordance with ASME Code Case N-716-1 Alternative Classification and Examination Requirements Section Xl, Division 1 Revised the program section to incorporate various outstanding changes.
A summary of changes is included as part of the review package for EC56288 providing details on all of the changes made.
2 9/18/15 Revised section 5.1.5 and 7.3.4 to remove the surface examination requirement for the Augmented Program ORM 4.12 welds. ORM 4.12-1 only requires volumetric examination.
3 12/13/15 Revised the program section in its entirety to reflect the program update to the fifth ISl interval which includes updating the program to the requirements of the American Society of Mechanical Engineers (ASME)
Boiler and Pressure Vessel Code, Section Xl, 2007 Edition through 2008 Addenda.
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4of 124 SEP-ISI-PLP-003 R3 PAGE REVISION STATUS Section Page No.
Revision Main Body All 3
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5of 124 TABLE OF CONTENTS Section Description Page REVISION
SUMMARY
3 1.0 ASME Section XI Inservice Inspection Program 7
1.1 Purpose 7
1.2 General 9
1.3 Inspection Intervals 13 1.4 ASME Section Xl Code of Record for Fifth Inservice Inspection Interval 16 1.5 ASME Section XI Inservice Inspection Program Description 18 1.6 Administrative Controls 26 2.0 ASME Section Xl Code Case Applicability 27 2.1 Adoption of Code Cases 27 2.2 Regulatory Guide 1.147, Revision 17, Approved Code Cases 29 2.3 Code Cases Approved through Request for Alternatives 32 2.4 Code Cases Required by 10 CFR 50.55a 32 3.0 Relief Requests 34 3.1 Request for Alternatives 34 3.2 Relief Request Required due to Impracticality or Limited Examinations 35 3.3 Requests to use Later Edition and Addenda of ASME Section Xl 35 4.0 Developmental References 37 4.1 External References 37 4.2 Entergy Fleet References 37 4.3 Palisades Site References 37 5.0 Augmented, Owner Elected, Alloy 600, and Renewed License Inservice Inspection Requirements 39 5.1 Augmented Examination Programs 39 5.2 Owner Elected Examinations for Internal Commitments 49 5.3 Alloy 600 Program 51 5.4 License Renewal Examinations for Aging Management Commitments..62 6.0 ASME Systems & Examination Boundaries 65 6.1 Definitions 65 6.2 Classification Criteria 65 6.3 Inspection Rules 65 6.4 Quality Group Classification 66 6.5 Identification 66
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6 of 124 7.0 Application Criteria and Code Compliance 70 7.1 ASME Section Xl 70 7.2 Augmented Program 84 7.3 Owner Elected Program 86 7.4 Code Category Summary 87 8.0 Inservice Inspection Data Management Software 115 8.1 Description 115 8.2 Control 115 8.3 Suite 115 8.4 Version 9 of the IDDEAL Software Suite 115 8.5 Data 116 9.0 Examination Evaluation Criteria 117 9.1 Successive Inspections 117 9.2 Additional Examinations 119 10.0 Risk-Informed lSl Program 123 10.1 Reactor Vessel Inspections 123 10.2 ASME Section Xl Code Case N-716-1 Implementation 123
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7 of 124 1.0 ASME Section XI Inservice Inspection Program 1
1.1 Purpose This programs objective is to provide a traceable link between the governing requirements of 10 CFR 50.55a, ASME Section Xl, and applicable commitments; and, the implementing procedures in order to ensure the Regulatory rules and ASME Section XI Code requirements for the Inservice Inspection of Nuclear Power Plant Components (ISI) are being fulfilled.
These instructions provide the necessary guidance for the Corporate & Station Engineering Programs personnel at Entergys Palisades Nuclear Plant (Palisades) to ensure the following:
1)
Conformance to Code of Federal Regulations, Title 10, Section 50.55a Codes and Standards (10 CFR 50.55a).
2)
Conformance to American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl, 2007 Edition through 2008 Addenda. (Commonly referenced in this document as ASME Section Xl Code or ASME Section Xl (2007/2008).)
3)
Conformance to Entergy Corporation and Station policies, practices and procedures.
4)
Inclusion of necessary technical content in the Palisades lSl Program and implementing procedures.
5)
Implementation of the proper ASME Section XI Code required examinations, tests and administrative procedures.
6)
Submittal to and approval by the regulatory authority, of the proper ASME Section Xl Code requests for alternatives and relief requests.
7)
Performance of component repair and replacement activities in accordance with ASME Section Xl Code requirements.
8)
Maintenance and submittal of the proper examination, test and repair and replacement records and reports.
Figure 1 shows how this program effectively functions as a central source to help ensure all regulatory rules and Palisades requirements are incorporated into the ISI Program. This program provides a useful aid in program self-assessments, procedure preparation and/or revision, management quick reference, and program familiarization.
1 The term program is used to provide the structure and methods for accomplishment of the objectives of 10 CFR 50.55a.
It is considered synonymous with the tern, program as used in ASME Section Xl (2007/2008), Article IWA-2400, which includes both the use of the term plan as used in IWA-2420 and IWA-2425, and the more restrictive use of the term uprogram as used in IWA-2431.
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8of 124 ASME Code Figure 1 Section Xl (2007/2008)
-H Examination
[**
Method Section III (as applicable)
Visual Inspection ANSI Program Specifications Code of Inservice Federal Regulations Inspection Procedures F
Implement Nuclear I
Regulato I
Title 10 Part Plant Technical Program H
Surveillance Inspections Specifications 50.55a 5.5.6, 5.5.7 Specifications Commission F
Regulato r
Final Safety H
Testing Guides Analysis Report
1.14 1.26 1.6 Administrative Procedures 1.84 1.147 Alternatives, 1.193 Relief Requests 1.200 Limitedination}
Compliance Records & Reports
[izecIea_
lnservice Inspector
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9 of 124 1.2 General The Palisades Fifth Interval 1St Program is established in accordance with Title 10 Code of Federal Regulations Part 50.55a (10 CFR 50.55a). This program has been developed to comply with the American Society of Mechanical Engineers (ASME)Section XI, Rules for lnservice Inspection of Nuclear Power Plant Components, 2007 Edition through 2008 Addenda, and implements the requirements of Final Safety Analysis Report (FSAR) 1.6, Inservice Inspection Program.
The Palisades nuclear power plant was built in the late 1960s and was placed into commercial operation on December 31, 1971. The Nuclear Steam Supply System (NSSS) was furnished by Combustion Engineering. The Architect Engineer for Palisades during construction was Bechtel Corporation.
During the first 40-month life of the plant, in order to comply with paragraphs 4.3 and 4.12 of the previous technical specifications (dated September 1, 1972) of the Palisades operating license DPR-20, which discusses ISI requirements of class 1 components and systems, nondestructive examinations were performed to satisfy the requirements of the ASME Section XI
- Code, 1971 edition including winter 1972 addenda.
In February 1976, the NRC amended paragraph 55a(g) of 10 CFR 50 to require nuclear plants to upgrade their technical specifications in the areas of 151 requirements and functional testing of pumps and valves. By amending paragraph 55a(g) and by invoking Regulatory Guide 1.26, the NRC required nuclear plants to upgrade their systems to include not only class 1 systems, but also class 2 and class 3 systems in their ISI programs.
The Palisades nuclear power plant has been owned and operated over time by different companies and under different company names including Consumers Power Company (CPCo),
Consumers
- Energy, Nuclear Management Company (NMC),
and Entergy.
As a
- result, commitments and other documentation include different corporate names.
Commitments made under different names continue to apply, unless they have been withdrawn.
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10 of 124 1.2.1 Abbreviations and Acronyms The following terms are used in the ASME Section Xl Code ISI program.
Note:
Risk informed abbreviations are included for reference to former risk informed program in effect during the latter portion of the Third Interval.
2001/2003 ASME B&PV Code,Section XI, 2001 Edition through 2003 Addenda 2007/2008 ASME B&PV Code, Section Xl, 2007 Edition through 2008 Addenda A600 Alloy 600 (also called Alloy 600/82/1 82, bimetallic, Ni-Cr-Fe, or SB-166)
AF-Sl Auxiliary Feedwater Structural Integrity AFW Auxiliary Feedwater (ref. Risk Informed)
AL-600 Alloy 600 Project ANII Authorized Nuclear Inservice Inspector ANSI American National Standards Institute ARH Auxiliary Return Header ASH Auxiliary Supply Header ASME American Society of Mechanical Engineers ASTM ASTM International, formerly American Society for Testing and Materials AWS Auxiliary Water System B&PV Boiler and Pressure Vessel BLD Blowdown (ref. Risk Informed)
BMV Bare Metal Visual Examination BWR Boiling Water Reactor CCS Component Cooling System CDS Condensate System (ref. Risk Informed)
CEP Common Engineering Program Section CHL Charging Line CHP Charging High Pressure CHX Cooling Heat Exchanger CMU Condensate Makeup CPU Component Cooling Pump CPL Cavity Pool Line CR Condition Report CRD Control Rod Drive CRS Containment Air Cooling CSH Containment Supply Header CSS Containment Spray System CST Condensate Storage Tank
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11 of 124 CSW Critical Service Water CVC Chemical and Volume Control CWR Clean Waste Receiver CWS Circulating Water System (ref. Risk Informed)
D-I-D Defense in Depth (ref. Risk Informed)
DMW Demineralized Water System DPT Dye Penetrant Testing (surface examination)
DRL Drain Line EPRI Electric Power Research Institute EPS Emergency Power System ESS Engineered Safeguards System ET Eddy Current Testing (surface examination)
EVT Enhanced Visual Testing (visual examination)
FAC Flow Accelerated Corrosion FPF Fuel Pool Filter FPP Fuel Pool Pump FPS Fire Protection System (ref. Risk Informed)
FWL Feedwater Line HED Heating and Extraction Steam, and Drains (ref. Risk Informed)
ID Inside Diameter lE Industry Experience IRS Inner Radius ISI Inservice Inspection LDD Letdown Drain LDL Letdown Line LTC Long Term Cooling LPI Low Pressure Injection (ref. Risk Informed)
MPT Magnetic Particle Testing (surface examination)
MRP Materials Reliability Program MSL Main Steam Line MSS Main Steam System MSV Main Steam Valve Line NDE Nondestructive Examination NMC Nuclear Management Company NPS Nominal Pipe Size (inches)
NRC Nuclear Regulatory Commission NRR NRC Office of Nuclear Reactor Regulation NSW Non-Critical Service Water (ref. Risk Informed)
CD Outside Diameter ORM4.12 Operating Requirements Manual, Section 4.12 P&ID Piping and Instrumentation Diagram PCN Procedure Change Notice
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l2of 124 PCS Primary Coolant System. Synonymous with RCS.
PDI Performance Demonstration Initiative PLP Palisades Nuclear Plant PORV Power Operated Relief Valve PRS Pressurizer Relief System PSL Pressurizer Surge Line PSS Pressurizer Spray Line PT Pressure Tap, or Penetrant Testing (surface examination)
PWR Pressurized Water Reactor PWSCC Primary Water Stress Corrosion Cracking PZR Pressurizer (ref. Risk Informed)
QAPM Entergy Quality Assurance Program Manual RCL Reactor Coolant Line RE Recirculation Line RG Regulatory Guide (NRC document)
RCS Reactor Coolant System. Synonymous with PCS.
RHC Return Header Combined RI Risk Informed RI-ISI Risk Informed ISI RWS Radwaste System RPV Reactor Pressure Vessel RVR Relief Valve Line SCH Shutdown Cooling Heat Exchanger SCS Shield Cooling System SDC Shutdown Cooling System SEP Site Engineering Program Section SFP Spent Fuel Pool SFX Spent Fuel Heat Exchanger SIS Safety Injection System SPT System Pressure Test (IWA-5000)
SRT Safety Refueling Tank (also called SIRVV)
SSS SIRW and Containment Sump Suction (ref. Risk Informed)
SWP Service Water Pump SWS Service Water System SX Sample Line UT Ultrasonic Testing (volumetric examination)
VAS Ventilation and Air Conditioning System VT Visual Testing (visual examination)
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13 of 124 1.3 Inspection Intervals The commercial operation date for Palisades was December 31, 1971. The First ISI Interval ended November 9, 1983, as allowed by IWA-2430(e), due to extended time out of service for modifications during the first fuel cycle, which ended on December 20, 1975.
The Second ISI Interval ended May 11, 1995, due to extended time out of service in 1983-1984 for reactor coolant pump repairs, and in 1986 for an NRC Diagnostic Evaluation Team.
The Third ISI Interval was extended to December 12, 2006, except as noted below, per IWA 2430(e), ASME Boiler and Pressure Vessel Code,Section XI, 1989 Edition. During the Second Period, Palisades was out of service for 215 consecutive days from June 21, 2001 through January 21, 2002 for replacement of control rod drive mechanism upper housings. A one-year interval extension also was applied, extending the Second Period to coincide with the 2003 refueling outage, as allowed by IWB-2412(b) (1989 edition).
Reactor vessel Category B-A and B-D welds remained in the Third lSl Interval due to NRC approval of Relief Request TAC MD9265, which allows extension of the reactor vessel inspection interval for these welds. Reactor vessel Category B-A and B-D weld inspections were performed during the January and February Winter 2014 refueling outage (1R24).
The Fourth ISI Interval began on December 13, 2006 and will end on December 12, 2015, to recover the one-year extension of the Third ISI Interval in accordance with ASME Section XI (2001/2003), IWA-2430(d)(1). The First Period of the Fourth ISI Interval was extended approximately ten months to include the Fall 2010 refueling outage in accordance with IWA 2430(d)(3).
The Fifth Interval began on December 13, 2015 and will end on December 12, 2025.
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3 14 of 124 Second Interval Period 2-1 Period 2-2 Period 2-3 Third Interval Period 3-I Period 3-2 Period 3-3 From 11I1011983 1 1/10/1 983 09/1 1/1 988 01/12/1992 From 0511211995 05/1 2/1 995 09112/1998 08/15/2003 To To To To To To To To 0511 Ill 995 09/1 0/1 988 01/1 1/1 992 05/11/1995 1211212006 09/11/1998 08/14/2003 12/12/2006 Palisades Inservice Inspection Intervals First Interval From 1213111971 To 11/0911983 Period 1-1 12/31/1971 To 10/31/1976 Period 1-2 1 1/01/1 976 To 05/31/1980 Period 1-3 06/01/1980 To 11109/1983 Fifth Interval From 1211312015 To 12/12I2025 Period 5-1 12/13/2015 TO 12/12/2018 Period 5-2 12/13/2018 TO 12/12/2022 Period 5-3 12/13/2022 TO 12/12/2025 Fourth Interval Period 4-1 Period 4-2 Period 4-3 From 1211 3!2006 12/13/2006 10/29/2010 05/13/2012 To To To To 04I30/201 5 10/28/2010 05/12/2012 12/12/2015 Refueling outages during the Fifth lSl designate ISI interval, period, and outage sequence within the period.
interval are scheduled as follows. ISI outage numbers
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l5of 124 Palisades Fifth Interval Inservice Inspection Schedule 2
Period 5-1 Period 5-2 Period 5-3 1 R25 1 R26 I R27 1 R28 1 R29 1 R30 5-1-1 5-1-2 5-2-1 5-2-2 5-3-1 5-3-2 Spring 2017 FaIl 2018 Spring 2020 FaIl 2021 Spring 2023 FaIl 2024 2 The term schedule is used to define the detailed scheme of performing the required inspections over the Inspection interval.
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l6of 124 1.4 ASME Section XI Code of Record for Fifth Inservice Inspection Interval 10 CFR 50.55a(g)(4) establishes the effective ASME Section Xl Code edition and addenda, if any, to be used by licensees for performing inservice inspections of components (including supports). Paragraph 50.55a(g)(4)(ii) requires the use of the latest edition and addenda that has been incorporated by 10 CFR 50.55a(a)(1)(ii), one year prior to the beginning of each 120-month (Inspection) interval. This is considered the Code of Record. At that time, 10 CFR 50.55a(a)(1)(ii) incorporated, by reference, the ASME Section Xl, 2007 Edition with the 2008 Addenda in paragraph (b)(2) with limits and conditions.
Revisions to 10 CFR 50.55a in October 2008 and June 2011 mandated implementation of Code Cases N-722-1, N-729-1, and N-770-1, with conditions in paragraphs 10 CFR 50.55a (g)(6)(ii)(E), (g)(6)(ii)(D), and (g)(6)(ii)(F), respectively.
Based on the referenced CFRs in 1.4, the Palisades Fifth ISI Interval ISI Program is based on the requirements of the 2007 Edition of the American Society of Mechanical Engineers (ASME)
Boiler and Pressure Vessel Code Section Xl through 2008 Addenda with the applicable conditions contained in 10 CFR 50.55a(b)(2) and (g)(6), as defined below.
10 CFR 50.55a Reference Mandated Additional Requirements!ConditionslExemptions 10 CFR 50.55a(b)(2)(ii)
Section Xl Condition: Pressure-retaining welds in ASME Code Class I piping (applies to Table IWB2500 and IWB2500I and Categoiy BJ). If the facilitys application for a construction permit was docketed prior to July 1, 1978, the extent of examination for Code Class 1 pipe welds may be determined by the requirements of Table IWB-2500 and Table IWB-2600 Category B-J of Section Xl of the ASME BPV Code in the 1974 Edition and Addenda through the Summer 1975 Addenda or other requirements the NRC may adopt.
(Note: This reference is provided for information/completeness only, Category B-J welds will be examined in accordance with CC N-716-1.)
Section Xl condition: Appendix VIII personnel qualification. All personnel qualified for performing ultrasonic examinations in accordance with Appendix VIII must receive 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of annual hands-on training on specimens that contain cracks. Licensees applying the 1999 Addenda through the latest edition and addenda incorporated by reference in paragraph (a)(1)(ii) of this section may use the annual practice requirements in Vll4240 of Appendix VII of Section Xl in place of the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of annual hands-on training provided that the supplemental practice is performed on material or welds that contain cracks, or by analyzing prerecorded data from material or welds that contain cracks. In either case, training must be completed no earlier than 6 months prior to performing ultrasonic examinations at a licensees facility.
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l7of 124 10 CFR 50.55a Reference Mandated Additional Req uirementslConditionslExemptions 10 CFR 50.55a(b)(2)(xviii)(A)
Section Xl Condition: NDE personnel certification: First provision. Level I and II nondestructive examination personnel must be recertified on a 3-year interval in lieu of the 5-year interval specified in the 1997 Addenda and 1998 Edition of IWA-2314, and IWA-2314(a) and IWA-2314(b) of the 1999 Addenda through the latest edition and addenda incorporated by reference in paragraph (a)(1)(iii) of this section.
Section Xl condition: Substitution of alternative methods.
. The provisions in IWA4520(b)(2) and IWA4521 of the 2008 Addenda through the latest edition and addenda incorporated by reference in paragraph (a)(1)(ii) of this section, allowing the substitution of ultrasonic examination for radiographic examination specified in the Construction Code, are not approved for use.
10 CFR 50 55ab2xxiA Section Xl Condition: Table IWB25001 examination requirements: First
provision. The provisions of Table IWB 25001, Examination Category BD, Full Penetration Welded Nozzles in Vessels,
... Items B3.120 and B3.140 (Inspection Program B) of the 1998 Edition must be applied when using the 1999 Addenda through the latest edition and addenda incorporated by reference in paragraph (a)(1)(ii) of this section. A visual examination with magnification that has a resolution sensitivity to detect a 1-mil width wire or crack, utilizing the allowable flaw length criteria in Table IWB35121, 1997 Addenda through the latest edition and addenda incorporated by reference in paragraph (a)(1 )(ii) of this section, with a limiting assumption on the flaw aspect ratio (i.e., all = 0.5), may be performed instead of an ultrasonic examination.
Section Xl condition: Surface examination. The use of the provision in IWA 2220, Surface Examination, of Section Xl, 2001 Edition through the latest edition and addenda incorporated by reference in paragraph (a)(1)(ii) of this section, that allows use of an ultrasonic examination method is prohibited.
10 CFR 50 55ab2xxix Section XI condition: NonmandatoryAppendix R. Nonmandatory Appendix R,
Risk-Informed Inspection Requirements for Piping, of Section XI, 2005 Addenda through the latest edition and addenda incorporated by reference in paragraph (a)(1)(ii) of this section, may not be implemented without prior NRC authorization of the proposed alternative in accordance with paragraph (z) of this section.
Augmented lSl requirements: Reactor vessel head inspections. All licensees of pressurized water reactors must augment their inservice inspection program with ASME Code Case N7291, subject to the conditions specified in paragraphs (g)(6)(ii)(D)(2) through (6) of this section....
(Program Note: (g)(6)(ii)(D)(4) By September 1, 2009, ultrasonic examinations must be performed using personnel, procedures, and equipment that have been qualified by blind demonstration on representative mockups using a methodology that meets the conditions specified in paragraphs (g)(6)(ii)(D)(4)Q) through (iv), instead of the qualification requirements of Paragraph 2500 of ASME Code Case N7291. References herein to Section Xl, Appendix VIII, must be to the 2004 Edition with no addenda of the ASME BPV Code.)
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18 of 124 10 CFR 50.55a Reference Mandated Additional RequirementslConditionslExemptions 10 CFR 50 55 6iiE1 Augmented IS! requirements: Reactor coolant pressure boundary visual inspections. All licensees of pressurized water reactors must augment their inservice inspection program by implementing ASME Code Case N7221, subject to the conditions specified in paragraphs (g)(6)(ii)(E)(2) through (4) of this section. The inspection requirements of ASME Code Case N7221 do not apply to components with pressure retaining welds fabricated with Alloy 600/82/182 materials that have been mitigated by weld overlay or stress improvement.
Augmented ISI requirements: Examination requirements for Class I piping and nozzle dissimilar-metal butt welds. Licensees of existing, operating pressurized-water reactors as of July 21, 2011 must implement the requirements of ASME Code Case N7701, subject to the conditions specified in paragraphs (g)(6)(ii)(F)(2) through (g)(6)(ii)(F)(1O) of this section, by the first refueling outage after August 22, 2011.
1.5 ASME Section XI Inservice Inspection Program Description The ASME Section Xl ISI Program for the Fifth Inspection Interval is comprised of the following individual programs:
ASME Section Xl and Augmented ISI Program for pressure retaining components and their
- supports, ASME Section Xl System Pressure Test Program, ASME Section Xl Containment Inspection Program, and ASME Section Xl Repair and Replacement Program.
These programs are separate documents or procedures, each bearing the title of the program.
The ISI Programs are administered through EN-DC-174, Engineering Program Sections.
The following definitions are used in the ASME Section Xl ISI program:
PROGRAM The term program is used to provide the structure and methods for accomplishment of the objectives of 10 CFR 50.55a.
It is considered synonymous with the term program as used in ASME Section XI (2007/2008),
Article IWA-2400, which includes both the use of the term plan as used in IWA 2420 and IWA-2425, and the more restrictive use of the term program as used in IWA-2431.
SCHEDULE The term schedule is used to define the detailed scheme of performing the required inspections over the Inspection Interval.
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l9of 124 1.5.1 Fifth ISI Interval Program Description The Fifth ISI Interval Program details Palisadess compliance with ASME Section Xl Code, Section Xl (2007/2008), Articles tWA, IWB, IWC, IWD, and IWF for examination of Class 1, 2, and 3 pressure retaining items and their supports. This document defines the Class 1, 2, and 3 components, Code required examinations for each ASME Section Xl examination category, and augmented inspection scope.
The purpose of the lSl Program is to periodically perform nondestructive examination of ASME Class 1, 2, and 3 safety related components and supports in order to identify the presence of service related degradation.
The administrative procedures and Inspection Schedule described in the ISI Program, combined with applicable Palisades, Entergy, and approved vendor procedures, constitute the ISI portion of the ISI Program required by FSAR 6.9.
The 1St Program also contains augmented examinations that are outside the scope of 10 CFR 50.55a. These examinations may result from activities including, but not limited to, commitments made to the NRC outside the scope of 10 CFR 50.55a, internal commitments, License Renewal commitments, or industry initiatives. These examinations may use ASME Section Xl techniques and procedures as defined in the commitment; however, the requirements of ASME Section Xl, including reporting, do not apply.
Augmented examinations are not required by the ASME Section Xl Code and are not included in summary totals for the specific examination category, except when an augmented inspection may also satisfy ASME Section Xl Code inspection requirements.
When ISI examination and schedule requirements for a component also satisfy the requirements for an augmented examination, then credit for both sets of requirements may be taken by one examination. Duplicate examinations are not required.
The ISI Program schedule is contained in the IDDEAL Software Suite ScheduleWorks computer database.
This information is retained at the plant site and is available for review.
Palisades Site Engineering Program Section (SEP-ISI-PLP-001), Inservice Inspection Program, is the implementing procedure which describes the implementation process for the ISI Program at Palisades.
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2Oof 124 a.
Exemptions ASME Section Xl provides rules for the examination and testing of all class 1, 2, and 3 pressure retaining components and their supports.
Included in the rules of ASME Section Xl are bases for exempting components from volumetric or surface examinations. Additionally, 10 CFR 50.55a(g)(6) allows the Regulatory Authority (NRC) to grant relief from specific portions of ASME Section Xl based upon impractically.
10 CFR 50.55a(z) allows the NRC to allow alternatives to examination and/or test requirements of ASME Section Xl where; a proposed alterative would provide an acceptable level of quality and safety; or, compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Exemptions identified within ASME Section Xl are:
Table IWB-2500 excludes Class 1 valve bodies (B-M-2) not exceeding NPS 4.
ASME Section Xl (2007/2008),
IWC-1221(c) exempts components from Nondestructive Examination (NDE) requirements when a vessel, piping, pump, valve or other component connections of any size in statically pressurized, passive (i.e., no pumps) safety injection systems of pressurized water reactor plants. Class 2 Safety Injection Tanks and their NPS 12 piping to motor operated outlet valves are filled to capacity with borated water and nitrogen, and as such can be considered statically pressurized. The bottles are maintained at the pressure required to operate.
The motor operated valves and Class 2 piping to Class 1 boundary SI outlet check valves are not considered statically pressurized.
Table 1.5.2-1 SI Tanks Exempted from NDE SI Tank Outlet Valve T-82A MO-3041 T-82B MO-3045 T-82C MO-3049 T-82D MO-3052
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Deferrals Section Xl of the code provides a degree of latitude in the scheduling of major component examinations in that certain category examinations may be deferred to the end of the inspection interval. Examples of major component examinations are mechanized ultrasonic (UT) of the reactor vessel, pump and valve teardowns and core internal examinations.
Table 1.5.2-2 Components Deferrable to the End of the Interval Category Component Type B-A Reactor Vessel Welds B-D Reactor Vessel Welds B-F Reactor Vessel Welds B-G-1 Bolting >2 Diameter B-G-2 Bolting 2 Diameter and less B-L-2 Pump Casings B-M-2 Valve Bodies B-N-3 Removable Core Support Structures B-C CRDM Housing Welds
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22 of 124 1.5.2 Containment Inspection Program Description ASME Section Xl requirements for CC and MC components are not contained in this program.
Palisades Site Engineering Program Section SEP-CISI-PLP-001, Containment Structural Integrity Program, implements the requirements of the ASME Section Xl Code, Section Xl Articles IWE and IWL (Class MC and CC components).
1.5.3 Flow Accelerated Corrosion Program Description Flow Accelerated Corrosion (FAC) program requirements are not contained in this program.
Entergy Procedure EN-DC-315, Flow Accelerated Corrosion Program, controls FAC program requirements.
1.5.4 Pressure Test Program Description ASME Section Xl requirements for pressure testing are not contained in this program.
Palisades Site Engineering Program Section SEP-PT-PLP-O01, Inservice Inspection Pressure Testing Program, and Corporate Engineering Program Section CEP-PT-001, ASME Section Xl, Division 1,
System Pressure Testing, satisfy the requirements established in ASME, Section Xl, Articles IWA-5000, IWB-5000, IWC-5000, and IWD 5000.
1.5.5 Pump and Valve Program Description Inservice Testing (1ST)
Program requirements are not contained in this program.
Palisades Site Engineering Program Section SEP-IST-PLP-1 01, lnservice Testing of Plant Valves, and Palisades Site Engineering Program Section SEP-IST-PLP-102, lnservice Testing of Selected SafetyRelated Pumps, are the implementing procedures.
1.5.6 Repair and Replacement Program Description ASME Section Xl requirements for repairs and replacements are not contained in this program.
Palisades Site Engineering Program Section SEP-RR-PLP-001, Code Requirements for ASME Section Xl Repairs and Replacements, and Corporate Engineering Program Section CEP-RR-001, ASME Section Xl Repair and Replacement Program are the procedures which describe the implementation process for the repair and replacement provisions of ASME Section Xl Code, Section Xl, Articles IWA-4000 and IWL-4000, at Palisades.
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23of 124 1.5.7 Snubber Program Description Snubber Program requirements are not contained in this program.
The Palisades Snubber Program satisfies the requirements of ISTD of the OM Code in lieu of IWF-5000 as permitted by 10 CFR 50.55a(b)(3)(v),
except that pre-service and in-service examinations must be performed using the VT-3 visual examination method described in IWA-2213. Within the support boundary shown by figure IWF-1300-1(f), snubber support hardware such as Jugs, bolting, pins, clamps, structural steel between the snubber pin and the pressure retaining item, and structural steel between the snubber pin and the building steel are included in the support population and examined in accordance with Subsection IWF per this Program Section.
Palisades Site Engineering Program Section SEP-SNB PLP-001, Snubber Examination and Testing Program, is the implementing procedure for the area excluded from ASME Section Xl examinations including pivot and clevis pins as shown in IWF-1300-1(f).
1.5.8 Steam Generator Tube Surveillance Program Description In accordance with ASME Boiler and Pressure Vessel Code Section XI 2007 Edition 2008 Addenda IWB-2500-1 Examination Category B-Q, the Steam Generator Tube Inspection Program is in accordance with Technical Specification 5.5.8 in lieu of ASME Section XI.
Palisades Site Engineering Program Section SEP-STMGEN-PLP-001, Steam Generator Program, is the implementing procedure.
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24of 124 1.5.9 Records Records of examinations, tests, and repair replacement activities shall be prepared in accordance with the governing procedure or program document.
Records and reports required by Section Xl and this program are safety related and shall be maintained as permanent plant records.
They shall be filed in a manner to ensure accessibility by the Authorized Nuclear Inservice Inspector (ANII).
Storage and maintenance of these records are under the auspices of the Quality Assurance Program.
Records and reports shall be either originals or reproduced legible copies. They may be maintained in electronic format meeting requirements of IWA-6320(a).
Radiographs may be microfilmed, or they may be digitally reproduced in accordance with IWA-6320(b).
Inservice Inspection Records shall include, as a minimum:
a.
Record Index b.
Preservice and Inservice inspection plans and schedules c.
Preservice and Inservice inspection reports d.
Records of flaw acceptance by analytical evaluation e.
Records of regions in ferritic class 1 components with modified acceptance criteria f.
Nondestructive examination procedures and records.
Records related to the Containment Inspection Program, Repair and Replace Program, Pressure Test Program, and Steam Generator Tube Surveillance Program are maintained as required by each of the respective programs.
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25 of 124 1.5.10 Reports and Submittals Reports and submittals comprise those documents or records that are required to be submitted to the NRC either on a recurring basis or as a result of activities described by Section Xl.
With the exception of submittals related to Exemptions (paragraphi.5.ia.,
reports and submittals shall be as described below, and are provided to the NRC for Information Only to meet a specific Section XI requirement.
NRC approval is not required.
Submittals related to Exemptions do require NRC approval prior to incorporation into the ASME Section Xl program.
In accordance with IWA-1400(c), the initial 151 Program and its revisions shall be provided to the NRC. Program Change Notices (PCN) are not required to be submitted.
Inservice Inspection Summary Reports required by IWA-6000 are replaced by the Owners Activity Report (OAR-i) described by Code Case N-532-5. The OAR-i shall be prepared to meet the requirements of the Code Case and submitted to the NRC within 90 calendar days of completing each refueling outage. The report shall include all applicable activities of the operating cycle not included in the previous report.
Analytical evaluations that accept items for continued service in accordance with IWB 3132.3, IWB-3i42.4, IWC-3i22.3, IWC-3i32.3, and IWD-3600 shall be submitted to the NRC.
If the analytical evaluation is performed during a refueling outage, the submittal may be included with the Owners Activity Report provided the cover letter makes specific reference to the contained analytical evaluation. Analytical evaluations performed during the operating cycle between refuel outages shall be submitted independent of the Owners Activity Report.
As a guide, these submittals should be timely and within 30 calendar days of completing the analytical evaluation.
Evaluation procedures used in analytical evaluations of flaws in austenitic and ferritic piping shall be provided to the NRC in accordance with IWB-3640, IWC-3640, and IWD 3640.
A one-time submittal is acceptable, provided subsequent revisions are provided and the scope and application of the procedure does not change. The cover letter should indicate that the procedure is only submitted once (not for each use) and what criteria will be used to determine when additional submittals will be made.
When acceptance standards have been modified as a result of using smaller flaw sizes in developing the Pressure/Temperature Limit Curves in accordance with IWB-34i0.2, the modified acceptance standards shall be filed with the NRC.
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26 of 124 1.6 Administrative Controls This program is written and implemented as a Program Section meeting the requirements of EN-.
DC-174, Program Sections.
This Program Section will be maintained through revisions and Program Change Notices in accordance with EN-DC-174.
This program will be maintained current to reflect applicable changes to plant configuration through the review process defined by EN-DC-115, Engineering Change Process.
Additions of items to the program resulting from changes to the plant configuration will be incorporated and scheduled for inspection or examination in accordance with IWB/IWC/IWD-241 1 and IWF-2410.
Organizational and divisions of responsibilities for the management and implementation of the ISI Program are defined in EN-DC-120, Engineering Code Programs.
Several elements required by Section Xl to be contained in the ISI Program are maintained in the Iddeal Concepts Software Suite.
This software and its contents are part of the formal ISI program and are controlled in accordance with Program Section CEP-COS-Ol 00, Control and Use of lddeal Concepts Software.
The initial lSl Program, revisions, and PCNs are subject to review by the Authorized Nuclear Inservice Inspector (AN II).
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27 of 124 2.0 ASME Section Xl Code Case Applicability This section contains ASME Section XI Code Cases applicable to the Palisades Fifth Inspection Interval.
2.1 Adoption of Code Cases ASME Section Xl Code Cases adopted for ISI and related NDE activities for the Fifth Interval are listed in Tables 2.2-1, 2.3-1, and 2.4-1.
The use of Code Cases is in accordance with ASME Section Xl, IWA-2440, 10 CFR 50.55a, and Regulatory Guide 1.147, Rev. 17. As permitted byASME Section Xl and Regulatory Guide 1.147 or 10 CFR 50.55a, ASME Section Xl Code Cases may be adopted and used as described below:
2.1.1 Adoption of Code Cases Listed for Generic Use in Regulatory Guide 1.147 Code Cases that are listed for generic use in the latest revision of Regulatory Guide 1.147 may be included in the lSl program, provided all additional provisions specified in the Regulatory Guide are also incorporated. Table 2.2-1 identifies Code Cases approved for generic use and adopted for the Fifth ISI Interval.
2.1.2 Adoption of Code Cases Not Approved in Regulatory Guide 1.147 Certain Code Cases that have been approved by the ASME Committee On Nuclear Inservice Inspection may not have been reviewed and approved by the NRC Staff for generic use and listed in Regulatory Guide 1.147.
Use of such Code Cases may be requested in the form of a Request for Alternative in accordance with 10 CFR 50.55a(z).
Once approved, these Requests for Alternatives will be available for use until such time that the Code Cases are adopted into Regulatory Guide 1.147, at which time compliance with the provisions contained in the Regulatory Guide is required.
Table 2.3-1 identifies those Code Cases that have been requested through Requests for Alternatives.
For convenience to the user of this lSI Program, the appropriate internal correspondence number is provided to assist in their retrieval from Document Control. All other Requests for Alternatives and Relief Requests (those not associated with NRC approval of Code Cases) are addressed in Section 3.
2.1.3 Adoption of Code Cases Mandated by 10 CFR 50.55a Code Cases required by rule in 10 CFR 50.55a are incorporated into the ISI Program and implemented at the specified schedule. Code Cases currently required by 10 CFR 50.55a are identified in Table 2.4-1.
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28 of 124 2.1.4 Use of Annulled Code Cases As permitted by Regulatory Guide 1.147, Code Cases that have been adopted for use in the current interval that are subsequently annulled by ASME, may be used for the remainder of the interval.
2.1.5 Code Case Revisions Initial adoption of a Code Case requires use of the latest revision of that Code Case listed in Regulatory Guide 1.147.
However, if an adopted Code Case is later revised and approved by the NRC, then either the earlier or later revision may be used until the end of the current Inspection Interval.
2.1.6 Adoption of Code Cases Issued Subsequent to Filing the ISI Program Code Cases issued by ASME subsequent to filing the ISI Program with the NRC may be incorporated within the provisions of paragraphs 2.1.1 or 2.1.2 by revision to this lSl Program.
Any subsequent Code Cases shall be incorporated into the program and identified in Table 2.2-1, 2.3-1, or 2.4-1, as applicable, prior to their use.
2.1.7 Non ISI Code Cases Only Code Cases applicable to lSl and related nondestructive examination requirements for Class 1, 2, and 3 components and component supports are included in Table 2.2-1, 2.3-1 and 2.4-1.
Code Cases applicable to System Pressure Testing, Containment lSl and Repair/Replacement Activities are addressed in their respective programs.
2.1.8 Code Cases not approved for use by the NRC Certain Code Cases that have been approved by the ASME Board of Nuclear Codes and Standards have been reviewed and are not approved by the NRC Staff for generic use.
These Code Cases are listed in Regulatory Guide 1.193, ASME Code Cases Not Approved for Use.
However, the NRC may approve their use in specific cases.
Code Cases listed in Regulatory Guide 1.193 will not be used at Palisades without an approved Request for Alternative in accordance with 10 CFR 50.55a(z).
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3 29 of 124 2.2 Regulatory Guide 1.147, Revision 17, ApDroved Code Cases Number Applicability Table 2.2-1
- Code Cases Adopted from ReQulatory Guide 1.147 Title NRC Limitations The repair or replacement 2008 Addenda Evaluation Criteria for Temporary activity temporarily deferred under the N-51 33 Acceptance of Flaws in Moderate provisions of this Code Energy Class 2 or 3 Piping Section Case shall be performed Xl, Division 1 during the next scheduled outage.
Alternative Requirements for 2011 Addenda N 526 Successive Inspections of Class 1 None and 2 Vessels Section Xl, Division 1
Repair/Replacement Activity 2010 Edition Documentation Requirements and N-532-5 Inservice Summary Report None Preparation and Submission Section Xl, Division 1 At least 50 percent of the 2004 Edition flaws in the (Approved for demonstration test set Use by RR 05-must be cracks and the 01) maximum mis-orientation must be demonstrated Alternative Methods - Qualification with cracks. Flaws in N-552 for Nozzle Inside Radius Section nozzles with bore from the Outside Surface diameters equal to or less than 4 inches may be notches.
Add to detection criteria, The number of false calls must not exceed three.
Alternative Additional Examination 2008 Addenda N-586-1 Requirements for Classes 1, 2, None and 3 Piping, Components, and Supports Section Xl, Division 1
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- Code Cases Adopted frOm Regulatory Guide 1.147 Number Title NRC Limitations Applicability Alternative Examination Essentially 100 percent 2004 Edition (not less than 90%) of the (Approved for N-593 Requirements for Steam examination volume A-B-Use by RR 05-Generator Nozzle to Vessel Welds C-D-E-F-G-H must be 01)
Section Xl, Division 1 inspected.
Ultrasonic Examination of Full 2008 Addenda Penetration Nozzles in Vessels, Examination Category B-D, Item N-613-1 Nos. B3.i0 and B3.90, Reactor None Nozzle-to-Vessel Welds, Figs.
IWB-2500-7(a), (b), and (c)
Section Xl, Division 1 Chemical ranges of the 2013 Edition calibration block may vary from the materials specification if (1) it is within the chemical range of the component N 639 Alternative Calibration Block specification to be Material Section Xl, Division I inspected, and (2) the phase and grain shape are maintained in the same ranges produced by the thermal process required by the material specification.
In lieu of an UT 2013 Edition examination, licensees may perform a VT-i examination in Alternative Requirements for Inner accordance with the code Radius Examination of Class I of record for the Inservice N-648-1 Reactor Vessel Nozzles Section Inspection Program Xl, Division 1 utilizing the allowable flaw length criteria of Table IWB-3512-1 with limiting assumptions of the flaw aspect ratio.
Alternative Requirements for 2011 Addenda Classes 1 and 2 Surface None N 663 ExaminationsSection XI, Division 1
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- Code Cases Adopted from ReQulatorv Number Applicability 1.147 Title NRC Limitations 2004 Edition I N-685 aremts for Surface None (Approved for Use by RR 05-01)
Alternative Requirements for 2004 Edition N 686 1 Visual Examinations, N
(Approved for VT-i, VT-2, and \\/T-3 one Use by RR 05-01)
Qualification Requirements for 2004 Edition I Dissimilar Metal Piping Welds 2003 Addenda N-695 None (Approved for Use by RR 05-01)
Qualification Requirements for 2004 Edition I Appendix VIII Piping Examinations 2003 Addenda N-696 Conducted From the Inside None (Approved for Surface Use by RR 05-01)
Evaluation Criteria for Temporary 2013 Edition Acceptance of Degradation in N-705 Moderate Energy Class 2 or 3 None Vessels and Tanks Section Xl, Division 1 Alternative Examination 2011 Addenda Requirements of Table IWB-2500-N 706 1 1 and Table IWC-2500-1 for PWR N
Stainless Steel Residual and one Regenerative Heat Exchangers Section Xl, Division I N-712 Class I Socket Weld Examinations None 2011 Addenda Section Xl, Division I Alternative Classification and 2013 Addenda N-716-1 Examination Requirements None Section Xl, Division 1 Successive Inspections of Class 1 2013 Edition N-735 and 2 Piping Welds Section Xl, None Division 1 Reactor Vessel Head-to-Flange 2013 Edition N-747 Weld Examinations, Section Xl, None Division 1 Section XI, Division 1
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- Code Cases Adopted frdn Regulatory Guid&
1.147 Title NRC Limitations Alternative to Inspection Interval None 2008 Addenda N-765 Scheduling Requirements of IWA 2430 Section Xl, Division 1 2.3 Code Cases Approved through Request for Alternatives The following ASME Section Xl Code Cases are not contained in Regulatory Guide 1.147, Revision 17 and require a request for alternative prior to implementation. See Section 3.0 of this program for the applicable requests.
I Table 2.3-1
- Code Cases Adopted Via NRC Aroved Requests I Number Title Request for Alternative No.
IlNone I
Code Cases Required by 10 CFR 50.55a The following ASME Section XI Code Cases are mandated in 10 CFR 50.55a.
Table 2.4-1
- Code Cases Adopted as Required by 10 CFR 50.55a Number Title Notes Additional Examinations for PWR Pressure Retaining Welds in Class 1 Conditions specified in 10 CFR 50.55a N-722-1 Components Fabricated With Alloy 600/82/1 82 Materials Section Xl, (g)(6)(ii)(E)
Division 1 Alternative Examination Conditions specified in 10 CFR 50.55a Requirements for PWR Reactor (g)(6)(ii)(D)
N-729-1 Vessel Upper Heads With Nozzles Having Pressure-Retaining Partial Penetration Welds Section Xl, Division 1 Number AplicabiIitv 2.4 II
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- Code Cases Adopted as Required by 10 CFR 50 55a Number Title Notes Alternative Examination Conditions specified in 10 CFR 50.55a Requirements and Acceptance (g)(6)(ii)(F)
Standards for Class 1 PWR Piping and Vessel Nozzle Butt Welds N-770-1 Fabricated with UNS06082 or UNS86182 Weld Filler Material With or Without Application of Listed Mitigation Activities Section Xl, Division 1
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34 of 124 3.0 Relief Requests Throughout this program, the term relief request is used interchangeably, referring to submittals to the NRC requesting permission to deviate from either an ASME Section Xl requirement, a 10 CFR 50.55a rule, or to use provisions from Editions or Addenda of Section Xl not approved by the NRC as referenced in 10 CFR 50.55a(b).
However, when communicating with the NRC and in written requests to deviate, the terms as defined below must be used for clarity and to satisfy 10 CFR 50.55a.
Submittals to the NRC must clearly identify which of the below rules are being used to request the deviation.
Table 3.0-1 contains an index of Relief Requests written in accordance with 10 CFR 50.55a(z).
The applicable Palisades submittal and NRC Safety Evaluation Report (SER) correspondence numbers are also included for each request.
Only requests associated with the ISI program and the supporting nondestructive examination requirements are listed in Table 3.0-1.
Requests applicable to System Pressure Testing and Repair/Replacement Activities are identified in their respective program documents.
3.1 Request for Alternatives When seeking an alternative to the rules contained in 10 CFR 50.55a(c), (d), (e), (f), (g), or (h) the request is submitted under the provision of 10 CFR 50.55a(z).
Once approved by the Director, Office of Nuclear Reactor Regulation, the alternative may be incorporated into the 1St program.
These types of requests are termed a Request for Alternative and are typically used to request use of Code Cases, Code Edition, or Addenda not yet approved by the NRC.
A Request for Alternative may also be used to request the use of technology or examination/testing protocol not yet within the boundary of the ASME Section Xl, yet applicable to a specific situation and deserving of consideration; e.g. new technology developed by an Owners Group or EPRI.
Request for Alternatives must be approved by the NRC prior to their implementation or use.
Within the provisions of 10 CFR 50.55a(z), there are two specific methods of submittal:
3.1.1 Quality and Safety 10 CFR 50.55a(z)(1) allows alternatives when authorized by the NRC, if the proposed alternatives would provide an acceptable level of quality and safety. Requests submitted under these provisions are not required to demonstrate hardship or burden.
3.1.2 Hardship or Unusual Difficulty 10 CFR 50.55a(z)(2) allows alternatives when authorized by the NRC, if compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Submittals under this provision must provide evidence of unusual hardship or difficulty. This typically is dose or excessive disassembly.
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35 of 124 3.2 Relief Request Required due to Impracticality or Limited Examinations 10 CFR 50.55(a)(g)(5)(iii) and (iv) allows relief to be requested in instances when a Code requirement is deemed impractical with (iv) being specific to examination requirements that are determined to be impractical.
The provisions of these two paragraphs are typically used to address impracticalities like limited examination coverage.
Under 10 CFR 50.55(a)(g)(5)(iv),
where the licensee determines that an examination required by Code Edition or Addenda is impractical, the basis for this determination must be submitted for NRC review and approval not later than 12 months after the expiration of the initial or subsequent 120-month inspection interval for which relief is sought, In cases where the ASME Section Xl requirements for ISI are considered impractical, Palisades will notify the NRC and submit information to support the determination, as required by 10 CFR 50.55a(g)(5). The submittal of this information will be referred to as a Request for Relief.
In the event that the entire examination volume or surface (as defined in the ASME Section XI Code) cannot be examined due to interference by another component or part geometry, then in accordance with IWA-2200(c), a reduction in examination volume or area is acceptable if the reduction is less than 10%.
In the event that the reduction in examination volume or area is 10%
or greater, a request for relief will be submitted.
NRC Information Notice 98-42 provides additional guidance that all ASME Section XI examinations should meet the examination coverage criteria established in IWA-2200(c).
Therefore, the guidance included in NRC Information Notice 98-42 will be followed by Palisades when determining whether to prepare a relief request or apply the criteria of IWA-2200(c) for examinations where less than 100%
coverage of any Section XI examination is obtained. This does not apply to the bare metal visual examination required by Code Case N-729-1. When performing visual examinations to meet N-729-1, the requirements of N-729-1 shall be used for determining allowance for partial examination of the required surface.
3.3 Requests to use Later Edition and Addenda of ASME Section Xl On July 28, 2004, the NRC published Regulatory Issue Summary (RIS) 2004-12, Clarification on Use of Later Editions and Addenda to ASME CM Code and Section Xl.
This RIS clarifies the NRC position on using Editions and Addenda of Section Xl, in whole or in part, later than those specified in the ISI program.
If the desired Editions or Addenda are referenced in 10 CFR 50.55a(a)(1)(ii), the request is submitted following the guidance of the RIS.
These types of requests are not required to demonstrate hardship, difficulty, or to provide evidence of quality and safety.
They do need to ensure that all related requirements are also met.
Requests to use editions and/or addenda of ASME Section Xl that are referenced in 10 CFR 50.55a(a)(1)(ii) that are later than the initial Code of Record established for the ISI program shall be submitted under the provisions of 10 CFR 50.55a(g)(4)(iv).
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36 of 124 Table 3.0-1 Palisades Fifth Interval Relief Requests Relief Category item Component Alternative Relief Requested Request Description RR 45(1)
B-P B15.1O Reactor Hazard and unusual Leakage detection per IWA Vessel difficulty of direct visual 5244, and remote visual Bottom examination examination Welds RR 4-11 IWA-2600 Impractical to establish Use alternate weld reference Weld standard weld system Reference reference system System RR 419:1)
Code N/A RV-1 041 Dissimilar metal in the Use the new alternative Case N-Nozzle to pressurizer safety relief provision in paragraph 1(b)(1) 638-4 flange weld valve RV-1041 nozzle, of N-638-5.
Relief is from the provision in paragraph 1(b) of N-638-4 that limits the depth of the weld to one-half the ferritic base metal thickness.
RR 424(2)
Code B
Alloy 600 Incomplete Perform N-770-1 volumetric Case N-Branch performance of examinations in I R25 770-1 Welds 2 required baseline inch and volumetric greater on examinations the Cold Leg RR 5-1 Various Various Various From various lnservice To implement the similar Inspection Related various Inservice Inspection (Under Activities of the 2007 Related Activities to Review by Edition through 2008 requirements of the 2001 the NRC)
Addenda of ASME Edition through 2003 Addenda Section Xl until of ASME Section Xl until December 31, 2017.
December 31, 2017.
Note 1: These relief requests were extended to December 31, 2017 by their inclusion in RR 5-1.
Note 2: Authorized by NRC letter dated September 30, 2015 (TAC NO, MF6755) to be effective until completion of the spring 2017 refueling outage (1R25).
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37 of 124 4.0 Developmental References 4.1 External References 4.1.1 Title 10, Code of Federal Regulations, Part 50 4.1.2 American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl, 2001 Edition through the 2003 Addenda 4.1.3 Regulatory Guide 1.14, Reactor Coolant Pump Flywheel Integrity 4.1.4 Regulatory Guide 1.147, Rev. 17, Code Case Applicability 4.1.5 Regulatory Guide 1.26, Quality Group Classifications 4.1.6 MRP-146, Revision 1, Management of Thermal Fatigue in Normally Stagnant Non-Isolable Reactor Coolant System Branch Lines 4.1.7 American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl, 2007 Edition through 2008 Addenda 4.2 Entergy Fleet References 4.2.1 CEP-COS-100, Control and Use of lddeal Concepts Software 4.2.2 CEP-COS-ilO, Control and Use of the of ScheduleWorks Module of IDDEAL Software 4.2.3 CEP-NDE-021 4, lnservice Inspection Implementation 4.2.4 EN-DC-120, Entergy Code Programs 4.2.5 EN-DC-i 74, Engineering Program Sections 4.2.6 eB Equipment Database 4.2.7 Entergy Quality Assurance Program Manual 4.2.8 CEP-PT-00i, ASME Section Xl, Division 1, System Pressure Testing 4.2.9 CEP-RR-001, ASME Section Xl Repair and Replacement Program 4.3 Palisades Site References 4.3.1 Operating License (DPR-20), Technical Specifications for the Palisades Plant, Docket No.
50.255, Appendix A, Sections 5.5.6 and 5.5.7 4.3.2 Operating Requirements Manual, Section 4.12, Augmented Inservice Inspection Program 4.3.4 Palisades ASME Section Xl Color Coded P&IDs 4.3.3 Palisades MERLIN Records Database 4.3.5 SEP-A600-PLP-001, Nickel-Alloy Program 4.3.6 SEP-lSl-PLP-001, Inservice Inspection Program 4.3.7 SEP-ISI-PLP-002, ASME Code Boundaries for ASME Section Xl lnservice Inspection Program
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38 of 124 4.3.8 Engineering Report PLP-RPT-14-00068, 0800075.301 Revision 0 Degradation Mechanism Evaluation for Palisades (EC52129) 4.3.9 Engineering Report PLP-RPT-14-00069, 0800075.302 Revision 0 N-716-1 Evaluation for Palisades (EC52129) 4.3.10 EC-56288, Implementation of Risk Informed Inservice Inspection in accordance with ASME Code Case N-716-1, Alternative Classification and Examination Requirements 4.3.11 SEP-PT-PLP-001, Inservice Inspection Pressure Testing Program 4.3.12 SEP-RR-PLP-001, Code Requirements for ASME Section XI Repairs and Replacements 4.3.13 SEP-SNB-PLP-001, Snubber Examination and Testing Program 4.3.14 SEP-STMGEN-PLP-001, Steam Generator Program
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39 of 124 5.0 Augmented, Owner Elected, Alloy 600, and Renewed License Inservice Inspection Requirements The ISI Program also contains examinations that are outside the scope of 10 CFR 50.55a. These may result from activities including, but not limited to, License Renewal commitments, other commitments made to the NRC, industry initiatives, or internal commitments. These examinations may use ASME Section Xl techniques and procedures, but ASME Section Xl requirements, including reporting, do not apply.
Augmented examinations are not included in summary totals for ASME Section Xl examination categories, except when an augmented inspection may also satisfy ASME Section Xl Code inspection requirements.
Changes to augmented examination requirements and schedules are outside of 10 CFR 50.55a and must be evaluated using the 10 CFR 50.59 screening/review process.
5.1 Augmented Examination Programs Augmented Examination Programs are those that Palisades has committed to perform to address NRC or industry concerns.
Plant Technical Specifications and the Operating Requirements Manual may require more frequent examination scheduling than does Section Xl, Paragraphs IWB-2400 and IWC-2400. Such requirements supersede those of Section Xl.
The following Palisades Technical Specification and Operating Requirements Manual sections apply to the Augmented Program and will be performed throughout the life of the plant.
Technical Specification Section 5.5.6 Operating Requirements Manual Section 4.12 Augmented examinations addressed by the Palisades ISI Program during the Fifth inspection interval are as follows:
5.1.1 RCP Flywheels: Reactor Coolant Pump Flywheel Integrity Source Document:
Technical Specification 5.5.6 Commitment No.:
None Associated Document: NRC Regulatory Guide 1.14
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Purpose:
Reactor coolant pump (RCP) motor flywheels are examined due to a concern about high-energy missiles inside containment that could potentially damage and cause the simultaneous failure of multiple trains of multiple safety-related systems.
Scope: The scope includes the examination of all four RCP upper flywheels.
Method: Surveillance of the primary coolant pump flywheels shall consist of a 100%
volumetric inspection of the upper flywheels each 10 years.
Industry Code or Standards:
ASME Section Xl, (2007/2008).
Frequency:
All 4 RCP upper flywheels shall be inspected once every ISI 10-Year Interval.
Acceptance Criteria or Standard: Any flaws detected during examination shall be forwarded to Palisades/Entergy Engineering for resolution.
Regulatory Basis:
Technical Specification 5.5.6 is loosely based on Regulatory Guide 1.14, but Palisades is not committed to this Regulatory Guide.
Application criteria and code compliance are addressed in Master Program Section 72.1.
5.1.2 ESS Check Valve Weld Overlays: Volumetric and Surface Examinations of Overlay Welds on CK-ES3166 and CK-ES3181 Source Document:
FSAR 6.9.1 Commitment No.:
CMT942002514, CMT942002555, CMT9420002686 Associated Document:
Purpose:
Ensure cracking does not propagate into the upper 25% of the original base metal of dissimilar metal welds that contain alloy that are mitigated by overlay.
Scope: Weld overlay repairs on containment sump recirculation check valves CK ES3166 and CK-ES3181.
Method: Perform PT and UT examination of weld overlays associated with check valves CK-ES3166 and CK-ES3181, using UT methods demonstrated to be effective.
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41of124 Industry Code or Standards:Examination required by ASME Section Xl Code Case N-504-3.
Frequency:
The examination shall be performed every refueling outage.
Acceptance Criteria or Standard: Per ASME Section Xl Code Case N-513-1.
Regulatory Basis:
Code Case N-51 3-1 Application criteria and code compliance are addressed in Master Program Section 7.2.2.
5.1.3 NUREG-0612
Control of Heavy Loads at Nuclear Power Plants Source Document:
NUREG-0612 Commitment No.: CMT891010064, LO-LAR-2009-00244-28, LO-LAR-2009-00244-60 Associated Documents:
NRC Generic Letter 85-11, FSAR 1.9.1.15, CLP-M-6, MSM-M-13, MSM-M-13A, MSM-M-13C, MSM-M-33
Purpose:
Perform examinations on cranes and special lifting devices in accordance with NUREG-0612.
Scope: As defined in Procedure CLP-M-6, these augmented examinations address special lifting devices (heavy load lift devices) for use in and around the reactor (closure head, upper guide structure, core support barrel, and missile shields); dry fuel storage (hoist rings, spreader bars, lift yoke, and transfer cask); and primary coolant pump and motor. These augmented examinations do not address the spent fuel pool crane or polar crane, which are addressed by separate Maintenance Department programs independent of the lSl Program.
Method: Subject components shall be subject to visual, surface, and for the reactor head lift rig, volumetric examinations as specified in Palisades Procedure CLP-M-6, Inspection of Heavy Load Lift Devices.
Industry Code or Standards: ANSI N 14.6, 1978 Edition, Section 5.5 Frequency:
Examination frequencies are specified in CLP-M-6.
Acceptance Criteria or Standard: Acceptance criteria are stated in ASME Section III, ANSI B30.9, and ANSI B30.10.
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42 of 124 ASME Section XI (2007/2008) may be used for Regulatory Basis:
NRC NUREG-0612 Application criteria and code compliance are addressed in Master Program Section 72.3.
5.1.4 BL 88-08: Auxiliary Spray Piping NDE Source Document:
NRC Bulletin 88-08 Commitment No.:
CMT891015850 Associated Document:
None
Purpose:
Plan and implement a program to provide continuing assurance that unisolable sections of all piping connected to the RCS will not be subjected to combined cyclic and static thermal and other stresses that could cause fatigue failure during the remaining life of the unit.
Scope: 2 inch Auxiliary Spray system piping.
Method:
UT Industry Code or Standards:
guidance.
Frequency:
Examinations shall be performed on a 5 year frequency.
Acceptance Criteria or Standard: ASME Section Xl (2007/2008)
Regulatory Basis:
NRC Bulletin 88-08 Application criteria and code compliance are addressed in Master Program Section 7.2.4.
5.1.5 ORM 4.12, HELB: Augmented lnservice Inspection Program for High Energy Lines Outside of Containment Source Document: Operating Requirements Manual 4.12 Commitment No.: None Associated Documents: FSAR 5.6.4, 5.8.6.3, 6.9
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Purpose:
Ensure continued integrity of high energy lines outside of containment over the service lifetime.
Under normal plant operating conditions, the piping materials operate under ductile conditions and within stress limits considerably below the ultimate strength properties of the materials. Flaws, which could grow under such conditions, are generally associated with cyclic loads that fatigue the material and lead to leakage cracks. The inservice examinations and frequency of inspection will provide a means for timely detection before flaws penetrate the wall of the piping.
The program applies to welds in piping systems or portions of systems located outside containment where protection from the consequences of postulated ruptures is not provided by a system of pipe whip restraints, jet impingement
- barriers, protective enclosures and/or other measures designed specifically to cope with such ruptures.
Scope: Welds in Main Steam and Main Feedwater lines located inside the Main Steam and Feedwater Penetration
ORM 4.12.1:
Welds are identified in the following figures.
Note: Some non-class welds are included within scope.
Figure 4.12.A: Main Steam Lines Figure 4.12.B: Main Feedwater Lines ORM 4.12.2:
Other Main Steam and Main Feedwater line welds not identified in Figures 4.12.A and 4.12.B, including safety valve attachment welds.
ORM 4.12.3: All welds included in ORM 4.12.1 and ORM 4.12.2.
Method:
ORM 4.12.1:
Volumetric ORM 4.12.2: Volumetric and surface examination.
ORM 4.12.3:
Visual inspection on the surfaces of the insulation at the weld locations shall be performed on a weekly basis for detection of leaks.
Industry Code or Standards: ASME Section Xl (1972 Winter Addenda, 2001/2003).
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Table IWC-2500-1, Examination Category C-F-2, ASME Section Xl (2007/2008).
ORM 4.12.2:
Examine in accordance with requirements of Subsections ISC 100 through 600 of ASME Section Xl (1972 Winter Addenda).
ORM 4.12.3:
Visually inspect insulation surfaces at weld locations for evidence of leaks.
Note:
This examination of normally operating lines at normal operating temperature and pressure is performed by VT-2 qualified examiners and is documented in Operations Department records.
Frequency:
ORM 4.12.1:
Volumetric inspection of 1/3 of the welds at the expiration of each 1/3 of the inspection interval, with a cumulative 100 percent coverage of all welds.
Note: The welds selected during each inspection period shall be distributed among the total number to be examined to provide a representative sampling of the condition of all welds.
ORM 4.12.2:
Examine in accordance with requirements of Subsections ISC 100 through 600 of ASME Section Xl Code, 1972 Winter Addenda.
ORM 4.12.3: Weekly examination.
Acceptance Criteria or Standard: Flaws detected during examination shall be evaluated by comparing the examination results to the acceptance standards established in ASME Section Xl, IWC-3514.
ORM 4.12.1:
Volumetric inspection of 1/3 of the welds at the expiration of each 1/3 of the inspection interval, with a cumulative 100 percent coverage of all welds.
1)
If repairs of any welds are required following any examination performed during successive inspection intervals, the inspection schedule for the repaired welds shall revert to the first inspection interval schedule.
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45of 124 2)
Examinations that reveal unacceptable structural defects in a weld shall be extended to require an additional inspection of an additional 1/3 of the welds.
If further unacceptable defects are detected in the second sampling, the remainder of the welds shall be inspected.
3)
Repairs, reexamination and piping pressure tests shall be conducted in accordance with ASME Section Xl Code.
ORM 4.12.2:
Repairs, reexamination and piping pressure tests shall be conducted in accordance with Section Xl of the ASME Section Xl Code.
Examine in accordance with requirements of Subsections ISC-100 through 600 of ASME Section Xl Code, 1972 Winter Addenda.
ORM 4.12.3:
Repairs, reexamination and piping pressure tests shall be conducted in accordance with Section Xl of the ASME Section Xl Code.
Regulatory Basis: NRC NUREG-0800, Section 3.6.2.
Application criteria and code compliance are addressed in Master Program Section 72.5.
5.1.6 AF-Sl
Auxiliary Feedwater Structural Integrity Source Document:
Reference letters:
RJB 34-88, dated May 18, 1988 BW88-032, dated July 14, 1988 THE 88-001, dated January28, 1988 Commitment No.:
Not stated Associated Documents:
None
Purpose:
Ensure structural integrity of Auxiliary Feedwater System Piping associated with Steam Generators.
Scope:
For both steam generators, the following portions of Auxiliary Feedwater piping adjacent to the steam generator:
1.
Pipe to Elbow Weld 2.
Elbow to Pipe Weld
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Pipe to Nozzle Weld 4.
Piping, beginning at the Elbow to Pipe Weld upstream of the Steam Generators.
5.
Internal Knuckle Region Method:
1,2,3 Perform volumetric examinations.
4.
Perform ultrasonic wall thinning examinations, under the Flow Accelerated Corrosion (FAC) program.
5.
Perform visual examinations, if Steam Generators are open for secondary side inspections.
Industry Code or Standards:
ASME Section Xl (2007/2008).
Frequency:
1,2,3 Every other outage (equivalent to once per lSl period).
4.
Schedule and perform under the FAC program.
5.
If Steam Generators are open for secondary side inspections.
Acceptance Criteria or Standard: Flaws detected during examination shall be evaluated by comparing the examination results to the acceptance standards established in ASME Section Xl, Subsection IWC.
Regulatory Basis:
None Application criteria and code compliance are addressed in Master Program Section 72.6.
5.1.7 MRP-146
Examination for Thermal Fatigue in Reactor Coolant System Piping Source Document:
MRP-146S Commitment No.:
Industry commitment Associated Documents:
Purpose:
Periodically examine for evidence of degradation from thermal fatigue.
Scope: The scope of these augmented examinations is piping that has been evaluated as potentially susceptible to thermal fatigue cracking, in accordance with MRP-146S.
The evaluation was performed under EC 51419 and
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47of 124 Engineering Report PLP-RPT-14-00085, Rev. 0, MRP-170, MRP-146 and MRP-146S Evaluation of Non-Isolable Normally Static Reactor Coolant Lines Candidate locations are normally stagnant pipe branches attached to RCS loop piping. Locations at Palisades include:
1.
12 inch Loop 2H Shutdown Cooling Outlet (ISI Component ID:
PCS-1 2-SDC-2H1 -3).
A related industry program is MRP-192: RHR Mixing Tee Thermal Fatigue.
Evaluation concluded that the Palisades RHR mixing tee does j require examination for thermal cycling fatigue.
Method: Subject piping segments shall be ultrasonically examined using techniques that are specially developed for detecting thermal fatigue cracking.
Industry Code or Standards:
MRP-146S Frequency: The subject welds shall be examined every second outage.
Acceptance Criteria or Standard: Flaws detected during examination shall be evaluated by comparing the examination results to the acceptance standards established in MRP-146S.
Regulatory Basis:
Nuclear Energy Institute (NED 03-08 Initiative.
Application criteria and code compliance are addressed in Master Program Section 7.2.7.
5.1.8 Pressurizer Spray Line: Postulated Break of Pressurizer Spray Line Source Document:
FSAR 5.6.7.2 Associated Document: None
Purpose:
Prevent pipe whip damage to cable tray.
Note:
The postulated break of the pressurizer spray line is assumed as a double-ended guillotine rupture that results in the whipping pipe striking a cable tray approximately 20 feet from the pipe. The purpose of this examination was to prevent damage to a hydrogen recombiner cable in that cable tray.
The hydrogen recombiners have since been eliminated, nullifying the consequences of cable damage.
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48 of 124 Scope: 3 inch Category B-J weld (ISI Weld ID: PCS-3-PSS-1B1-1-X1)
Method: Surface examination in accordance with ASME Section Xl, Table IWB-2500-1, Category B-J Industry Code or Standards:
ASME Section Xl, Section Xl (2007/2008).
Frequency:
Examine once per interval.
Weld shall be included within the scope of welds to be examined every interval.
Acceptance Criteria or Standard: ASME Section Xl (2007/2008), IWB-3514.
Regulatory Basis:
None Application criteria and code compliance are addressed in Master Program Section 72.8.
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49 of 124 5.2 Owner Elected Examinations for Internal Commitments Owner Elected Programs are those that have been developed to address plant concerns such that Palisades has not committed to the NRC to perform but believes are necessary.
The owner elected examinations addressed by the Palisades ISI Program during the Fifth inspection interval are as follows:
5.2.1 Containment Penetration Piping Source Document:
None Associated Document: None
Purpose:
All piping penetrations are examined in accordance with the rules of ASME Section Xl, Articles IWB and IWC and are in the program as required. Palisades also classifies the equipment hatch, escape airlock and personnel airlock as Class 2. These three penetrations are included due to the piping which is attached to these openings for the purpose of pressurizing the two air locks and performing the between-the seals test of the equipment hatch. However, all of the test piping is less that NPS 4 inch and is exempt from examination by IWC-1 222(a).
Scope: Welds within the personnel air lock, escape hatch, and equipment hatch.
Method: The welds within the air lock and the equipment hatch will be examined in accordance with the rules of ASME Section Xl, Article IWE program.
Industry Code or Standards:
ASME Section Xl (2007/2008).
Frequency:
Examinations will be performed in accordance with the rules of ASME Section Xl, Article IWE program.
Acceptance Criteria or Standard: In accordance with the rules of ASME Section Xl, Article IWE program.
Regulatory Basis:
10 CFR 50.55a 5.2.2 CRD Upper Housings Internal Inspections Source Document:
CR-PLP-2012-05623 Associated Document:
WT-WTPLP-20 14-00033 CA-52
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Purpose:
Perform internal examinations of the centering band region of the CRDM Upper Housing (former weld 5 area).
Scope: Perform internal examinations of two upper housings each 10 year interval. One housing should be selected from the periphery housings and one housing should be selected from the remaining internal housings.
Method: Utilize Eddy Current or Visual methods developed to inspect the internals of the CRD Upper Housings Industry Code/Standard:
None Frequency:
Two Upper Housing every 10 year interval Acceptance Criteria/Standard:
The acceptance criteria for the inspections would utilize ASME Section XI Code acceptance criteria as guidance (i.e.
Category B-O IWB-3523).
Any crack like indications even if it meets the code acceptance criteria, would require further evaluation as part of the corrective action program.
Regulatory Basis:
None 5.2.3 Additional Examinations Additional examinations will be performed as required by Site Engineering Procedure SEP-lSl-PLP-001.
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51 of 124 5.3 Alloy 600 Program Pressurized Water Stress Corrosion Cracking (PWSCC) in Alloy 600 (also called Alloy 600/82/1 82, bimetallic, Ni-Cr-Fe, or SB-I 66) material has been recognized as a significant issue in PWR reactor coolant systems (RCS).
Palisades has 252 Alloy 600 RCS penetrations. The RCS includes two identical heat transfer loops connected in parallel to the reactor vessel.
Each loop contains one steam generator, two reactor coolant pumps, instrumentation, and connecting piping.
A pressurizer is connected to one hot leg by means of a surge line. As a result of Alloy 600 cracking associated with the pressurizer power operated relief valve (PORV) nozzle, a project was initiated in 1993 to identify and rank all RCS Alloy 600 penetrations.
The project based penetration ranking on four main criteria:
PWSCC susceptibility, failure consequence, leakage detection margin, and radiation dose rates. Examination requirements for Alloy 600 penetrations are contained in the Palisades ISI Program.
Alloy 600 examinations also are credited for implementation of aging management program requirements under the renewed license.
Alloy 600 examinations are also applied to the ASME Section Xl lSl program, when applicable to both programs.
Alloy 600 penetrations are contained within the required inspection boundary for the American Society of Mechanical Engineers (ASME) Section Xl system leakage test (pressure testing program) required each refueling outage.
This visual inspection, which differs from bare metal visual examinations discussed below, is performed without the removal of insulation.
In October 2008, a 10 CFR 50.55a revision changed Alloy 600 inspection requirements, imposing ASME Section Xl Code Cases N-722 and N-729-I with conditions. Bimetallic butt weld exams were required in accordance with MRP-I 39, Rev. 1.
In June 2011, a 10 CFR 50.55a revision changed Alloy 600 inspection requirements, imposing ASME Section Xl Code Cases N-722-1, N-729-1, and N-770-1 with conditions.
MRP-139 was superseded.
Cold leg butt welds 2 and larger were added to N-770-1 examination scope, effective the first refueling outage after August 22, 2011. A related NRC interpretation in July 2011 forced inclusion of the PORV nozzle replacement weld within Alloy 600 scope, increasing the total number of in-scope locations from 251 to 252. At locations with two Alloy 600 welds (safe ends, for example), each weld has a unique Component ID.
Different scheduling requirements for visual and volumetric examinations for the same Alloy 600 components complicate data entry into Iddeal ScheduleWorks software.
Volumetric
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52 of 124 examinations are capable of meeting ASME Section Xl requirements, so they are scheduled as Code exams.
Bare metal visual examinations of Code exempt and non-exempt components do not have any corresponding Code examinations, so they are scheduled as augmented exams.
The following sections describe the 252 Alloy 600 penetration configurations, examination history, repairs and examination requirements.
Except as noted, Alloy 600 inspection results to date have been acceptable.
5.3.1 Reactor Vessel Penetrations The reactor pressure vessel is a vertical cylindrical vessel with a hemispherical lower head welded to the vessel, and a removable hemispherical upper closure head. The pressure vessel and upper head assembly are constructed of ASTM SA-302 Grade material. Interior surfaces that contact reactor coolant are clad with 3/16 inch minimum Type 308/309 austenitic stainless steel.
The reactor vessel contains two Alloy 600 penetrations, categorized as follows:
(2)
- Reactor flange leak detector taps. These penetrations were given the lowest ranking because they are not primary system pressure boundaries, due to location downstream of the reactor head 0-rings. Visual examination is not required.
(Code Case N-722-1 Item No. B15.100, Note 8).
The reactor vessel bottom head does not have any penetrations. The bottom head receives a
remote bare metal visual examination each refueling outage in accordance with the Pressure Test Program and is performed under Technical Specification Surveillance Test RT-71A-2, Primary Coolant System, Class I Reactor Vessel Visual Examination.
Reactor vessel to RCS loop butt welds do not include any Alloy 600 material.
5.3.2 Reactor Vessel Upper Head Penetrations The reactor upper head has 54 Alloy 600 penetrations, categorized as follows:
(45)
- Control rod drive (CRD) Alloy 600 nozzles that are J-welded at the reactor head inter-diameter (ID) and then butt-welded to the CRD flange above the reactor head.
(8)
Incore instrumentation (lCl) nozzles that are J-welded at the reactor head ID and then butt-welded to the ICI flange above the reactor head.
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- Reactor vent line nozzle that is J-welded at the reactor head ID and then butt-welded to the reactor vent line above the reactor head.
(Code Case N-729-1 Items No. B4.1O (head) and B4.20 (nozzles))
During the 1995 refueling outage, a bare metal examination of the upper head was performed. Additionally, eddy current examination (ECT) was performed on J-welds on the eight ICI penetrations.
All results were acceptable.
NRC Order EA-03-009, Issuance of Order Establishing Interim Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors, required bare metal visual exams and volumetric exams to be performed on the reactor vessel head Alloy 600 penetrations. A bare metal exam was successfully performed during the 2003 refueling outage.
A volumetric examination was performed for all 54 head penetrations during the 2004 refueling outage. During this inspection, CRDM Penetrations 29 and 30 had potential leak path indications and were repaired prior to restart. As a result of the repairs, a bare metal examination of all 54 penetrations as required by the order also was performed, with acceptable results. Volumetric and bare metal visual examinations have been performed as required during every subsequent refueling outage.
In October 2008, a revision to 10 CFR 50.55a superseded EA-03-009 through mandatory imposition of ASME Section Xl Code Case N-729-1.
N-729-1 requires bare metal visual examination of the reactor head outer surface, and volumetric or inside surface examination of nozzles and partial penetration welds, of the Palisades reactor head every refueling outage. Additional criteria are specified in Code Case N-729-1 and 10 CFR 50.55a.
5.3.3 Pressurizer The pressurizer maintains RCS operating pressure and compensates for changes in reactor coolant volume during load changes.
It is constructed of ASTM A533, Grade B, Class I steel plate. The interior surface of the cylindrical shell and upper head is clad with type 304 stainless steel. The lower head is clad with Alloy 600 to facilitate welding of Alloy 600 heater sleeves to the shell.
The pressurizer contains 136 Alloy 600 penetrations, categorized as follows:
(1) 3-inch ID X 6-inch CD PORV nozzle in the upper head (ISl Weld ID: PCS-4-PRS-I P1-I), fabricated of ASTM-A-508-64 CL2 forged steel with type 304 stainless steel cladding and originally fitted with a schedule 120, Alloy 600 safe-end.
In 1993, the
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54 of 124 safe-end developed a leak due to PWSCC.
It was repaired by removing the cracked weld and heat affected zone, welding a stainless steel pup piece into their place, and performing code required examinations.
In 1995, the PORV safe-end, pup piece, and part of the 4 piping were replaced with a type 316 stainless steel safe-end/spool piece. Alloy 690 was used to eliminate RCS contact with Alloy 600 weld butter remaining on the nozzle.
Ultrasonic (UT) and liquid penetrant (PT) baseline examinations of the new welds were performed, with acceptable results.Section XI UT/PT examination of this safe end was performed in 2004, with acceptable results.
Between 1995 and 2011, the PORV nozzle weld was not included in Alloy 600 program scope due to susceptible material being isolated from reactor coolant water.
In 2011, the NRC declared that locations with Alloy 600/82/182 in the load path, even if not exposed to RCS chemistry, shall be included in the Alloy 600 program.
Palisades has revised the number of Alloy 600 penetrations within the program from 251 to 252.
The PORV nozzle was scheduled for volumetric examination in 2012.
(Code Case N-722-1 Item No. B15.160, N-770-1 Inspection Item A-I)
(1) 4-inch spray line nozzle assembly fabricated of ASTM-A-508-64 CL2 forged alloy steel with type 304 stainless steel cladding and fitted with a schedule 120, Alloy 600 safe-end (ISI Weld IDs: PCS-4-PSS-IP1-20 and PCS-4-PSS-IP1-21). The elbow to safe-end and safe-end to nozzle welds were UT/PT examined in 1995 with acceptable results.
Both welds are volumetrically examined every other refueling outage and are visually inspected during intervening outages.
(Code Case N-722-1 Item No. B15.150, N-770-1 Inspection Item A-I)
(I) 12-inch surge line nozzle located in the bottom head of the pressurizer (ISI Weld IDs: PCS-12-PSL-1HI-1 and PCS-12-PSL-1HI-2).
The surge nozzle is fabricated of ASTM-A-508-64 CL2 forged alloy steel with type 304 stainless steel cladding and fitted with a schedule 140, Alloy 600 safe-end.
Mechanical Stress Improvement Process (MSIP) was applied to the safe end to pipe weld, but not the safe end to nozzle weld, in 1995.
MSIP changes the residual stress patterns from tensile to compressive by plastically deforming the piping near the weld, in order to help mitigate PWSCC. The MSIP was evaluated against the requirements of Code Case N-770-I and determined that it did not meet those requirements and therefore was put into Item A-I.
Both welds are volumetrically examined every other refueling outage and are visually inspected during intervening outages.
(Code Case N-722-I Item No. B15.170; N-770-1 unmitigated nozzle weld Code Inspection Item A-I)
(3) 3-inch ID X 6-inch CD valve nozzles, all in the upper head, fabricated of ASTM A-508-64 CL2 forged alloy steel with type 304 stainless steel cladding and fitted with
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55 of 124 Alloy 600 nozzle flanges to provide a 3-inch, 2500# flange connection to the safety valves (ISI Weld IDs: PCS-6-PRS-l Al-I (RV-1 039), PCS-6-PRS-l BI -l (RV-l 040),
and PCS-6-PRS-IC1-l(RV-1041)).
All three nozzle welds were examined by UT, RT and PT of the ID in 1993 with acceptable results.
During 1R23 a crack was identified in the RV-1041 nozzle to safe end weld and the weld was replaced with alloy 52M weld material which is more resistant to PWSCC under EC 49132.
Two welds are volumetrically examined every other refueling outage (N-770-1 Inspection Item A-I).
All three welds are visually inspected during intervening outages(Code Case N-722-1 Item No. B15.160)
(8)
I-inch level nozzles, four upper and four lower, fabricated of ASTM-A-508-64 CL2 alloy steel forgings, clad and fitted with Alloy 600 ends.
The alloy end is to facilitate welding SA-182 (F-316) stainless steel socket weld safe-ends for connection of the water level instrumentation piping (ISI Weld IDs: PZR-002 Weld I (LT-0103), PZR-002 Weld 2 (LT-0103), PZR-002 Weld 7 (LT-0103), PZR-002 Weld 8 (LT-0103), PZR-003 Weld I (LT-0102), PZR-003 Weld 2 (LT-0102), PZR-003 Weld 7 (LT-0102), PZR-003 Weld 8 (LT-0102), PZR-004 Weld I (LT-O1O1B), PZR 004 Weld 2 (LT-O1O1B), PZR-004 Weld 7 (LT-OIOIB), PZR-004 Weld 8 (LT-01 01 B),
PZR-005 Weld 1 (LT-O1O1A), PZR-005 Weld 2 (LT-OIO1A), PZR-005 Weld 7 (LT OIOIA), PZR-005 Weld 8 (LT-OIOIA)).
All 16 welds receive bare metal visual inspection every refueling outage.
They are exempt from volumetric examination due to size.
(Code Case N-722-1 Item No. B15.180; N-770-l Inspection Item A-i)
(2)
I-inch temperature element nozzle penetrations (TE-0i0I, TE-0102), one in the upper head and one in the lower shell, fabricated of Alloy 600 with SA-182 (F316) stainless steel socket weld safe-ends (ISI Weld IDs: PZR Weld TE-OlOl, PZR Weld TE-0102). These two penetrations leaked in 1993. Axial PWSCC, in the heat affected zone of these Alloy 600 nozzles, was found to be the root cause for this leakage.
A pad weld repair was performed in both nozzle locations.
Additionally, a notch was cut in the TE-OlOl nozzle.
Both pad welds receive bare metal visual inspection every refueling outage.
(Code Case N-722-l Item No. B15.180)
(120)
- Pressurizer heater penetrations, which are J-welded to the Alloy 600 internal cladding of the vessel lower head.
Palisades operates with more heaters in full-time service than most other plants. This improves equalization of the RCS loop and pressurizer chemistry, reduces thermal stratification and cycling in the surge and spray lines, and maintains lower pressurizer spray inlet safe-end temperatures.
In addition to
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56 of 124 Code Case requirements, Palisades committed to perform a bare metal visual examination of all 120 heater penetrations during each refueling outage.
(Code Case N-722-1 Item No. B15.140; WCAP-16180-NP)
Pressurizer Inspection Commitments:
CMT082011260:
Response
Bare metal visual inspections of 100% of all pressurizer heater sleeves in a manner to access 3600 of each sleeve each refuel outage.
Code Case N-722-1 meets this commitment.
CMT082011261:
NRC Bulletin 2004-01 Response Perform NDE capable of characterizing crack orientation of all pressurizer heater sleeves with evidence of leakage.
No evidence of leakage has been identified to date.
CMTO82OI 1262:
Notify the NRC of any potential circumferential PWSCC in either the pressure boundary or non-pressure boundary portions of any locations covered under bulletin 2004-01.
Since the issuance of Bulletin 2004-01, no evidence of potential circumferential PWSCC has been identified. The 1993 PORV line crack was reported to the NRC upon discovery.
CMT082011296:
(Revised)
NMC will inspect the Alloy 600/82/182 pressurizer butt-welds per MRP-139, on a frequency of at least every four
- years, until the Alloy 600/82/182 pressurizer butt-welds are mitigated or removed at PNP. NMC will notify the NRC in writing, prior to making any changes to this commitment.
Code Case N-770-1 meets this commitment.
10 CFR 50.55a was revised in June 2011, superseding MRP-1 39 by mandatory Code Cases N-722-1 and N-729-1, with conditions.
Required inspection frequency is a volumetric examination every second refueling
- outage, with visual or volumetric examination every refueling outage.
CMT082011299:
(Revised) NMC will provide results of future inspections, including inspections on unmitigated welds and any corrective or mitigated actions taken on the pressurizer surge, spray, safety, or relief nozzle and safe end welds containing Alloy 600/82/1 82 material, within 60 days of the end of the station refueling outage during which the inspection was performed, until the Alloy 600/82/1 82 pressurizer butt-welds are mitigated or removed at PNP.
NMC will notify the NRC in writing, prior to making any changes to this commitment.
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57of 124 CMT952010242:
I) Complete inspections for Primary Water Stress Corrosion Cracking (PWSCC) of the areas to which the mechanical stress improvement process (MSIP) is applied every other refueling outage.
CMT9520 10247 supersedes this requirement.
- 2) Perform a VT-2 examination of the TE-OlOl nozzle at every future refueling outage to identify any leakage from the nozzle.
- 3) Complete appropriate PWSCC inspections of the pressurizer spray nozzle every other refueling outage.
Code Case N-770-1 meets these commitments.
CMT95201 0247:
Pressurizer butt welds treated with MSIP are required to be identified in the lSl master program and volumetrically examined using PDI demonstrated techniques once per Section Xl interval (MRP-139).
Code Case N-770-1 is more stringent than this commitment, requiring NRC permission before welds treated with MSIP are moved into the ASME Section Xl population. The MSIP that was performed was evaluated against the requirements of Code Case N-770-1 and determined that they did not meet those requirements and are scheduled as either Item A-I or Item A-2.
All 3 welds treated with MSIP meet the N-770-1 requirement.
5.3.4 Steam Generators Palisades Nuclear Plant has two steam generators (SG5) that were installed as replacements in 1990.
Reactor coolant enters each SG through the inlet nozzle, flows through 3/4-inch CD U-tubes, and leaves through two outlet nozzles. A vertical partition plate in the lower head separates the inlet and outlet plenums.
The plenums are stainless steel clad, while the primary side of the tubesheet is Alloy 600 clad.
The Alloy 600 U-tubes are rolled in the full depth of the tubesheet, and the tube-to-tubesheet joints are welded on the primary side.
SG tubes are included in the SG Reliability Program, not the Alloy 600 program.
(4) 3/4-inch primary bowl drain plugs, one for each inlet and outlet plenum (ISI Weld IDs: E-50A Bowl Plug SGA-1, E-50A Bowl Plug SGA-2, E-50B Bowl Plug SGB-1, 50B Bowl Plug SGB-2). The tapered plugs are installed and welded from the inside of the steam generators.
Leakage between bare metal inspections could be identified by boric acid buildup at primary bowl insulation seams.
All 4 welds receive bare metal visual inspection once per interval.
(Code Case N-722-1 Item No. B15.120)
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58 of 124 5.3.5 Reactor Coolant Pumps Reactor coolant is circulated by four pumps, which are of the vertical single suction, centrifugal type. The pumps are constructed of high alloy casting (ASTM A351, CR CF8M) and stainless steel parts to minimize corrosion.
Reactor coolant pumps and attachment welds to loop piping do not include Alloy 600 material (ref. CR-PLP-2008-02388).
5.3.6 Reactor Coolant Piping Reactor coolant piping consists of the following:
a 42-inch ID hot leg pipe from the reactor vessel outlet to the SC inlet, a 30-inch ID cold leg pipe between the SC outlet and the pump suction nozzle, a 30-inch cold leg pipe between the pump discharge and the reactor vessel inlets, and a 12-inch, schedule 140 surge line pipe between the pressurizer and one hot leg. The reactor coolant piping is of rolled bond clad construction, with a base metal of ASTM A 516, Grade 70, with a cladding of 304L stainless steel with a nominal thickness of %-inch.
The 12-inch surge line is type 316 stainless steel. The 12-inch safety injection nozzles on the 30-inch ID cold leg pipes are constructed of carbon steel with stainless steel clad interior.
The 12-inch shutdown cooling nozzle on the 42-inch ID hot leg pipe is of the same construction.
Reactor coolant piping contains 55 Alloy 600 penetrations, categorized as follows:
(1) 12-inch, schedule 140 surge hot leg nozzle consisting of a carbon steel forging clad with type 304 stainless steel (ISI Weld IDs: PCS-12-PSL-IH1-8 and PCS PSL-1 H 1-7). An Alloy 600 safe-end is welded to the nozzle forging to permit welding to the connecting piping. MSIP was applied to the safe end to pipe weld, but not the safe end to nozzle weld, in 1995.
MSIP changes the residual stress patterns at these locations from tensile to compressive by plastically deforming the piping near the welds, in order to help mitigate PWSCC.
The welds associated with the surge line safe-end were examined in 1995 with acceptable results.
These welds are additionally UT examined every other refueling outage as required by a previous commitment to the NRC as detailed in reference 1.
Both welds are volumetrically examined every other refueling outage and are visually inspected during intervening outages.
(Code Case N-722-1 Item No. B15.210; N-770-1 unmitigated nozzle weld Code Inspection Item A-2)
(1) 12-inch, schedule 140, hot leg shutdown cooling outlet nozzle, consisting of an alloy steel forging, clad with type 304 stainless steel (ISI Weld IDs: PCS-12-SDC-2H1-1 and PCS-12-SDC-2H1-2).
An Alloy 600 SB-166 safe-end is welded to the nozzle forging to permit welding to the connecting piping.
MSIP was applied to the
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59 of 124 safe end to pipe weld, but not the safe end to nozzle weld, in 1995.
MSIP changes the residual stress patterns at these locations from tensile to compressive by plastically deforming the piping near the welds, in order to help mitigate PWSCC.
The welds associated with the shutdown cooling outlet safe-end were UT/PT examined in 1995 with acceptable results. These welds are also PT examined every other refueling outage as required by a previous commitment to the NRC as detailed in reference 1.
Both welds are volumetrically examined every other refueling outage and are visually inspected during intervening outages.
(Code Case N-722-1 Item No. B15.210; N-770-1 unmitigated nozzle weld Code Inspection Item A-2 (4) 12-inch, schedule 140, cold leg safety injection and shutdown cooling inlet nozzles, consisting of carbon steel forging, clad with type 304 stainless steel (ISI Weld IDs: PCS-1 2-SIS-1AI -11, PCS-12-SIS-IAI -12, PCS-12-SIS-1 BI -15, PCS-1 2-SlS-1 B1 -16, PCS-12-SIS-2A1-1 4, PCS-1 2-SIS-2A1 -15, PCS-12-SIS-2B1 -14, PCS 12-SIS-2B1-15).
An Alloy 600 SB-166 safe-end is welded to the nozzle forging to permit welding to the connecting piping.
All 8 welds are volumetrically examined every second inspection period (not exceeding 7 years) and are visually inspected once per interval.
(Code Case N-722-1 Item No. B15.215, N-770-1 Inspection Item B)
(1) 2-inch, schedule 160 hot leg drain, Alloy 600 nozzle (ISI Weld IDs: PCS DRL-IHI-1 and PCS-42-RCL-1H-3/2).
In 1995, the RCS pipe to nozzle weld was PT examined, and the nozzle to pipe weld was examined by UT/PT methods, with acceptable results.
During 1R23, it was determined that the branch connection welds should have been included in the examination scope on Code Case N-770-1. RR 4-18 was initiated to allow performance of the examinations in 1 R24.
The butt weld is volumetrically examined every third refueling outage, not to exceed 5 years (N-770-1 Inspection Item A-2).
The butt weld is visually inspected during all intervening outages (N-722-1 Item No. B15.210).
The full penetration branch weld is visually inspected every outage.
(Code Case N-722-1 Item No. B15.210)
The full penetration branch weld is volumetrically examined every third refueling outage, not to exceed 5 years (N-770-1 Inspection Item A-2).
(4) 2-inch, schedule 160 cold leg drain, Alloy 600 nozzles (ISI Weld IDs: PCS DRL-IAI -1, PCS-2-DRL-1 B1 -1, PCS-2-DRL-2A1 -1, PCS-2-LDL-2B1 -1, PCS RC L-1 A-512, PCS-30-RCL-1 B-512, PCS-30-RCL-2A-5/2, PCS-30-RCL-2B-5/2). The Loop 2B (P-50D) drain nozzle is referred to as the letdown nozzle.
In 1995, PT examinations were performed on the four RCS pipe to nozzle welds and the four
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60of124 nozzle to pipe welds associated with these drains.
All examinations performed in 1995 had acceptable results.
In June 2011, 10 CFR 55a added cold leg butt welds 2 and larger to the required scope of Code Case N-770-1 examinations, effective the first refueling outage after August 22, 2011.
During 1R23, the alloy 600 welds in the three cold leg drain nozzle to pipe butt welds were cut out and the drain piping removed under EC 45561. The nozzle was plugged with Alloy 690 plug and weld material 52M which are more resistant to PWSCC. This mitigation activity removed the three cold line drain nozzles to pipe butt welds from the scope of Code Case N-770-1.
During 1R23, it was determined that the branch connection welds should have been included in the examination scope on Code Case N-770-1. RR 4-18 was initiated to allow performance of the examinations in 1R24.
The letdown nozzle butt weld is volumetrically examined every second inspection period, not exceeding 7 years (Code Case N-770-1 Inspection Item B).
All four cold leg drain nozzle to pipe are visually inspected once per interval (Code Case N-722-1 Item No. B15.215).
All 4 full penetration branch welds are volumetrically examined every second inspection period, not exceeding 7 years (Code Case N-770-1 Inspection Item B).
All 4 full penetration branch welds are visually inspected once per interval.
(Code Case N-722-1 Item No. B15.215)
(2) 2-inch, schedule 160 cold leg charging inlet Alloy 600 nozzles (lSl Weld IDs PCS-2-CHL-1 Al -17, PCS-2-CHL-2A1 -48, PCS-30-RCL-l A-I 1/2, PCS-30-RCL-2A-11/2).
In June 2011, 10 CFR 55a added cold leg butt welds 2 and larger that operate >525° F to the required scope of Code Case N-770-I examinations, effective the first refueling outage after August 22, 2011.
In 1R23 the Alloy 600 weld material (82/182) for the nozzle to pipe weld on one of the charging nozzles was replaced with Alloy 52M material which is more resistant to PWSCC under EC 45560.
During 1 R23, it was determined that the branch connection welds should have been included in the examination scope on Code Case N-770-l. RR 4-18 was initiated to allow performance of the examinations in 1R24.
Both butt welds are visually inspected once per interval (Code Case N-722-1 Item No. BI5.215).
Both charging nozzle to pipe butt weld is volumetrically examined every second inspection period, not exceeding 7 years (Code Case N-770-l Inspection Item B).
Both full penetration branch welds are visually inspected once per interval.
(Code Case N-722-l Item No. Bl5.215)
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61 of 124 Both full penetration branch welds are volumetrically examined every second inspection period, not exceeding 7 years (Code Case N-770-I Inspection Item B).
(2) inch, schedule 160 cold leg spray supply Alloy 600 nozzles (ISI Weld IDs:
PCS-3-PSS-1 B1 -1, PCS-3-PSS-2A1 -I, PCS30-RCL-1 B-I 0/3, PCS-30-RCL-2A-11/3).
In June 2011, 10 CFR 55a added cold leg butt welds 2 and larger that operate >525° F to the required scope of Code Case N-770-1 examinations, effective the first refueling outage after August 22, 2011.
In I R23 the Alloy 600 weld material (82/1 82) for the nozzle to pipe weld was replaced with Alloy 52M material which is more resistant to PWSCC under EC 45560.
During 1R23, it was determined that the branch connection welds should have been included in the examination scope on Code Case N-770-1.
RR 4-18 was initiated to allow performance of the examinations in 1 R24.
Both butt welds are visually inspected once per interval (Code Case N-722-1 Item No. B15.215).
Both full penetration branch welds are visually inspected once per interval.
(Code Case N-722-1 Item No. B15.215)
Both full penetration branch welds are volumetrically examined every second inspection period, not exceeding 7 years (Code Case N-770-1 Inspection Item B).
(10)
- Temperature measurement, hot leg Alloy 600 nozzles, welded on the ID with a J-weld (ISI Weld IDs: PCS-042 Weld I
(TE-0112H), PCS-042 Weld 10 (TE 0122HB), PCS-042 Weld 2 (TE-O1I2HC), PCS-042 Weld 3 (TE-OI12HA), PCS-042 Weld 4 (TE-Ol 12HD), PCS-042 Weld 5 (TE-Ol I2HB), PCS-042 Weld 6 (TE-0122H),
PCS-042 Weld 7 (TE-0122HC), PCS-042 Weld 8 (TE-0122HD), PCS-042 Weld 9 (TE-Ol 22 HA)).
All 10 welds receive bare metal visual inspection every refueling outage.
(Code Case N-722-I Item No. B15.200)
(12)
- Temperature measurement, cold leg Alloy 600 nozzles, welded on the ID with a J-weld (ISI Weld IDs:
. PCS-043 Weld 1 (TE-OII1A), PCS-043 Weld 10 (TE 01 22CB), PCS-043 Weld II (TE-Ol 22CD), PCS-043 Weld 12 (TE-Ol 21 B), PCS-043 Weld 2 (TE-OI12CC), PCS-043 Weld 3 (TE-OII2CA), PCS-043 Weld 4 (TE-OII1B),
PCS-043 Weld 5 (TE-0122CD), PCS-043 Weld 6 (TE-0122CB), PCS-043 Weld 7 (TE-0122CA), PCS-043 Weld 8 (TE-0122CC), PCS-043 Weld 9 (TE-0121A))
All 12 welds receive bare metal visual inspection once per interval.
(Code Case N-722-l Item No. B15.205)
(10)
- %-inch, schedule 160, hot leg pressure measurement and sampling, Alloy 600
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62 of 124 nozzles, each with a stainless steel (SA-182, TP316) socket weld safe-end (ISI Weld IDs: PCS-011 Weld 15 (PCIOI3), PCS-011 Weld 15A (PC1O13), PCS-011 Weld 8 (PCIOI5), PCS-011 Weld 8A (PC1O15), PCS-012 Weld I (PCIOI4), PCS-012 Weld 15 (PC1OI6), PCS-012 Weld 15A (PCIOI6), PCS-012 Weld 1A (PC1O14), PCS-013 Weld 15 (PC1025), PCS-013 Weld 15A (PC1025), PCS-013 Weld 8 (PC1027),
PCS-013 Weld 8A (PC1027), PCS-014 Weld 20 (PC1026), PCS-014 Weld 20A (PC1026), PCS-014 Weld 6 (PC1024), PCS-014 Weld 6A (PC1024), PCS-026 Weld I (SX-1012), PCS-026 Weld 1A (SX-1012), PCS-027 Weld I (SX-1023A), PCS-027 Weld IA (SX-1023A)). In 1995, PT exams were performed on all 10 RCS pipe to nozzle welds, and UT/PT exams were performed on all 10 nozzle to safe-end welds, with acceptable results.
All 20 welds receive bare metal visual inspection every refueling outage.
(Code Case N-722-1 Item Nos. B15.200 and B15.210)
(8)
- %-inch, schedule 160, cold leg pressure measurement, Alloy 600 nozzles, each with a stainless steel (SA-182, TP316) socket weld safe-end (ISI Weld IDs: PCS 011 Weld 1 (PC1O17), PCS-011 Weld IA (PCIO17), PCS-011 Weld 22 (PC1OI8),
PCS-011 Weld 22A (PCIOI8), PCS-012 Weld 22 (PCIO2O), PCS-012 Weld 22A (PCi 020), PCS-012 Weld 8 (PCi 019), PCS-012 Weld 8A (PCIOI9), PCS-013 Weld 1 (PC1028), PCS-013 Weld 1A (PC1028), PCS-013 Weld 22 (PC1O3O), PCS-013 Weld 22A (PCIO3O), PCS-014 Weld 1 (PC1029), PCS-014 Weld 13 (PCIO31),
PCS-014 Weld 13A (PCIO3I), PCS-014 Weld 1A (PC1029)).
In 1995, PT exams were performed on all 8 RCS pipe to nozzle welds and all 8 nozzle to safe-end welds, with acceptable results.
All 16 welds receive bare metal visual inspection once per interval.
(Code Case N-722-i Item Nos. B15.205 and B15.215) 5.3.7 Repair Options for Alloy 600 Components Repair options, which had been included in Revision 20 of the Palisades ISI Master Program, have been relocated to the Palisades Site Engineering Procedure SEP A600-PLP-001, Nickel Alloy Program.
5.4 License Renewal Examinations for Aging Management Commitments Palisades License Renewal Application credits the ISI Program for aging management in the following sections: Reactor Vessel Internals, Reactor Coolant System, Reactor Pressure Vessel and Component Supports.
The license renewal examinations addressed by the Palisades ISI Program during the Fifth inspection interval are as follows:
WCAP-17133-NP, PWR Vessel Internals Program Plan for Aging Management of Reactor Internals at Palisades Nuclear
- Plant, is credited for implementation of renewed license requirements and has been submitted for regulatory approval.
Final scope and scheduling
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63 of 124 requirements are pending approval of the program. In the interim, inspections are being scheduled in accordance with the program as it was submitted.
5.4.1 Fire Piping Fire piping examinations under Palisades Site Engineering Program Section SEP-SW-PLP
- 002, Service Water and Fire Protection Inspection
- Program, are credited for implementation of renewed license requirements.
5.4.2 High Strength Bolting Source Document:
Palisades Aging Management Program Commitment No.:
CMTO92OI 1407 Associated Documents:
Passport ID 01038684-01 (LO-LAR-2009-244-1 1)
EPRI NP-5769, Degradation and Failure of Bolting in Nuclear Power Plants NUREG-1339, Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plants
Purpose:
Renewed License Commitment # 01038684-01 requires that high strength bolting used for component supports be evaluated for susceptibility to cracking and that appropriate inspection requirements be implemented to provide adequate age-management for the bolts. The evaluation identified specific high strength bolting associated with support of the pressurizer and the steam generators as being potentially susceptible to stress corrosion cracking (SCC).
Scope:
Steam Generator Snubber Anchor Bolting:
Inspection of susceptible SG snubber anchor bolting is addressed in snubber inspection procedure RT-42.
Pressurizer Support Frame Anchor Bolting:
For the pressurizer, bolting components determined to be potentially susceptible to SCC are the anchor bolts that attach the north and south lateral bracing for the pressurizer support frame to the building structure.
Reference detail entitled Plan
- Pressurizer Support on drawing C-160.
The north brace attaches to the wall via (8) embedded 1 3/8 diameter ASTM A-490 bolts. The south brace attaches to the wall via (8) through-bolted 1 3/8 ASTM A-490 bolts.
Aging Effects: Stress Corrosion Cracking (SCC)
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64 of 124 Method:
For SCC to occur, there must be corrosion or a corrosive environment. Evidence would include indications of current or past wetting of the bolts.
If evidence of corrosion or a corrosive environment is found, a check for SCC can be made via removal of bolting for further inspection, proof testing by tension or torquing, in-situ UT, or hammer testing. Prior to removal of any high strength bolting or their nuts, engineering will be contacted, in case of need to determine whether the bolting is reusable.
5.4.3 Nickel Alloy (Alloy 600)
Nickel alloy (Alloy 600) weld augmented and lSl examinations under Section 5.3 of this Master Program are credited for implementation of renewed license requirements.
5.4.4 RVI-AMP
Reactor Vessel Internals Aging Management Program WCAP-17133-NP, PWR Vessel Internals Program Plan for Aging Management of Reactor Internals at Palisades Nuclear Plant, is credited for implementation of renewed license requirements and has been submitted for regulatory approval.
Final scope and scheduling requirements are pending approval of the program.
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65 of 124 6.0 ASME Systems & Examination Boundaries 6.1 Definitions This section defines those systems that are designated as ASME Class 1, 2, or 3, and provides justification for their inclusion or exclusion within the Fifth Inspection Interval NDE Program. Some systems or portions of systems are excluded from system and component NDE as allowed by Articles IWB-1200, IWC-1200, and IWD-1200.
However, they are not excluded from system pressure testing requirements of ASME Section Xl Code, Section Xl, except as allowed by Articles IWA-5000, IWB-5000, IWC-5000, and IWD-5000. ASME Section XI (2007/2008) defines the inspection requirements for each of the ASME Section Xl Code Classes within the Fifth inspection Interval.
6.2 Classification Criteria Per IWA-1400(a) of ASME Section Xl (2007/2008), it is the responsibility of Palisades to determine the appropriate Code Class for each component and to identify the system boundaries subject to inspection.
IWA-1400(a), footnote 1, states that classification criteria are specified in 10 CFR 50.
This reference is to footnote 7 of 10 CFR 50.55a, which references Regulatory Guide 1.26 and Section 3.2.2 of NUREG-0800.
6.3 Inspection Rules The component classifications of the ASME Section Xl Code (Class 1, 2, or 3) determine the rules and requirements for inspection and define the Section Xl examination boundaries. The Palisades nuclear plant was designed and constructed before Section III of the ASME Boiler and Pressure Vessel Code was incorporated into 10 CFR 50.55a, so the ASME Section Xl Code classifications for ISI may differ from the original design classifications.
Therefore, while the ASME Section Xl Code classifications determine the rules for repairs and replacements and the component inspection requirements, repairs and replacements are generally performed to meet the specifications of the original design code.
The Palisades nuclear plant was designed and constructed prior to the issuance of the ASME Section Xl Code, before inspection access requirements of IS-142, 1971 Edition were available to impact plant design parameters. The technical specification/relief requests of this program detail specific Code requirements that cannot be met.
10 CFR 50.55a mandates the application, with additional conditions, of ASME Section Xl Code Cases N-722-1, N-729-1, and N-770-1 for inspection of Class I Alloy 600 pressure boundary welds.
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66 of 124 6.4 Quality Group Classification The Title 10 Code of Federal Regulations (10 CFR) provides criteria for the classification of Quality Group A (Class 1) components.
In previous issues of 10 CFR, this criterion was provided in section 50.2(v).
Regulatory Guide 1.26, Quality Group Classifications and Standards for Water, Steam, and Radioactive Waste Containing Components of Nuclear Power Plants, provides criteria for the classification of Quality Group B, C, and D components (Class 2, Class 3, and Non-Class, respectively). Regulatory Guide 1.26, Revision 3 was used for ASME Section Xl Code,Section XI component classification at Palisades.
6.5 Identification The ASME Section XI Code Class 1, 2, and 3 systems required to be examined in accordance with ASME Section Xl (2007/2008), are identified on color coded P&ID drawings.
These are Plant Controlled drawings. Color coding is:
ASME Section Xl Code Class 1:
Red ASME Section Xl Code Class 2:
Blue ASME Section XI Code Class 3:
Green ASME Section Xl Code boundary components are listed in Palisades Site Engineering Program Section SEP-ISI-PLP-002, ASME Code Boundaries for ASME Section Xl Inservice Inspection Program, Appendix A. Table 6.1 provides a correlation between a System within the ASME Section Xl Code boundaries and the associated P&IDs.
The original construction code used at Palisades did not require establishment of a weld reference system. A post-construction weld reference system in accordance with the ASME Section Xl Code,Section XI, IWA-2600, cannot be practically established at Palisades. Relief Request 4-11 permits the use of an alternative weld reference system during the Fifth Interval.
In lieu of marking weld identifications on each weld, Palisades provides detailed identification and location of each weld on isometric drawings.
If a weld containing volumetric indications is accepted for continued service under the acceptance criteria of IWX-3500 or IWX-3600, it shall be identified using appropriate reference marks to ensure it can be relocated. These reference marks may be permanently fixed on the weld or by documentation on a map or photograph of the weld or surface that permits accurate identification of areas on the examination surface (e.g., reference points, orientation, and/or proximity to other welds) to positively identify the weld or area in question and the examination starting point.
The starting point is determined from the instructions provided for determining the location of the zero reference point.
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Chemical & Volume Control Clean Radwaste Component Cooling Compressed Air P&ID # including Connecting Systems M-202, Sheet 1 Chemical and Volume Control M-202, Sheet 1A Chemical and Volume Control M-202, Sheet lB Chemical and Volume Control M-21 0, Sheet 1A Radioactive Waste Treatment Clean M-210, Sheet I B Radioactive Waste Treatment Clean M-210, Sheet 1C Radioactive Waste Treatment Clean M-210, Sheet 2 Radioactive Waste Treatment Clean M-208, Sheet 1A Service Water M-209, Sheet 1 Component Cooling M-209, Sheet 2 Component Cooling M-209, Sheet 3 Component Cooling M-219, Sheet lB Process Sampling M-221, Sheet 2 Spent Fuel Pool Cooling M-223, Sheet 1 B Radiation Monitoring and Sampling M-224, Sheet I Gas Analyzing M-212, Sheet 1 Service and Instrument Air M-212, Sheet 4 Instrument Air TABLE 6.1 PALISADES PLANT ASME SECTION Xl CODE CLASS SYSTEMS IDDENTIFIED BY ASSOCIATED P&IDs Demineralized Water Diesel Engine M-214, Sheet 1 Lube Oil, Fuel Oil and Diesel Generator Condensate M-207, Sheet 1 B Feedwater and Condensate M-220, Sheet 1 Make-Up Domestic Water and Chemical Injection M-221, Sheet 1 Shield Cooling M-220, Sheet I Make-Up Domestic Water and Chemical Injection Program Section No.: SEP-ISI-PLP-003
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P&lD # including Connecting Systems M-205, Sheet 2 Main Steam and Auxiliary Turbine M-207, Sheet 1 Feedwater and Condensate M-207, Sheet 2 Auxiliary Feedwater M-207, Sheet IA Feedwater and Condensate M-220, Sheet 2 Make-Up Domestic Water and Chemical Injection M-213, Sheet Service Water, Screen Structure and Chlorination M-203, Sheet I Safety Injection, Containment Spray and Shutdown Cooling M-203, Sheet 2 Safety Injection, Containment Spray and Shutdown Cooling M-204, Sheet 1 Safety Injection, Containment Spray and Shutdown Cooling M-204, Sheet 1A Safety Injection, Containment Spray and Shutdown Cooling M-204, Sheet lB Safety Injection and Containment Spray M-209, Sheet 2 Component Cooling M-219, Sheet lB Process Sampling M-221, Sheet 2 Spent Fuel Pool Cooling TABLE 6.1 PALISADES PLANT ASME SECTION XI CODE CLASS SYSTEMS IDDENTIFIED BY ASSOCIATED P&lDs Dirty Radwaste M-21 1, Sheet 1 Dirty Waste and Gaseous Waste Engineering Safeguards consisting of Safety Injection, Containment Spray and Shutdown Cooling Feedwater Fire Protection Main Steam M-205, Sheet I Main Steam, Main and Auxiliary Turbine M-205, Sheet 2 Main Steam and Auxiliary Turbine M-207, Sheet 1 Feedwater and Condensate M-226, Sheet 1 Steam Generator Blowdown Modification
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Miscellaneous Gas (N2)
TABLE 6.1 PALISADES PLANT ASME SECTION XI CODE CLASS SYSTEMS IDDENTIFIED BY ASSOCIATED P&lDs Waste Gas M-21 1, Sheet 2 Radioactive Waste Treatment Gaseous Waste M-224, Sheet 2 FSO-Containment Hydrogen Monitoring Service Water Spent Fuel Pool Ventilation & Air Conditioning M-222, Sheet 1 Miscellaneous Gas Supply M-222, Sheet 3 Miscellaneous Gas Supply M-201, Sheet 1 Primary Coolant M-201, Sheet 2 Primary Coolant M-207, Sheet I Feedwater and Condensate M-209, Sheet 1 Component Cooling M-219, Sheet lB Process Sampling M-208, Sheet 1A Service Water M-208, Sheet 1 B Service Water M-209, Sheet 3 Component Cooling M-213, Sheet Service Water, Screen Structure and Chlorination M-218, Sheet 7 Htg, Vent and Air Cond. Control Room M-223, Sheet lB Radiation Monitoring and Sampling M-653, Sheet 3 Cooling Tower M-221, Sheet 2 Spent Fuel Pool Cooling M-215, Sheet 1 Plant Heating M-218, Sheet 2 Htg, Vent and Air Cond. Containment Building M-218, Sheet 7 Htg, Vent and Air Cond. Control Room Reactor Coolant P&ID # including Connecting Systems
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70 of 124 7.0 Application Criteria and Code Compliance 7.1 ASME Section XI The following provides a summary of the application of ASME Section Xl (2007/2008) to the Palisades ISI Program for the Fifth Inspection Interval.
The application and distribution of examinations for this interval is based upon utilizing Inspection Program B as defined by Articles IWB-2412, IWC-2412, IWD-2412 and IWF-2410 of Section Xl.
The results of this application are summarized by ASME Category and Item number and are contained within Table found in section 7.4.1. The tables only contain ASME Item numbers that are relevant to Palisades.
7.1.1 CATEGORY B-A - PRESSURE RETAINING WELDS IN REACTOR VESSEL Reactor vessel examinations for the Third Interval were deferred until the Fourth Interval, with permission from the NRC. Relief Request TAC No. MD9205, dated February 11, 2009, allowed extension of Third Interval Category B-A and B-D reactor vessel weld examinations from 10-year to 20-year periodicity, ending December 12, 2015. Palisades performed examinations of the RV pressure retaining welds in January and February of the Palisades FaIl 2013 refueling outage per this extension request authorized under 10 CFR 50.55a. This was the Third RV ISI completed at Palisades.
Section Xl requires examination of the accessible length of all reactor vessel head welds.
The upper closure head has six meridional welds and one circumferential weld, all of which are inaccessible for examination due to nozzle and alignment grid interferences.
The reactor vessel lower head has six meridional welds and one circumferential weld. All meridional lower head welds are partially obstructed on the interior side by the flow skirt.
Examination from the exterior would result in unacceptably high radiation exposure.
However, the welds considered inaccessible or obstructed are still scheduled so that verification of inaccessibility or obstruction is validated.
Section XI requires examination of the reactor head to flange weld.
This meets the Examination Category B-A examination requirements in ASME Section XI (2007/2008).
7.1.2 CATEGORY B-B
- PRESSURE RETAINING WELDS IN VESSELS OTHER THAN REACTOR VESSELS ASME Section Xl (2007/2008), Examination Category B-B requires that pressurizer and primary side of steam generators and Class 1 heat exchangers be examined during the inspection interval.
The examinations may be limited to one of a group of vessels with similar function.
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71 of 124 PRESSURIZER Two longitudinal shell welds intersect each shell-to-head weld.
Section Xl requires examination of one foot of one intersecting longitudinal weld per head. One such weld per head is selected for examination, meeting the 50% inspection requirement.
Section Xl requires examination of both shell-to-head welds, but neither one can be fully scanned due to obstructions.
Both shell-to-head welds are selected for scanning of accessible volumes, meeting the 100% requirement. After the performance of the stated examinations, a relief request to address the less than essentially 100% coverage of either weld examined, as required per IWA-2200(c), will be submitted.
Pressurizer upper and lower heads each have four meridional welds and one circumferential weld.
Section Xl requires examination of one weld of each type per head.
The upper circumferential weld is selected, meeting the upper head requirement.
However, all lower head welds (circumferential and meridional) are obstructed.
As an alternative, the accessible length (25%) of each lower meridional weld will be scanned.
All four lower meridional welds are selected, meeting the 100% requirement. After the performance of the stated examinations, a relief request to address the less than essentially 100% coverage of any one of the meridional welds examined, as required per IWA-2200(c), will be submitted.
In addition, the pressurizer lower head receives a bare metal visual examination as part of mandatory Code Case N-722-1.
STEAM GENERATORS Each steam generator has eight Class 1
Examination Category B-B welds:
one circumferential head weld at the stay cylinder, one circumferential weld between the stay cylinder and tubesheet, five meridional head welds, and one tubesheet to head weld. Table IWB-2500-1, Category B-B, Note (1) allows examination to be limited to one vessel among a group of vessels performing a similar function, or 50%.
Table IWB-2500-1, Category B-B allows examination of one primary side head weld per head after the first inspection interval.
Two of four stay cylinder welds and one of two tubesheet to head welds are selected for examination, thus meeting the 50% inspection requirement.
One meridional weld is selected for examination, thus meeting 20% of 50% for a 10% inspection requirement.
REGENERATIVE HEAT EXCHANGER The Regenerative Heat Exchanger is constructed of two identical vertical heat exchanger vessels in series, each with one lower shell-to-lower head weld and one lower shell-to tubesheet weld.
The two vessels comprise one heat exchanger.
Due to the high dose incurred by such volumetric inspections, Code Case N-706-1 permits VT-2 visual pressure testing every cycle in lieu of volumetric examination once per interval. This is performed as part of the ASME Section Xl pressure testing program. Code Case N-706-1 was invoked at the last outage of the first inspection period.
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72 of 124 These meet Examination Category B-B examination requirements in ASME Section Xl (2007/2008).
7.1.3 CATEGORY B-D - FULL PENETRATION WELDS OF NOZZLES IN VESSELS This category applies to the reactor vessel, pressurizer, steam generators, and regenerative heat exchanger. ASME Section Xl does not allow deferral of these examinations, except for reactor vessel to nozzle welds.
Table IWB-2500-1, Category B-D, Note 3, allows partial deferral if examinations are conducted from inside the component and the nozzle weld is examined by straight beam UT from the nozzle bore. Examinations that must be conducted from the shell inside diameter may be performed at or near the end of the interval.
REACTOR VESSEL Relief Request TAC No. MD9205, dated February 11, 2009, allows extension of Third Interval Category B-A and B-D reactor vessel weld examinations from 10-year to 20-year periodicity, ending December 12, 2015.
PRESSURIZER All pressurizer nozzle-to-head welds and inner radii are selected for examination, meeting the 100% examination requirement.
10 CFR 50.55a(b)(2)(xxi)(A) requires that the provisions of Table IWB25001, Examination Category BD, Full Penetration Welded Nozzles in Vessels, Code Items B3.120 and B3.140 in the 1998 Edition must be applied when using ASME Section XI (2007/2008).
A visual examination with magnification that has a resolution sensitivity to detect a 1-mu width wire or crack, utilizing the allowable flaw length criteria in Table IWB35121 with a limiting assumption on the flaw aspect ratio (Le.,
a/l=0.5), may be performed instead of an ultrasonic examination.
STEAM GENERATORS 10 CFR 50.55a(b)(2)(xxi)(A) requires that the provisions of Table IWB2500--1, Examination Category BD, Full Penetration Welded Nozzles in Vessels, Code Items B3.120 and B3.140 in the 1998 Edition must be applied when using Section Xl (2007/2008).
A visual examination with magnification that has a resolution sensitivity to detect a 1-mil width wire or crack, utilizing the allowable flaw length criteria in Table IWB35121 with a limiting assumption on the flaw aspect ratio (i.e., a/l=0.5), may be performed instead of an ultrasonic examination.
All of the steam generator nozzle to vessel welds and nozzle inner radii are selected for examination, meeting the 100% examination requirement.
Each Steam Generator has three integrally cast nozzles. Therefore, all six inner radii are scheduled for examination.
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73 of 124 REGENERATIVE HEAT EXCHANGER The Regenerative Heat Exchanger is constructed of two identical vertical heat exchanger vessels in series, connected by primary and secondary side crossover pipes. There are four Class 1 nozzles.
Due to the high dose incurred by volumetric inspections, Code Case N-706-1 permits VT-2 visual pressure testing every cycle in lieu of volumetric examination once per interval.
This is performed as part of the ASME Section Xl pressure testing program.
This meets the Examination Category B-D examination requirements in ASME Section Xl (2007/2008), as modified by 10 CFR 50.55a(b)(2)(xxi)(A).
7.1.4 CATEGORY B-F
- PRESSURE RETAINING DISSIMILAR METAL WELDS IN VESSEL NOZZLES This category addresses pressure retaining dissimilar metal welds in vessel nozzles.
Palisades has six such nozzles in the pressurizer: three safety valve flanges, one surge line safe end, one spray safe end, and one power operated relief valve (PORV) transition piece.
All six welds are scheduled for ASME Section Xl examination. They also are subject to examination in accordance with Code Cases N-722-1, N-729-1, and N-770-1 as directed by 10 CFR 50.55a.
ASME Code Case N-716-1 allows inclusion of some Examination Category B-F welds into a risk informed lSl program.
Examination of these welds will not be covered under Examination Category B-F but under Examination Category R-A as discussed below.
This meets the Examination Category B-F examination requirements in ASME Section XI (2007/2008), as modified by 10 CFR 50.55a.
7.1.5 CATEGORY B-G-1
- PRESSURE RETAINING BOLTING, GREATER THAN 2 IN DIAMETER The examination of reactor vessel bolting, except for threads in the flange, is distributed across inspection periods, with one third of the fasteners examined each period. The flange will be examined at one time.
For volumetric examination of reactor coolant pump studs, one of four sets of studs is selected for volumetric examination.
For visual examination of pump bolting including flange ligaments, one reactor coolant pump will be examined only if disassembled. This is the same requirement as for Examination Category B-L-2 and will be met during the repair replacement process.
This meets the Examination Category B-G-1 examination requirements in ASME Section Xl (2007/2008).
7.1.6 CATEGORY B-G-2
- PRESSURE RETAINING BOLTING, 2 AND LESS IN DIAMETER This category includes connection bolting for reactor vessel CRDM housings and incore instrumentation flanges, pressurizer and steam generator manways, pressurizer relief valve
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74 of 124 inlet flanges, reactor coolant pump seals, and valves. This bolting will only be examined if associated connections are disassembled.
For components other than piping, bolting examinations will be required only when components are examined under Examination Category B-B, B-L-2, or B-M-2 (Palisades has included Category B-A for completeness, noting that the 2011 Addenda of Section Xl was revised to include Category B-A).
This meets the Examination Category B-G-2 examination requirements in ASME Section Xl (2007/2008).
CATEGORY B-J
- PRESSURE RETAINING WELDS IN PIPING This category addresses pressure retaining welds in piping, including carbon steel, stainless steel, nickel alloy, and dissimilar metal welds.
It does not include Category B-F dissimilar metal welds to vessel nozzles.
Pressure retaining dissimilar metal welds containing Alloy 600/82/182 material in the loading path also are subject to examination in accordance with Code Cases N-722-1, N-729-1, and N-770-1 as directed by 10 CFR 50.55a.
ASME Section Xl Code Case N-716-1 allows inclusion of the remaining Examination Category B-J welds into a risk informed ISI program. The risk informed ISI program will be implemented in the Fifth Inspection Interval. Examination of these welds will not be covered under Examination Category B-J but under Examination Category R-A as discussed below.
These alternative examinations to the Examination Category B-J examination requirements satisfies the requirements of ASME Section Xl (2007/2008), as modified by the applicable augmented lSl requirements of 10 CFR 50.55a.
7.1.7 CATEGORY B-K WELDED ATTACHMENTS FOR VESSELS, PIPING, PUMPS, AND VALVES This category requires examination of Integral Attachments. For multiple vessels of similar design, function, and service, Note 4 allows only one welded vessel attachment of only one of the multiple vessels shall be selected for examination.
For single vessels, only one welded attachment shall be selected for examination.
Palisades has one attachment weld on each Steam Generator and one attachment weld on the pressurizer. One of the two S/G attachment welds and the pressurizer attachment welds are selected for examination, or 66% of all vessel attachment welds.
For piping, pumps and valves, examination of 10% of the total population of integral welded attachments associated with the component supports selected for examination under IWF 2510 is required. There are a total of 160 piping supports, 41 of those supports have been selected for examination under IWF-2510. Of those supports selected for examination only 7 have welded attachments, 10% or 1 (4.5%) would require examination.
Each reactor
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75of 124 coolant pump has four support attachments with only one welded attachment of one pump required, therefore I of 16 is selected or 6.25%.
This meets the Examination Category B-K examination requirements in ASME Section Xl (2007/2008).
7.1.8 CATEGORY B-L-2
- PUMP CASINGS This category involves reactor coolant pumps and requires visual examination on pump casing welds and pump internal pressure retaining surfaces when disassembled.
The reactor coolant pumps are the only Code Class 1 pumps.
B-L-2 requires examination of one pump in each group of pumps performing similar functions in the system.
However, this examination is only required when a pump is dissembled for maintenance, repair, or volumetric examination. No Reactor Coolant Pumps have been selected. This requirement will be met during the repair/replacement process.
This meets the Examination Category B-L-2 examination requirements in ASME Section Xl (2007/2008).
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76 of 124 7.1.9 CATEGORY B-M-2
- VALVE BODIES These categories involve fourteen shutdown cooling and safety injection valves.
Examinations will be conducted as required in Table IWB-2500-1.
B-M-2 requires examination of one valve in each group of valves that are of the same size, constructural design, and manufacturing method, and that performs similar functions in the system.
However, this examination is only required when a valve is disassembled for maintenance, repair, or volumetric examination. No valve body internal surfaces have been selected. This requirement will be met during the repair/replacement process.
Class I valve bodies (B-M-2) not exceeding 4-inch nominal pipe size (NPS 4) are excluded by Table IWB-2500. Palisades Class I valves NPS 4 and larger have been separated into 3 valve groups, identified in the Program Type field in the Version 9 of the IDDEAL Software Suite computer program.
This meets the Examination Category B-M-2 examination requirements in ASME Section XI (2007/2008).
7.1.10 CATEGORY B-N-I
- INTERIOR OF REACTOR VESSEL These examinations shall include the spaces above and below the reactor core and will be conducted each inspection period when pressure retaining surfaces are exposed by removal of components during normal refueling operations.
This meets the Examination Category B-N-i examination requirements in ASME Section Xl (2007/2008).
7.1.11 CATEGORY B-N-2
- WELDED CORE SUPPORT STRUCTURES AND INTERIOR ATTACHMENTS TO REACTOR VESSEL These examinations will be conducted once per interval.
This meets the Examination Category B-N-2 examination requirements in ASME Section Xl (2007/2008).
7.1.12 CATEGORY B-N-3
- REMOVABLE CORE SUPPORT STRUCTURES This examination will be conducted once per interval.
This meets the Examination Category B-N-2 examination requirements in ASME Section Xl (2007/2008).
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77of 124 7.1.13 CATEGORY B-C
- PRESSURE RETAINING WELDS IN CONTROL ROD HOUSING AND INSTRUMENT NOZZLE HOUSINGS ASME Section Xl (2007/2008) requires volumetric or surface examination of 10% of peripheral control rod drive housings during the inspection interval. Palisades committed to volumetric examination of the replacement housings. 20 of the 45 Control Rod Drive (CRD)
Upper Housings are in peripheral locations.
Each housing has 2 welds plus each CRD penetration has one weld at the penetration flange for a total of 60 CRD peripheral welds.
10% of the peripheral welds require examination, therefore 6. In addition there are 8 ICI penetration flange welds on the periphery. 10% of the peripheral welds require examination, therefore 1.
Total welds to be examined is 7.
This meets the Examination Category B-O examination requirements in ASME Section Xl (2007/2008).
7.1.14 CATEGORY B-P
- ALL PRESSURE RETAINING COMPONENTS The pressure testing program at Palisades meets the requirements for Class I systems in ASME Section Xl (2007/2008). Details are in the Pressure Test Program.
7.1.15 CATEGORY B-Q
- STEAM GENERATOR TUBING Palisades Technical Specification 5.5.8 governs the S/G tube inspection program.
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78 of 124 7.1.16 CATEGORY C-A
- PRESSURE RETAINING WELDS IN PRESSURE VESSELS This category applies to the steam generators, shutdown cooling heat exchangers, and regenerative heat exchanger. Note (3) allows required examinations to be limited to one vessel or distributed among the vessels, in the case of multiple vessels of similar design, size, and service.
STEAM GENERATORS Palisades S/G shells each have one Category C-A head weld, two conical transitions, one tubesheet weld, and one internal stay cap-to-tubesheet weld.
Two tubesheet welds on one S/G are selected for 50%.
Steam generator upper shell-to-cone welds are not accessible for 100% inspection as required by the Code.
ASME SECTION Xl CODE CASE N-716-1 ASME Section Xl Code Case N-716-1 allows inclusion of some Examination Category C-A welds into a risk informed ISI program. Steam Generators are not determined to be of low risk, and as such, will be examined per the requirements of Category C-A. The Shutdown Cooling Heat Exchanger and the Regenerative Heat Exchanger are included in the scope on Code Case N-716-1. The risk informed ISI program will be implemented in the Fifth Inspection Interval.
Examination of welds associated with these components will not be covered under Examination Category C-A but under Examination Category R-A, as discussed below.
This meets the Examination Category C-A examination requirements in ASME Section Xl (2007/2008).
7.1.17 CATEGORY C-B
- PRESSURE RETAINING NOZZLE WELDS IN VESSELS This category applies to the nozzles of the two steam generators only.
The shutdown cooling heat exchanger nozzles will be assessed for examination per the requirements of CC N-716-1.
Table IWC-2500-1, Category C-B, Note (1) excludes manways and handholes.
Note (3) requires that nozzles selected initially for examination be reexamined over the service life of the component. In the case of multiple vessels of similar design, size, and service, Note (4) allows required examinations to be limited to one vessel or distributed among the vessels.
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79 of 124 STEAM GENERATORS C2.21 One inlet nozzle-to-shell weld, one outlet nozzle-to-shell weld, one recirculation nozzle-to-shell weld, and one auxiliary feedwater nozzle-to-shell weld on one steam generator are selected for examination, for 50%.
C2.22 One inlet nozzle-to-shell weld, one outlet nozzle-to-shell weld, and one recirculation nozzle-to-shell weld on one steam generator are selected for examination, for 50%.
SHUTDOWN COOLING HEAT EXCHANGERS AND REGENRATIVE HEAT EXCHANGER ASME Section Xl Code Case N-716-l allows inclusion of some Examination Category C-B
- welds, which includes the Shutdown Cooling Heat Exchangers nozzle welds and Regenerative Heat Exchanger nozzle weld, into a risk informed ISI program.
The risk informed lSl program will be implemented in the Fifth Inspection Interval.
Examination of these Shutdown Cooling Heat Exchangers nozzle welds will not be covered under Examination Category C-B but under Examination Category R-A, as discussed below.
This meets the Examination Category C-B examination requirements in the 2007 Edition through the 2008 Addenda of Section Xl.
7.1.18 CATEGORY C-C
- WELDED ATTACHMENTS FOR VESSELS, PIPING, PUMPS, AND VALVES Examination Category C-C of ASME Section Xl (2007/2008) requires examination of integral attachments.
For multiple vessels of similar design, function, and service, Note 4 allows only one welded attachment among the multiple vessels to be selected for examination.
Each of the two steam generators has six welded upper vessel support attachments. One attachment is selected for examination, for 8.3% of all vessel welded attachments.
For piping, pumps and valves, examination of 10% of the total population of integral welded attachments associated with the component supports selected for examination under IWF 2510 is required. There are a total of 447 piping supports, 71 of those supports have been selected for examination under IWF-2510. Of those supports selected for examination only 13 have welded attachments, 10% or 2 (3.57%) would require examination.
This meets the Examination Category C-C examination requirements in ASME Section Xl (2007/2008).
(Note:
CATEGORY C-D, PRESSURE RETAINING BOLTING GREATER THAN 21n.
IN DIAMETER, is not applicable to this ISI program.)
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80 of 124 7.1.19 CATEGORY C-F-i-PRESSURE RETAINING WELDS IN AUSTENITIC STAINLESS STEEL OR HIGH ALLOY PIPING This category addresses Class 2 pressure retaining welds in austenitic stainless steel and high alloy piping.
ASME Section Xl Code Case N-7i6-i allows inclusion of Examination Category C-F-i welds into a risk informed ISI program. The risk informed ISI program will be implemented in the Fifth Inspection Interval.
Examination of these welds will not be covered under Examination Category C-F-i but under Examination Category R-A as discussed below.
This meets the Examination Category C-F-i examination requirements in ASME Section Xl (2007/2008), as modified by 10 CFR 50.55a.
7.1.20 CATEGORY C-F-2
- PRESSURE RETAINING WELDS IN CARBON OR LOW ALLOY STEEL PIPING This category addresses Class 2 pressure retaining welds in carbon and low alloy steel piping ASME Section XI Code Case N-7i6-i allows inclusion of Examination Category C-F-2 welds into a risk informed lSl program. The risk informed ISI program will be implemented in the Fifth Inspection Interval.
Examination of these welds will not be covered under Examination Category C-F-2 but under Examination Category R-A as discussed below.
This meets the Examination Category C-F-2 examination requirements in ASME Section Xl (2007/2008), as modified by 10 CFR 50.55a.
7.1.21 CATEGORY C-H
- ALL PRESSURE RETAINING COMPONENTS The pressure testing program at Palisades meets the requirements for Class 2 systems in ASME Section Xl (2007/2008). Details are contained in the Pressure Test Program.
7.1.22 CATEGORY D-A WELDED ATTACHMENTS FOR VESSELS, PIPING, PUMPS, AND VALVES Examination Category D-A of ASME Section Xl (2007/2008) requires examination of welded attachments. Palisades has no vessel attachment welds.
For piping, pumps, and valves, inspection of 10% of the total population of welded attachments is required.
All welded attachments selected for examination shall be those most subject to corrosion, as determined by Palisades.
Ten percent of all piping welded attachments are selected for examination. Selections are proportional to the total number of nonexempt welded attachments in each system.
This meets the Examination Category D-A examination requirements in ASME Section Xl (2007/2008).
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81 of 124 7.1.23 CATEGORY D-B ALL PRESSURE RETAINING COMPONENTS The pressure testing program at Palisades meets the requirements for Class 3 systems in ASME Section Xl (2007/2008). Details are contained in the Pressure Test Program.
7.1.24 CATEGORY F-A - SUPPORTS Examination Category F-A of the ASME Section Xl (2007/2008) requires VT-3 visual examination of Class 1, 2, and 3 piping and non-piping supports. The supports have been separated by type as defined in Note (I) to Examination Category F-A. This type has been added to the Item Number to clearly identify each support by type.
Suffix A:
Unidirectional supports such as rod hangers Suffix B:
Multidirectional supports such as restraints Suffix C:
Supports that allow thermal movement The following percentages of piping supports must be examined during the inspection interval, prorated by type and function within each system. Palisades has selected supports for examination accordingly.
Class 1 (F1.l0) 25%
Class 2(Fl.20) 15%
Class 3(Fl.30) 10%
Supports Other Than Piping Supports (Fl.40)
For multiple non-piping components of similar design, function, and service, Category F-A, Note (3), requires the non-piping supports of only one component to be scheduled for inspection. Palisades has scheduled the following supports:
One of two Steam Generator lower vessel support structures; Six of twelve Steam Generator upper vessel support structures; One Pressurizer lower vessel support structure; One of four Reactor Coolant Pump support structures; Three of six Regenerative Heat Exchanger supports; One of two High Pressure Safety Injection Pump supports; One of two Low Pressure Safety Injection Pump supports; One of three Containment Spray Pump supports.
One CRDM Shock Mount Assembly Reactor pressure vessel supports are inaccessible per IWF-1230, as they are encased in concrete within the reactor cavity bioshield.
CRDM shock mount assemblies were added to the ISI program per CR-PLP-20l4-05596.
The CRDM shock mount assemblies consist of 45 subassemblies (one attached to each CRDM Upper Housing. Palisades CRDM housings are not connected to any other structure
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82 of 124 except at the reactor head where the housings are anchored.
The housings are interconnected by the snubber like shock mount assemblies which are composed of mating cylinders and bars. The shock mount assemblies allow some relative axial movement of the mating cylinder and bar but restrict housing relative rotations.
The CRD shock mount assemblies are entered into the lSl program as one component as the assemblies act in unison to perform their support function.
16 of 33 accessible non-piping supports are selected for examination, for 48% of all non-piping supports.
The selection of these component supports for examination meets the requirements of Examination Category F-A Examination Requirements in ASME Section Xl (2007/2008).
7.1.25 CATEGORY R-A-- RISK INFORMED ISI (ASME SECTION XI CODE CASE N-716-l)
ASME Section XI Code Case N-716-1 applies to the High Safety Significant (HSS) piping and components at the Palisades Nuclear Plant. This program supports the 4th and 5th ISI Intervals at Palisades.
The scope of the program includes all Examination Category B-F, B-J, C-F-i and C-F-2 piping welds, Examination Category C-A (pressure retaining welds in pressure vessels),
Examination Category C-B (pressure retaining nozzle welds in vessels), Examination Category C-D (pressure retaining bolting > 2 inch diameter), and Examination Category C-G (pressure retaining welds in pumps and valves) identified in the ISI Program Weld Databases as well as all BER program welds> NPS 4 and any additional piping segments determined to be high safety significant based on review of the plant PRA. Section 10 provides more details on the RI-ISI program.
The risk informed lSl program will be implemented during the plants Third Period of the current (fourth) inspection interval. By the end of Second Period of the Fourth ISI interval, 56% of the piping weld examinations required by ASME Section XI had been completed for Examination Categories B-F, B-J, C F-i and C-F-2, with the remaining 44% of the examinations to be completed during the two refueling outages in the Third Period (I R23 and I R24). The examinations in the first outage of the Third Period (1 R23) were completed under the ASME Section Xl requirements while the examinations in the second outage of the Third Period (1 R24) will be completed per the risk informed ISI process. Examinations will be performed such that the period percentage requirements of ASME Section XI are met.
The results of this application are summarized by ASME Category and Item number and are contained within Table found in section 7.4.2. The table only contains ASME Item numbers that are relevant to Palisades.
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83 of 124 7.1.26 CODE CASE N-722-1
- PWR CLASS I COMPONENTS FABRICATED WITH ALLOY 600/82/182 MATERALS Code Case N-722 has been mandated, with conditions, by 10 CFR 50.55a. This Code Case requires visual examination of Class 1 components containing Alloy 600/82/1 82 material. Examination requirements are discussed in Master Program Section 5.3, Alloy 600 Program.
The selection of these welds for examination meets the requirements of Code Case N-722 examination requirements as mandated in 10 CFR 50.55a.
The results of this application are summarized by ASME Category and Item number and are contained within Table found in section 7.4.3. The table only contains ASME Item numbers that are relevant to Palisades.
7.1.27 CODE CASE N-729-1
- PRESSURE RETAINING PARTIAL PENETRATION WELDS IN VESSELS Code Case N-729-1 has been mandated, with conditions, by 10 CFR 50.55a. This Code Case requires visual and volumetric examination of the reactor vessel upper head.
Examination requirements are discussed in Master Program Section 5.3, Alloy 600 Program.
The selection of these examination components meets the requirements of Code Case N-729-1 examination requirements as mandated in 10 CFR 50.55a.
The results of this application are summarized by ASME Category and Item number and are contained within Table found in section 7.4.3. The table only contains ASME Item numbers that are relevant to Palisades.
7.1.28 CODE CASE N-770-1
- PRESSURE RETAINING BUTT WELDS IN PIPING AND VESSELS Code Case N-770-1 has been mandated, with conditions, by 10 CFR 50.55a. This Code Case requires visual examination of Class 1 pressure boundary butt welds NPS 1 and larger, and volumetric examination of Class 1 pressure boundary butt welds NPS 2 and larger, if they contain Alloy 600/82/1 82 material and operate above 525° F. Examination requirements are discussed in Master Program Section 5.3, Alloy 600 Program.
Baseline PDI UT examination of essentially 100% in axial and circumferential directions by the end of the first refueling outage after January 20, 2012 was required. Two Palisades welds could not be examined at all, and five others could not attain the required coverage.
Hardship Relief Request 4-12 deferred baseline examinations of these seven welds to the 2013 outage.
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84 of 124 The selection of these examination components meets the requirements of Code Case N-770-1 examination requirements as mandated in 10 CFR 50.55a.
The results of this application are summarized by ASME Category and Item number and are contained within Table found in section 7.4.3. The table only contains ASME Item numbers that are relevant to Palisades.
7.2 Augmented Program 7.2.1 RCP Flywheels The Reactor Coolant Pump Motor flywheels will be inspected as required by Palisades Technical Specification 5.5.6. Inservice inspection of each reactor coolant pump flywheel shall be performed at least once every ten years in accordance with Regulatory Guide 1.14, Revision 1, August 1975, section C.4.B.1. The RCP Flywheels are scheduled to meet these augmented requirements.
These examinations are to be performed to the extent possible through the access ports in the motor housings without disassembly of the motors. All 4 RCP flywheels shall be inspected once every ISI 10-Year Interval and are scheduled to meet this augmented requirement.
The results of this application are summarized by ASME Category and Item number and are contained within Table found in section 7.4.4.
7.2.2 ESS Check Valve Weld Overlays Two stainless steel ESS check valve weld overlays shall be surface and volumetrically examined in accordance with the Performance Demonstration Initiative (PDI) Program. The weld overlay shall be examined every refueling outage. These welds are scheduled to meet these augmented requirements.
The results of this application are summarized by ASME Category and Item number and are contained within Table found in section 7.4.4.
7.2.3 NUREG-0612 The special lifting devices addressed by this augmented examination are Lift Rigs for the RPV Closure Head, Upper Guide Structure, Core Support Barrel, and Missile Shield. They are subject to visual examination within one year before use. Once every five years, they are subject to surface examination and, as specified, volumetric examination. Examinations are controlled by Palisades Permanent Maintenance Procedure CLP-M-6.
The results of this application are summarized by ASME Category and Item number and are contained within Table found in section 7.4.4.
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85 of 124 7.2.4 BL88-08 Examinations of auxiliary spray piping in accordance NRC Bulletin 88-08 shall be performed every five years. These examinations are scheduled to meet this augmented requirement.
The results of this application are summarized by ASME Category and Item number and are contained within Table found in section 7.4.4.
7.2.5 ORM 4.12 Examinations are required on 100% of the piping welds subject to High energy Line Break (HELB), in accordance with Operating Requirements Manual 4.12. Ultrasonic examinations will be performed on each of the subject welds once per 10 year interval, and visual examination for leakage will be performed weekly. Examinations are scheduled to meet this augmented requirement.
The results of this application are summarized by ASME Category and Item number and are contained within Table found in section 7.4.4.
7.2.6 AF-SI Augmented volumetric, FAC, and visual exams will assess structural integrity of Auxiliary Feedwater System Piping at the Steam Generators. Examinations are scheduled as required to meet this augmented requirement.
The results of this application are summarized by ASME Category and Item number and are contained within Table found in section 7.4.4.
7.2.7 MRP-146 MRP-146S identified one normally stagnant reactor coolant piping segment as potentially susceptible to thermal fatigue. The one location have been scheduled for examination every other cycle to meet this augmented requirement.
The results of this application are summarized by ASME Category and Item number and are contained within Table found in section 7.4.4.
7.2.8 Pressurizer Spray Line A postulated break of the Pressurizer Spray Line is assumed as a double-ended guillotine rupture that results in the whipping pipe striking a cable tray approximately 20 feet from the
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86 of 124 pipe. The purpose of this examination was to prevent damage to a hydrogen recombiner cable in that cable tray. The subject weld shall be included within the scope of welds to be examined every interval.
The hydrogen recombiners have been removed, but the commitment has not been withdrawn.
The weld is scheduled to meet this augmented requirement.
The results of this application are summarized by ASME Category and Item number and are contained within Table found in section 7.4.4.
7.2.9 MRP-227A PWR Internal Vessel Inspection The Materials Reliability Program (MRP) developed inspection and evaluation (l&E) for managing long-term aging reactor vessel internal components of pressurized water reactors (PWRs) reactor internals. For Palisades this includes the following components:
- 1) Core Shroud Assembly (Bolted) Core Shroud Bolts, 2) Core Shroud Assembly (Bolted) Assembly,
- 3) Core Support Barrel Assembly Upper (core support barrel) flange weld, 4) Core Support Barrel Assembly Lower cylinder girth welds, 5) Lower Support Structure Core support column welds, 6) Lower Support Structure Core support plate, and 7) Control Element Assembly Instrument guide tubes.
The results of this application are summarized by ASME Category and Item number and are contained within Table found in section 7.4.4.
7.3 Owner Elected Program 7.3.1 Upper CRD Housing Perform internal examinations of two upper housings each 10 year interval. One housing should be selected from the periphery housings and one housing should be selected from the remaining internal housings. Examination method performed is either Eddy Current or Visual Examination.
The results of this application are summarized by ASME Category and Item number and are contained within Table found in section 7.4.5.
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87 of 124 7.4 Code Category Summary 7.4.1 ASME Section Xl Palisades ASME Section Xl Code Category Summary R
dto Numberto Numberto Numberto E
Number of b
d Examination Numbertobe be be be Category N ier Description Mhod Components in e
Dun Percentage Examined in Examined Examined Examined U
Item No.
mt Required Interval in First in Second in Third e
a Penod Period Penod B-A Pressure Retaining Welds in Reactor Vessel B-A B1.11 Circumferential Shell Volumetric 3
3 100%
All Welds 0
3 0
Welds B-A B1.12 Longitudinal SheliWelds Volumetric 9
9 100%
All Welds 0
9 0
Accessible B-A B1.21 Cwcumferential Head Volumetric 2
2 100%(1)
Length of All 0
2 0
e S
Welds Accessible B-A B1.22 Meridional Head Welds Volumetric 12 12 100%
Length of All 0
12 0
B-A 81.30 Shell to Flange Weld Volumetric 1
1 100%
All Welds 0
1 0
B-A Bi.40 Head to Flange Weld 1
1 100%
All Welds 0
1 0
Category Total 28 28 0
28 0
Notes for C t B-A Note 1: Section Xl requires examination of the accessible length of all reactor vessel head welds. Note the NRC SER for a.
4 th Interval Relief Request RR 4-1 indicated that relief was not required for the meridional welds.
B-B Pressure Retaining Welds in Vessels Other Than Reactor Vessels B-B B2.11 Volumetric 2
2 100%(1)
Both welds I
0 1
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88 of 124 Palisades ASME Section XI Code Category Summary Number to Number to Number to Number of Required tO Examination Number to be be be be Category Number Description Method Components in be Dunn Percentage Examined in Examined Examined Examined Item No.
Intervl Required Interval in First in Second in Third Period Period Period B-B B2.12 Volumetric 4
2 5%(2>
weld per head 1
1 0
PZR Head Welds (3)
One B2.20 B-B B2.21 Circumferential Volumetric 2
2 100/o weld per head 0
1 1
One B2.20 weld per head. 25% of B-B B2.22 PZR Head Welds Volumetric 8
2 25%
four lower 0
2 0
Meridional welds in lieu of one lower head weld.
B B B2 31 SIG (Primary Side) Head I
ic 4
1 25°/
One B2.30 0
0 1
Welds Circumferential o ume r weld per head B-B B2.32 S/G(PrimarySkle) Head Volumetric 10 1
1O%
ead 0
0 1
B-B B2.40 Tubesheet-to-Head Weld Volumetric 2
1 5O%
Weld 0
0 1
Regen HX (Primary Side)
Vol met ic VT-2 every B-B B2.51 Head-to-Shell Welds (5) r 2
2 1OO%
cycle in lieu of Circumferential volumetric 5
Regen HX (Primary Side)
VT-2 every B-B B2.80 Shell -to-Tubesheet Voluetric 2
2 1OO%
cycle in lieu of Welds volumetric Category Total 36 2
4 5
Notes for Cat. B-B See following page.
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3 89 of 124 Palisades ASME Section Xl Code Category Summary Number to Number to Number to Number of Required to Examination Number to be be be be Category Number Description Components in be xarnined Percentage Examined in Examined Examined Examined Item No.
In,l Required Interval in First in Second in Third Period Period Period Note 1: Section XI requires examination of both shell-to-head welds, but neither one can be fully scanned due to obstructions. After the performance of the stated examinations, a relief request to address the less than essentially 100% coverage of either weld examined, as required per IWA-2200(c), will be submitted.
Note 2: Each head has two longitudinal welds. Section Xl requires examination of one longitudinal weld per head. Two of the 4 longitudinal welds are selected for examination or 50%.
Note 3: For the upper head, circumferential weld 2-983 is selected, the lower head circumferential weld 2-984 is inaccessible. The Pressurizer upper and lower heads each have four meridional welds and one circumferential weld.Section XI requires examination of one weld per head. However, all lower head welds are obstructed. As an alternative, the accessible length (25%) of each lower meridional weld will be scanned, meeting the 100% requirement. After the performance of the stated N
f B-B examinations, due to configuration and design of the Lower Head Circumferential and Meridional Welds a Relief Request for 0 es or a.
Impracticality will be required (Reference Relief Request 4-2 from 4 th Interval).
Note 4: The examination may be limited to one vessel among the group of vessels performing a similar function. (Ref. Table IWB 2500-1, Examination Category B-B, Note 1)
There are two SGs each with 2 class 1 welds per head. Only one of multiple vessels requires examination and only one weld per head, therefore 1 weld is required or 25% for Item No. B2.31. For Item B2.32 welds there are 5 meridional welds on each steam generator. Only one of the multiple vessels requires examination and only one weld per head therefore 1 weld or 10%.
Note 5: Each regenerative heat exchanger vessel has one circumferential head weld and one circumferential shell-to-tubesheet weld.
The two regenerative heat exchanger vessels comprise one heat exchanger. Code Case N-706-1 permits VT-2 pressure test every cycle in lieu of volumetric examination once per interval. This is performed in conjunction with the ASME Pressure Testing Program.
B-D Full Penetration Welded Nozzles in Vessels Reactor Vessel Nozzle B-D B3.90 I Volumetric to-Vessel Welds I
Reactor Vessel Nozzle B-D 83.100 Volumetric Inside Radius Section
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9Oof 124 Palisades ASME Section XI Code Category Summary Number to Number to Number to Number of Required to Examination Number to be be be be Item Exam be Examined Category Number Description Method Components in Dunng Percentage Examined in Examined Examined Examined Item No.
Interval Required Interval in First in Second in Third Period Period Period Accessible PZR Nozzle-to-Vessel volumes of B-D B3.110 Volumetric 6
6 100%
0 4
2 Welds welds Volumetric PZR Nozzle All nozzles B-D B3.120 orvisual 6
6 100%
(1)(2) 0 4
2 Inside Radius Section (2)
B-D B3.130 SIG (Primary Side)
Volumetric 6
6 100%
All nozzles 3
3 0
3 Nozzle-to-Vessel Weld SIG (Primary Side)
Volumetric All nozzles B-D B3.140 Nozzle or visual 6
6 100%
(l)(2) 3 0
3 Inside Radius Section (2)
B-D B3.150 Regen HX (Primary Side)
Volumetric VT-2 every 4
4 100%
cycle in lieu of Nozzle-to-Vessel Welds (4) volumetric 4
Regen HX (Primary Side)
Volumetric VT-2 every B-D B3.160 Nozzle or visual 2
2 100%
cycle in lieu of Inside Radius Section (4) volumetric 4
Category Total 42 6
20 10
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9lof 124 Palisades ASME Section Xl Code Catego Summa Numbertol Numberto I Numberto I
Number of Required to I
I i
Item I
Exam I be Examined Examination I Number to be be I
be I
be Category Number Description Method Components in During I Percentage Examined in Examined Examined Examined Item No.
Interval I
Required Interval I
in First in Second I
in Third I
Period I
Period I
Period Note 1: 10 CFR 50.55a(b)(2)(xxi)(A) requires that the provisions of Table IWB25001, Examination Category BD, Code Items B3.120 and 83.140 in the 1998 Edition must be applied.
Note 2: 10 CFR 50.55a(b)(2)(xxi)(A) allows use of a visual examination with magnification that has a resolution sensitivity to detect a 1-mil width wire or crack, utilizing the allowable flaw length criteria in Table IWB35121, with a limiting assumption on the flaw Notes for Cat. B-D aspect ratio (i.e., all=0.5), instead of an ultrasonic examination. Note 3: The nozzle welds on the steam generator are partially inaccessible. A limited exam relief request will be necessary following the examination (Reference Relief Request 4-3 in the 4 Interval).
Note 4: Each regenerative heat exchanger vessel has one Class I circumferential nozzle-to-vessel weld. The two regenerative heat exchanger vessels comprise one heat exchanger. Code Case N-706-1 permits VT-2 pressure test every cycle in lieu of volumetric examination once per interval. This is performed in conjunction with the ASME Pressure Testing Program.
B-F I Pressure Retaining Dissimilar Metal Welds in Vessel Nozzles B-F B5.40 IPressurizer Nozzle-to-I Volumetric 4
I I
I I
I I
ISafe End Butt Welds land Surface I
I I
I I
Category TotalI 4(1)
I I
I I
I
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92 of 124 Palisades ASME Section Xl Code Category Summary Numbertol Numberto I Numberto Exam Number of Required to I Examination I Number to be be I
be I
be be Examined I Category Number Description Method Componen During I
Percentage I
Examined in Examined I Examined I Examined Item No.
Interval Required Interval in First I in Second I
in Third Period I
Period I
Period Note 1:Code Case N-716-1 allows inclusion of the Examination Category B-F welds, excluding dissimilar metal welds subject to examination to the requirements of Code Cases N-722-1 and N-770-1, into a risk informed ISI program (Note: dissimilar metal welds with damage mechanisms in addition to PWSCC are included in Category Notes for Cat. B-F R-A, two previously identified B5.40 welds are now included into Category R-A, Ri. 11, but still examined under Code Cases N-722-1 and N-770-i).
The risk informed ISI program will be implemented in the Fifth Inspection Interval. The excluded welds will be examined per the requirements of the noted Code Cases and 10 CFR 50.55a.
B-G-1 Pressure Retaining Bolting, Greater Than 2 in. (50 mm) in Diameter Reactor Vessel Closure B-C-I B6.10 Visual, VT-i 3(5) 3(5) 100%
All nuts i
i Head Nuts (l8IComp. ID)
Reactor Vessel Closure Volumetric 3(5) 3(5) 1 OO%
All studs (5)
(5)
B-G-l B6.20 Studs (4)
(18/Comp. ID)
Reactor Vessel Threads Volumetric All holes B-C-I B6.40 in Flange (4) 1 1
l00%
(54/Comp. ID) 0 0
1 Reactor Vessel Closure B-G-1 B6.50 Visual, VT-i 3(5) 3(5) 100%
All washers Washers, Bushings (18/Cornp. ID)
Volumetric All bolts &
B-C-I B6.180 Pump Bolts and Studs (4) 4 1
25%(2)(4) studs 1
0 0
(16/Comp. ID)
Pumps Flange Surface B-C-i B6.i90 when connection Visual, VT-i 4
1 25%(1)(3)
All holes 0
0 0
disassembled (i6/Comp. ID)
B-G-l B6.200 Pumps Nuts, Bushings, Visual, VT-i 4
1 25%(1)(3)
All nuts 0
0 0
and Washers (16/Comp. ID)
Category Total 22 13 4
3 4
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93 of 124 Palisades ASME Section XI Code Category Summary I
INumbertol Numberto I Numberto Item I
Exa I
Number of Required to I Examination Number to be I be I
be I
be be Examined I Category Number Description Method Components in I During Percentage Examined in I Examined Examined I Examined Interval Required Interval in First in Second in Third Item No.
Period I
Period I
Period Note 1: Not required unless disassembled.
Note 2: Volumetric examination of bolting of heat exchangers, pump, or valves may be conducted on one heat exchanger, one pump, or one valve among a group of heat exchangers, pumps, or valves that are similar in design, type, and function. (Ref. Table IWB-2500-1, Examination Category B-G-1, Note 3).
Note 3:
For heat exchangers, piping, pumps, and valves, visual examinations are limited to components selected for examination Notes for Cat. B-G-i under Examination Categories B-B, B-J, B-L-2, and B-M-2. (Ref. Table IWB-2500-i, Examination Category B-G-1, Note 3)
Note 4:
If bolts or studs are removed for examination, surface examination meeting the acceptance standards of IWB-3515 may be substituted for volumetric examination.
Note 5: Individual groupings of approximately one-third (1/3) of the reactor vessel closure head studs, nuts, closure washers and bushings are tracked as a component for the purposes of this table.
B-G-2 Pressure Retaining Bolting, 2 in. (50 mm) and Less in Diameter Reactor Vessel (8 Sets of 3 B-G-2 B7.10 Visual, VT-i 53 53 iOO%(1)(3) per Comp. ID) 0 0
0 Fasteners (2)(3)
All fasteners Pressurizer Bolts, Studs, Visual,VT-1 1
1 iOO%(1)
(20 Sets of2 0
0 0
B-G-2 B7.20 and Nuts per Comp. ID)
ç2)(3)
All fasteners Steam Generator Bolts, B-G-2 B7.30 Visual, VT-i 4
2 50%(1)
(20 Sets of 2 0
0 0
Studs, and Nuts per Comp. ID)
(2)(3)
All fasteners B-G-2 B7.50 Piping Bolts, Studs, and Visual, VT-I 5
2 40%(1)(4)
(8 Sets of 3 0
0 0
Nuts er Comp. ID)
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94 of 124 Palisades ASME Section Xl Code Category Summary Number to Number to Number to Number of equired tO Examination Number to be be be be Category Nr Description Method Components in e
Dunn Percentage Examined in Examined Examined Examined Item No.
lnten,l Required Interval in First in Second in Third Period Period Period All fasteners B-G-2 B7.60 Pump Bolts, Studs, and Visual VT-i 4
1 25%(1)(3)
(1 Set of 16 Nuts per Comp. ID) 2)(3)
All fasteners B-G-2 B7.70 Valve Bolts, Studs, and Visual VT-I 14 3
214
%(1X5)
(I Full Set 0
0 0
Nuts per Comp. ID) 2)(3)
Category Total 81 62 0
0 0
Note 1: Not required unless disassembled.
Note 2: Examination is only required once per interval.
Notes for Cat.B-G-2 Note 3: For components other than piping, examination of bolting is required only when the component is examined under Examination Categories B-B, B-L-2, and B-M-2 (Palisades has included Category B-A for completeness, noting that the 2011 Addenda of Section Xl was revised to include Category B-A).
Note 4: Examination of flange bolting in piping may be limited to one bolted connection among a group of bolted connections that are similar in design, size, function, and service. There are 2 groups (PRVs and SVs on the upper head of the pressurizer) so one of each group is required to be examined if disassembled for a total of 2 out of 5.
Note 5: There are three groups and only one valve of each group of valves is required as outlined in B-M-2.
B-J Pressure Retaining Welds in Piping B-J B9. 11 NPS 4 Circumferential Volumetric 10 Note I Note 1 Note I Note 1 Note 1 Note 1
< NPS 4 Circumferential B-J B9.21 other than HPSI Surface 5
B-J B9.32 rcipe connection Surface 7
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95of 124 1
Palisades ASME Section Xl Code Category Summary Number to Number to Number to Item I
Exam be Examined Number of Required to Examination Number to be be be be Item No.
Category Number Description Method Components in During Percentage Examined in Examined Examined Examined Interval Required Interval in First in Second in Third Period Period Period Category Total 22(1)
Note 1: Code Case N-716-1 allows inclusion of the Examination Category B-J welds, excluding dissimilar metal welds subject to examination to the requirements of Code Cases N-722-1 and N-770-1, into a risk informed ISI program Notes for Cat. B..J (Note: Previously identified Category B-J welds with multiple damage mechanisms including PWSCC are included in Category R-A, but also are still examined under Code Cases N-722-1 and N-770-1). The risk informed ISI program will be implemented in the Fifth Inspection Interval. The excluded welds will be examined per the_requirements_of the_noted_Code_Cases_as_required_by_10_CFR_50.55a.
B-K Welded Attachments for Vessels, Piping, Pumps, and Valves Each welded Pressure Vessels attachment B-K B10.1O Surface 3
2 66%((2) and identified 0
0 2
Welded Attachments occurrence (3)
Each welded attachment Piping (4)
Surface 22 1
45%(4) and identified 1
0 0
B-K B1O.20 Welded Attachments occurrence (3)
Each welded attachment B-K B10.30 Pumps (4)
Surface 16 1
6.25%
and identified 0
1 0
Welded Attachments occurrence (3)
Category Total 41 4
1 1
2
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96 of 124 Palisades ASME Section XI Code Category Summary Numberto Numberto Numberto Number of Required to Examination Number to be be be be Category Nrnber Description Method Components in be xamined Percentage Examined in Examined Examined Examined U
Item No.
lntei,,
9 1
Required Interval in First inSecond in Third a
Period Period Period Note 1: For multiple vessels of similar design, function, and service, only one welded attachment of only one of the multiple vessels shall be selected for examination. For single vessels, only one welded attachment shall be selected for examination.
Note 2: There is one welded attachment on each Steam Generator, and one welded attachment on the pressurizer. One S/G attachment weld and the pressurizer attachment weld are selected.
Note 3: Examination is required whenever component support member deformation (for example, broken, bent or pulled out parts) is identified during operation refueling maintenance examination, or testing.
Notes for Cat. B-K Note 4: For piping, pumps, and valves, a sample of 10% of the welded attachments associated with the component supports selected for examination under IWF-2510 shall be examined. There are a total of 160 piping supports, 41 of those supports have been selected for examination under IWF-2510. Of those supports selected for examination only 7 have welded attachments, 10%
of those 7 or 1 (this equates to 4.5% of the 22 piping welded attachments) would require examination. Each reactor coolant pump has four support attachments with only one welded attachment of one pump required, therefore I of 16 is selected or 6.25%.
B-L-2 Pump Casings B-L-2 B12.20 Pump Casing Visual, VT-3 4
1 25%(12)
(1)(2) 0 Category Total 4
1 0
Notes for Cat B-L-2 Note 1: Examination is limited to at least one pump in each group of pumps performing similar functions in the system.
Note 2: Not required unless disassembled. No Reactor Coolant Pumps have been selected..
B-M-2 Valve Bodies B-M-2 B12.50 Valve Body> NPS 4 Visual, VT-3 14 3
214
%(1X2) 0 0
0 Category Total 14 3
0 0
0 0
0
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97 of 124 Palisades ASME Section Xl Code Category Summary Number to Number to Number to Number of Required to Examination Number to be be be be Category Number Description Mhod Components be Examined Percentage Examined in Examined Examined Examined Item No.
IntervI Required Interval in First in Second in Third Peod Peod Peod Note 1: Examination is limited to at least one valve in each group of valves that are of the same size, constructural design, Notes for Cat. B-M-2 manufacturing method, and that perform similar functions in the system. Palisades B-M-2 valves are grouped into three groups.
Note 2: Not required unless disassembled. No valve body internal surfaces have been selected.
B-N-I Interior of Reactor Vessel Each B-N-i B13.iO ReactorVessel Interior Visual, VT-3 1
3(1) iOO%(1) inspection 1
1 1
period Category Total 1
3(1) 1 1
1 Note 1: Examination of this item number is required each period that pressure retaining surfaces made accessible by removal of Jotes for Cat B-N-I components during normal refueling operations. The pressure retaining surfaces are not accessible without the core barrel removal, The core barrel removal is not scheduled until the second period.
B-N-2 Welded Core Support Structures and Interior Attachments to Reactor Vessels B-N-2 B13.50 Visual, VT-i 6
6 100%
Welds 0
6 0
B-N-2 B13.60 Visual, VT-3 15 15 100%
Welds 0
15 0
Category Total 21 21(1) 0 21 0
Note 1: Examinations may be deferred until the end of the interval.
Notes for Cat. B-N-2 B-N-3 Removable Core Support Structures
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98of 124 Palisades ASME Section Xl Code Catego Summa Number to Number to Number to Number of Required to Examination Number to be be be be Item Exam be Examined Category Number Description Method Components ui Dunng Percentage Examined in Examined Examined Examined Item No.
Required Interval in First in Second in Third Interval Period Period Period Visual VT-3 B-N-3 813.70 Core Support Structure i
3 3
100%
Surfaces 0
3 0
Category Total 3
3(1) 0 3
0 Notes for Cat. B-N-3 j Note 1: Examination will be performed in conjunction with MRP-227A reactor vessel internal aging management examinations.
B-O Pressure Retaining Welds in Control Rod Housings 10% of Reactor Vessel (PWR)
Volumetric 60(2) 6 peripheral Welds 0
0 6
B-C B14.20 Welds in CRD Housing (1) housings Reactor Vessel Welds in 10% of In-Core Instrumental Volumetric 8(2) 1 peripheral Welds 0
0 1
B-C 814.21 Nozzle (ICI) Housings>
(1) housings NPS 2 Category Total 68 7
0 0
7(3)
Note 1: Palisades committed to volumetric examination of replacement CRDM housings.
Note 2: 20 of 45 CRDM housings are peripheral. Each housing has 2 welds plus each CRD penetration has one weld at the Notes for Cat. B-C penetration flange for a total of 60 CRD peripheral welds. 10% of the peripheral welds require examination, therefore 6. In addition there are B ICI penetration flange welds on the periphery. 10% of the peripheral welds require examination, therefore 1.
Total welds to be examined is 7.
Note 3: Examinations may be deferred to the end of the interval.
C-A Pressure Retaining Welds in Pressure Vessels
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99 of 124 Palisades ASME Section Xl Code Category Summary Number to Number to Number to Number of Required to Examination Number to be be be be Category N Iter Description Method Components in e
Dunn Percentage Examined in Examined Examined Examined U
Item No.
lnteiil Required Interval in First in Second in Third Period Period Period Welds at C-A CilO Shell Circumferential Volumetric 4(2)(5) 2(1) 50%(1) structural 0
2 0
e ds discontinuities Volumetric Head-to-shell C-A Cl 20 Head Circumferential Visual 2
(3X5) i 50%
weld 1
0 0
Volumetric Tubesheet-to C-A Cl.30 Tubesheet-to-Shell Visual 4(4)(5) 2(1) 50%(1) shell weld 0
0 2
Category Total 8
5 1
2 2
Note 1: The examination may be limited to one vessel among a group of vessels of similar design, size, and function, and shall include essentially 100% of the weld length. (Ref. Table IWC-2500-1, Examination Category C-A, Notes 2 & 3)
Note 2: There are 2 Steam Generators in the Palisades plant. Each steam generator has two circumferential shell welds at the conical Notes for Cat. C-A transition.
Note 3: Each steam generator has one Class 2 circumferential head-to-shell weld.
Note 4: Each steam generator has one Class 2 tubesheet-to-shell weld and one Class 2 stay cap-to-tubesheet weld.
Note 5: Under RI-ISI per Code Case N-716-1, the Shutdown Cooling Heat Exchanger welds and the Regenerative Heat Exchanger welds have been determined to be low safety significant and therefore do not require examination under Category C-A.
Pressure Retaining Nozzle Welds in Vessels Nozzles Without Reinforcing Plate in N zzl C-B c2.21 Vessels > % in. Nominal Surface and 4
50%2) terminal :nds 1
1 2
Thickness Nozzle-to-volumetric f
(Shell or Head or Nozzle) o piping runs Weld
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100 of 124 Palisades ASME Section Xl Code Category Summary Number to Number to Number to Exam Number of Required to Examination Number to be be be be be Examined Category Number Description Method Components in Dunng Percentage Examined in Examined Examined Examined Item No.
Interval Required Interval in First in Second in Third Period Period Period Nozzles Without Reinforcing Plate in Nozzles at C-B C2.22 Vessels > % in. Nominal Volumetric 4(3) 2 50%(1)(2) terminal ends 1
0 1
Thickness Nozzle Inside of piping runs Radius Section Category Total 12 6
2 1
3 Notes for Cat. C-B Note 1: The examination may be limited to one vessel among the group of vessels of similar design, size, and function. (Ref. Table IWC-2500-1, Examination Category C-B, Note 4)
Note 2: Nozzles selected initially for examination be reexamined in the same sequence over the service life of the component, to the extent practical.
Note 3: Under RI-IS I, the regenerative heat exchanger welds and the shutdown cooling heat exchanger welds have been determined to be low safety significant and therefore do not require examination under Category C-B.
C-C Welded Attachments for Vessels, Piping, Pumps, and Valves 100% of required Pressure Vessels C-C C3.10 Surface 12 1
areasofeach 0
0 1
Welded Attachments welded attachment (4)
Each identified occurrence C-C C3.20 Piping Welded Surface 56 2
357%(2) and each I
1 0
Attachments inspection interval (4)
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101 of 124 Palisades ASME Section XI Code Category Summary R
d Number to Number to Number to E
Number of brs.
Examination Number to be be be be Category NUeF Description M.d Components in Dunn ne Percentage Examined in Examined Examined Examined Item No.
IntervI Required Interval in First in Second in Third Period Period Period Category Total 68 3
1 1
1 Note 1: For multiple vessels of similar design, function, and service, only one welded attachment of only one of the multiple vessels shall be selected for examination. For single vessels, only one welded attachment shall be selected for examination. (Ref.
Notes for Cat. c-c Table IWC-2500-1, Examination Category C-C, Note 4)
Note 2: For piping, pumps, and valves, a sample of 10% of the welded attachments associated with the component supports selected for examination under IWF-251 0 shall be examined. There are a total of 446 piping supports, 71 of those supports have been selected for examination under IWF-251 0. Of those supports selected for examination only 13 have welded attachments, 10% of those 13 or 2 (this equates to 3.57% of the 56 piping welded attachments) would require examination.
Note 3: Each steam generator has six upper vessel supports.
Note 4: Examination is required whenever component support member deformation is identified. (Ref. Table IWC-2500-1, Examination Category C-C, Note 6)
C-ID Pressure Retaining Bolting Greater Than 2 in. In Diameter (None)
C-F-I Pressure Retaining Welds in Austenitic Stainless Steel or High Alloy Piping Note 1: Examination of these welds will not be covered under Examination Category C-F-i but under Examination Category R-A as discussed below.
Notes for Cat. C-F-i C-F-2 Pressure Retaining Welds in Carbon or Low Alloy Steel Piping Note 1: Examination of these welds will not be covered under Examination Category C-F-2 but under Examination Category R-A as discussed below.
Notes for Cat. C-F-2
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102 of 124 Palisades ASME Section XI Code Category Summary Numberto Numberto Numberto Number of Required to Examination Number to be be be be Category Number Description Componenta be Examined Percentage Examined in Examined Examined Examined Item No.
lntervI Required Interval in First in Second in Third Period Period Period D-A Welded Attachments for Vessels, Piping, Pumps, and Valves Each identified occurrence D-A D1.20 Piping Welded Visual VT-I 50 5
10%
(2) and each 1
2 2
Attachments inspection interval (1)
Category Total 50 5
1 2
2 Notes for Cat. D-A Note 1: Examination is required whenever component support member deformation is identified. (Ref. Table IWD-2500-1, Examination Category D-A, Note 4)
Note 2: For welded attachments of piping, pumps, and valves, a 10% sample shall be selected for examination. All welded attachments selected for examination shall be those most subject to corrosion, as determined by the Owner, such as the welded attachments of the Service Water or Emergency Service Water systems.
F-A Supports F-A Fl.1OA pp0rts
- Visual, VT-3 103 26 (1) inspection 10 6
10 F-A F1.IOB lra01 - Visual, VT-3 26 7
(1) inspection 3
2 2
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lO3of 124 Palisades ASME Section Xl Code Category Summary Number to Number to Number to Number of Required to Examination Number to be be be be Item Exam be Examined Category Number Description Method Components in Dunng Percentage Examined in Examined Examined Examined Item No.
Interval Required Interval in First in Second in Third Period Period Period Each F-A Fib Class 1 Piping Supports
- Visual, VT-3 31 8
(1) inspection 2
3 3
Thermal Movement interval Category F-A, Item F1.10 Total 160 41 25%
15 11 15 Each F-A F1.20A Class 2 Piping Supports
- Visual, VT-3 165 27 (1) inspection 8
6 13 One Directional interval Each F-A F1.20B Class 2 Piping Supports Visual, VT-3 126 19 (1) inspection 5
5 9
Multi-directional interval Each F-A F1.20C Class 2 Piping Supports
- Visual, VT-3 156 24 (1) inspection 7
5 12 Thermal Movement interval Category F-A, Item F1.20 Total 447 70 15%
20 16 34 Each F-A F1.30A Class 3 Piping Supports
- Visual, VT-3 125 12 (1) inspection 4
2 6
One Directional interval Each F-A F1.30B Class 3 Piping Supports
- Visual, VT-3 93 9
(1) inspection 3
3 3
Multi-directional interval
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lO4of 124 Palisades ASME Section Xl Code Category Summary Number to Number to Number to Number of Required to Examination Number to be be be be Category Ner Exam be Examined Percentage Examined in Examined Examined Examined n
Method Components in Item No.
Dunng Required Interval in First in Second in Third Interval Period Period Period Each F-A P1.30C Class 3 Piping Supports
- Visual, VT-3 38 5
(1) inspection 1
2 2
Thermal Movement interval Category F-A, Item F1.30 Total 256 26 10%
8 7
11 One directional Supports Each F-A F1.40A other than Piping
- Visual, 20 9
45%
inspection 3
1 5
Supports (Class 1,2,3, interval 2
and MC)
Multi directional Supports Each F-A F1.40B other than Piping
- Visual, 13 7
53.8%
inspection 1
6 0
Supports (Class 1,2,3, interval 2
and MC)
Category F-A, Item F1.40 Total 33 16 42.4%
4 7
5 Category Total 896 153 47 41 65 Note 1: The total percentage sample shall be comprised of supports from each system, where the individual sample sizes are proportional to the total number of non-exempt supports of each type and function within each system. (Ref. Table IWF-2500-1, Examination Category F-A, Note 2). Palisades interprets this to be conservative and is required to do a minimum of one support per system and type.
In addition Palisades uses the traditional rounding method of >.5 the number is rounded up and Notes for Cat. F-A if <.5 the number is rounded down.
Note 2: For multiple components other than piping, within a system of similar design, function, and service, the supports of only one of the multiple components are required to be examined. (Ref. Table IWF-2500-1, Examination Category F-A, Note 3). Palisades has scheduled the following supports: One of two Steam Generator lower vessel support structures; Six of twelve Steam Generator upper vessel support structures; One Pressurizer lower vessel support structure; One of four Reactor Coolant Pump support structures; Three of six Regenerative Heat Exchanger supports; One of two High Pressure Safety Injection Pump supports; One of two Low Pressure Safety Injection Pump supports; One of three Containment Spray Pump supports; One CRDM Shock Mount Assembly.
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105 of 124 7.4.2 Risk Informed 1St (N-716-1)
Palisades RI-ISI (N-716-1) Examination Catego Summa Numberto Number to Number to E
Number of Required to Examination Number to be be be be Category Numb r Description Mhod Components in e
Dunn Percentage Examined in Examined Examined Examined e
Item No Intervl Required Interval in First in Second in Third Period Period Period N-716-1 Code Case N-716-1 Alternative Classification and Examination Requirements N-716-l R0.00 LSS Piping Welds N/A 625 0
0%
0 0
0 0
N-716-1 R1.l0 HSS Piping Welds N/A 0
0 0%
0 0
0 0
N-716-I R1.11 Welds Subjectto Volumetric 26 11 42.3%
11 4
4 3
Welds Subject to Volumetric 52 13 5
4 4
N-716-1 R1.11S 3
Thermal Fatigue (socket 25%
13 welds)
Visual, VT-2 52 13 (5)
(5)
(5)
N-716-1 R1.12 Not Used N/A 0
0 0%
0 0
0 0
N-716-1 R1.13 Volumetric 0
0 0%
0 0
0 0
N7161 RI 14 Welds Subject to Crevice Volumetric 0
0 0%
0 0
0 0
Corrosion Cavitation Visual, VT-2 Welds Subject to Primary N-716-1 R1.15 2
Water Stress Corrosion Volumetric 0
0 0%
0 0
0 0
Cracking (PWSCC)
- isua, Welds Subject to Intergranularor N-716-1 R1.16 2
TransgranularStress 15 4
26.6%
4 2
0 2
Corrosion Cracking (IGSCC_or TGSCC)
N-716-1 RI 17(2)
Welds Subject to Visual VT-3 0
0 0%
0 0
0 0
Localized Corrosion Volumetric
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lO6of 124 Palisades Rl-lSl (N-716-1) Examination Category Summary Number to Number to Number to Number of Required to Examination Number to be be be be be Examined Item Exam Category Number Description Method Components in During Percentage Examined in Examined Examined Examined Item No.
Required Interval in First in Second in Third Interval Period Period Period N-716-1 Code Case N-716-1 Alternative Classification and Examination Requirements
[Microbiologically Influenced Corrosion (MIC)_or_Pitting]
Welds Subject to Flow N-716-1 R1.18 2
Accelerated Corrosion (2) 0 0
0%
0 0
0 0
(FAC)
Welds Subject to External Chloride Stress N-716-1 R119 Surface 0
0 0%
0 0
0 0
Corrosion Cracking (ECSCC)
Welds not Subject to a Volumetric 425 32 7.5%
32 6
15 11 N-716-1 R1.20 Degradation Mechanism HSS Elements Subject to N-716-1 R1.20118 FAC but treated as no Volumetric 90 13 14.4%
13 6
2 5
Degradation Mechanism Welds not Subject to a N-716-1 R1.20S 4
Degradation Mechanism Visual, VT-2 283 23 8.1%
23 (5)
(5)
(5)
(socket welds)
Category Total 1517 96 6.3%
96 Note 1:
The volume requirements of the examinations are expanded to include the counterbore region.
Note 2:
In accordance with the Owners existing programs, such as PWSCC, IGSCC, MIC, or FAC inspection programs Note 3:
N-716-1 does not include this Item No. These welds are a subset of Item No. R1.11 that consist of socket welds. The Notes for Category examination requirements for these welds are defined in notes (8) and (10) of Table 1 of N-71 6-1.
R-A Note 4:
N-716-1 does not include this Item No. These welds are a subset of Item No. RI.20 that consist of socket welds. The examination requirements for these welds are defined in notes (9) and (10) of Table I of N-716-1.
Note 5:
The total examined in each period does not include the Visual VT-2 examinations. These examinations are performed in accordance with the applicable pressure testing requirements.
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lO7of 124 7.4.3 Alloy 600 Palisades Alloy 600 Examination Category Summary Number to Number to Number to Number of Required to Examination Number to be be be be Item Exam be Examined Category Number Method Components in Dunng Percentage Examined in Examined Examined Examined Item No.
Interval Required Interval in First in Second in Third Peod Peod Peod N-722-1 Code Case N-722-1 PWR Class I Components Fabricated with Alloy 6001821182 Materials (1)
Each S/C Bottom Channel Visual VE (3) 4 100%
inspection 4
0 0
N-722-1 815.120 Head Drain Penetrations (2) (4) interval PZR Heater Penetrations Visual VE 1
(3) 1 100%
Each refuel (5)
(5)
(5)
N-722-1 B15.140 (120 Heaters)
(2)(4) outage N-722-1 B15.150 PZR Spray Nozzle to Visual, VE 2
(3) 2 100%
Each refuel (5)
(5)
(5)
Pipe Connections (2) (4) outage PZR Safety and Relief Visual VE N-722-1 B15.160 Valve Nozzle to Pipe (2)(4)
(3) 4 100%
Each refuel (5)
(5)
(5)
Connections outage N-722-1 B15.170 PZR Surge Nozzle to Visual, VE 2
(3) 2 100%
Each refuel (5)
(5)
(5)
Pipe Connections (2) (4) outage PZR Visual VE 18 (3) 18 100%
Each refuel (5)
(5)
(5)
N-722-1 B15.180 Instrument Connections (2) (4) outage N-722-1 815.200 Piping Hot Leg Visual, VE 10 (3) 10 100%
Each refuel (5)
(5)
(5)
Instrument Connections (2) (4) outage N-722-1 B15.205 Piping Cold Leg Visual, VE Each 12 12 100%
inspection 12 0
0 Instrument Connections (2) (4) interval N7221 B15.210 Piping Hot Leg Full Visual, VE 26 (3) 26 100%
Each refuel (5)
(5)
(5)
Penetration Welds (2) (4) outage
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lO8of 124 Palisades Alloy 600 Examination Category Summary Number to Number to Number to E
Number of Required tO Examination Number to be be be be Category Nmber Description Me.d Components in Dunn Percentage Examined in Examined Examined Examined U
Item No.
ln-,l Required Interval in First in Second in Third Period Period Period N-722-1 B15.215 FuN Penetration Welds Visual,VE 40 40 100%
inspection 28 7
5 interval Category Total 119 119 44 7
5 Note 1: Frequency of examination, examination method, and personnel qualifications are in accordance with Code Case N-722-1, Table 1 as required by 10 CFR 50.55a(g)(6)(ii)(E).
Note f r Note 2: An ultrasonic examination from either the ID or the OD in accordance with the requirements of Appendix VIII shall be 5 0 acceptable in lieu of the Visual, yE.
Cat. N-722-1 Note 3: Code Case N-722, Table 1 requires multiple examinations within the interval for these components. The number of exams required per period has been adjusted to reflect these multiple examinations.
Note 4: Visual examination in accordance with Code Case N-722-1 also meets visual code case requirements of Code Case N-770-1.
Note 5: These examinations are performed each refueling outage.
N-729-1 Code Case N-729-1 PWR Reactor Pressure Vessel Upper Head (1)
RVH with nozzles and N-729-1 B4.10 partial-penetration welds Visual VE 1
1 100%
Each refuel (1)
(1)
(1) of non-PWSCC-resistant outage material Nozzles and partial-Volumetri N72o1 A 2 penetration welds of non-C Each refuel (1)
(1)
(I)
PWSCC-resistant or
° outage materials in head Surface Category Total 2
2 (1)
(1)
(1)
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109 of 124 Palisades Alloy 600 Examination Category Summary Numbertol Numberto I Numberto Exam Number of Required to Examination Number to be I be I
be I
be I be Examined Category NeF Description Method Components in During I Percentage Examined in I Examined I Examined I Examined Item No.
intervai Required Interval in First I in Second I
in Third Period I
Period I
Period Note 1: These examinations are in accordance with Code Case N-729-1 Table I as required by 10 CFR 50.55a(g)(6)(ii)(D). These Notes for Cat.
examinations are scheduled each refueling outage per an NRC commitment due to indications found in the existing RPVCH N7291 in 2004.
N-770-1 Code Case N-770-1 Pressure Retaining Butt Welds in Piping and Vessels (1)
Unmitigated Hot Leg Volumetric, Every second N-770-1 A-I
> 625° F.
Visual 2
7 7
100%
refueling 7(4) 7(4) 7(4) outage Unmitigated Hot Leg Volumetric, N-770-I A-2 580° F and 625° F.
Visual (2) 6 6
1 00%
Every 5 years 1
6 5
Every second Unmitigated Cold Leg Volumetric, inspection N-770-1 B
18 18 100%
period notto 10 8
10 525° F and < 580 ° F Visual (2) exceed 7 years Category Total 31 31 18 21 22 Note 1: These examinations are in accordance with Code Case N-770-1, Table 1 as required by 10 CFR 50.55a(g)(6)(ii)(F).
Note 2: Volumetric examination scheduling is depicted in this table. Visual examination scheduling is identical to Code Case N-722-1 Notes for and is scheduled accordingly.
Cat. N-770-1 Note 3: The requirement is to perform an examination every 5 years which resulted at Palisades in two locations being performed twice during the interval.
Note 4: The volumetric examinations are performed every second refueling outage.
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110 of 124 7.4.4 Augmented Palisades Augmented Examination Category Summary Number to Number to Number to E
Number of Required to Examination Number to be be be be Category Number Description Method Components in be Dunn Percentage Examined in Examined Examined Examined Item No.
lntervi Required Interval in First in Second in Third Period Period Period AUG RCP Flywheels AUG RG1.14 RCP Flywheels UT 5
4 100%
0 1
3 Category Total 5(1) 4 0
1 3
Notes for RG 1 14 Note 1: Palisades has four installed RCP motors, and one spare. Flywheel inspection of each installed motor shall be performed at least once every ten years. Flywheel inspection of the spare motor is performed prior to its being put into service.
AUG ESS Check Valve Weld Overlays AUG WOL 24 Weld Overlays Volum:tnc, 2
2 100%
L (1)
(1)
(1)
Category Total 2
2 1
(1)
(1)
(1)
Notes for WOL Note 1: Weld overlays shall be examined every refueling outage.
AUG NUREG-0612 Control of Heavy Loads at Nuclear Power Plants MT I PT I On ch (1) 1)
AUG NR-0612 Lifting Devices UT 1
4 100%
five years Once each (1)
(1)
(1)
AUG NR-0612 Lifting Devices vT-3 2
4 4
100%
refueling outage Category Total 4
4 (1)
(1)
(1)
NUREGO6I2 Note 1: These examinations are controlled by Maintenance Procedure CLP-M-6.
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111 of 124 Palisades Augmented Examination Category Summary Number to Number to Number to Number of Required to Examination Number to be be be be Category Number Description Method Components in be Examined Percentage Examined in Examined Examined Examined Item No.
Intel Required Interval in First in Second in Third Period Period Period AUG BL 88-08 Auxiliary Spray Piping AUG BL-88-08 Aux Spray Piping Welds UT 1
2 2
100%
0 2
2 Category Total 2
2 0
2 2
Notes for AUG Note 1: The subject welds shall be ultrasonically examined using techniques that are specially developed for detecting intergranular stress corrosion cracking in thin-wall stainless steel piping to enhance the detection of any cracking. Reference CR-i BL-88-08 0131, CA-07.
AUG NUREG-0800 High Energy Line Break (HELB)
AUG 4.12.1 ORM4.12.i in Volumetric 16 16 100%
spection 5
5 6
interval Volumetric Once each AUG ORM Welds identified in ORM or Surface 22 13 50%
inspection 0
2 11 per Code interval Category Total 38 29 5
7 17 Notes for AUG Note 1: Volumetric examination shall be performed once per interval.
NR-0800 Note 2: Visual examination for evidence of leakage past insulation shall be performed every week.
AUG AF-SI Auxiliary Feedwater Piping at Steam Generators Once each AUG AF-SI Circ Welds UT 1
8 8
100%
inspection 8
8 8
period Category Total 8
8 8
8 8
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11201 124 Palisades Augmented Examination Category Summary Number to Number to Number to Number of Required to Examination Number to be be be be Category Nrnb Description Mhod Components in be D
Percentage Examined in Examined Examined Examined u
er Item No.
IntervI Required Interval in First in Second in Third Period Penod Penod Note 1: Perform ultrasonic wall thinning examinations of the piping beginning at the elbow to pipe weld upstream of the Notes for AUG Steam Generators, under the Flow Accelerated Corrosion (FAC) program.
Perform visual examinations of the AF-SI internal knuckle region, if Steam Generators are open for secondary side inspections.
AUG MRP-146S Thermal Fatigue in Stagnant Lines AUG MRP-146 Pipe Volumetric 1
1 100%
Every second 1
1 1
Category Total 1
1 1
1 1
Notes for AUG MRP-146 None AUG Pressurizer Spray Line Pipe Whip AUG PZR-SL Circumferential Weld Surface 1
1 100%
0 1
0 Category Total 1
0 1
0 Notes for AUG PZRSL Note 1: Weld shall be included in Category B-J examination scope for examination once per interval.
RVi MRP-227-A Reactor Vessel internals Aging Management Program Core Shroud Assembly AUG (Bolted)
Volumetric 768 (2) 100%
768 0
1(1) 0 Core shroud bolts Core Shroud Assembly AUG (Bolted)
Visual (VT-12 1
100%
1 0
i 0
Assembly
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113 of 124 Palisades Augmented Examination Category Summary Number to Number to Number to Number of Required to Examination Number to be be be be Item Exam be Examined Category Number Description Method Components in During Percentage Examined in Examined Examined Examined Item No.
Interval Required Interval in First in Second in Third Period Period Period Core Support Barrel MRP-Assembly Visual 1
1 10O%
1 0
i 0
AUG 227-A Upper (core support (EVT-1) barrel) flange weld Core Support Barrel MRP-Assembly Visual jQQ%(3) 1 0
1(1) 0 AUG 227-A Lower cylinder girth (E\\T-l) welds Lower Support MRP-Structure Visual AUG 227-A Core support column
(-3) 1 1
1OO%
1 0
0 welds MRP Lower Support Visual 1
1 100%
1 0
i 0
AUG 227-A Structure (EVT-1)
Core support plate MRP Control Element Visual AUG 227-A Assembly (V-r3) 1 1
100%
1 0
0 Instrument guide tubes Category Total 774 100%
774 0
7 0
Note 1:
In accordance with MRP-227A and the Palisades Aging Management Plan examinations will be performed in 2022.
(approximately 34.3 EFPY)
Note 2: Examinations included 768 shroud to former bolts and 96 shroud to anchor bolts (1 record for all bolting is used in IDDEAL Notes for RVIAMP database.).
Note 3: 100% of the accessible surface is required with a minimum of 75% of the total population or total weld length required.
Note 4: The lower cylinder girth welds consist of an upper girth weld, a middle girth weld and a lower girth weld.
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ll4of 124 r
Palisades Owner Elected Examination Category Summary Number to Number to Number to Number of Required to Examination Number to be be be be Category N
Description Components be Examined Percentage Examined in Examined Examined Examined U
Item No.
IntervI Required Interval in First in Second in Third Period Period Period Upper CRD Upper CR0 Housing Internal Examinations Qflfl________________________
Eddy Owner CRD Internal Surfaces Current or 45 2(2) 4.4%
2 0
0 2
Visual Category Total 45 2
4.4%
2 0
0 2
Note 1:
Palisades has elected to use the Eddy Current method.
Notes for Category Note 2:
Perform internal examinations of two upper housings each 10 year interval. One housing should be selected from the periphery housings and one housing should be selected from the remaining internal housings.
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ll5of 124 8.0 Inservice Inspection Data Management Software 8.1 Description The ISI Data Management software is comprised of a series of program modules assembled in a comprehensive software package entitled the IDDEAL Software Suite. This software suite is Internet best and is accessible by any computer with permissions.
8.2 Control Version 8 of the IDDEAL Software Suite is a quality level B software.
It is the Controlled copy of the ISI Schedule. The software has limited access to protect the contents of the databases.
Access to the software is limited through the use of a user defined password controlled via Central Engineering Procedure CEP-COS-100.
8.3 Suite Access to the IDDEAL Software Suite is obtained through the internet at https://entergy.iddeal.info.
Palisades has begun the process of converting from Version 8 of the software to Version 9. The following programs comprise the IDDEAL Software Suite: The modules are in Version 8 unless noted.
IDDEAL - IDDEAL is used to track and progress completion of outage examinations.
Generates various reports to status examinations.
Version 9 - Maintains the complete ISI database. Outage schedules are assembled and progressed for interval and period statistics.
CERTWORKS - Maintains and tracks the personnel certifications of inspectors.
EQUIPWORKS
- Maintains and tracks the NDE equipment certifications.
SNUBWORKS - Used to track all work associated with plant snubbers.
8.4 Version 9 of the IDDEAL Software Suite Version 9 of the IDDEAL Software Suite contains the Palisades information necessary to perform lSl and Augmented Programs. Maintenance of the database is controlled via Central Engineering Procedure CEP-COS-ilO. All changes to data in the Palisades ISI Database must be made in accordance with CEP-COS-1 10 once Palisades has verified and accepted the data in Version 9.
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116 of 124 8.5 Data The controlled Version 9 of the IDDEAL Software Suite houses the information below which meets the requirements of ASME Section Xl, IWA-2420(b).
8.5.1 Components Identification of components selected for examination and test, including successive exams from prior periods; 8.5.2 Requirements Code requirements by examination category and item number for each component, including the examination or test to be performed, and the extent of the examination or test; 8.5.3 Drawings Identification of drawings showing items that require examination; 8.5.4 Procedures List of examination procedures; 8.5.5 Alternatives Description of alternative examinations, and identification of components to be examined using alternative methods; 8.5.6 Calibration Blocks
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117 of 124 9.0 Examination Evaluation Criteria Evaluation of indications detected by volumetric or surface examination during the preservice or ISI of components will be performed in accordance with CEP-NDE-3000. Evaluation of conditions detected by visual examinations during the preservice or ISI of components and component supports will be performed in accordance with the applicable visual examination procedure.
Evaluation of indications detected during the augmented examination of components and component supports will be performed in accordance with this section and the applicable document that governs each augmented examination.
9.1 Successive Inspections 9.1.1 Successive Inspections on Class I components will be performed in accordance with IWB 2420, which includes the following criteria in IWB-2420(b), (C) and (e):
(b) If a component is accepted for continued service in accordance with IWB-31 32.3 or IWB-3142.4, the areas containing flaws or relevant conditions shall be reexamined during the next three inspection periods listed in the schedule of the inspection program of IWB-2400. Alternatively, acoustic emission may be used to monitor growth of existing flaws in accordance with IWA-2234.
(c) If the reexaminations required by IWB-2420(b) reveal that the flaws or relevant conditions remain essentially unchanged for three successive inspection periods, the component examination schedule may revert to the original schedule of successive inspections.
(e) If welded attachments are examined as a result of identified component support deformation, and the results of these examinations exceed the acceptance standards of Table IWB-341 0-1, successive examinations shall be performed, if determined necessary, based on an evaluation by Palisades.
9.1.2 Successive Inspections on Class 2 components will be performed in accordance with IWC-2420, which includes the following criteria in IWC-2420(b), (c) and (d):
(b) If a component is accepted for continued service in accordance with IWC-3122.3 or IWC-31 32.3, the areas containing flaws or relevant conditions shall be reexamined during the next inspection period listed in the schedule of the inspection program of IWC-2400. Alternatively, acoustic emission may be used to monitor growth of existing flaws in accordance with IWA-2234.
(C) If the reexaminations required by 9.1.2(b) (IWC-2420(b)) reveal that the flaws or relevant conditions remain essentially unchanged for the next inspection period, the component examination schedule may revert to the original schedule of successive inspections.
(d) If welded attachments are examined as a result of identified component support deformation, and the results of these examinations exceed the acceptance standards
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1180! 124 of Table IWC-341 0-1, successive examinations shall be performed, if determined necessary, based on an evaluation by Palisades.
9.1.3 As an alternative to 9.1.1 and 9.1.2 for Class I and 2 vessels, the requirements of Code Case N-526 may be used to eliminate successive examinations. The requirements of Code Case N-526 are outlined below.
(a) The flaw is characterized as subsurface in accordance with Figure 1 of Code Case N-526.
(b) The NDE technique and evaluation that detected and characterized the flaw, with respect to both sizing and location, shall be documented in the flaw evaluation report.
(c) The vessel containing the flaw is acceptable for continued service in accordance with IWB 3600, and the flaw is demonstrated acceptable for the intended service life of the vessel.
9.1.4 Successive Inspections on Class 3 components will be performed in accordance with IWD-2420, which includes the following criteria in IWD-2420(b), (C) and (d):
(b) If components are accepted for continued service by evaluation in accordance with IWD-3000, the areas containing flaws or relevant conditions shall be reexamined during the next inspection period listed in the schedule of the inspection program of IWD-2400.
(c) If the reexaminations required by 9.1.4 (IWD-2420(b)) reveal that the flaws or relevant conditions remain essentially unchanged for the next inspection period, the component examination schedule may revert to the original schedule of successive inspections.
(d) If welded attachments are examined as a result of identified component support deformation, and the results of these examinations exceed the acceptance standards of IWD-3000, successive examinations shall be performed, if determined necessary, based on an evaluation by Palisades.
9.1.5 Successive Inspections on Class 1, 2 and 3 component supports will be performed in accordance with IWF-2420, which includes the following criteria in IWF-2420(b) and (C):
(b) When a component support is accepted for continued service in accordance with IWF-31 12.2 or IWF-31 22.2, the component support shall be reexamined during the next inspection period listed in the schedule of the inspection programs of IWF-2410 (c) When the examinations required by 9.1.5 (IWF-2420(b)) do not require additional corrective measures during the next period, the inspection schedule may revert to the requirements of IWF-2420(a).
9.1.6 Successive inspections on Category R-A components will be performed in accordance with subsection 6(a) of Code Case N-716-1.
9.1.7 Successive Inspections on Augmented examinations will be performed in accordance with the respective Augmented Program requirements document.
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ll9of 124 9.1.8 Plant specific successive inspections are identified in Version 9 of the IDDEAL Software Suite.
9.2 Additional Examinations 9.2.1 Section Xl additional examinations shall be determined in accordance with 9.2.2, 9.2.3, 9.2.4, 9.2.5 as applicable, or 9.2.6 may be used as an alternative.
Additional examinations for augmented components and component supports will be performed in accordance the applicable document that governs each augmented examination.
9.2.2 Additional examinations on Class I components will be performed in accordance with IWB-2430, which includes the following criteria in IWB-2430(a), (b), (c) and (e):
(a) Examinations performed in accordance with Table IWB-2500-1, except for Examination Category B-P, that reveal flaws or relevant conditions exceeding the acceptance standards of Table IWB-3410-1 shall be extended to include additional examinations during the current outage. The additional examinations shall include an additional number of welds, areas, or parts 1 included in the inspection item 2 equal to the number of welds, areas, or parts included in the inspection item that were scheduled to be performed during the present inspection period. The additional examinations shall be selected from welds, areas, or parts of similar material and service. This additional selection may require inclusion of piping systems other than the one containing the flaws or relevant conditions.
(b) If the additional examinations required by IWB-2430(a) reveal flaws or relevant conditions exceeding the acceptance standards of Table IWB-3410-1, the examinations shall be further extended to include additional examinations during the current outage. These additional examinations shall include the remaining number of welds, areas, or parts of similar material and service subject to the same type of flaws or relevant conditions.
(c) For the inspection period following the period in which the examinations of IWB 2430(a) or (b) were completed, the examinations shall be performed as originally scheduled in accordance with IWB-2400.
(d) If welded attachments are examined as a result of identified component support deformation, and the results of these examinations exceed the acceptance standards of Table IWB-341 0-1, additional examinations shall be performed, if determined necessary, based on an evaluation by Palisades.
1 Welds, areas or parts are those described or intended in a particular inspection item of Table IWB-2500-1.
2 An inspection item, as listed in Table IWB-2500-1, may comprise a number of welds, areas, or parts of a component required to be examined in accordance with the inspection program and schedule (IWA-2420).
9.2.3 Additional examinations on Class 2 components will be performed in accordance with IWC-2430, which includes the following criteria in IWC-2430(a), (b), (c), and (d):
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l2Oof 124 a)
Examinations performed in accordance with Table IWC-2500-1, except for Examination Category C-H, that reveal flaws or relevant conditions exceeding the acceptance standards of Table IWC-3410-1 shall be extended to include additional examinations during the current outage. The additional examinations shall include an additional number of welds, areas, or parts included in the inspection item 2 equal to 20% of the number of welds, areas, or parts included in the inspection item that were scheduled to be performed during the interval. The additional examinations shall be selected from welds, areas, or parts of similar material and service. This additional selection may require inclusion of piping systems other than the one containing the flaws or relevant conditions.
(b) If the additional examinations required by IWC-2430(a) reveal flaws or relevant conditions exceeding the acceptance standards of Table IWC-3410-1, the examinations shall be further extended to include additional examinations during the current outage. These additional examinations shall include the remaining number of welds, areas, or parts of similar material and service subject to the same type of flaws or relevant conditions.
(c) For the inspection period following the period in which the examinations of IWC 2430(a) or (b) were completed, the examinations shall be performed as originally scheduled in accordance with IWC-2400.
(d) If welded attachments are examined as a result of identified component support deformation, and the results of these examinations exceed the acceptance standards of Table IWC-341 0-1, additional examinations shall be performed, if determined necessary, based on an evaluation by Palisades.
1 Welds, areas or parts are those described or intended in a particular inspection item of Table IWC-2500-1.
2 An inspection item, as listed in Table IWC-2500-1, may comprise a number of welds, areas, or parts of a component required to be examined in accordance with the inspection program and schedule (IWA-2420).
9.2.4 Additional examinations on Class 3 components will be performed in accordance with IWD-2430, which includes the following criteria in IWD-2430(a), (b), (c) and (d):
(a) Examinations performed in accordance with Table IWD-2500-1, except for Examination Category D-B, that reveal flaws or relevant conditions exceeding the acceptance standards of IWD-3000 shall be extended to include additional examinations during the current outage. The additional examinations shall include an additional number of welds, areas, or parts included in the inspection item 2 equal to 20% of the number of welds, areas, or parts included in the inspection item that are\\
scheduled to be performed during the interval. The additional examinations shall be selected from welds, areas, or parts of similar material and service. This additional selection may require inclusion of piping systems other than the one containing the flaws or relevant conditions.
(b) If the additional examinations required by IWD-2430(a) reveal flaws or relevant conditions exceeding the acceptance standards of IWD-3000, the examinations shall be further extended to include additional examinations during the current outage. The extent of the additional examinations shall be determined by Palisades based upon an
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121 of 124 engineering evaluation of the root cause of the flaws or relevant conditions.
Palisades corrective actions shall be documented in accordance with IWA-6000.
(c) For the inspection period following the period in which the examinations of IWD 2430(a) or (b) were completed, the examinations shall be performed as originally scheduled in accordance with IWD-2400 (d) If welded attachments are examined as a result of identified component support deformation, and the results of these examinations exceed the acceptance standards of Table IWD-3000, additional examinations shall be performed, if determined necessary, based on an evaluation by Palisades.
1 Welds, areas or parts are those described or intended in a particular inspection item of Table IWD-2500-1.
2 An inspection item, as listed in Table IWD-2500-1, may comprise a number of welds, areas, or parts of a component required to be examined in accordance with the inspection program and schedule (IWA-2420).
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122 of 124 9.2.5 Additional examinations on Class 1, 2 and 3 component supports will be performed in accordance with IWF-2430, which includes the following criteria in IWF-2430(a), (b), (c) and (d):
(a)
Component support examinations performed in accordance wfth Table IWF-2500-1 that reveal flaws or relevant conditions exceeding the acceptance standards of IWF 3400, and that require corrective measures, shall be extended during the current outage, to include the component supports immediately adjacent to those component supports for which corrective measures are required. The additional examinations shall be extended, during the current outage, to include additional supports within the system, equal in number and of the same type and function as those scheduled for examination during the inspection period.
(b)
When the additional examinations required by IWF-2430(a) reveal flaws or relevant conditions exceeding the acceptance standards of IWF-3400, and that require corrective measures, the examinations shall be further extended to include additional examinations during the current outage. These additional examinations shall include the remaining component supports within the system of the same type and function.
(c)
When the additional examinations required by IWF-2430(b) reveal flaws or relevant conditions exceeding the acceptance standards of IWF-3400, and that require corrective measures, the examinations shall be extended, during the current outage, to include all nonexempt supports potentially subject to the same failure modes that required corrective actions in accordance with IWF-2430(a) and (b). Also, these additional examinations shall include nonexempt component supports in other systems when the support failures requiring corrective actions indicate non-system-related support failure modes.
(d)
When the additional examinations required by IWF-2430(c) reveal flaws or relevant conditions exceeding the acceptance standards of IWF-3400, and that require corrective measures, Palisades shall examine, during the current outage, those exempt component supports that could be affected by the same observed failure modes and could affect nonexempt components.
9.2.6 The following criteria of Code Case N-586-1 may be applied for the performance of additional examinations on Class 1, 2 or 3 components or component supports.
(a) An engineering evaluation shall be performed. Topics to be addressed in the engineering evaluation shall include:
1)
A determination of the root cause of the flaws or relevant conditions.
2)
An evaluation of applicable service conditions and degradation mechanisms to establish that the affected welds, areas, or supports will perform their intended safety functions during subsequent operation.
3)
A determination of which additional welds, areas, or supports could be subject to the same root cause conditions and degradation mechanisms. This may require
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123of 124 the inclusion of piping systems other than the one containing the original flaws or relevant conditions.
(b) Additional examinations shall be performed on those welds, areas, or supports subject to the same root cause conditions and degradation mechanisms. No additional examinations are required if the engineering evaluation concludes that either:
- 1) There are no additional welds, areas, or supports subject to the same root cause conditions, or 2)
No degradation mechanism exists.
(c) Any required additional examinations shall be performed during the current outage.
(d) The engineering evaluation shall be retained in accordance with IWA-6000.
9.2.7 Additional examinations of Category R-A components will be performed in accordance with subsection 6(b) of Code Case N-716-1.
9.2.8 Plant specific additional examinations are identified in Version 9 of the IDDEAL Software Suite.
10.0 Risk-Informed ISI Program Palisades has implemented a risk informed lSl (Rl-lSl) program in the Third Period of the Fourth Inte,va!in accordance with the requirements of ASME Section Xl Code Case N-716-1 as discussed in section 10.4 below. An Rl-ISI program was in effect during the Third Period of the third inspection interval. Some inspection requirements remain from the former RI-ISI program, as discussed in sections 10.1 through 10.3 below.
10.1 Reactor Vessel Inspections Third interval reactor vessel inspections were deferred to 2013 by Relief Request TAC No.
MD9265.
10.2 ASME Section Xl Code Case N-716-1 Implementation Regulatory Guide 1.147 Inservice Inspection Code Case Applicability, ASME Section XI, Division 1 Revision 17 was published in August of 2014. The Regulatory Guide approved the use of ASME Section Xl Code Case N-716-1 without restrictions.
The Regulatory Guide was published in the Federal Register Volume 79, NO. 214 on November 5, 2014. 10 CFR 50.55a was revised on Dec 11, 2015 to include the use of Regulatory Guide 1.147, Revision 17.
Palisades performed evaluations to update their ISl program to the requirements of N-716-1.
These evaluations document the application of ASME Section Xl Code Case N-716-1 to the Class 1, Class 2 and Break Exclusion Region (BER) program piping systems at Palisades Nuclear Plant using risk-informed and safety based (RIS_B) insights.
This program supports the 4tt1 and 5 th ISI Intervals at Palisades.
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124of124 The scope of this evaluation includes all Examination Category B-F, B-J, C-F-I and C-F-2 piping welds, Examination Category C-A (pressure retaining welds in pressure vessels), Examination Category C-B (pressure retaining nozzle welds in vessels), Examination Category C-D (pressure retaining bolting > 2 inch diameter), and Examination Category C-G (pressure retaining welds in pumps and valves) identified in the ISI Program Weld Databases as well as all BER program welds
> NPS 4 and any additional piping segments determined to be high safety significant based on review of the plant PRA.
The following summarizes the ASME Section Xl scope included in the N-716-1 RI-ISI program:
Table 1: RIS_B Evaluation Scope Piping Systems Evaluated 1
Code CIass 2
Examination Category CVC - Chemical Volume & Control 1, 2 B-J, C-A, C-B ESS
- Engineered Safeguards (SI) 1, 2 B-J, C-F-i, C-A, C-B FWS Feedwater 2, NNS C-F-2, AUG MSS
- Main Steam 2, NNS C-F-2, AUG PCS
- Primary Coolant I
B-F, B-J RWS - Radwaste Drains i
B-J SWS
- Service Water 2
C-F-2 VAS
- Vent & Air Conditioning 2
C-F-2 Steam Generators 2
C-A, C-B Notes I.
The scope of this evaluation also includes any additional piping segments and their welds determined to be high safety significant (HSS) based upon a review of the plant PRA. This requirement is addressed in Section 3.
2.
There are no Code Class 3 welds in the scope, but there are non-ASME (NNS) piping welds in the BER scope (FWS and MSS).