ML19084A288

Ltr. 03/25/19 Information Request to Support Upcoming Inspection at the Palisades Nuclear Plant (DRS-M.Holmberg)

ML19084A288
Person / Time
Site:	Palisades
Issue date:	03/25/2019
From:	Mel Holmberg Division of Reactor Safety III
To:	Arnone C Entergy Nuclear Operations
References
Download: ML19084A288 (6)

Text

March 25, 2019 Mr. Charles Arnone Vice President, Operations Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530

SUBJECT:

INFORMATION REQUEST TO SUPPORT UPCOMING INSPECTION AT THE PALISADES NUCLEAR PLANT

Dear Mr. Arnone:

This letter is to request information to support our scheduled follow-up inspection for Unresolved Item 05000255/2018004-01, Potential Failure to Identify/Correct Rejectable Flaws in Reactor Pressure Vessel Head Penetration Nozzles, and Licnesee Event Report 2018-003-00, Indications Identified in Reactor Pressure Vessel Head Nozzle Penetrations, scheduled from June 17, 2019, through June 27 2019, at your Palisades Nuclear Plant. This inspection will be performed in accordance with U.S. Nuclear Regulatory Commission (NRC) Baseline Inspection Procedures 71111.08 and 71153.

In order to minimize the impact that the inspection has on the site and to ensure a productive inspection, we have enclosed a list of documents required for the inspection. The information requested may be provided in either CD-ROM/DVD (preferred) or hard copy format and should be ready for NRC review by June 17, 2019.

We have discussed the schedule for the inspection with your staff and understand that our regulatory contact for this inspection will be Ms. Barb Dotson of your organization. If there are any questions about the material requested or the inspection in general, please contact the lead inspector Mr. Mel Holmberg at 630-829-9748 or msh@nrc.gov.

This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, Control Number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Office of Management and Budget Control Number.

This letter and its enclosure will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations, Part 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Mel Holmberg, Reactor Inspector Engineering Branch 1 Division of Reactor Safety Docket No. 50-255 License No. DPR-20

Enclosure:

Document Request to Support Upcoming Inspection cc: Distribution via LISTSERV

Letter to Charles Arnone from Mel Holmberg dated March 25, 2019.

SUBJECT:

INFORMATION REQUEST TO SUPPORT UPCOMING INSPECTION AT THE PALISADES NUCLEAR PLANT DISTRIBUTION:

Michael McCoppin RidsNrrPMPalisades Resource RidsNrrDorlLpl3 RidsNrrDirsIrib Resource Darrell Roberts John Giessner Jamnes Cameron Allan Barker DRPIII DRSIII ADAMS Accession Number: ML19084A288 OFFICE RIII NAME MHolmberg:cl DATE 03/25/19 OFFICIAL RECORD COPY

DOCUMENT REQUEST TO SUPPORT UPCOMING INSPECTION Enclosure Please provide the information on a compact disc, if possible or hard copy.

Please provide the following information to the site Resident Inspectors Office by June 17, 2019. Please label any electronic files with file content information.

1. Corrective action records for boric acid leakage identified at the reactor vessel closure head (RVCH) nozzle 25 during the 2018 refueling outage (RFO) as identified in Licensee Event Report (LER) 2018-003-00. Records should include copies of completed corrective actions and planned corrective actions and include actions/assignments tracking the corrective measures for contracted Non-Destructive Examination vendor examination of the Palisades RVCH nozzles as discussed in LER 2018-003-00.

Specifically, the corrective actions and associated records should include the following:

a. Corrective actions associated with the LER statement, Future inspections will require prior training on the operating experience from this event, along with the requirement to identify the reactor head nozzles of interest population similar to that completed during the Extent of Condition review. Once nozzles of interest are identified, techniques up to and including eddy current testing, will be used to resolve indications in that population to ensure all flawed reactor head nozzles are addressed appropriately.

b. Cause investigation of for flaws identified in Palisades vessel head nozzles 25, 33 and 36 as discussed in LER 2018-003-00, including investigations of processing or operating factors that may have contributed to the initiation of primary water stress corrosion cracking type flaws from the inside surface (see MRP-110 Material Reliability Program Reactor Vessel Head Closure Penetration Safety Assessment for US PWR Plants.)

c. Vendor and site cause investigation records for prior ultrasonic (UT) examinations of Palisades RVCH nozzles that potentially missed flaw indications (including all referenced documents supporting these cause investigations). Include copies of corrective action records associated with these investigations including actions assigned as a result of these investigations (e.g., to correct any prior UT examination records with incomplete or inaccurate information, and or actions to enhance application of the UT procedures). Specifically, includes site actions in response to vendor cause investigations for prior UT examinations of RVCH nozzles that potentially missed flaw indications.

d. Records of vendor and site actions established with respect to UT examination procedure changes or additional examinations (e.g., Eddy Current) necessary to ensure reliable detection of flaws in the Palisades RVCH nozzles to ensure flaws are detected prior to through-wall leakage.

e. Investigations and test reports (e.g., isotopic and chemical analysis) that were completed to determine the source and/or age of the boron deposit identified at nozzle 25 during the previous outage and investigations to determine the length of time that the through-wall flaw was present in nozzle 25 during the past operating cycle.

DOCUMENT REQUEST TO SUPPORT UPCOMING INSPECTION 2

f. Document that identifies the period of plant operation with nozzle 25 leakage based on evaluation and/or testing of the as-found condition (e.g., extent of rust and/or boric acid deposit isotopic or chemical analysis to determine time these deposits formed/existed).

2. Dates (beginning and end dates) of operating cycle that proceeded evidence of through-wall reactor coolant system leakage at RVCH nozzle 25 as discussed in LER 2018-003-00 and reactor coolant unidentified leakage trends recorded during this operating cycle.

3. Boric Acid Program documentation and evaluations performed on RVCH nozzle 25 leakage as discussed in LER 2018-003-00 and copies of site procedures applicable to the evaluation.

4. Recent outage UT examination report for the RVCH nozzles and prior outage UT examination records for the RVCH nozzles dating back to 2007.

5. Vendor UT examination procedures applied during each outage for RVCH nozzle examinations beginning with 2007 RFO.

6. Records supporting the vendors UT examination procedure qualification for application to Palisades RVCH nozzle examinations. This should include:

a. Drawings that identify the Palisades RVCH nozzle dimensions (e.g., thickness and inside diameter)

b. Vendor UT procedure demonstration qualification sheet issued by Electric Power Research Institute;

c. EPRI and vendor records that identify material, size (e.g., thickness and inside diameter) and serial numbers of mockups used for vendor UT procedure demonstration qualification tests (both planar flaws and leak-path mockups); and

d. EPRI and vendor records of certification that the UT flaw mockups used for procedure qualification met: American Society of Mechanical Engineers (ASME)

Code Case N-729-1; or ASME Code Case 729-4; or the low rigor requirements of ASME Code Section V, Article 14; and associated U.S. Nuclear Regulatory Commission requirements identified in Title 10 of the Code of Federal Regulations, Part 50.55a.

7. Records that identify the vendor qualified UT examiner staff that performed examinations of nozzles 25, 33 and 36 during each of the 2007, 2009, 2010 and 2012 RVCH nozzle examinations.

8. Records of vendor or site corrective actions taken with respect to vendor examiner personnel UT qualifications/certifications for vendor staff that potentially misinterpreted flaws or leakage path indications during prior head examinations and that were subsequently identified in the Palisades vessel head nozzles 25, 33 and 36 during the 2018 refueling outage.

DOCUMENT REQUEST TO SUPPORT UPCOMING INSPECTION 3

9. Record of the flaws identified by your vendor during UT examination of nozzles 25, 33 and 36 during the 2018 RFO and during the in-depth review of prior data on reactor head as discussed in Palisades LER 2018-003-00. Specifically, include the documents that record flaw length, depth and orientation for each flaw in the affected nozzles in 2007, 2009, 2010 and 2012 and any evaluations for acceptability of these flaws with respect to meeting ASME Code Case N-729-1 and N-729-4 acceptance criteria (as applicable).

10. Site and vendor procedures that apply 10 CFR Part 21 requirements.

11. Part 21 evaluations completed by site and/or vendor for any prior UT examinations (back thru 2007) for investigations concluded ASME Code rejectable flaws that existed within RVCH nozzles at Palisades but were not identified or reported as rejectable flaws or record that identifies why these evaluations were not required. Specifically, records (site or vendor) that evaluated/applied the 10 CFR Part 21 definitions of defect and deviation to the vendor UT examination services procured for the reactor head UT examinations that did not identify detectible flaws in nozzles 25, 33 and 36 during the 2007, 2009, 2010 and 2012 UT examinations as discussed in Palisades LER 2018-003-00.

12. Corrective action records or design change actions that assigned actions to updated/revised the Reactor Vessel Design Specification to reflect the new materials and configuration for the RVCH repaired nozzles 25, 33, and 36 (reference paragraph IWA-4311(e) of the ASME Code Section XI) or provide a copy of the updated Reactor Vessel Design Specification that reflects these changes.

13. Record of review (Operating Experience) completed and actions taken (if any) a result of Shearon Harris Unit 1 LER 05000400-2013-001-00, Reactor Pressure Vessel Head Penetration Nozzle Indications Attributed to Primary Water Stress Corrosion Cracking, or similar operating experience issued on this topic and reviewed as a result of this event and site procedures applicable to review of operating experience.

14. Record of review (Operating Experience) completed and actions taken (if any) as a result of SHEARON HARRIS NUCLEAR PLANT - NRC SPECIAL INSPECTION REPORT 05000400/2013010.

Other:

On the first day of the inspection, provide the inspectors a copy of any corrective action records prompted by assembling records requested by this letter.