ML16078A037

Pilgrim - Notification for Information Only - Deviations from BWRVIP-41, Rev. 3, BWRVIP-76, Rev. 1-A, BWRVIP-139-A, and BWRVIP-180, Rev.0 Guidelines

ML16078A037
Person / Time
Site:	Pilgrim
Issue date:	03/11/2016
From:	Perkins E P Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.16.016
Download: ML16078A037 (7)

Text

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

SUBJECT:

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

REFERENCES:

1. BWRVIP-41, Rev.3, "BWR Jet Pump Assembly Inspection and Flaw Evaluation Guidelines" 2. BWRVIP-76, Rev.l-A, "BWR Core Shroud Inspection and Flaw Evaluation Guidelines" 3. BWRVIP-139-A, "BWR Steam Dryer Inspection and Flaw Evaluation Guidelines

4. BWRVIP-1 80, Rev.0, "BWR Access Hole Cover- Inspection and Flaw Evaluation Guidelines" 5. BWRVIP-94NP, Rev.2, "BWR Program Implementation Guidelines" 6. U.S. Nuclear Regulatory Commission Letter to Entergy, Supplemental Safety Evaluation Report Related to the License Renewal of Pilgrim Nuclear Power Station (TAC No. MC9669), June 30, 2011. (1.11.076)

LETTER NUMBER: 2.16.016

Dear Sir or Madam:

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

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

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

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

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

Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station Letter No. 2.16.016 Page 2 of 2 The deviations listed in Table 1 of the Attachment are all deviations from BWRVIP guidelines that are classified as "needed" elements of the BWRVIP program. The deviations are due to Entergy's recent announcement of plant closure, performance deficiencies with vendor ultrasonic testing tooling and plant configuration interferences to weld examinations.

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

Table 1 also lists the Pilgrim Station License Renewal Commitment Number associated with the corresponding BWRVIP guidelines document, if any (Reference 6).The deviations from the listed BWRVIP guidelines have been reviewed and approved in accordance with Entergy procedures and NEI 03-08 guidance.

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

If you have any questions or require additional information, please contact me at (508) 830-8323.This is a notification of deviation only, and no action is being requested from the NRC.There are no regulatory commitments made in this letter.Sincerely, Everett P. Perkins, Jr.' 'Regulatory Assurance Manager EPP/mw

Attachment:

TABLE I -Deviation Listing cc: Mr. Daniel H. Dorman Regional Administrator, Region I U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd., Suite 100 King of Prussia, PA 19406-2713 Mr. Joseph Holonich NRC/NRR BWRVIP Project Manager U.S. Nuclear Regulatory Commission Mail Stop 13 H10 Washington, DC 20555 Ms. Booma Venkataraman, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8C2A Washington, DC 20555 NRC Senior Resident Inspector Pilgrim Nuclear Power Station Attachment Letter Number 2.16.016 TABLE 1 -Deviation Listing (4 Pages)

Entergy Nuciear Operations, Inc.Pilgrim Nuclear Power Station Attachment to 2.16.016 Page 1 of 4 TABLE 1 -Deviation Listing BWRVIP Deviation from Justification for Deviation Alternative Actions /Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No.,___________________________________

BWRVIP-41, Rev.3 Pilgrim Station is required to re-inspect all jet pump (JP) beam BB-1 and BB-2 regions by UT methods by 2017; a 10-year re-inspection frequency (There are a total of 20 JPs).Instead, Pilgrim plans to perform an EVT-1 visual examination of all beams during the 2017 (RFO21) last planned refuel outage in lieu of UT re-inspection examination required by BWRVIP-41, Rev.3, Table 2-4.Pilgrim replaced all 20 original JP beams with the improved Group 2 beams in 1984 and has subsequently examined all beams by UT method per BWRVIP guidelines without any relevant indications.

The BWRVIP 10-year re-inspection frequency is based on a normal water chemistry environment.

However, Pilgrim's superior water chemistry environment should be conducive to a longer re-inspection interval, i.e., no-less than a 12-year interval ending in 2019 when the plant will be retired from active service.The alternative proposed examination of all 20 beams in 2017 will provide additional assurance that sufficient structural integrity exists to justify an additional cycle of operation to 2019. This alternative method is appropriate as the EVT-1 method has the capability to detect lntergranular Stress Corrosion Cracking (IGSCC)initiating from visible areas of the top surface and IGSCC is the only known significant degradation mechanism associated with JP beams.Pilgrim plans to perform an EVT-1 visual examination of all 20 beams during the 2017 (RFO21) refuel outage in lieu of UT re-inspection examination required by BWRVIP-41, Rev.3, Table 2-4.There are no License Renewal Commitments for inspection of jet pump beams.Upon BWRVIP approval, this deviation disposition constitutes an approved plant-specific application of the BWRVIP guidelines.

Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station Attachment to 2.16.016 Page 2 of 4 TABLE I -Deviation Listing BWRVIP TDeviation from 1Justification for Deviation Alternative Actions/Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No. j __ _____ __BWRVI P-76, Rev. 1 -A Pilgrim is required to re-inspect core shroud beltline vertical welds V15, V16, V17 and V18 by either a UT volumetric or two-sided EVT-1 visual examination method by 2017.The deviation is a one-time two-year extension over the 10-year re-inspection interval for the UT inspection strategy of the core shroud beltline vertical welds V15, V16, V17 and V18 as required by BWRVIP-76, Rev.l-A, Figure 3-3. The two year extension is from 2017 to 2019, when Pilgrim plans to cease operations.

Pilgrim is a BWR-3 with a repaired Category C core shroud. The plant installed a pre-emptive shroud repair in 1995 to structurally replace shroud horizontal welds HI through H10. The repair consists of four tie-rods installed at azimuths 450, 1350, 2250 and 3150 which coincide with azimuthal locations of shroud vertical welds V1 5, Vi16, V17 and V18. These tie-rod locations completely prevent inspection access to the welds from the shroud exterior surface and would require peripheral fuel removal for interior access.Pilgrim has an extensive history of shroud inspections with no relevant indications by visual or UT methods. The four vertical welds V1 5, Vi16, V1 7 and VI18 were last inspected in 2007 with a full volumetric UT method from the shroud interior surface achieving>90% coverage of all four welds with no relevant indications noted.These shroud welds are fully mitigated by Hydrogen Water Chemistry (HWC) and Noble Metals Chemical Addition (NMCA) to prevent or reduce the effects of IGSCC.Fleet operating experience shows "very little vertical weld cracking has occurred within the U.S. fleet" as stated in BWRVIP-278, Section 5.3.2.Pilgrim performed plant-specific calculations in accordance with BWRVIP guidelines and conservatively concluded that the 20%extension over the 10-year inspection interval is structurally acceptable to justify an additional cycle of operation.

Pilgrim performed plant-specific calculations in accordance with BWRVIP guidelines and conservatively concluded that the one-time 20%extension over the 10-year inspection interval is structurally acceptable to justify an additional cycle of operation.

There are no License Renewal Commitments for inspection of core shroud welds.Upon BWRVIP approval, this deviation disposition constitutes an approved plant-specific application of the BWRVIP guidelines.

/Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station TABLE 1 -Deviation Listing Attachment to 2.16.016 Page 3 of 4 BWRVIP Deviation from Justification for Deviation Alternative Actions /Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No.7 BWRVIP-1 39- Pilgrim is required to Pilgrim has complied with the inspection requirements of BWRVIP- Pilgrim plans to visually A re-inspect steam dryer 139-A and previously with GE SIL No.644. PNPS recently examine tie-bars #6, #7 and interior key locations completed the re-inspection of exterior dryer locations required by #8 ini 2017 (RFO21).and a 10% sampling of BWRVIP-1 39-A in 2015. The Pilgrim steam dryer is a non-safety-other dryer interior related component with no history of significant structural License Renewal welds every 10 years degradation.

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

The interior structure No. MC9669)139-A, Section 5.3.4(D) of the square hood dryer configuration does not have diagonal by the visual VT-1(89) bracings and interior brackets that have caused high stress This is a one-time action.method by 2017. concentrations in some dryer designs. Inspection of this component*is an economic issue directed primarily at preventing the generation Upon BWRVIP approval, this The deviation is a one- of loose parts in the reactor vessel. There have been few indications deviation disposition time two-year in dryer welds or components but these indications have been re- constitutes an approved extension over the 10- inspected repeatedly and have shown to be stable with no evidence plant-specific application of year re-inspection of crack growth or continued degradation.

However, one new the BWRVIP guidelines.

interval for selected indication was identified in 2015 when original tie-bar #8 was found interior locations from to be partially cracked. Tie-bar #8 will be re-inspected (and re-10 to 12 years (2017 to evaluated) in 2017 along with adjacent tie-bars #6 and #7. An 2019, when Pilgrim evaluation confirmed that tie-bar #8 does not present a loose-parts plans to cease concern. The structural integrity of the dryer is monitored by operations).

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

Based on moisture carryover trends since 2005, there has been no indication of a reduction in the structural integrity of the steam dryer. Pilgrim has not installed a power uprate other than a thermal power uprate.It is therefore reasonable to conclude that the alternative plans to re-examine tie-bars #6, #7 and #8 in 2017, will provide sufficient assurance to maintain the structural integrity of the dryer for an additional cycle of operation to 2019.

Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station Attachment to 2.16.016 Page 4 of 4 TABLE 1 -Deviation Listing BWRVIP Deviation from Justification for Deviation Alternative Actions /Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No.BWRVIP-1 80, Pilgrim is required to Pilgrim has an extensive inspection history regarding the AH~s with Pilgrim plans to perform an Rev.0 complete a UT no service-induced recordable indications since the first UT EVTI-1 visual examination of baseline examination examination in RFO8 (1991). The similarly constructed AHC weld at the 180 degree AHC in 2017 of the access hole azimuth 0° was recently examined with UT in RFO2O (2015) with (RFO2I).cover (AHC) weld at 100% coverage achieved and no service-induced relevant 1800 by 2017. Pilgrim_ indications.

License Renewal successfully completed Commitment No.34 (TAO the baseline UT of the The BWRVIP-180 inspection guidelines allow use of the EVT-1 No. MC9669)00 AHC in 2015 but examination method until such time as a UT technique is deferred examination demonstrated and documented by the BWRVIP. The UT technique This is a one-time action.of the 1800 cover to the was demonstrated by EPRI/GEH however, the UT tooling used at 2017 refuel outage due Pilgrim Station in RFO2O lacked reliability as it could only examine Upon BWRVIP approval, this to adverse inspection the AHC at the 00 but not at the 1800 side as planned. The AHC deviation disposition tooling issues which design at Pilgrim Station is unique to the industry consisting of an constitutes an approved prevented completion "intermediate" thickness configuration that required a hybrid plant-specific application of of the baseline combination of "thin" and "thick" mockups for the EPRI/GEH the BWRVIP guidelines.

examination of the demonstration.

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

Only a small percentage of Instead, Pilgrim plans the AHC 3600 circumferential seal weld is required to maintain a to perform an EV-I-1 leak-tight barrier. There are no known industry operating experience visual examination of reports of cracking in AHCs since the BWR fleet implemented the 1800 AHC in 2017, improved water chemistry.

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

degradation mechanism for this weld._____________

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

SUBJECT:

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

REFERENCES:

1. BWRVIP-41, Rev.3, "BWR Jet Pump Assembly Inspection and Flaw Evaluation Guidelines" 2. BWRVIP-76, Rev.l-A, "BWR Core Shroud Inspection and Flaw Evaluation Guidelines" 3. BWRVIP-139-A, "BWR Steam Dryer Inspection and Flaw Evaluation Guidelines

4. BWRVIP-1 80, Rev.0, "BWR Access Hole Cover- Inspection and Flaw Evaluation Guidelines" 5. BWRVIP-94NP, Rev.2, "BWR Program Implementation Guidelines" 6. U.S. Nuclear Regulatory Commission Letter to Entergy, Supplemental Safety Evaluation Report Related to the License Renewal of Pilgrim Nuclear Power Station (TAC No. MC9669), June 30, 2011. (1.11.076)

LETTER NUMBER: 2.16.016

Dear Sir or Madam:

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

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

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

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

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

Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station Letter No. 2.16.016 Page 2 of 2 The deviations listed in Table 1 of the Attachment are all deviations from BWRVIP guidelines that are classified as "needed" elements of the BWRVIP program. The deviations are due to Entergy's recent announcement of plant closure, performance deficiencies with vendor ultrasonic testing tooling and plant configuration interferences to weld examinations.

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

Table 1 also lists the Pilgrim Station License Renewal Commitment Number associated with the corresponding BWRVIP guidelines document, if any (Reference 6).The deviations from the listed BWRVIP guidelines have been reviewed and approved in accordance with Entergy procedures and NEI 03-08 guidance.

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

If you have any questions or require additional information, please contact me at (508) 830-8323.This is a notification of deviation only, and no action is being requested from the NRC.There are no regulatory commitments made in this letter.Sincerely, Everett P. Perkins, Jr.' 'Regulatory Assurance Manager EPP/mw

Attachment:

TABLE I -Deviation Listing cc: Mr. Daniel H. Dorman Regional Administrator, Region I U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd., Suite 100 King of Prussia, PA 19406-2713 Mr. Joseph Holonich NRC/NRR BWRVIP Project Manager U.S. Nuclear Regulatory Commission Mail Stop 13 H10 Washington, DC 20555 Ms. Booma Venkataraman, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8C2A Washington, DC 20555 NRC Senior Resident Inspector Pilgrim Nuclear Power Station Attachment Letter Number 2.16.016 TABLE 1 -Deviation Listing (4 Pages)

Entergy Nuciear Operations, Inc.Pilgrim Nuclear Power Station Attachment to 2.16.016 Page 1 of 4 TABLE 1 -Deviation Listing BWRVIP Deviation from Justification for Deviation Alternative Actions /Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No.,___________________________________

BWRVIP-41, Rev.3 Pilgrim Station is required to re-inspect all jet pump (JP) beam BB-1 and BB-2 regions by UT methods by 2017; a 10-year re-inspection frequency (There are a total of 20 JPs).Instead, Pilgrim plans to perform an EVT-1 visual examination of all beams during the 2017 (RFO21) last planned refuel outage in lieu of UT re-inspection examination required by BWRVIP-41, Rev.3, Table 2-4.Pilgrim replaced all 20 original JP beams with the improved Group 2 beams in 1984 and has subsequently examined all beams by UT method per BWRVIP guidelines without any relevant indications.

The BWRVIP 10-year re-inspection frequency is based on a normal water chemistry environment.

However, Pilgrim's superior water chemistry environment should be conducive to a longer re-inspection interval, i.e., no-less than a 12-year interval ending in 2019 when the plant will be retired from active service.The alternative proposed examination of all 20 beams in 2017 will provide additional assurance that sufficient structural integrity exists to justify an additional cycle of operation to 2019. This alternative method is appropriate as the EVT-1 method has the capability to detect lntergranular Stress Corrosion Cracking (IGSCC)initiating from visible areas of the top surface and IGSCC is the only known significant degradation mechanism associated with JP beams.Pilgrim plans to perform an EVT-1 visual examination of all 20 beams during the 2017 (RFO21) refuel outage in lieu of UT re-inspection examination required by BWRVIP-41, Rev.3, Table 2-4.There are no License Renewal Commitments for inspection of jet pump beams.Upon BWRVIP approval, this deviation disposition constitutes an approved plant-specific application of the BWRVIP guidelines.

Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station Attachment to 2.16.016 Page 2 of 4 TABLE I -Deviation Listing BWRVIP TDeviation from 1Justification for Deviation Alternative Actions/Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No. j __ _____ __BWRVI P-76, Rev. 1 -A Pilgrim is required to re-inspect core shroud beltline vertical welds V15, V16, V17 and V18 by either a UT volumetric or two-sided EVT-1 visual examination method by 2017.The deviation is a one-time two-year extension over the 10-year re-inspection interval for the UT inspection strategy of the core shroud beltline vertical welds V15, V16, V17 and V18 as required by BWRVIP-76, Rev.l-A, Figure 3-3. The two year extension is from 2017 to 2019, when Pilgrim plans to cease operations.

Pilgrim is a BWR-3 with a repaired Category C core shroud. The plant installed a pre-emptive shroud repair in 1995 to structurally replace shroud horizontal welds HI through H10. The repair consists of four tie-rods installed at azimuths 450, 1350, 2250 and 3150 which coincide with azimuthal locations of shroud vertical welds V1 5, Vi16, V17 and V18. These tie-rod locations completely prevent inspection access to the welds from the shroud exterior surface and would require peripheral fuel removal for interior access.Pilgrim has an extensive history of shroud inspections with no relevant indications by visual or UT methods. The four vertical welds V1 5, Vi16, V1 7 and VI18 were last inspected in 2007 with a full volumetric UT method from the shroud interior surface achieving>90% coverage of all four welds with no relevant indications noted.These shroud welds are fully mitigated by Hydrogen Water Chemistry (HWC) and Noble Metals Chemical Addition (NMCA) to prevent or reduce the effects of IGSCC.Fleet operating experience shows "very little vertical weld cracking has occurred within the U.S. fleet" as stated in BWRVIP-278, Section 5.3.2.Pilgrim performed plant-specific calculations in accordance with BWRVIP guidelines and conservatively concluded that the 20%extension over the 10-year inspection interval is structurally acceptable to justify an additional cycle of operation.

Pilgrim performed plant-specific calculations in accordance with BWRVIP guidelines and conservatively concluded that the one-time 20%extension over the 10-year inspection interval is structurally acceptable to justify an additional cycle of operation.

There are no License Renewal Commitments for inspection of core shroud welds.Upon BWRVIP approval, this deviation disposition constitutes an approved plant-specific application of the BWRVIP guidelines.

/Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station TABLE 1 -Deviation Listing Attachment to 2.16.016 Page 3 of 4 BWRVIP Deviation from Justification for Deviation Alternative Actions /Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No.7 BWRVIP-1 39- Pilgrim is required to Pilgrim has complied with the inspection requirements of BWRVIP- Pilgrim plans to visually A re-inspect steam dryer 139-A and previously with GE SIL No.644. PNPS recently examine tie-bars #6, #7 and interior key locations completed the re-inspection of exterior dryer locations required by #8 ini 2017 (RFO21).and a 10% sampling of BWRVIP-1 39-A in 2015. The Pilgrim steam dryer is a non-safety-other dryer interior related component with no history of significant structural License Renewal welds every 10 years degradation.

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

The interior structure No. MC9669)139-A, Section 5.3.4(D) of the square hood dryer configuration does not have diagonal by the visual VT-1(89) bracings and interior brackets that have caused high stress This is a one-time action.method by 2017. concentrations in some dryer designs. Inspection of this component*is an economic issue directed primarily at preventing the generation Upon BWRVIP approval, this The deviation is a one- of loose parts in the reactor vessel. There have been few indications deviation disposition time two-year in dryer welds or components but these indications have been re- constitutes an approved extension over the 10- inspected repeatedly and have shown to be stable with no evidence plant-specific application of year re-inspection of crack growth or continued degradation.

However, one new the BWRVIP guidelines.

interval for selected indication was identified in 2015 when original tie-bar #8 was found interior locations from to be partially cracked. Tie-bar #8 will be re-inspected (and re-10 to 12 years (2017 to evaluated) in 2017 along with adjacent tie-bars #6 and #7. An 2019, when Pilgrim evaluation confirmed that tie-bar #8 does not present a loose-parts plans to cease concern. The structural integrity of the dryer is monitored by operations).

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

Based on moisture carryover trends since 2005, there has been no indication of a reduction in the structural integrity of the steam dryer. Pilgrim has not installed a power uprate other than a thermal power uprate.It is therefore reasonable to conclude that the alternative plans to re-examine tie-bars #6, #7 and #8 in 2017, will provide sufficient assurance to maintain the structural integrity of the dryer for an additional cycle of operation to 2019.

Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station Attachment to 2.16.016 Page 4 of 4 TABLE 1 -Deviation Listing BWRVIP Deviation from Justification for Deviation Alternative Actions /Guidelines BWRVIP Guidelines License Renewal Document Regulatory Commitment No.BWRVIP-1 80, Pilgrim is required to Pilgrim has an extensive inspection history regarding the AH~s with Pilgrim plans to perform an Rev.0 complete a UT no service-induced recordable indications since the first UT EVTI-1 visual examination of baseline examination examination in RFO8 (1991). The similarly constructed AHC weld at the 180 degree AHC in 2017 of the access hole azimuth 0° was recently examined with UT in RFO2O (2015) with (RFO2I).cover (AHC) weld at 100% coverage achieved and no service-induced relevant 1800 by 2017. Pilgrim_ indications.

License Renewal successfully completed Commitment No.34 (TAO the baseline UT of the The BWRVIP-180 inspection guidelines allow use of the EVT-1 No. MC9669)00 AHC in 2015 but examination method until such time as a UT technique is deferred examination demonstrated and documented by the BWRVIP. The UT technique This is a one-time action.of the 1800 cover to the was demonstrated by EPRI/GEH however, the UT tooling used at 2017 refuel outage due Pilgrim Station in RFO2O lacked reliability as it could only examine Upon BWRVIP approval, this to adverse inspection the AHC at the 00 but not at the 1800 side as planned. The AHC deviation disposition tooling issues which design at Pilgrim Station is unique to the industry consisting of an constitutes an approved prevented completion "intermediate" thickness configuration that required a hybrid plant-specific application of of the baseline combination of "thin" and "thick" mockups for the EPRI/GEH the BWRVIP guidelines.

examination of the demonstration.

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

Only a small percentage of Instead, Pilgrim plans the AHC 3600 circumferential seal weld is required to maintain a to perform an EV-I-1 leak-tight barrier. There are no known industry operating experience visual examination of reports of cracking in AHCs since the BWR fleet implemented the 1800 AHC in 2017, improved water chemistry.

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

degradation mechanism for this weld._____________