new palisades - inservice inspection master program fifth 10-year … · 2015. 12. 17. · (pnp)...

Entergy Nuclear Operations, Inc.Palisades Nuclear Plant27780 Blue Star Memorial HighwayE’nterg)fJeffery A. HardyRegulatory Assurance Manager

PNP 201 5-089

December 09, 2015

U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001

SUBJECT: Inservice Inspection Master Program Fifth 10-year Interval

Palisades Nuclear PlantDocket 50-255Renewed Facility Operating License No. DPR-20

References: 1. Entergy Nuclear Operations, Inc. leffer to NRC, PNP 2015-022, ReliefRequest Number RR 5-1, Proposed Alternative, Extend the CurrentASME Code of Record into the Fifth 10-year IS! Interval for ISI RelatedActivities, dated April 29, 2015 (ADAMS Accession NumberML151 19A223)

2. NRC letter to Entergy Nuclear Operations, Inc., Palisades Nuclear Plant —Relief Request Number 5-1, Proposed Alternative, Extend the CurrentASME Code of Record into the Fifth 10-year ISI Interval for ISl RelatedActivities (CAC No. MF6162), dated November 25, 2015 (ADAMSAccession 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 Plant’s (PNP) inservice inspection (ISI) masterprogram 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 by10 CFR 50.55a(b), Use and conditions on the use of standards, PNP’s plan will comply with theAmerican 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 maintainrepair/replacement (R/R), pressure testing (PT), and nondestructive examination (NDE)activities to the fourth 10-year inspection interval’s ASME BPV, Section XI, 2001 Edition through2003 Addenda requirements for the first period of the fifth 10-year interval through December31, 2017. This was requested to align RIR, PT, and NDE for all Entergy units to the same codeof 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 5-089Page 2 of 2

Sincerely,

JAH/jpm

Enclosure: Entergy Nuclear Operations, Inc., Palisades Nuclear Plant, Palisades InserviceInspection Master Program Fifth Interval, ASME Section XI, Division 1

cc: Administrator, Region III, USNRCProject Manager, Palisades, USN RCResident 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

Program Section No.: SEP-ISI-PLP-003

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Revision No.: 3Page No.: I of 124

PROGRAM SECTIONFOR

PALISADES INSERVICE INSPECTION MASTER PROGRAMFIFTH 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:

, Program Section No.: SEP 1S1-PLP-003Revision No.: 3

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REVIEW AND CONCURRENCE SHEET

Program Section Title: ASME SECTION Xl, DIVISION 1, PALISADESINSERVICE 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//i5ResfiibIe isor


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REVISION STATUS SHEET

REVISION SUMMARY

REVISION ISSUE DATE DESCRIPTION0 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 withASME Code Case N-716-1 “Alternative Classification andExamination Requirements Section Xl, Division 1”

Revised the program section to incorporate various outstandingchanges. A summary of changes is included as part of thereview package for EC56288 providing details on all of thechanges made.

2 9/18/15 Revised section 5.1.5 and 7.3.4 to remove the surfaceexamination requirement for the Augmented Program ORM 4.12welds. ORM 4.12-1 only requires volumetric examination.

3 12/13/15 Revised the program section in its entirety to reflect the programupdate to the fifth ISl interval which includes updating theprogram to the requirements of the American Society ofMechanical Engineers (ASME) Boiler and Pressure VesselCode, Section Xl, 2007 Edition through 2008 Addenda.


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SEP-ISI-PLP-003 R3PAGE REVISION STATUS

Section Page No. RevisionMain Body All 3


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TABLE OF CONTENTS

Section Description PageREVISION SUMMARY 3

1.0 ASME Section XI Inservice Inspection Program 71.1 Purpose 71.2 General 91.3 Inspection Intervals 131.4 ASME Section Xl Code of Record for Fifth Inservice Inspection

Interval 161.5 ASME Section XI Inservice Inspection Program Description 181.6 Administrative Controls 26

2.0 ASME Section Xl Code Case Applicability 272.1 Adoption of Code Cases 272.2 Regulatory Guide 1.147, Revision 17, Approved Code Cases 292.3 Code Cases Approved through Request for Alternatives 322.4 Code Cases Required by 10 CFR 50.55a 32

3.0 Relief Requests 343.1 Request for Alternatives 343.2 Relief Request Required due to Impracticality or Limited

Examinations 353.3 Requests to use Later Edition and Addenda of ASME Section Xl 35

4.0 Developmental References 374.1 External References 374.2 Entergy Fleet References 374.3 Palisades Site References 37

5.0 Augmented, Owner Elected, Alloy 600, and Renewed License Inservice InspectionRequirements 395.1 Augmented Examination Programs 395.2 Owner Elected Examinations for Internal Commitments 495.3 Alloy 600 Program 515.4 License Renewal Examinations for Aging Management Commitments..62

6.0 ASME Systems & Examination Boundaries 656.1 Definitions 656.2 Classification Criteria 656.3 Inspection Rules 656.4 Quality Group Classification 666.5 Identification 66


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7.0 Application Criteria and Code Compliance 707.1 ASME Section Xl 707.2 Augmented Program 847.3 Owner Elected Program 867.4 Code Category Summary 87

8.0 Inservice Inspection Data Management Software 1158.1 Description 1158.2 Control 1158.3 Suite 1158.4 Version 9 of the IDDEAL Software Suite® 1158.5 Data 116

9.0 Examination Evaluation Criteria 1179.1 Successive Inspections 1179.2 Additional Examinations 119

10.0 Risk-Informed lSl Program 12310.1 Reactor Vessel Inspections 12310.2 ASME Section Xl Code Case N-716-1 Implementation 123


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1.0 ASME Section XI Inservice Inspection Program1

1.1 Purpose

This program’s objective is to provide a traceable link between the governing requirements of 10CFR 50.55a, ASME Section Xl, and applicable commitments; and, the implementing proceduresin order to ensure the Regulatory rules and ASME Section XI Code requirements for the InserviceInspection of Nuclear Power Plant Components (ISI) are being fulfilled.

These instructions provide the necessary guidance for the Corporate & Station EngineeringPrograms personnel at Entergy’s 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 PressureVessel Code, Section Xl, 2007 Edition through 2008 Addenda. (Commonly referenced in thisdocument 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 implementingprocedures.

5) Implementation of the proper ASME Section XI Code required examinations, tests andadministrative procedures.

6) Submittal to and approval by the regulatory authority, of the proper ASME Section Xl Coderequests for alternatives and relief requests.

7) Performance of component repair and replacement activities in accordance with ASMESection Xl Code requirements.

8) Maintenance and submittal of the proper examination, test and repair and replacementrecords and reports.

Figure 1 shows how this program effectively functions as a central source to help ensure allregulatory rules and Palisades requirements are incorporated into the ISI Program. This programprovides 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 isconsidered synonymous with the tern, program” as used in ASME Section Xl (2007/2008), Article IWA-2400, which includesboth the use of the term “plan” as used in IWA-2420 and IWA-2425, and the more restrictive use of the term uprogram as usedin IWA-2431.


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ASME CodeFigure 1

Section Xl(2007/2008)

-H

Examination

[••

MethodSection III

(as applicable)

____________

Visual

__________________

Inspection

_______________

ANSI ProgramSpecifications

______________

Code of

______________

_________________

Inservice

________________

Federal

_______________

________________

- Regulations

_________

Inspection

____________

ProceduresF

ImplementNuclear I

Regulato I Title 10 PartPlant Technical Program

H

Surveillance

InspectionsSpecifications

_________________ ________ ________

50.55a 5.5.6, 5.5.7

Specifications

Commission

F Regulato r Final Safety HTesting

Guides Analysis Report— 1.14

1.261.6 Administrative

Procedures1.84

1.147 Alternatives,1.193 Relief Requests1.200

____________________________________

Limitedination}

ComplianceRecords & Reports [izecIea_

lnservice Inspector

• Program Section No.: SEP-ISI-PLP-003

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1.2 General

The Palisades Fifth Interval 1St Program is established in accordance with Title 10 Code ofFederal Regulations Part 50.55a (10 CFR 50.55a). This program has been developed to complywith the American Society of Mechanical Engineers (ASME) Section XI, Rules for lnserviceInspection of Nuclear Power Plant Components, 2007 Edition through 2008 Addenda, andimplements the requirements of Final Safety Analysis Report (FSAR) 1.6, Inservice InspectionProgram.

The Palisades nuclear power plant was built in the late 1960’s and was placed into commercialoperation on December 31, 1971. The Nuclear Steam Supply System (NSSS) was furnished byCombustion Engineering. The Architect Engineer for Palisades during construction was BechtelCorporation. During the first 40-month life of the plant, in order to comply with paragraphs 4.3and 4.12 of the previous technical specifications (dated September 1, 1972) of the Palisadesoperating 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 XICode, 1971 edition including winter 1972 addenda. In February 1976, the NRC amendedparagraph 55a(g) of 10 CFR 50 to require nuclear plants to upgrade their technical specificationsin the areas of 151 requirements and functional testing of pumps and valves. By amendingparagraph 55a(g) and by invoking Regulatory Guide 1.26, the NRC required nuclear plants toupgrade their systems to include not only class 1 systems, but also class 2 and class 3 systemsin their ISI programs.

The Palisades nuclear power plant has been owned and operated over time by differentcompanies 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 madeunder different names continue to apply, unless they have been withdrawn.


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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 informedprogram in effect during the latter portion of the Third Interval.

2001/2003 ASME B&PV Code, Section XI, 2001 Edition through 2003 Addenda2007/2008 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 IntegrityAFW Auxiliary Feedwater (ref. Risk Informed)AL-600 Alloy 600 ProjectANII Authorized Nuclear Inservice InspectorANSI American National Standards InstituteARH Auxiliary Return HeaderASH Auxiliary Supply HeaderASME American Society of Mechanical Engineers

ASTM ASTM International, formerly American Society for Testing andMaterials

AWS Auxiliary Water SystemB&PV Boiler and Pressure VesselBLD Blowdown (ref. Risk Informed)BMV Bare Metal Visual ExaminationBWR Boiling Water ReactorCCS Component Cooling SystemCDS Condensate System (ref. Risk Informed)CEP Common Engineering Program SectionCHL Charging LineCHP Charging High PressureCHX Cooling Heat ExchangerCMU Condensate MakeupCPU Component Cooling PumpCPL Cavity Pool LineCR Condition ReportCRD Control Rod DriveCRS Containment Air CoolingCSH Containment Supply HeaderCSS Containment Spray SystemCST Condensate Storage Tank

Program Section No: SEP-ISI-PLP-003

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CSW Critical Service WaterCVC Chemical and Volume ControlCWR Clean Waste ReceiverCWS Circulating Water System (ref. Risk Informed)D-I-D Defense in Depth (ref. Risk Informed)DMW Demineralized Water SystemDPT Dye Penetrant Testing (surface examination)DRL Drain LineEPRI Electric Power Research InstituteEPS Emergency Power SystemESS Engineered Safeguards SystemET Eddy Current Testing (surface examination)EVT Enhanced Visual Testing (visual examination)FAC Flow Accelerated CorrosionFPF Fuel Pool FilterFPP Fuel Pool PumpFPS Fire Protection System (ref. Risk Informed)FWL Feedwater LineHED Heating and Extraction Steam, and Drains (ref. Risk Informed)ID Inside DiameterlE Industry ExperienceIRS Inner RadiusISI Inservice InspectionLDD Letdown DrainLDL Letdown LineLTC Long Term CoolingLPI Low Pressure Injection (ref. Risk Informed)MPT Magnetic Particle Testing (surface examination)MRP Materials Reliability ProgramMSL Main Steam LineMSS Main Steam SystemMSV Main Steam Valve LineNDE Nondestructive ExaminationNMC Nuclear Management CompanyNPS Nominal Pipe Size (inches)NRC Nuclear Regulatory CommissionNRR NRC Office of Nuclear Reactor RegulationNSW Non-Critical Service Water (ref. Risk Informed)CD Outside DiameterORM4.12 Operating Requirements Manual, Section 4.12P&ID Piping and Instrumentation DiagramPCN Procedure Change Notice

Program Section No.: sEP-ISI-PLP-003

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PCS Primary Coolant System. Synonymous with RCS.PDI Performance Demonstration InitiativePLP Palisades Nuclear PlantPORV Power Operated Relief ValvePRS Pressurizer Relief SystemPSL Pressurizer Surge LinePSS Pressurizer Spray LinePT Pressure Tap, or Penetrant Testing (surface examination)PWR Pressurized Water ReactorPWSCC Primary Water Stress Corrosion CrackingPZR Pressurizer (ref. Risk Informed)QAPM Entergy Quality Assurance Program ManualRCL Reactor Coolant LineRE Recirculation LineRG Regulatory Guide (NRC document)RCS Reactor Coolant System. Synonymous with PCS.RHC Return Header CombinedRI Risk InformedRI-ISI Risk Informed ISIRWS Radwaste SystemRPV Reactor Pressure VesselRVR Relief Valve LineSCH Shutdown Cooling Heat ExchangerSCS Shield Cooling SystemSDC Shutdown Cooling SystemSEP Site Engineering Program SectionSFP Spent Fuel PoolSFX Spent Fuel Heat ExchangerSIS Safety Injection SystemSPT System Pressure Test (IWA-5000)SRT Safety Refueling Tank (also called SIRVV)SSS SIRW and Containment Sump Suction (ref. Risk Informed)SWP Service Water PumpSWS Service Water SystemSX Sample LineUT Ultrasonic Testing (volumetric examination)VAS Ventilation and Air Conditioning SystemVT Visual Testing (visual examination)


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1.3 Inspection Intervals

The commercial operation date for Palisades was December 31, 1971. The First ISI Intervalended November 9, 1983, as allowed by IWA-2430(e), due to extended time out of service formodifications 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 1983-1984for 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 IWA2430(e), ASME Boiler and Pressure Vessel Code, Section XI, 1989 Edition. During the SecondPeriod, Palisades was out of service for 215 consecutive days from June 21, 2001 throughJanuary 21, 2002 for replacement of control rod drive mechanism upper housings. A one-yearinterval extension also was applied, extending the Second Period to coincide with the 2003refueling 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 NRCapproval of Relief Request TAC MD9265, which allows extension of the reactor vessel inspectioninterval for these welds. Reactor vessel Category B-A and B-D weld inspections were performedduring 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, torecover 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 extendedapproximately ten months to include the Fall 2010 refueling outage in accordance with IWA2430(d)(3).

The Fifth Interval began on December 13, 2015 and will end on December 12, 2025.


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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 lSldesignate ISI interval, period, and outage sequence within the period.

interval are scheduled as follows. ISI outage numbers

Program Section No.:SEP-ISI-PLP-003

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Palisades Fifth Interval Inservice Inspection Schedule2

Period 5-1 Period 5-2 Period 5-3

1 R25 1 R26 I R27 1 R28 1 R29 1 R305-1-1 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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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, ifany, to be used by licensees for performing inservice inspections of components (includingsupports). Paragraph 50.55a(g)(4)(ii) requires the use of the latest edition and addenda that hasbeen 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 inparagraph (b)(2) with limits and conditions. Revisions to 10 CFR 50.55a in October 2008 andJune 2011 mandated implementation of Code Cases N-722-1, N-729-1, and N-770-1, withconditions 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 onthe 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 applicableconditions 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 Ipiping (applies to Table IWB—2500 and IWB—2500—I and Categoiy B—J). Ifthe facility’s application for a construction permit was docketed prior to July 1,1978, the extent of examination for Code Class 1 pipe welds may bedetermined by the requirements of Table IWB-2500 and Table IWB-2600Category B-J of Section Xl of the ASME BPV Code in the 1974 Edition andAddenda through the Summer 1975 Addenda or other requirements the NRCmay adopt.

(Note: This reference is provided for information/completeness only, CategoryB-J welds will be examined in accordance with CC N-716-1.)

10 CFR 50.55a(b)(2)(xiv) Section Xl condition: Appendix VIII personnel qualification. All personnelqualified for performing ultrasonic examinations in accordance with AppendixVIII must receive 8 hours of annual hands-on training on specimens thatcontain cracks. Licensees applying the 1999 Addenda through the latest editionand addenda incorporated by reference in paragraph (a)(1)(ii) of this sectionmay use the annual practice requirements in Vll—4240 of Appendix VII ofSection Xl in place of the 8 hours of annual hands-on training provided that thesupplemental practice is performed on material or welds that contain cracks, orby analyzing prerecorded data from material or welds that contain cracks. Ineither case, training must be completed no earlier than 6 months prior toperforming ultrasonic examinations at a licensee’s facility.


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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 Iand II nondestructive examination personnel must be recertified on a 3-yearinterval in lieu of the 5-year interval specified in the 1997 Addenda and 1998Edition of IWA-2314, and IWA-2314(a) and IWA-2314(b) of the 1999 Addendathrough the latest edition and addenda incorporated by reference in paragraph(a)(1)(iii) of this section.

10 CFR 50.55a(b)(2)(xix) Section Xl condition: Substitution of alternative methods.. . . The provisions in IWA—4520(b)(2) and IWA—4521 of the 2008 Addendathrough the latest edition and addenda incorporated by reference in paragraph(a)(1)(ii) of this section, allowing the substitution of ultrasonic examination forradiographic examination specified in the Construction Code, are not approvedfor use.

10 CFR 50 55a”b”2”xxi”A’ Section Xl Condition: Table IWB—2500—1 examination requirements: First‘ “ “ “‘ provision. The provisions of Table IWB 2500—1, Examination Category B—D,

Full Penetration Welded Nozzles in Vessels, ... Items B3.120 and B3.140(Inspection Program B) of the 1998 Edition must be applied when using the1999 Addenda through the latest edition and addenda incorporated byreference in paragraph (a)(1)(ii) of this section. A visual examination withmagnification that has a resolution sensitivity to detect a 1-mil width wire orcrack, utilizing the allowable flaw length criteria in Table IWB—3512—1, 1997Addenda through the latest edition and addenda incorporated by reference inparagraph (a)(1 )(ii) of this section, with a limiting assumption on the flaw aspectratio (i.e., all = 0.5), may be performed instead of an ultrasonic examination.

10 CFR 50.55a(b)(2)(xxii) Section Xl condition: Surface examination. The use of the provision in IWA—2220, “Surface Examination,’ of Section Xl, 2001 Edition through the latestedition and addenda incorporated by reference in paragraph (a)(1)(ii) of thissection, that allows use of an ultrasonic examination method is prohibited.

10 CFR 50 55a”b”2”xxix Section XI condition: NonmandatoryAppendix R. Nonmandatory Appendix R,“ “ “Risk-Informed Inspection Requirements for Piping,” of Section XI, 2005 Addendathrough 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 theproposed alternative in accordance with paragraph (z) of this section.

10 CFR 50.55a(g)(6)(ii)(D)(1) Augmented lSl requirements: Reactor vessel head inspections. Alllicensees of pressurized water reactors must augment their inservice inspectionprogram with ASME Code Case N—729—1, subject to the conditions specified inparagraphs (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 performedusing personnel, procedures, and equipment that have been qualified by blind demonstration onrepresentative 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 ASMECode Case N—729—1. References herein to Section Xl, Appendix VIII, must be to the 2004 Editionwith no addenda of the ASME BPV Code.)


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10 CFR 50.55a Reference Mandated Additional RequirementslConditionslExemptions

10 CFR 50 55 “6”ii”E’1’Augmented IS! requirements: Reactor coolant pressure boundary visualinspections. All licensees of pressurized water reactors must augment theirinservice inspection program by implementing ASME Code Case N—722—1,subject to the conditions specified in paragraphs (g)(6)(ii)(E)(2) through (4) ofthis section. The inspection requirements of ASME Code Case N—722—1 do notapply to components with pressure retaining welds fabricated with Alloy600/82/182 materials that have been mitigated by weld overlay or stressimprovement.

10 CFR 50.55a(g)(6)(ii)(F)(1) Augmented ISI requirements: Examination requirements for Class Ipiping and nozzle dissimilar-metal butt welds. Licensees of existing,operating pressurized-water reactors as of July 21, 2011 must implement therequirements of ASME Code Case N—770—1, subject to the conditions specifiedin paragraphs (g)(6)(ii)(F)(2) through (g)(6)(ii)(F)(1O) of this section, by the firstrefueling 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 followingindividual programs:

• ASME Section Xl and Augmented ISI Program for pressure retaining components and theirsupports,

• 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 foraccomplishment of the objectives of 10 CFR 50.55a. It is consideredsynonymous 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 IWA2420 and IWA-2425, and the more restrictive use of the term “program” as usedin IWA-2431.

SCHEDULE The term “schedule” is used to define the detailed scheme of performing therequired inspections over the Inspection Interval.


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1.5.1 Fifth ISI Interval Program Description

The Fifth ISI Interval Program details Palisades’s compliance with ASME Section Xl Code,Section Xl (2007/2008), Articles tWA, IWB, IWC, IWD, and IWF for examination of Class1, 2, and 3 pressure retaining items and their supports. This document defines the Class1, 2, and 3 components, Code required examinations for each ASME Section Xlexamination category, and augmented inspection scope.

The purpose of the lSl Program is to periodically perform nondestructive examination ofASME Class 1, 2, and 3 safety related components and supports in order to identify thepresence of service related degradation.

The administrative procedures and Inspection Schedule described in the ISI Program,combined with applicable Palisades, Entergy, and approved vendor procedures, constitutethe ISI portion of the ISI Program required by FSAR 6.9.

The 1St Program also contains augmented examinations that are outside the scope of 10CFR 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, internalcommitments, License Renewal commitments, or industry initiatives. These examinationsmay 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 notincluded in summary totals for the specific examination category, except when anaugmented inspection may also satisfy ASME Section Xl Code inspection requirements.When ISI examination and schedule requirements for a component also satisfy therequirements for an augmented examination, then credit for both sets of requirementsmay 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 forreview.

Palisades Site Engineering Program Section (SEP-ISI-PLP-001), “Inservice InspectionProgram”, is the implementing procedure which describes the implementation process forthe ISI Program at Palisades.

_ Program Section No.: SEP-ISI-PLP-003

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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 ofASME Section Xl are bases for exempting components from volumetric or surfaceexaminations. Additionally, 10 CFR 50.55a(g)(6) allows the Regulatory Authority(NRC) to grant relief from specific portions of ASME Section Xl based uponimpractically. 10 CFR 50.55a(z) allows the NRC to allow alternatives toexamination and/or test requirements of ASME Section Xl where;

• a proposed alterative would provide an acceptable level of quality andsafety; or,

• compliance with the specified requirements would result in hardship orunusual difficulty without a compensating increase in the level of qualityand 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 fromNondestructive 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. Class2 Safety Injection Tanks and their NPS 12 piping to motor operated outlet valvesare filled to capacity with borated water and nitrogen, and as such can beconsidered statically pressurized. The bottles are maintained at the pressurerequired to operate. The motor operated valves and Class 2 piping to Class 1boundary 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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b. Deferrals

Section Xl of the code provides a degree of latitude in the scheduling of majorcomponent examinations in that certain category examinations may be deferred tothe end of the inspection interval. Examples of major component examinations aremechanized ultrasonic (UT) of the reactor vessel, pump and valve teardowns andcore internal examinations.

Table 1.5.2-2— Components Deferrable to the End of theInterval

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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1 .5.2 Containment Inspection Program Description

ASME Section Xl requirements for CC and MC components are not contained in thisprogram. Palisades Site Engineering Program Section SEP-CISI-PLP-001, ContainmentStructural 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 thisprogram. Entergy Procedure EN-DC-315, Flow Accelerated Corrosion Program, controlsFAC 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 InspectionPressure Testing Program, and Corporate Engineering Program Section CEP-PT-001,ASME Section Xl, Division 1, System Pressure Testing, satisfy the requirementsestablished in ASME, Section Xl, Articles IWA-5000, IWB-5000, IWC-5000, and IWD5000.

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 PlantValves, and Palisades Site Engineering Program Section SEP-IST-PLP-102, lnserviceTesting 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 thisprogram. Palisades Site Engineering Program Section SEP-RR-PLP-001, CodeRequirements for ASME Section Xl Repairs and Replacements, and CorporateEngineering Program Section CEP-RR-001, ASME Section Xl Repair and ReplacementProgram are the procedures which describe the implementation process for the repair andreplacement provisions of ASME Section Xl Code, Section Xl, Articles IWA-4000 andIWL-4000, at Palisades.


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1.5.7 Snubber Program Description

Snubber Program requirements are not contained in this program. The PalisadesSnubber Program satisfies the requirements of ISTD of the OM Code in lieu of IWF-5000as permitted by 10 CFR 50.55a(b)(3)(v), except that pre-service and in-serviceexaminations must be performed using the VT-3 visual examination method described inIWA-2213. Within the support boundary shown by figure IWF-1300-1(f), snubber supporthardware such as Jugs, bolting, pins, clamps, structural steel between the snubber pin andthe pressure retaining item, and structural steel between the snubber pin and the buildingsteel are included in the support population and examined in accordance with SubsectionIWF per this Program Section. Palisades Site Engineering Program Section SEP-SNBPLP-001, Snubber Examination and Testing Program, is the implementing procedure forthe area excluded from ASME Section Xl examinations including pivot and clevis pins asshown 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 2008Addenda IWB-2500-1 Examination Category B-Q, the Steam Generator Tube InspectionProgram 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 GeneratorProgram, is the implementing procedure.

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1.5.9 Records

Records of examinations, tests, and repair replacement activities shall be prepared inaccordance with the governing procedure or program document.

Records and reports required by Section Xl and this program are safety related and shallbe maintained as permanent plant records. They shall be filed in a manner to ensureaccessibility by the Authorized Nuclear Inservice Inspector (ANII). Storage andmaintenance 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 bemaintained in electronic format meeting requirements of IWA-6320(a). Radiographs maybe 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 maintainedas required by each of the respective programs.


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1.5.10 Reports and Submittals

Reports and submittals comprise those documents or records that are required to besubmitted to the NRC either on a recurring basis or as a result of activities described bySection 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 notrequired. Submittals related to Exemptions do require NRC approval prior toincorporation into the ASME Section Xl program.

In accordance with IWA-1400(c), the initial 151 Program and its revisions shall be providedto the NRC. Program Change Notices (PCN) are not required to be submitted.

Inservice Inspection Summary Reports required by IWA-6000 are replaced by theOwner’s Activity Report (OAR-i) described by Code Case N-532-5. The OAR-i shall beprepared to meet the requirements of the Code Case and submitted to the NRC within 90calendar days of completing each refueling outage. The report shall include all applicableactivities of the operating cycle not included in the previous report.

Analytical evaluations that accept items for continued service in accordance with IWB3132.3, IWB-3i42.4, IWC-3i22.3, IWC-3i32.3, and IWD-3600 shall be submitted to theNRC. If the analytical evaluation is performed during a refueling outage, the submittalmay be included with the Owner’s Activity Report provided the cover letter makes specificreference to the contained analytical evaluation. Analytical evaluations performed duringthe operating cycle between refuel outages shall be submitted independent of the Owner’sActivity Report. As a guide, these submittals should be timely and within 30 calendardays of completing the analytical evaluation.

Evaluation procedures used in analytical evaluations of flaws in austenitic and ferriticpiping shall be provided to the NRC in accordance with IWB-3640, IWC-3640, and IWD3640. A one-time submittal is acceptable, provided subsequent revisions are providedand the scope and application of the procedure does not change. The cover letter shouldindicate that the procedure is only submitted once (not for each use) and what criteria willbe used to determine when additional submittals will be made.

When acceptance standards have been modified as a result of using smaller flaw sizes indeveloping the Pressure/Temperature Limit Curves in accordance with IWB-34i0.2, themodified acceptance standards shall be filed with the NRC.

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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 andProgram Change Notices in accordance with EN-DC-174.

This program will be maintained current to reflect applicable changes to plant configurationthrough 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 beincorporated and scheduled for inspection or examination in accordance with IWB/IWC/IWD-241 1and IWF-2410.

Organizational and divisions of responsibilities for the management and implementation of the ISIProgram 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 theIddeal Concepts Software Suite®. This software and its contents are part of the formal ISIprogram and are controlled in accordance with Program Section CEP-COS-Ol 00, “Control andUse of lddeal Concepts Software”.

The initial lSl Program, revisions, and PCNs are subject to review by the Authorized NuclearInservice Inspector (AN II).


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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 FifthInterval are listed in Tables 2.2-1, 2.3-1, and 2.4-1. The use of Code Cases is inaccordance with ASME Section Xl, IWA-2440, 10 CFR 50.55a, and Regulatory Guide1.147, Rev. 17. As permitted byASME Section Xl and Regulatory Guide 1.147 or 10 CFR50.55a, 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 1.147may be included in the lSl program, provided all additional provisions specified in theRegulatory Guide are also incorporated. Table 2.2-1 identifies Code Cases approved forgeneric 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 NuclearInservice Inspection may not have been reviewed and approved by the NRC Staff forgeneric use and listed in Regulatory Guide 1.147. Use of such Code Cases may berequested 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 timethat the Code Cases are adopted into Regulatory Guide 1.147, at which time compliancewith the provisions contained in the Regulatory Guide is required.

Table 2.3-1 identifies those Code Cases that have been requested through Requests forAlternatives. For convenience to the user of this lSI Program, the appropriate internalcorrespondence number is provided to assist in their retrieval from Document Control. Allother Requests for Alternatives and Relief Requests (those not associated with NRCapproval 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 andimplemented at the specified schedule. Code Cases currently required by 10 CFR 50.55aare identified in Table 2.4-1.

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2.1.4 Use of Annulled Code Cases

As permitted by Regulatory Guide 1.147, Code Cases that have been adopted for use inthe current interval that are subsequently annulled by ASME, may be used for theremainder 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 listedin Regulatory Guide 1.147. However, if an adopted Code Case is later revised andapproved by the NRC, then either the earlier or later revision may be used until the end ofthe 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 beincorporated within the provisions of paragraphs 2.1.1 or 2.1.2 by revision to this lSlProgram. Any subsequent Code Cases shall be incorporated into the program andidentified 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 examinationrequirements for Class 1, 2, and 3 components and component supports are included inTable 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 respectiveprograms.

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 andStandards 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 NotApproved for Use”. However, the NRC may approve their use in specific cases. CodeCases listed in Regulatory Guide 1.193 will not be used at Palisades without an approvedRequest for Alternative in accordance with 10 CFR 50.55a(z).


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2.2 Regulatory Guide 1.147, Revision 17, ApDroved Code Cases

NumberApplicability

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 temporarilydeferred under theN-51 33 Acceptance of Flaws in Moderate provisions of this CodeEnergy Class 2 or 3 Piping Section Case shall be performedXl, Division 1

during the next scheduledoutage.

Alternative Requirements for 2011 Addenda

N 526 SuccessiveInspections of Class 1 Noneand 2 Vessels Section Xl, Division

1Repair/Replacement Activity 2010 EditionDocumentation Requirements and

N-532-5 Inservice Summary Report NonePreparation and SubmissionSection Xl, Division 1

“At least 50 percent of the 2004 Editionflaws in the (Approved fordemonstration test set Use by RR 05-must be cracks and the 01)maximum mis-orientationmust be demonstrated

Alternative Methods - Qualification with cracks. Flaws inN-552 for Nozzle Inside Radius Section nozzles with bore

from the Outside Surface diameters equal to or lessthan 4 inches may benotches.”

Add to detection criteria,“The number of false callsmust not exceed three.”

Alternative Additional Examination 2008 Addenda

N-586-1Requirements for Classes 1, 2,

Noneand 3 Piping, Components, andSupports Section Xl, Division 1

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Table 2.2-1 - Code Cases Adopted frOm Regulatory Guide’1.147

Number Title NRC LimitationsApplicability

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 WeldsC-D-E-F-G-H must be 01)Section Xl, Division 1 inspected.

Ultrasonic Examination of Full 2008 AddendaPenetration Nozzles in Vessels,Examination Category B-D, Item

N-613-1 Nos. B3.i0 and B3.90, Reactor NoneNozzle-to-Vessel Welds, Figs.IWB-2500-7(a), (b), and (c)Section Xl, Division 1

Chemical ranges of the 2013 Editioncalibration block may varyfrom the materialsspecification if (1) it iswithin the chemical rangeof the component

N 639 AlternativeCalibration Block specification to be

Material Section Xl, Division I inspected, and (2) thephase and grain shapeare maintained in thesame ranges produced bythe thermal processrequired by the materialspecification.In lieu of an UT 2013 Editionexamination, licenseesmay perform a VT-iexamination in

Alternative Requirements for Inner accordance with the codeRadius Examination of Class I of record for the InserviceN-648-1Reactor Vessel Nozzles Section Inspection ProgramXl, Division 1 utilizing the allowable flaw

length criteria of TableIWB-3512-1 with limitingassumptions of the flawaspect ratio.

Alternative Requirements for 2011 AddendaClasses 1 and 2 Surface NoneN 663 Examinations Section XI, Division1


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Table 2.2-1 - Code Cases Adopted from ReQulatorv

NumberApplicability

1.147Title NRC Limitations

2004 Edition I

N-685 aremts for Surface None (Approved forUse by RR 05-01)

Alternative Requirements for 2004 Edition

N 686 1Visual Examinations,

N(Approved for

- VT-i, VT-2, and \/T-3 one Use by RR 05-01)

Qualification Requirements for 2004 Edition IDissimilar Metal Piping Welds 2003 Addenda

N-695 None (Approved forUse by RR 05-01)

Qualification Requirements for 2004 Edition IAppendix VIII Piping Examinations 2003 Addenda

N-696 Conducted From the Inside None (Approved forSurface Use by RR 05-

01)Evaluation Criteria for Temporary 2013 EditionAcceptance of Degradation in

N-705 Moderate Energy Class 2 or 3 NoneVessels and Tanks Section Xl,Division 1Alternative Examination 2011 AddendaRequirements of Table IWB-2500-

N 706 11 and Table IWC-2500-1 for PWR

N- Stainless Steel Residual and one

Regenerative Heat ExchangersSection Xl, Division I

N-712 Class I Socket Weld Examinations None 2011 AddendaSection Xl, Division IAlternative Classification and 2013 Addenda

N-716-1 Examination Requirements NoneSection Xl, Division 1Successive Inspections of Class 1 2013 Edition

N-735 and 2 Piping Welds Section Xl, NoneDivision 1Reactor Vessel Head-to-Flange 2013 Edition

N-747 Weld Examinations, Section Xl, NoneDivision 1 Section XI, Division 1

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Table 2.2-1 - Code Cases Adopted frdn Regulatory Guid&1.147

Title NRC Limitations

Alternative to Inspection Interval None 2008 AddendaN-765 Scheduling Requirements of IWA

2430 Section Xl, Division 1

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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 thisprogram for the applicable requests.

I Table 2.3-1 - Code Cases Adopted Via NRC Aroved RequestsI 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 50.55aNumber Title Notes

Additional Examinations for PWRPressure Retaining Welds in Class 1 Conditions specified in 10 CFR 50.55aN-722-1 Components Fabricated With Alloy600/82/1 82 Materials Section Xl, (g)(6)(ii)(E)

Division 1Alternative Examination Conditions specified in 10 CFR 50.55aRequirements for PWR Reactor (g)(6)(ii)(D)

N-729-1 Vessel Upper Heads With NozzlesHaving Pressure-Retaining PartialPenetration Welds Section Xl,Division 1

NumberAplicabiIitv

2.4

II


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Table 2 4-1 - Code Cases Adopted as Required by 10 CFR 50 55aNumber Title Notes

Alternative Examination Conditions specified in 10 CFR 50.55aRequirements and Acceptance (g)(6)(ii)(F)Standards for Class 1 PWR Pipingand Vessel Nozzle Butt Welds

N-770-1 Fabricated with UNS06082 orUNS86182 Weld Filler Material Withor Without Application of ListedMitigation Activities Section Xl,Division 1


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3.0 Relief Requests

Throughout this program, the term “relief request” is used interchangeably, referring to submittals to theNRC requesting permission to deviate from either an ASME Section Xl requirement, a 10 CFR 50.55arule, or to use provisions from Editions or Addenda of Section Xl not approved by the NRC as referencedin 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 theNRC 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). Theapplicable Palisades submittal and NRC Safety Evaluation Report (SER) correspondence numbers arealso included for each request.

Only requests associated with the ISI program and the supporting nondestructive examinationrequirements are listed in Table 3.0-1. Requests applicable to System Pressure Testing andRepair/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) therequest 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 requestuse of Code Cases, Code Edition, or Addenda not yet approved by the NRC. A Request forAlternative may also be used to request the use of technology or examination/testing protocol notyet within the boundary of the ASME Section Xl, yet applicable to a specific situation anddeserving of consideration; e.g. new technology developed by an Owner’s 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 proposedalternatives would provide an acceptable level of quality and safety. Requests submittedunder 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 withthe specified requirements would result in hardship or unusual difficulty without acompensating increase in the level of quality and safety. Submittals under this provisionmust provide evidence of unusual hardship or difficulty. This typically is dose or excessivedisassembly.

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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 Coderequirement is deemed impractical with (iv) being specific to examination requirements that aredetermined to be impractical. The provisions of these two paragraphs are typically used toaddress 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 isimpractical, the basis for this determination must be submitted for NRC review and approval notlater than 12 months after the expiration of the initial or subsequent 120-month inspection intervalfor which relief is sought,

In cases where the ASME Section Xl requirements for ISI are considered impractical, Palisadeswill notify the NRC and submit information to support the determination, as required by 10 CFR50.55a(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 XICode) cannot be examined due to interference by another component or part geometry, then inaccordance with IWA-2200(c), a reduction in examination volume or area is acceptable if thereduction 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 providesadditional guidance that all ASME Section XI examinations should meet the examinationcoverage criteria established in IWA-2200(c). Therefore, the guidance included in NRCInformation Notice 98-42 will be followed by Palisades when determining whether to prepare arelief 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 visualexamination 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 partialexamination 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 onUse of Later Editions and Addenda to ASME CM Code and Section Xl”. This RIS clarifies theNRC position on using Editions and Addenda of Section Xl, in whole or in part, later than thosespecified in the ISI program. If the desired Editions or Addenda are referenced in 10 CFR50.55a(a)(1)(ii), the request is submitted following the guidance of the RIS. These types ofrequests are not required to demonstrate hardship, difficulty, or to provide evidence of quality andsafety. They do need to ensure that all related requirements are also met. Requests to useeditions and/or addenda of ASME Section Xl that are referenced in 10 CFR 50.55a(a)(1)(ii) thatare later than the initial Code of Record established for the ISI program shall be submitted underthe provisions of 10 CFR 50.55a(g)(4)(iv).


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Table 3.0-1Palisades Fifth Interval Relief Requests

Relief Category item Component Alternative Relief RequestedRequest DescriptionRR 45(1) B-P B15.1O Reactor Hazard and unusual Leakage detection per IWA

Vessel difficulty of direct visual 5244, and remote visualBottom examination examinationWelds

RR 4-11 IWA-2600 Impractical to establish Use alternate weld referenceWeld standard weld systemReference reference systemSystem

RR 419:1) Code N/A RV-1 041 Dissimilar metal in the Use the new alternativeCase 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 theprovision in paragraph1(b) of N-638-4 thatlimits the depth of theweld to “one-half theferritic base metalthickness.”

RR 424(2) Code B Alloy 600 Incomplete Perform N-770-1 volumetricCase N- Branch performance of examinations in I R25

770-1 Welds 2 required baselineinch and volumetricgreater on examinationsthe ColdLeg

RR 5-1 Various Various Various From various lnservice To implement the similarInspection Related various Inservice Inspection

(Under Activities of the 2007 Related Activities toReview by Edition through 2008 requirements of the 2001the NRC) Addenda of ASME Edition through 2003 Addenda

Section Xl until of ASME Section Xl untilDecember 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 completionof the spring 2017 refueling outage (1R25).

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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, SectionXl, 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-IsolableReactor Coolant System Branch Lines

4.1.7 American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, SectionXl, 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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4.3.8 Engineering Report PLP-RPT-14-00068, 0800075.301 Revision 0 Degradation MechanismEvaluation for Palisades” (EC52129)

4.3.9 Engineering Report PLP-RPT-14-00069, 0800075.302 Revision 0 N-716-1 Evaluation forPalisades” (EC52129)

4.3.10 EC-56288, Implementation of Risk Informed Inservice Inspection in accordance with ASMECode 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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5.0 Augmented, Owner Elected, Alloy 600, and Renewed License InserviceInspection Requirements

The ISI Program also contains examinations that are outside the scope of 10 CFR 50.55a. Thesemay result from activities including, but not limited to, License Renewal commitments, othercommitments made to the NRC, industry initiatives, or internal commitments. These examinationsmay 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 examinationcategories, except when an augmented inspection may also satisfy ASME Section Xl Codeinspection requirements.

Changes to augmented examination requirements and schedules are outside of 10 CFR 50.55aand 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 toaddress NRC or industry concerns. Plant Technical Specifications and the OperatingRequirements Manual may require more frequent examination scheduling than doesSection Xl, Paragraphs IWB-2400 and IWC-2400. Such requirements supersede those ofSection Xl.

The following Palisades Technical Specification and Operating Requirements Manualsections apply to the Augmented Program and will be performed throughout the life of theplant.

• Technical Specification Section 5.5.6

• Operating Requirements Manual Section 4.12

Augmented examinations addressed by the Palisades ISI Program during the Fifthinspection 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 aconcern about high-energy missiles inside containment that could potentiallydamage and cause the simultaneous failure of multiple trains of multiplesafety-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-YearInterval.

Acceptance Criteria or Standard: Any flaws detected during examination shall beforwarded to Palisades/Entergy Engineering for resolution.

Regulatory Basis: Technical Specification 5.5.6 is loosely based on RegulatoryGuide 1.14, but Palisades is not committed to this Regulatory Guide.

Application criteria and code compliance are addressed in Master Program Section72.1.

5.1.2 ESS Check Valve Weld Overlays: Volumetric and Surface Examinations of OverlayWelds on CK-ES3166 and CK-ES3181

Source Document: FSAR 6.9.1

Commitment No.: CMT9420025 14, CMT942002555, CMT9420002686

Associated Document: Code Case N-504-1

Purpose:Ensure cracking does not propagate into the upper 25% of the original basemetal of dissimilar metal welds that contain alloy that are mitigated by overlay.

Scope: Weld overlay repairs on containment sump recirculation check valves CKES3166 and CK-ES3181.

Method: Perform PT and UT examination of weld overlays associated with checkvalves CK-ES3166 and CK-ES3181, using UT methods demonstrated to beeffective.


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Industry Code or Standards:Examination required by ASME Section Xl Code CaseN-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 Section7.2.2.

5.1.3 NUREG-0612: Control of Heavy Loads at Nuclear Power Plants

Source Document: NUREG-0612

Commitment No.: CMT89 1010064, 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 accordancewith NUREG-0612.

Scope: As defined in Procedure CLP-M-6, these augmented examinations addressspecial lifting devices (heavy load lift devices) for use in and around thereactor (closure head, upper guide structure, core support barrel, and missileshields); dry fuel storage (hoist rings, spreader bars, lift yoke, and transfercask); and primary coolant pump and motor. These augmented examinationsdo not address the spent fuel pool crane or polar crane, which are addressedby separate Maintenance Department programs independent of the lSlProgram.

Method: Subject components shall be subject to visual, surface, and for the reactorhead lift rig, volumetric examinations as specified in Palisades ProcedureCLP-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.

rnEntergy

Program Section No.: SEP-ISI-PLP-003Revision No.: 3Page No.: 42 of 124

ASME Section XI (2007/2008) may be used for

Regulatory Basis: NRC NUREG-0612


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 thatunisolable sections of all piping connected to the RCS will not be subjected tocombined cyclic and static thermal and other stresses that could cause fatiguefailure 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


5.1.5 ORM 4.12, HELB: Augmented lnservice Inspection Program for High Energy LinesOutside 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 containmentover the service lifetime.

Under normal plant operating conditions, the piping materials operate underductile conditions and within stress limits considerably below the ultimatestrength properties of the materials. Flaws, which could grow under suchconditions, are generally associated with cyclic loads that fatigue thematerial and lead to leakage cracks. The inservice examinations andfrequency of inspection will provide a means for timely detection beforeflaws penetrate the wall of the piping.

The program applies to welds in piping systems or portions of systemslocated outside containment where protection from the consequences ofpostulated ruptures is not provided by a system of pipe whip restraints, jetimpingement barriers, protective enclosures and/or other measuresdesigned specifically to cope with such ruptures.

Scope: Welds in Main Steam and Main Feedwater lines located inside the MainSteam and Feedwater Penetration Rooms, commonly called theComponent Cooling Water (CCW) Room. Welds are grouped as follows:

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 LinesFigure 4.12.B: Main Feedwater Lines

ORM 4.12.2: Other Main Steam and Main Feedwater line welds notidentified in Figures 4.12.A and 4.12.B, including safety valveattachment 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 weldlocations shall be performed on a weekly basis for detection ofleaks.

Industry Code or Standards: ASME Section Xl (1972 Winter Addenda, 2001/2003).


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ORM 4.12.1: Table IWC-2500-1, Examination Category C-F-2, ASMESection Xl (2007/2008).

ORM 4.12.2: Examine in accordance with requirements of Subsections ISC100 through 600 of ASME Section Xl (1972 Winter Addenda).

ORM 4.12.3: Visually inspect insulation surfaces at weld locations forevidence of leaks.

Note: This examination of normally operating lines at normaloperating temperature and pressure is performed by VT-2 qualifiedexaminers and is documented in Operations Department records.

Frequency:

ORM 4.12.1: Volumetric inspection of 1/3 of the welds at the expiration ofeach 1/3 of the inspection interval, with a cumulative 100percent coverage of all welds.

Note: The welds selected during each inspection period shallbe distributed among the total number to be examined toprovide a representative sampling of the condition of all welds.

ORM 4.12.2: Examine in accordance with requirements of Subsections ISC100 through 600 of ASME Section Xl Code, 1972 WinterAddenda.

ORM 4.12.3: Weekly examination.

Acceptance Criteria or Standard: Flaws detected during examination shall beevaluated by comparing the examination results to the acceptance standardsestablished in ASME Section Xl, IWC-3514.

ORM 4.12.1: Volumetric inspection of 1/3 of the welds at the expiration ofeach 1/3 of the inspection interval, with a cumulative 100percent coverage of all welds.

1) If repairs of any welds are required following anyexamination performed during successive inspection intervals,the inspection schedule for the repaired welds shall revert tothe first inspection interval schedule.


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2) Examinations that reveal unacceptable structural defectsin a weld shall be extended to require an additional inspectionof an additional 1/3 of the welds. If further unacceptabledefects are detected in the second sampling, the remainder ofthe welds shall be inspected.

3) Repairs, reexamination and piping pressure tests shall beconducted in accordance with ASME Section Xl Code.

ORM 4.12.2: Repairs, reexamination and piping pressure tests shall beconducted in accordance with Section Xl of the ASME SectionXl Code. Examine in accordance with requirements ofSubsections ISC-100 through 600 of ASME Section Xl Code,1972 Winter Addenda.

ORM 4.12.3: Repairs, reexamination and piping pressure tests shall beconducted in accordance with Section Xl of the ASME SectionXl Code.

Regulatory Basis: NRC NUREG-0800, Section 3.6.2.


5.1.6 AF-Sl: Auxiliary Feedwater Structural Integrity

Source Document: Reference letters:

RJB 34-88, dated May 18, 1988BW88-032, dated July 14, 1988THE 88-001, dated January28, 1988

Commitment No.: Not stated

Associated Documents: None

Purpose: Ensure structural integrity of Auxiliary Feedwater System Pipingassociated with Steam Generators.

Scope: For both steam generators, the following portions of Auxiliary Feedwaterpiping adjacent to the steam generator:

1. Pipe to Elbow Weld2. Elbow to Pipe Weld


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3. Pipe to Nozzle Weld4. 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 beevaluated by comparing the examination results to the acceptancestandards established in ASME Section Xl, Subsection IWC.

Regulatory Basis: None


5.1.7 MRP-146: Examination for Thermal Fatigue in Reactor Coolant System Piping

Source Document: MRP-146S

Commitment No.: Industry commitment

Associated Documents: MRP-192

Purpose: Periodically examine for evidence of degradation from thermalfatigue.

Scope: The scope of these augmented examinations is piping that has beenevaluated as potentially susceptible to thermal fatigue cracking, in accordancewith MRP-146S. The evaluation was performed under EC 51419 and


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Engineering Report PLP-RPT-14-00085, Rev. 0, “MRP-170, MRP-146 andMRP-146S Evaluation of Non-Isolable Normally Static Reactor Coolant Lines”Candidate locations are normally stagnant pipe branches attached to RCSloop 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 requireexamination for thermal cycling fatigue.

Method: Subject piping segments shall be ultrasonically examined using techniquesthat 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 beevaluated by comparing the examination results to the acceptancestandards established in MRP-146S.

Regulatory Basis: Nuclear Energy Institute (NED 03-08 Initiative.


5.1.8 Pressurizer Spray Line: Postulated Break of Pressurizer Spray Line

Source Document: FSAR 5.6.7.2


Purpose: Prevent pipe whip damage to cable tray.

Note: The postulated break of the pressurizer spray line is assumed as adouble-ended guillotine rupture that results in the whipping pipe striking acable tray approximately 20 feet from the pipe. The purpose of thisexamination was to prevent damage to a hydrogen recombiner cable in thatcable tray. The hydrogen recombiners have since been eliminated,nullifying the consequences of cable damage.


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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 ofwelds to be examined every interval.

Acceptance Criteria or Standard: ASME Section Xl (2007/2008), IWB-3514.



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5.2 Owner Elected Examinations for Internal Commitments

Owner Elected Programs are those that have been developed to address plant concernssuch 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 Fifthinspection interval are as follows:

5.2.1 Containment Penetration Piping

Source Document: None


Purpose: All piping penetrations are examined in accordance with the rules ofASME Section Xl, Articles IWB and IWC and are in the program asrequired. Palisades also classifies the equipment hatch, escape airlock andpersonnel airlock as Class 2. These three penetrations are included due tothe piping which is attached to these openings for the purpose ofpressurizing the two air locks and performing the between-the seals test ofthe equipment hatch. However, all of the test piping is less that NPS 4 inchand 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 inaccordance 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 ASMESection 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-20 12-05623

Associated Document: WT-WTP LP-20 14-00033 CA-52


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Purpose: Perform internal examinations of the centering band region of theCRDM Upper Housing (former weld 5 area).

Scope: Perform internal examinations of two upper housings each 10 yearinterval. One housing should be selected from the periphery housings andone housing should be selected from the remaining internal housings.

Method: Utilize Eddy Current or Visual methods developed to inspect the internalsof 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 wouldutilize ASME Section XI Code acceptance criteria as guidance (i.e.Category B-O IWB-3523). Any crack like indications even if it meets thecode acceptance criteria, would require further evaluation as part of thecorrective action program.


5.2.3 Additional Examinations

Additional examinations will be performed as required by Site EngineeringProcedure SEP-lSl-PLP-001.

m Program Section No.: SEP-ISI-PLP-003

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5.3 Alloy 600 Program

Pressurized Water Stress Corrosion Cracking (PWSCC) in Alloy 600 (also called Alloy600/82/1 82, bimetallic, Ni-Cr-Fe, or SB-I 66) material has been recognized as a significantissue in PWR reactor coolant systems (RCS). Palisades has 252 Alloy 600 RCSpenetrations. The RCS includes two identical heat transfer loops connected in parallel tothe reactor vessel. Each loop contains one steam generator, two reactor coolant pumps,instrumentation, and connecting piping. A pressurizer is connected to one hot leg bymeans of a surge line. As a result of Alloy 600 cracking associated with the pressurizerpower operated relief valve (PORV) nozzle, a project was initiated in 1993 to identify andrank all RCS Alloy 600 penetrations. The project based penetration ranking on four maincriteria: PWSCC susceptibility, failure consequence, leakage detection margin, andradiation dose rates. Examination requirements for Alloy 600 penetrations are contained inthe Palisades ISI Program.

Alloy 600 examinations also are credited for implementation of aging management programrequirements under the renewed license.

Alloy 600 examinations are also applied to the ASME Section Xl lSl program, whenapplicable to both programs.

Alloy 600 penetrations are contained within the required inspection boundary for theAmerican Society of Mechanical Engineers (ASME) Section Xl system leakage test(pressure testing program) required each refueling outage. This visual inspection, whichdiffers from bare metal visual examinations discussed below, is performed without theremoval 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 buttweld 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-770-1examination scope, effective the first refueling outage after August 22, 2011. A related NRCinterpretation in July 2011 forced inclusion of the PORV nozzle replacement weld withinAlloy 600 scope, increasing the total number of in-scope locations from 251 to 252. Atlocations with two Alloy 600 welds (safe ends, for example), each weld has a uniqueComponent ID.

Different scheduling requirements for visual and volumetric examinations for the same Alloy600 components complicate data entry into Iddeal ScheduleWorks® software. Volumetric


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examinations are capable of meeting ASME Section Xl requirements, so they arescheduled as Code exams. Bare metal visual examinations of Code exempt and non-exempt components do not have any corresponding Code examinations, so they arescheduled as augmented exams.

The following sections describe the 252 Alloy 600 penetration configu