|
---|
Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217N8911999-10-15015 October 1999 Forwards Rept of Changes,Tests & Experiments at Pilgrim Nuclear Power Station for Period of 970422-990621,IAW 10CFR50.59(b).List of Changes Effecting Fsar,Encl ML20217D3951999-10-13013 October 1999 Forwards Request for Addl Info Re Util 990806 Submittal on USI A-46, Implementation Methodology Used at Pilgrim Nuclear Power Station, Per GL 87-02 ML20217E1581999-10-0808 October 1999 Forwards Insp Rept 50-293/99-05 on 990726-0905.Three Violations Noted & Being Treated as Ncvs.Violations Include Failure to Assure That Design Bases Correctly Translated Into Specifications ML20217C3151999-10-0606 October 1999 Forwards Scenario Package for Pilgrim Nuclear Power Station Nrc/Fema Evaluated Exercise Scheduled for 991207.Without Encl ML20217D5591999-10-0505 October 1999 Documents Pilgrim Nuclear Power Station Five Yr Survey of Main Breakwater.Survey Has Determined That Pilgrim Main Breakwater Is Intact & Remains Adequately Constructed to Perform Designed Safety Function ML20217C8051999-10-0505 October 1999 Forwards Proprietary Results of Audiologic Evaluations for Jp Giar,License SOP-10061-3.Attachment Clearly Shows Requirements for Operator Hearing Ability Are Met. Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML20212J8301999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of Pilgrim Nuclear Power Station.Staff Conducts Reviews for All Operating NPPs to Integrate Performance Info & to Plan Insp Activities at Facility Over Next Six Months ML20216J9961999-09-29029 September 1999 Forwards Resume of Person Identified as Acting RPM in Licensee to NRC Re Notification That Person Named in License Condition 11 of 20-07626-02,is No Longer Employed at Pilgrim Station.Resume Withheld,Per 10CFR2.790 ML20212F7871999-09-24024 September 1999 Advises That Util 990121 Application for Amend Being Treated as Withdrawn.Proposed Changes Would Have Modified Facility UFSAR Pertaining to Values for post-accident Containment Pressure Credited in Pilgrim Net Positive Head Analyses ML20212H1381999-09-23023 September 1999 Submits Info in Support of Request Filed on 990730 to Grant one-time Exemption from 10CFR50,App E,Authorizing Biennial Full Participation Emergency Preparedness Exercise to Be Conducted in 2002 Instead of 2001 ML20212H1441999-09-23023 September 1999 Withdraws 990121 Request for License Change Re Emergency Core Cooling Sys Net Positive Suction Head,Due to Incorrect Datum Preparation ML20212C2861999-09-16016 September 1999 Forwards SER Accepting Licensee 981123 Request for Relief RR-E1,RR-E5,RR-E6 Pursuant to 10CFR50.55a(a)(3)(i) & Request for Relief RR-E2,RR-E3 & RR-E4 Pursuant to 10CFR50.55a(a)(3)(ii) ML20216F3451999-09-16016 September 1999 Forwards Summary Rept Providing Results of ISI Conducted at PNPS on-line & Refueling Outage (RFO 12) ML20216E7111999-09-0909 September 1999 Forwards License Renewal Application Including Form NRC-398 & Form NRC-396 for Jp Giar,License SOP-10061-3.Without Encls ML20216E5891999-09-0707 September 1999 Forwards Copy of Pilgrim Station Organization Structure. Encl Refelcts Changes in Upper Mgt Level Structure.Changes Were Effective 990901 ML20211M4501999-09-0303 September 1999 Informs That Pilgrim Nuclear Power Station Plans to Conduct Full Participation Emergency Preparedness Exercise with Commonwealth of Ma on 991207,IAW 10CFR50,App E,Section IV.F.2 ML20211M9161999-08-31031 August 1999 Submits Review & Correction of Info in Reactor Vessel Integrity Database (Rvid),Version 2,re Pilgrim Station ML20211J8391999-08-30030 August 1999 Forwards Rev 1 to Provisional Decommissioning Trust Agreement for Plant,Changing Portions of Agreement to Permit Up to Two Distributions & Clarify Formula for Distribution ML20211H5701999-08-27027 August 1999 Forwards Insp Rept 50-293/99-04 on 990610-0725.Two Violations Identified Being Treated as non-cited Violations ML20211C3381999-08-19019 August 1999 Provides semi-annual LTP Update,Including Schedule, Commitment Descriptions,Progress Since Last Update & Summary of Changes.Rev Bars Indicate Changes in Status Since Last Submittal ML20210U7521999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opossing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U6691999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opposing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U5761999-08-18018 August 1999 Responds to Opposing Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts. Informs That for Sale,Nrc Responsible for Only Ensuring That Entergy Technically & Financially Qualified to Operate NPP ML20210U5151999-08-17017 August 1999 Forwards Notice of Withdrawal of Application for Approval of Indirect Transfer of FOL for Pilgrim in Response to .Approval No Longer Needed Since Beco Sold Interest in Pilgrim to EOI on 990713 ML20211B3841999-08-16016 August 1999 Forwards Response to NRC Second RAI Re Pressure Locking & Thermal Binding of SR power-operated Gate Valves ML20210U4831999-08-13013 August 1999 Forwards fitness-for-duty Program Performance Data Sheets for Period of 990101-0630,per 10CFR26.71(d) ML20210S0891999-08-0909 August 1999 Forwards Amend 11 to Indemnity Agreement B-48 Signed by Boston Edison Co & Entergy Nuclear Generation Co ML20210R6251999-08-0606 August 1999 Provides Supplementary Info on USI A-46 Implementation Methodology at Pilgrim Station,To Enable NRC to Perform Evaluation & Issuance of Plant Specific SER for Plant ML20210M9411999-08-0202 August 1999 Requests That NRC Treat Pending Actions Requested by Beco Prior to 990713,as Requests Made by Entergy.Ltr Requests That Minor Administrative Changes to License Amend 182 & Associated Ser, ,reflect 990713 Transfer ML20210H8761999-07-30030 July 1999 Requests That NRC Grant Exemption from Requirements of 10CFR50,App E,Section IV F,Which Would Authorize Rescheduling of 2001 Biennial Full Participation Emergency Preparedness Exercise for Pilgrim Station to 2002 ML20210H8661999-07-29029 July 1999 Provides Revised Response to GL 96-06 & Addresses NRC Insp Concern for Containment Penetration X-12.Info Submitted to Facilitate NRC Review & Closeout of Subject GL for Plant ML20216E2321999-07-26026 July 1999 Discusses GL 92-01,rev 1,suppl 1, Rv Structural Integrity. NRC Revised Info in Rvid & Releasing as Rvid Version 2 ML20216D4131999-07-22022 July 1999 Informs That J Conlon,License OP-11040-1,terminated Employment with Beco on 990703,per 10CFR50.74.Individual Will Not Participate in Util Licensed Operator Requalification Training Program ML20210E2231999-07-20020 July 1999 Discusses Arrangements Made by Dennis & M Santiago During 990615 Telephone Conversation for NRC to Inspect Licensed Operator Requalification Program at Pilgrim During Wk of 991004 ML20210C4151999-07-19019 July 1999 Informs That Util Intends to Submit Approx Eight Licensing Actions in FY00 & Eight in FY01,in Response to Administrative Ltr 99-02.Actions Are Not Expected to Generate Complex Reviews ML20210A9441999-07-14014 July 1999 Responds to Re Changes to Pilgrim Nuclear Power Station Physical Security Plan Identified as Issue 2,rev 14, Addendum 1,respectively.No NRC Approval Is Required IAW 10CFR54(p) ML20210F3711999-07-14014 July 1999 Informs NRC That Effective 990713,listed Pilgrim Station Security Plans Have Been Transferred from Boston Edison to Entergy & Are Still in Effect ML20209G2251999-07-0909 July 1999 Forwards Insp Rept 50-293/99-03 on 990419-0609.Five Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations,Consistent with App C. Several Individual Tagging Errors Occurred ML20209C4661999-07-0707 July 1999 Forwards SE Accepting Addendum on Proposed Change in Corporate Ownership Structure Involving Entergy Nuclear Generation Co ML20209C3851999-07-0606 July 1999 Forwards Redacted Draft of Decommissioning Trust Agreement Re Transfer of PNPS & NRC Operating License & Matls License from Boston Edison Co to Entergy Nuclear Generating Co ML20209C7761999-07-0606 July 1999 Submits Annual Summary Rept of Changes Made to QAP Description as Described in QA Manual,Vol Ii.Rept Covers Period of Jul 1998 Through June 1999.No Changes Made During Period ML20196J7251999-07-0101 July 1999 Informs of Completion of Licensing Action for GL 96-01, Testing of Safety-Related Logic Circuits, for Pilgrim Nuclear Power Station ML20209B9411999-06-30030 June 1999 Discusses Deferral of IGSCC Welds to RFO 13.Deferral of Welds to Refueling Outage 13 Does Not Impact Acceptable Level of Quality & Safety Per 10CFR50.55(a)(3)(i) Since Plant in Compliance W/Exam Percentage Requirements ML20209B9431999-06-30030 June 1999 Provides Formal Notification That Closing Date for Sale & Transfer of Pilgrim Station Scheduled to Occur on 990713. a Wang Will Be Verbally Notified of Time of Sale Closing ML20196H2381999-06-29029 June 1999 Forwards SER Denying Licensee 980820 Request for Alternative Under PRR-13,rev 2 for Use of Code Case N-522 During Pressure Testing of Containment Penetration Piping ML20209B9791999-06-29029 June 1999 Forwards Rev 13A to Pilgrims COLR for Cycle 13,IAW TS 5.6.5 Requirements.Rev 13A Provides cycle-specific Limits for Operating Pilgrim During Remainder of Cycle 13 ML20209A8761999-06-28028 June 1999 Forwards SER Authorizing Licensee 990317 Relief Request to Use ASME Code Case N-573 as Alternative to ASME Code Section XI Article IWA-4000 for Remainder of 10-year Interval Pursuant to 10CFR50.55a(a)(3)(i) ML20209A8701999-06-25025 June 1999 Responds to NRC Request for Info Re Y2K Readiness of Computer Sys at Nuclear Power Plants. Y2K Readiness Disclosure for Plant,Reporting Status of Facility Y2K Readiness Encl ML20210U5901999-06-25025 June 1999 Opposes Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts.Expresses Skepticism Re Claim by Companies That Consumers Will Benefit from Proposed Consolidation & four-year Freeze in Base Rates ML20209C3431999-06-22022 June 1999 Forwards Addendum 1,Rev 14 to Pilgrim Station Security Plan,Iaw 10CFR50.54(p)(2).Changes Proposed Have Been Implemented & Constitute Increase in Plant Defense Plan Commitments.Encl Withheld,Per 10CFR73.21 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217N8911999-10-15015 October 1999 Forwards Rept of Changes,Tests & Experiments at Pilgrim Nuclear Power Station for Period of 970422-990621,IAW 10CFR50.59(b).List of Changes Effecting Fsar,Encl ML20217C3151999-10-0606 October 1999 Forwards Scenario Package for Pilgrim Nuclear Power Station Nrc/Fema Evaluated Exercise Scheduled for 991207.Without Encl ML20217C8051999-10-0505 October 1999 Forwards Proprietary Results of Audiologic Evaluations for Jp Giar,License SOP-10061-3.Attachment Clearly Shows Requirements for Operator Hearing Ability Are Met. Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML20217D5591999-10-0505 October 1999 Documents Pilgrim Nuclear Power Station Five Yr Survey of Main Breakwater.Survey Has Determined That Pilgrim Main Breakwater Is Intact & Remains Adequately Constructed to Perform Designed Safety Function ML20216J9961999-09-29029 September 1999 Forwards Resume of Person Identified as Acting RPM in Licensee to NRC Re Notification That Person Named in License Condition 11 of 20-07626-02,is No Longer Employed at Pilgrim Station.Resume Withheld,Per 10CFR2.790 ML20212H1441999-09-23023 September 1999 Withdraws 990121 Request for License Change Re Emergency Core Cooling Sys Net Positive Suction Head,Due to Incorrect Datum Preparation ML20212H1381999-09-23023 September 1999 Submits Info in Support of Request Filed on 990730 to Grant one-time Exemption from 10CFR50,App E,Authorizing Biennial Full Participation Emergency Preparedness Exercise to Be Conducted in 2002 Instead of 2001 ML20216F3451999-09-16016 September 1999 Forwards Summary Rept Providing Results of ISI Conducted at PNPS on-line & Refueling Outage (RFO 12) ML20216E7111999-09-0909 September 1999 Forwards License Renewal Application Including Form NRC-398 & Form NRC-396 for Jp Giar,License SOP-10061-3.Without Encls ML20216E5891999-09-0707 September 1999 Forwards Copy of Pilgrim Station Organization Structure. Encl Refelcts Changes in Upper Mgt Level Structure.Changes Were Effective 990901 ML20211M4501999-09-0303 September 1999 Informs That Pilgrim Nuclear Power Station Plans to Conduct Full Participation Emergency Preparedness Exercise with Commonwealth of Ma on 991207,IAW 10CFR50,App E,Section IV.F.2 ML20211M9161999-08-31031 August 1999 Submits Review & Correction of Info in Reactor Vessel Integrity Database (Rvid),Version 2,re Pilgrim Station ML20211J8391999-08-30030 August 1999 Forwards Rev 1 to Provisional Decommissioning Trust Agreement for Plant,Changing Portions of Agreement to Permit Up to Two Distributions & Clarify Formula for Distribution ML20211C3381999-08-19019 August 1999 Provides semi-annual LTP Update,Including Schedule, Commitment Descriptions,Progress Since Last Update & Summary of Changes.Rev Bars Indicate Changes in Status Since Last Submittal ML20211B3841999-08-16016 August 1999 Forwards Response to NRC Second RAI Re Pressure Locking & Thermal Binding of SR power-operated Gate Valves ML20210U4831999-08-13013 August 1999 Forwards fitness-for-duty Program Performance Data Sheets for Period of 990101-0630,per 10CFR26.71(d) ML20210S0891999-08-0909 August 1999 Forwards Amend 11 to Indemnity Agreement B-48 Signed by Boston Edison Co & Entergy Nuclear Generation Co ML20210R6251999-08-0606 August 1999 Provides Supplementary Info on USI A-46 Implementation Methodology at Pilgrim Station,To Enable NRC to Perform Evaluation & Issuance of Plant Specific SER for Plant ML20210M9411999-08-0202 August 1999 Requests That NRC Treat Pending Actions Requested by Beco Prior to 990713,as Requests Made by Entergy.Ltr Requests That Minor Administrative Changes to License Amend 182 & Associated Ser, ,reflect 990713 Transfer ML20210H8761999-07-30030 July 1999 Requests That NRC Grant Exemption from Requirements of 10CFR50,App E,Section IV F,Which Would Authorize Rescheduling of 2001 Biennial Full Participation Emergency Preparedness Exercise for Pilgrim Station to 2002 ML20210H8661999-07-29029 July 1999 Provides Revised Response to GL 96-06 & Addresses NRC Insp Concern for Containment Penetration X-12.Info Submitted to Facilitate NRC Review & Closeout of Subject GL for Plant ML20216D4131999-07-22022 July 1999 Informs That J Conlon,License OP-11040-1,terminated Employment with Beco on 990703,per 10CFR50.74.Individual Will Not Participate in Util Licensed Operator Requalification Training Program ML20210C4151999-07-19019 July 1999 Informs That Util Intends to Submit Approx Eight Licensing Actions in FY00 & Eight in FY01,in Response to Administrative Ltr 99-02.Actions Are Not Expected to Generate Complex Reviews ML20210F3711999-07-14014 July 1999 Informs NRC That Effective 990713,listed Pilgrim Station Security Plans Have Been Transferred from Boston Edison to Entergy & Are Still in Effect ML20209C7761999-07-0606 July 1999 Submits Annual Summary Rept of Changes Made to QAP Description as Described in QA Manual,Vol Ii.Rept Covers Period of Jul 1998 Through June 1999.No Changes Made During Period ML20209C3851999-07-0606 July 1999 Forwards Redacted Draft of Decommissioning Trust Agreement Re Transfer of PNPS & NRC Operating License & Matls License from Boston Edison Co to Entergy Nuclear Generating Co ML20209B9431999-06-30030 June 1999 Provides Formal Notification That Closing Date for Sale & Transfer of Pilgrim Station Scheduled to Occur on 990713. a Wang Will Be Verbally Notified of Time of Sale Closing ML20209B9411999-06-30030 June 1999 Discusses Deferral of IGSCC Welds to RFO 13.Deferral of Welds to Refueling Outage 13 Does Not Impact Acceptable Level of Quality & Safety Per 10CFR50.55(a)(3)(i) Since Plant in Compliance W/Exam Percentage Requirements ML20209B9791999-06-29029 June 1999 Forwards Rev 13A to Pilgrims COLR for Cycle 13,IAW TS 5.6.5 Requirements.Rev 13A Provides cycle-specific Limits for Operating Pilgrim During Remainder of Cycle 13 ML20209A8701999-06-25025 June 1999 Responds to NRC Request for Info Re Y2K Readiness of Computer Sys at Nuclear Power Plants. Y2K Readiness Disclosure for Plant,Reporting Status of Facility Y2K Readiness Encl ML20210U5901999-06-25025 June 1999 Opposes Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts.Expresses Skepticism Re Claim by Companies That Consumers Will Benefit from Proposed Consolidation & four-year Freeze in Base Rates ML20209C3431999-06-22022 June 1999 Forwards Addendum 1,Rev 14 to Pilgrim Station Security Plan,Iaw 10CFR50.54(p)(2).Changes Proposed Have Been Implemented & Constitute Increase in Plant Defense Plan Commitments.Encl Withheld,Per 10CFR73.21 ML20195G3721999-06-0707 June 1999 Informs That Proposed Indicators Failed QA Assessments for Digital Verification,Validation & Control of Software. Proposed Mod Can Be Completed on-line ML20195B5021999-05-27027 May 1999 Provides Suppl Info to 990203 Request of Beco That NRC Consent to Indirect Transfer of Control of Util Interest in License DPR-35.Request Described Proposed Merger of Bec Energy with Commonwealth Energy Sys ML20207D4681999-05-24024 May 1999 Provides Addl Info to That Included in Beco Ltr 98-123 Dtd 981001,addressing NRC Concerns Described in GL 96-06, Concerning Waterhammer in Reactor Bldg Closed Cooling Water Sys ML20195B9051999-05-20020 May 1999 Forwards Completed Renewal Applications for Listed Operators.Without Encls ML20206J4901999-05-0606 May 1999 Forwards Completed License Renewal Application,Including Forms NRC-398 & 396 for Sc Power,License OP-6328-3 ML20206P0711999-05-0606 May 1999 Forwards NRC Form 396, Certification of Medical Exam by Facility Licensee, for K Walz,License SOP-10886-1.Encl Withheld IAW 10CFR2.790(a)(6) ML20206D3621999-04-27027 April 1999 Informs NRC That Final Five Sys self-assessments Required to Fulfill Commitment Made in 980828 Response to Insp Rept 50-293/98-04 Were Completed on 990422.Completion Was Delayed by High Priority Refueling Outage 12 Preparatory Work ML20205R9871999-04-21021 April 1999 Forwards Affidavit of JW Yelverton of Entergy Nuclear Generation Co Supporting Request for Withholding Info from Rept on Audit of Financial Statements for Year Ended 971231. Pages 16 & 18 of Subj Rept Also Encl ML20207B0891999-04-20020 April 1999 Forwards e-mail Message from Constituent,J Riell Re Y2K Compliance of Nuclear Power Plant in Plymouth,Massachusetts. Copy of Article Entitled Nuke Plants May Not Be Y2K Ready Also Encl ML20206A2741999-04-16016 April 1999 Dockets Encl Ltr Which Was Sent to AL Vietti-Cook Re Condition of Approval of Transfer of License & License Condition for DPR-35.Encl Resolves Issues Between Attorney General of Commonwealth of Massachusetts & Applicants ML20205P9131999-04-16016 April 1999 Submits Applicant Consent to Listed Condition of Approval of Transfer of License & License Condition for License DPR-35 & Affirmatively Request That NRC Adopt Listed Language in Order ML20205P9271999-04-16016 April 1999 Withdraws Motion for Leave to Intervene & Petition for Summary Or,In Alternative,For Hearing.Requests That NRC Adopt Condition of Approval of Transfer of License & License Condition Agreed to Beco & Entergy Nuclear Generation Co ML20205Q9231999-04-15015 April 1999 Forwards Proprietary & non-proprietary Addl Info in Support of Request to Transfer of Plant FOL & Matls License to Entergy Nuclear Generation Co.Proprietary Info Withheld,Per 10CFR2.790 ML20205P9631999-04-15015 April 1999 Provides Attachments a & B in Support of Request for Transfer of Plant Operating License & NRC Matl License from Beco to Entergy Nuclear Generation Co as Submitted in Ref 1. Info Provided in Response to Request at 990413 Meeting ML20205H9281999-04-0707 April 1999 Requests Withdrawal of Uwua Locals 369 & 387 Unions Joint Intervention in Listed Matter ML20205F3731999-04-0202 April 1999 Submits Addl Info Provided in Support of Request for Transfer of Pilgrim Nuclear Power Station Operating License & Matls License.State of Ma Order Authorizing Divestiture & Copy of Financial Arrangement Encl ML20204H3771999-03-26026 March 1999 Informs That Local 387,Utility Workers Union of America,AFL- Cio Voted to Approve New Contract with Entergy Nuclear Generation Co & Voted to Accept Boston Edison Divestiture Agreement ML20205D4231999-03-24024 March 1999 Forwards Decommissioning Funding Rept for Pilgrim Nuclear Power Station,In Accordance with 10CFR50.75(f)(1) 1999-09-09
[Table view] |
Text
a t e Ov Boston Edison Pilgrim Nuclear Power Station Rocky Hill Road Plymouth, Massachusetts 02360 en or V Presiden Nuclear anuar 24, 997 3
U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Docket No. 50-293 License No. DPR-35 INFORMATION ON PILGRIM STATION ALTERNATE REACTOR BUILDING RESPONSE SPECTRA This letter requests NRC review and approval of the engineering report used as closure for I Long Term Program (LTP) item Number 599, in the Semi-Annual LTP report submittal of February 28,1994.
BACK. GROUND The LTP is a voluntary program developed by Boston Edison Company (BECo) in 1983 to coordinate and schedule major work activities at Pilgrim Station, whether mandated by NRC or identified by BECo. At our request, the program became part of our license and was issued as Amendment No. 75 on July 13,1984. The program is dynamic and updated and submitted to the NRC on a semi-annual frequency. Issues such as rule compliance, generic letter and bulletin actions, and other commitments to the NRC are prioritized according to safety significance and according to other ongoing betterment activities undertaken at Pilgrim Station. 1 LTP item Number 599, entitled, " Class l Piping Seismic Damping Ratio" involved activities established to resolve use of increased damping ratios in certain Class I piping. This issue l was reported to the NRC in LER 92-001-00, dated February 21,1992.
LER 92-001-00 detailed the circumstances related to the use of damping values in the seismic
~
analyses of certain piping systern? a Pilgrim Station. Seismic response spectra and seismic damping values are two of the key prameters used to establish the design oasis for piping and supports. For the analyses in question, damping values from Regulatory Guide 1.61 or ASME Code Case N-411 were used. The NRC has generally permitted use of these damping values in conjunction with response spectra based on the Regulatory Guide 1.60. Since the Pilgrim Station design basis seismic response spectra are based on a Housner shape ground ;
response spectrum, the analyses that used Regulatory Guide 1.61 or ASME Code Case N-411 !
may not be considered acceptable by the NRC. t y'{LD l I 9701290227 970124 -
PDR ADOCK 05000293 P PDR l
i ,
l As described in the LER, an operability evaluation was developed to support operation for Cycle 9 following discovery of this issue. The operability evaluation is consistent with the requirements of NRC Generic Letter 91-18. While the use of Regulatory Guide 1.61 or ASME Code Case N-411 damping with a Housner based spectra may be inappropriate for design basis analyses, such use has generally been considered acceptable to demonstrate operability. Note that for the operability evaluation, current design basis allowable criteria was used for all considerations even though NRC Generic Letter 91-18 allows the use of the increased faulted service limits for operability evaluations.
]
The LER corrective actions were integrated into the LTP and, subsequently, status was updated on a semi-annual frequency. These corrective actions initially included identification of stress analyses where the higher damping ratios were used, development of enhanced design specifications for piping and supports, and systematic review of safety grade piping systems to demonstrate conformance with the appropriate licensing basis.
As part of the LER corrective actions, preliminary analyses were also performed to re-evaluate the seismic response of buildings at Pilgrim Station. Initially, these analyses used the original, simplified mathematical model for the reactor building, but factored in the mitiga%g effects of soil / structure interaction behavior using techniques not available at the time of Pilgrim's original design work. Encouraged by the results, this work was continued. A state of the art three dimensional finite element model of the reactor building and supporting soil was created. The model combined the building structure, the reactor vessel and pedestal, the biological shield wall, and the drywell and torus in sufficient detail to eliminate interfaces resulting from previously separate models. Seismic analyses were then performed and response spectra generated using current NRC requirements and guidance for ground response spectra and soil / structure interaction. Results using Pilgrim's 0.15g Safe Shutdown Earthquake )
acceleration anchored to a control point at ground grade showed significantly reduced seismic responses when compared to those used for original plant design.
An updated operability evaluation was developed for Cycle 10 operation. Pilgrim's NRC Project Manager and appropriate NRR staff were kept informed of these efforts as they progressed. The NRC attended a detailed briefing at BECo offices on September 3,1992, and was updated on the operability evaluation details by teleconference on January 14,1993.
The NRC was particularly interested in these developments because of interest about the seismicity of the Pilgrim site and offered constructive comments on our work.
In our March 1,1993, LTP update, we notified the NRC of a revised action plan consisting of: ,
l
. Development of new amplified response spectra (ARS) for the reactor building to be i used for resolution of the LER issues. New ARS would use an enhanced reactor building model and include soil structure interaction effects. Two families of ARS would be developed.
a) ARS based on Housner for various rates of damping, including Code Case N-411 levels.
b) ARS based on the Regulatory Guide 1.60 shape for various rates of damping, including Code Case N-411 levels.
1
, . . 1 Comparison of the spectral contents of the two new families of ARS to the spectral contents of the design basis ARS at Regulatory Guide 1.61 and Code Case N-411 damping levels.
Performance of several confirmatory piping stress analyses using the newly j developed ARS (sample basis). !
Upon completion of the above LTP activities, we concluded the content of any specific newly developed ARS was essentially enveloped by the content of the comparable FSAR design basis ARS; that is, a new Housner ARS at Regulatory Guide 1.61 damping was enveloped by a FSAR design basis ARS at Regulatory Guide 1.61 damping, and a new Regulatory Guide 1.60 ARS at Code Case N-411 damping was enveloped by a FSAR design basis ARS at l
Code Case N-411 damping.
Likewise, confirmatory stress analyses performed using the newly-developed spectra l produced results that were less than design basis allowables. We, therefore, concluded i that a systematic piping re-analysis was not warranted.
The new spectra were considered valid for the resolution of the damping issues identified l in LER 92-001-00 only. Any future design modification analyses were to be based on l existing FSAR design criteria. Details of the methodology and results were presented to I the NRC during a meeting at our facilities on October 14,1993. A final report on the evaluation of the effects of using various damping values in the seismic analysis of Pilgrim piping systems was issued in-house on January 6,1994. The final report documented the completion of the required actions described in the LTP commitment scope. This LTP item was closed accordingly in the February 28,1994, LTP Update.
Subsequently, we issued a letter dated April 1,1994, that fumished these new seismic spectra for NRC review. These spectra were based on Regulatory Guide 1.60 and soil-structure interaction analysis. The letter requested approval to use these spectra with Regulatory Guide 1.61 and ASME Code Case N-411 damping as an altemative to the design basis Housner spectra for future evaluations or modifications of reactor building structures, systems, and components. The NRC reviewed the above in-house report for closure of the original LER unresolved item number 50-293/92-04-01. Based on this report and our April 1,1994, submittal, the NRC closed the LER unresolved item.
Reauested Action The engineering report dated October 1993, is provided as Attachment A. Attachment B provides the scope of the piping systems and analyses affected by LER 92-001-00, which are considered acceptable based on the evaluation contained in the engineering report. We reauest NRC review and approval of the Attachment A report by March 15,1997. Based on NRC approval, our intention is to revise our FSAR to annotate that the engineering report is the referenced design basis of record for the piping systems affected by this issue. The scope is limited to those piping systems described in Attachment B. We recognize that any future modifications to these piping systems will be based on the current FSAR damping criteria unless the licensing basis is revised otherwise.
1 l
In this regard, Attachment C provides responses to the NRC " Request for Additional i information Regarding Pilgrim Nuclear Power Station Alternative Reactor Building Response Spectra", dated May 23,1996. These NRC questions stem from our April 1,1994, submittal requesting approval to use these new response spectra and the Regulatory Guide 1.61 and ASME Code Case N-411 modal damping as an alternate to the existing reactor building design response spectra and modal damping.
We request continued NRC review of our April 1,1994, submittal and will provide a continued high level of importance to any questions or concems that may arise in your review, t
E. T. Boulette, PhD JDK/dmc/ltp599B cc: Mr. Alan B. Wang, Project Manager Project Directorate I-1 Office of Nuclear Reactor Regulation Mail Stop: 1482 U. S. N*> clear Regulatory Commission 1 White Flint North 11555 Rockville Pike Rockville, MD 20852 Regional Administrator, Region i U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident inspector Pilgrim Nuclear Power Station l
l 1
Attachment A Evaluation of the Effects of Usina Various Damoina Values in the Seismic Analysis of PNPS Pioina Systems l
l l
l l