ML023390067

Supplementary Information in Support of Request for Technical Specification Change Re Change of Trip Level Settings, Calibration Frequencies and Editorial Changes, Rev 1

ML023390067
Person / Time
Site:	Pilgrim
Issue date:	11/22/2002
From:	Bellamy R Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.02.1206
Download: ML023390067 (3)

Text

`Entergy Entergy Nuclear Operations, Inc.

Pilgnm Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Mike Bellamy Site Vice President November 22, 2002 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

SUBJECT:

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 Supplementary information in Support of Request for Technical Specification Change Concerning Change of Trip Level Settings, Calibration Frequencies, and Editorial Changes, Revision 1

REFERENCE:

Entergy letter No. 2.01.084, Request for Technical Specification Change Concerning Change of Trip Level Settings, Calibration Frequencies, and Editorial Changes, Revision 1, dated October 10, 2002 LETTER NUMBER: 2.02.106

Dear Sir or Madam:

The enclosure to this letter provides supplementary information in support of the referenced Technical Specification (TS) change request. The supplementary information was discussed with the NRC Staff in support of a Pilgrim calculation included as an attachment to the proposed TS change request.

If you have any questions or require additional information, please contact Mr. Bryan Ford, Licensing Manager, at (508) 830-8403.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on the 22nd dayof November ,2002.

Sincerely, Robert M. Bellamy WGL/dd

Enclosure:

Additional Information (1 page)

-0 202106

Entergy Nuclear Operations, Inc. Letter Number: 2.02.106 Pilgrim Nuclear Power Station Page 2 cc: Mr. Travis Tate, Project Manager Mr. Robert Walker Project Directorate 1-3 Radiation Control Program Office of Nuclear Reactor Regulation Commonwealth of Massachusetts Mail Stop: 0-8B-1 Exec Offices of Health & Human Services U. S. Nuclear Regulatory Commission 174 Portland Street 1 White Flint North Boston, MA 02114 11555 Rockville Pike Rockville, MD 20555-0001 U.S. Nuclear Regulatory Commission Mr. Steve McGrail, Director Region I Mass. Emergency Management Agency 475 Allendale Road 400 Worcester Road King of Prussia, PA 19406 P.O. Box 1496 Framingham, MA 01701-0313 Senior Resident Inspector Pilgrim Nuclear Power Station 202106

ENCLOSURE Additional Information

Reference:

Attachment 4 to Entergy Letter 2.02.084, dated October 10, 2002 The Attachment 4 to the Entergy Letter 2.02.084, dated October 10, 2002, contains two Pilgrim (PNPS) calculations.

The following additional information relates to the Pilgrim Calculation No. 1-Ni-1195.

The data depicted in Attachment 3 to calculation I-Ni-195 was statistically analyzed as mentioned and explained in Note 9. The data is based upon actual Pilgrim data. The data was analyzed by looking at intervals of 30 months. This was accomplished by combining consecutive surveillances that did not require interim calibrations. Per the plant procedure this method is referred to as the "sliding filter approach". The basis for this approach is to create 30-month interval shifts by looking at the difference between each as-found value and the as-left value from four months earlier in the original file. At the first record after 30 months into the data, the difference between the as-found data and the as-left data 30 months later is utilized as one point. We then slide down to-the next record and maintain the 30-month interval between the as-found and as-left values.

This method is used for all records unless there is a set point change or equipment adjustment at the as-found or as-left record. If there is a set point change or equipment adjustment/ replacement, the analysis of the 30-month shift is suspended until another 30-month interval has elapsed since the change. The analysis continues until the end of the records is reached.

The following additional information relates to the Pilgrim Calculation No. 1-N1-115.

Calculation I-Ni-115 has two attachments representing drift data. Attachment 2 reflects quarterly calibrations associated with our temperatures switches. Based on a review of this data we could not use the above data since adjustments were made to the switch in the interval of interest. As a result, we contacted the vendor, EGS/Patel and obtained surveillance data for switches identical to those used at Pilgrim and used in similar applications. This data is based on a 2.5-year surveillance interval and is attached to the calculation. The PNPS data was left in the calculation as Attachment 2 to provide the argument that supports why we could not use this data. It also validated that the drift data used from EGS which was based on another utility for switches identical to those used at Pilgrim and used in similar applications was indeed similar to what we were trending at Pilgrim. It is generally known that most drift occurs at the beginning of the time interval and remains stable over the long term. The data between Attachment 2 and 3 was to hi-light the fact that the drift associated with these switches behaved as expected. The use of this data would be no different from using data contained in manufacturers specifications.

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