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MONTHYEARML0223206562002-09-0909 September 2002 Meeting Summary with Entergy Nuclear Operations, Inc., Pilgrim Nuclear Power Station Proposed Safety-Relief Valve Seismic Analysis Methodology Project stage: Meeting ML0228204672002-09-27027 September 2002 Response to NRC Request for Additional Information Appendix K Measurement Uncertainty Recovery - Power Uprate Request Project stage: Response to RAI ML0226601372002-10-0202 October 2002 Withholding from Public Disclosure, General Electric Proprietary Document, NEDC-33050P, Safety Analysis Report for Pilgrim Nuclear Power Station Thermal Power Optimization, Dated July 2002 Project stage: Other ML0230401802002-10-31031 October 2002 Request for Additional Information, Appendix K Measurement Uncertainty Recovery - 1.5% Power Uprate Request Project stage: RAI ML0231002832002-11-0101 November 2002 Request for Withholding Information from Public Disclosure Pilgrim Nuclear Power Station Project stage: Withholding Request ML0232201472002-11-0606 November 2002 Response to NRC Request for Additional Information, Appendix K Measurement Uncertainty Recovery - Power Uprate Request Project stage: Response to RAI ML0231701742002-11-13013 November 2002 Request for Additional Information, Regarding Appendix K Measurement Uncertainty Recovery, Power Uprate Request Project stage: RAI ML0235400352002-12-20020 December 2002 Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance ML0235703862002-12-23023 December 2002 RAI, Appendix K Measurement Uncertainty Recovery - Power Uprate Request Project stage: RAI ML0302204502002-12-30030 December 2002 Response to NRC Request for Additional Information Appendix K Measurement Uncertainty Recovery - Power Uprate Request Project stage: Response to RAI ML0309000992003-04-0202 April 2003 Request for Additional Information Regarding Appendix K Measurement Uncertainty Recovery - 1.5% Power Uprate Request Project stage: RAI 2002-12-20
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Category:Letter
MONTHYEARL-24-002, Late LLRW Shipment Investigation Report Pursuant to 10 CFR 20, Appendix G2024-02-0202 February 2024 Late LLRW Shipment Investigation Report Pursuant to 10 CFR 20, Appendix G ML23342A1182024-01-0909 January 2024 Independent Spent Fuel Storage Installation Security Inspection Plan L-23-019, Proof of Financial Protection 10 CFR 140.152023-12-18018 December 2023 Proof of Financial Protection 10 CFR 140.15 ML23334A1822023-11-30030 November 2023 Biennial Report for the Defueled Safety Analysis Report Update, Technical Specification Bases Changes, 10 CFR 50.59 Evaluation Summary, and Regulatory Commitment Change Summary November 2021 Through October 2023 L-23-012, Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point2023-11-13013 November 2023 Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point ML23306A0992023-11-0202 November 2023 and Indian Point Energy Center, Notification of Changes in Schedule in Accordance with 10 CFR 50.82(a)(7) L-23-011, 10 CFR 72.48 Biennial Change Summary Report2023-10-27027 October 2023 10 CFR 72.48 Biennial Change Summary Report IR 05000293/20234012023-08-31031 August 2023 NRC Inspection Report No. 05000293/2023401 & 2023001 (Cover Letter Only) IR 05000293/20230022023-08-0404 August 2023 NRC Inspection Report No. 05000293/2023002 L-23-008, Correction to Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations Holtec Decommissioning International, LLC (HDI)2023-05-23023 May 2023 Correction to Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations Holtec Decommissioning International, LLC (HDI) ML23136A7792023-05-15015 May 2023 Annual Radiological Environmental Operating Report, January 1 Through December 31, 2022 ML23135A2152023-05-15015 May 2023 Annual Radioactive Effluent Release Report, January 1 Through December 31, 2022 L-23-004, HDI Annual Occupational Radiation Exposure Data Reports - 20222023-04-24024 April 2023 HDI Annual Occupational Radiation Exposure Data Reports - 2022 L-23-003, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2023-03-31031 March 2023 Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations ML23088A0382023-03-29029 March 2023 Stations 1, 2, & 3, Palisades Nuclear Plant, and Big Rock Point - Nuclear Onsite Property Damage Insurance ML23069A2782023-03-13013 March 2023 Request for Scoping Comments Concerning the Environmental Review of Monticello Nuclear Generating Plant, Unit 1 Subsequent License Renewal Application ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities IR 05000293/20220042023-02-15015 February 2023 NRC Inspection Report No. 05000293/2022004 ML22356A0712023-01-31031 January 2023 Issuance of Exemption for Pilgrim Nuclear Power Station ISFSI Regarding Annual Radioactive Effluent Release Report - Cover Letter ML22347A2782022-12-21021 December 2022 Independent Spent Fuel Storage Installation Security Inspection Plan Dated December 21, 2022 L-22-042, Oyster, Pilgrim, Indian Point, Palisades and Big Rock Point - Proof of Financial Protection 10 CFR 140.152022-12-14014 December 2022 Oyster, Pilgrim, Indian Point, Palisades and Big Rock Point - Proof of Financial Protection 10 CFR 140.15 L-22-041, Supplemental Information to Enhance Exemption Request Detail for Pilgrim ISFSI Annual Radioactive Effluent Release Report Due Date Extension2022-12-0909 December 2022 Supplemental Information to Enhance Exemption Request Detail for Pilgrim ISFSI Annual Radioactive Effluent Release Report Due Date Extension IR 05000293/20220032022-11-18018 November 2022 NRC Inspection Report No. 05000293/2022003 L-22-036, Decommissioning Trust Fund Agreement2022-11-0808 November 2022 Decommissioning Trust Fund Agreement ML22276A1762022-10-24024 October 2022 Decommissioning International Proposed Revisions to the Quality Assurance Program Approval Forms for Radioactive Material Packages ML22266A1922022-09-23023 September 2022 and Pilgrim Nuclear Power Station - Request to Withdraw Prior Submissions from NRC Consideration ML22272A0352022-09-22022 September 2022 S. Lynch-Benttinen Letter Regarding U.S. Citizen Intent to Sue U.S. Fish and Wildlife and NOAA Fisheries Representing the Endangered Species (Na Right Whale) Which Will Be Adversely Affected by Holtec International Potential Actions ML22269A4202022-09-22022 September 2022 Citizen Lawsuit ML22241A1122022-08-29029 August 2022 Request for Exemption from 10 CFR 72.212(a)(2), (b)(2), (b)(3), (b)(4), (B)(5)(i), (b)(11), and 72.214 for Pilgrim ISFSI Annual Radioactive Effluent Release Report IR 05000293/20220022022-08-12012 August 2022 NRC Inspection Report No. 05000293/2022002 ML22215A1772022-08-0303 August 2022 Decommissioning International (HDI) Proposed Revisions to the Quality Assurance Program Approval Forms for Radioactive Material Packages ML22206A1512022-08-0101 August 2022 NRC Office of Investigations Case Nos. 1-2022-002 & 1-2022-006 ML22221A2592022-08-0101 August 2022 LTR-22-0217-1-NMSS - Town of Duxbury Letter Opposing the Irradiated Water Release from Pilgrim (Docket No. 05000293) ML22193A1662022-07-28028 July 2022 LTR-22-0154-1 - Heather Govern, VP, Clean Air and Water Program, Et Al., Letter Regarding Radioactive Wastewater Disposal from the Pilgrim Nuclear Power Station (Docket No. 05000293) ML22175A1732022-07-28028 July 2022 LTR-22-0153-1 - Response Letter to D. 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'0 EAEnteWg Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Charles M. Dugger Vice President - Operations December 30, 2002 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station Docket 50-293 License No. DPR-35 Response to NRC Request for Additional Information Appendix K Measurement Uncertainty Recovery - Power Uprate Request
REFERENCE:
NRC Letter "PILGRIM NUCLEAR POWER STATION - REQUEST FOR ADDITIONAL INFORMATION RE: APPENDIX K MEASUREMENT UNCERTAINTY RECOVERY - POWER UPRATE REQUEST (TAC NO.
MB5603)," dated December 23, 2002 LETTER NUMBER: 2.02.112
Dear Sir or Madam:
The NRC and Entergy conducted a teleconference on December 12, 2002 to discuss certain NRC questions related to the Entergy Power Uprate Request and on December 24, 2002 Entergy received the reference letter. Attachment 1 of this letter provides the responses to the requested information. Attachment 2 provides the results of the PNPS grid stability study, meeting commitment C14 from the initial submittal letter 2.02.048, dated July 5, 2002.
Should you have any questions or comments concerning this submittal, please contact Bryan Ford at (508) 830-8403.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 30th day of December 2002.
JRH/dd AUoD0I 202112
Entergy Nuclear Operations, Inc. Letter Number: 2.02.112 Pilgrim Nuclear Power Station Page 2
Attachment:
- 1. Response to NRC Request for Additional Information
Attachment:
2 Summary of Results of the PNPS Grid Stability Study cc: Mr. Travis Tate, Project Manager Mr. Robert Walker Office of Nuclear Reactor Regulation Radiation Control Program Mail Stop: 0-8B-1 Commonwealth of Massachusetts U.S. Nuclear Regulatory Commission Exec Offices of Health & Human Services 1 White Flint North 174 Portland Street 11555 Rockville Pike Boston, MA 02114 Rockville, MD 20852 U.S. Nuclear Regulatory Commission Mr. Steve McGrail, Director Region 1 Mass. Emergency Management Agency 475 Allendale Road 400 Worcester Road King of Prussia, PA 19406 P.O. Box 1496 Framingham, MA 01702 Senior Resident Inspector Pilgrim Nuclear Power Station 202112
ATTACHMENT 1 LETTER NUMBER 2.02.112 Response to NRC Request for Additional Information Appendix K Measurement Uncertainty Recovery-Power Uprate Request 202112
Letter Number: 2.02.112 Page 1 of 2
- 1. NRC Request:
Item 2 (a) on page 1-5 of the General Electric Company report, NEDC-33050P, Revision 1, "Safety Analysis Report for Pilgrim Nuclear Power Station [PNPS]
Thermal Power Optimization," stated the following:
"PNPS does not have an existing Crossflow [ultrasonic flow meter] UFM installation. It does have a crossbeam UFM system..."
In the first line on page 3 of 9 of Letter 2.02.096 dated November 6, 2002, you stated the following:
"During the past 4 years Pilgrim found the AMAG UFM to be extremely reliable.."
The staff approved topical report, CENPD-397-P, dated May 2000, does not include the Crossbeam type UFM and the staff believes the Crossflow and Crossbeam UFMs are two different types of UFMs. If the AMAG UFM referenced in the second statement above is a crossbeam UFM, please provide justification of how the historical data and experience of this Crossbeam UFM could be applied to determine allowed outage time (AOT) for the proposed Crossflow UMF. Please include a discussion of similarities and differences between the design of the Crossflow and Crossbeam UFMs.
Response
PNPS installed an AMAG CROSSBEAM Ultrasonic Flow Meter (UFM) on the feedwater system to improve the accuracy of the flow measurement about four years ago. The underlying technology of the existing CROSSBEAM installation and the new CROSSFLOW UFM is the same for both systems. However, the new CROSSFLOW installation will be in accordance with the Westinghouse Topical Report and the NRC SER, while the existing system is not.
Both CROSSBEAM and CROSSFLOW utilize the same cross-correlation technology as described in the Westinghouse Topical Report CENPD-397-P-A, Rev 01. That is, both rely on sophisticated technology to recognize a flow turbulence signature as it passes two separate transducer pairs, which are precisely spaced longitudinally along the pipe.
Each transducer pair contains a transmitter and a receiver.
CROSSBEAM is technology, which offsets the transducer pairs radially to account for flow-induced swirl in the fluid. The offset is designed to correspond to the amount of swirl between the two sets of transducer pairs to facilitate recognition of the turbulence signature. Although this system has proved to be very accurate and reliable, this installation is not in accordance with the Topical Report.
CROSSBEAM will remain a backup system following installation of the new CROSSFLOW system. PNPS has monitored the drift of the installed CROSSBEAM Correction Factor over a one-year period and found it to be very stable. One standard deviation is approximately 0.086%. Both the CROSSBEAM system and the plant flow nozzles provide repeatable results and when compared, duplicate readings very well.
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Letter Number: 2.02.112 Page 2 of 2 The fourteen-day period of operation without CROSSFLOW was chosen based on engineering judgment and the estimated time to complete component replacement, maintenance and testing on the system. Although actual historical data based on the availability of the CROSSBEAM demonstrates the window of operation without CROSSFLOW could be extended much longer than fourteen days, the period of fourteen days was considered reasonable and adequate.
- 2. NRC Request:
In your response to item 3.B on page 3 of 9 of Letter 2.02.096 dated November 6, 2002, you stated, "In the event the AOT is reached, PNPS will be required, by procedure, to reduce its power level to an alternate value that accounts for the uncertainty associated with instrumentation then being used to measure power." In the event that both AMAG UFMs are out of service, please provide the alternate power level to be allowed by procedure for the instrumentation available to be used for measuring power. If the reduced power level is greater that the current licensed power level of 1998 MWt, please provide a discussion of the technical basis for the proposed power level.
Response
Should both CROSSFLOW systems remain out of service longer than the proposed 14 day allowed out-of-service time (AOT) or if both the CROSSFLOW and the CROSSBEAM systems are unavailable, reactor thermal power will be lowered to the original licensed thermal power of 1998 MWt within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Procedures incorporating the AOT and the associated actions will be developed consistent with commitment C5 of Entergy Letter 2.02.048, dated July 5, 2002.
- 3. NRC Request:
Section 10.3.1 of NEDC-33050p, Revision 1, addresses environmental qualification (EQ) for electrical equipment. In this section you indicate that power uprate issues related to EQ for electrical equipment are under review. Please provide the results of this review or provide a commitment to complete the review and incorporate any changes, as necessary, in accordance with applicable regulatory requirements prior to implementing the power uprate.
Response
A review of the environmental qualifications of equipment potentially impacted by TPO is under review and revisions are being made as identified. As stated in Entergy Letter 2.02.048, dated July 5, 2002, Commitment C2, "All changes necessary to support operation above the current licensed thermal power will be completed prior to exceeding 1998 MWT." This includes performing necessary updates of affected environmental qualification files.
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ATTACHMENT 2 LETTER NUMBER 2.02.112 Response to NRC Request for Additional Information Appendix K Measurement Uncertainty Recovery-Power Uprate Request 202112
Letter Number: 2.02.112 Page 1 of 1 PNPS Grid Stability PNPS completed a grid stability study in November 2002 that was approved by ISO New England on December 10, 2002. This action meets the requirement of commitment C14 contained in Entergy Letter 2.02.048, dated July 5, 2002.
The study provided the following information. The current operating point of the main generator is 699 MWe at 0.896 power factor (pf). At the 1.5% power uprate, the main generator will operate at 734 MWe at 0.941 pf. The generator capability curve contained in the study shows that operation at power uprated condition is possible at a power factor of 0.941. The main generator can operate within the range of 280 megavolt-ampere reactive (MVAR) lagging and 100 MVAR leading. The leading limit is a result of the generator excitation system's under excited reactive ampere limit (URAL) set point. The study identified a "minor" stability issue requiring the replacement of a lockout relay for the West Walpole substation 345 kV circuit breaker 108. The relay replacement is scheduled prior to TPO implementation in 2003. The study identified no other stability issues for the 1.5% measurement uncertainty recapture uprate for the unit.
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