ML030650969
| ML030650969 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/24/2003 |
| From: | Ronald Bellamy Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC MB7318 | |
| Download: ML030650969 (5) | |
Text
S En tergy Entergy Nuclear Operations, Inc.
Pilgnm Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Mike Bellamy Site Vice President February 24, 2003 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 Concerning Request for Amendment to the Technical Specifications Emergency Core Cooling System Requirements During Shutdown (MB7318)
LETTER NUMBER:
2.03.028
Dear Sir or Madam:
The NRC and Entergy conducted a teleconference on February 13, 2003 to discuss NRC questions related to the Entergy request for an amendment to the Technical Specifications Emergency Core Cooling System Requirements during shutdown (MB7318). Attachment 1 of this letter provides the responses to the requested information.
This response does not change the no significant hazard conclusions previously submitted in Entergy Letter 2.03.004, dated January 23, 2003.
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 24th day of February 2003.
Sincerely, Robert M. Bellamy MJG/dd 0
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Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station Letter Number: 2.03.028 Page 2 Attachments: 1.
Response to NRC Request for Additional Information (2 pages) cc:
Mr. Travis Tate, Project Manager Office of Nuclear Reactor Regulation Mail Stop: 0-8B-1 U.S. Nuclear Regulatory Commission 1 White Flint North 11555 Rockville Pike Rockville, MD 20852 U.S. Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspector Pilgrim Nuclear Power Station Mr. Robert Walker Radiation Control Program Commonwealth of Massachusetts Exec Offices of Health & Human Services 174 Portland Street Boston, MA 02114 Mr. Steve McGrail, Director Mass. Emergency Management Agency 400 Worcester Road P.O. Box 1496 Framingham, MA 01702 203028
ATTACHMENT 1 LETTER NUMBER 2.03.028 Response to NRC Request for Additional Information Request for Amendment to the Technical Specifications Emergency Core Cooling System Requirements During Shutdown (MB7318) 203028
Letter Number: 2.03.028 Page 1 of 2 Request for Additional Information
- 1.
In your application dated January 23, 2003, water level at the 114 ft elevation is referred to in various places. On Page 5 of 10, first paragraph, you state "-..... equal to elevation 114 foot in excess of 300,000 gallons of water is available to provide core cooling The standard technical specification (STS), NUREG 1433, makes reference to water level at 23 feet over the top of the RPV vessel flange. Please explain the significance of the elevation 114 feet in relation to top of the active fuel (How many feet from TAF?) or top of the RPV vessel flange.
Response
114' was chosen to be consistent with current TS 3.5.F.5.b requirements. This level also provides a significant water inventory and a viable reference elevation.
Top of Active Fuel: 67'6 1/" elevation (114-67'6 1'" =46'5 3")
Top of RPV flange: 93'33/4" elevation (114-93'3 3/4" =20'8 14")
- 2.
The TS Page 3/4.2-17, proposed note 1 (Table 3.2.B) change in the January 23, 2003, application is not consistent with the completion time guidance specified in STS 3.3.5.1.
Please provide a justification that addresses your proposed change in relation to guidance specified in the STS.
Response
The requirements proposed are consistent with the current requirements. Please refer to letter 2.03.004 Enclosure page 6 of 10, item B. The proposed AOT (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and then declare affected systems inoperable) is consistent with STS LCO 3.3.5.1 required actions-1B.3, C.2, D.2.1. These are the STS Required Actions that apply to failures that do not result in a loss of function. Our Technical Specifications currently do not address loss of function separately. In addition, we do not have many of the allowances presently in STS e.g. Required Actions E.2, F.2, G.2. We tried to limit the scope of this change in order to ease NRC reviews. Therefore, we did not propose a complete upgrade of the instrumentation LCO.
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Letter Number: 2.03.028 Page 2 of 2
- 3.
The deleted portions in TS Page 3/4.5-10, of the January 23, 2003, application refer to containment cooling systems. The new replacement additions do not mention containment cooling systems. Please explain why the reference to the containment cooling systems is being deleted.
Response
There are no requirements for containment cooling to be operable when in cold shutdown (reference TS 3.5.B.1. /2). This statement provided no real requirements and was probably included because the RHR system; which Low Pressure Coolant Injection (LPCI) is a mode of, also provides the containment cooling functions. When RHR is operating in the LPCI mode, it is considered one of the Core Standby Cooling Systems (CSCS).
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