ML043030493

30-Day Report Required by 10 CFR 50.46(a)(3)(ii)

ML043030493
Person / Time
Site:	Pilgrim
Issue date:	10/21/2004
From:	Bethay S Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.04.097
Download: ML043030493 (4)

Text

Ot077 0 Entergy Nuclear Operations, Inc.

l ntegyt En Pilgrim Station 600 Rocky Hill Road Plymouth, MA 02360 Stephen J. Bethay October 21, 2004 Director, Nuclear Assessment U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Docket No.: 50-293 License No.: DPR-35 30-Day Report Required by 10 CFR 50.46(a)(3)(ii)

REFERENCES:

1. Entergy letter to U.S. NRC dated June 17, 2004, 10 CFR 50.46(a)(3)(ii) Annual Report

2. General Electric 10 CFR 50.46 Notification Letter 2004-01, dated September 24, 2004.

3. GE Nuclear Energy Report NEDC-31852P, "Pilgrim Nuclear Power Station SAFER/GESTR-LOCA Analysis," Rev. 2 dated January 2003.

LETTER NUMBER: 2.04.097

Dear Sir or Madam:

This letter submits a 30-day report required by 10 CFR 50.46(a)(3)(ii).

Reference 1 submitted the most recent annual report required by 10 CFR 50.46. In summary, the report described a change in the evaluation model that resulted in no impact to the licensing basis peak clad temperature (PCT) for GE1 1 fuel (21200 F) and GE14 fuel (2130TF) for Pilgrim.

By Reference 2 General Electric notified Entergy of an error in the Pilgrim LOCA analysis for GE14 fuel. The error resulted in an increase of 1400 F to the Pilgrim licensing basis PCT for GE14 fuel, to 2270TF. describes the error and initial actions taken to ensure the PCT of GE14 fuel will not exceed 2200TF in the event of a LOCA. Enclosure 2 identifies the commitments made in this letter that includes implementing changes to the Pilgrim 3D MONICORE system, based on a reanalysis of the Pilgrim LOCA analysis. The LOCA reanalysis will be routinely documented as part of the reload design for the next fuel cycle, beginning in the April - May 2005 timeframe.

Please feel free to contact Bryan Ford, (508) 830-8403, for any questions regarding this subject.

Sincerely, Stepen J. 47 Director, Nuclear Assessment 204097

Entergy Nuclear Operations, Inc. Letter Number: 2.04.97 Pilgrim Nuclear Power Station Page 2

.I DWE/dm .. . I

. .: . I . ..'. I : Description of Error and Actions Taken and Ongoing (1 page) : Commitments (1 page) cc: Mr. Lee Licata, Project Manager Mr. Samuel J. Collins Office of Nuclear Reactor Regulation Regional Administrator, Region 1 Mail Stop: 0-8B-1 U.S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission 475 Allendale Road 1 White Flint North King of Prussia, PA 19406 11555 Rockville Pike Rockville, MD 20852 Senior Resident Inspector Pilgrim Nuclear Power Station 204097

.7 ENCLOSURE 1 Description of Error and Actions Taken and Ongoing General Electric Notification Letter 2004-01 reported a radiation resistance array error in the GE14 fuel LOCA analysis for Pilgrim. The error is summarized as follows. The radiation resistance input to generate SAFER basedecks is a two dimensional array that is entered as input in a sequential 1-d array. Updated values were identified for GE14 fuel. In the course of modifying the basedecks for the updated values, an error occurred in the GE14 LOCA analysis for Pilgrim, reported in Reference 3. The sequential order of the radiation resistance values did not correspond to the order in which they were interpreted by SAFER input routine.

As discussed in the Notification Letter, a review of the SAFER basedecks showed that only the Pilgrim GE14 analysis, reported in Reference 3, contained the radiation resistance array error.

The impact of the error on the PCT was evaluated by correcting the SAFER radiation resistance array order and repeating the limiting GE14 LOCA analysis. The maximum average planar linear heat generation rate (MAPLHGR) for Pilgrim was previously optimized to limit the licensing basis PCT to 2130OF (based on an Appendix K PCT of 21200 F). The evaluation was performed for a LPCI injection valve failure under MELLA conditions with the current limiting MAPLHGR. Correction of this error increased the Appendix K PCT for the limiting case by 140 0F.

This means that based on an increase of 140OF in the Pilgrim licensing basis PCT for GE14 fuel due to the error, the licensing basis PCT for GE14 fuel for Pilgrim is 22700F, which is greater than the 22000 F criterion in 10 CFR 50.46(b)(1).

Entergy evaluated the operating conditions existing on September 24, 2004, when the Notification Letter was issued. The evaluation included review of reactor fuel Technical Specifications 3.11.A (APLHGR), 3.11.B (LHGR), 3.11.C (MCPR), and 3.11.D (power/flow relationship). The review determined that of these limits, only the operating limits for MAPLHGR (APLHGR) had the potential for being exceeded. The evaluation determined the current operational conditions were conservative and the PCT limit would have been met. The administrative limits for MAPLHGR (APLHGR) were reduced approximately 9.23 percent to ensure a PCT of less than 22000 F until a reanalysis of the Pilgrim LOCA analysis is completed and from which new limits will be entered in Pilgrim's 3D MONICORE system. The adjustment in the administrative limits is consistent with the Notification Letter that identifies a 1% reduction in MAPLHGR results in a PCT reduction of 131F.

A review was ongoing when this report was prepared. The review includes the potential of exceeding the MAPLHGR operating limits during certain instances before September 24, 2004.

The review has identified no instances when actual plant conditions existed such that the limits would have been violated. After the review is completed, the potential of other additional reporting will be evaluated in accordance with the corrective action program.

204097

- r -s ENCLOSURE 2 Commitments NUMBER REGULATORY COMMITMENTS DUE DATE 1 Implement changes to the 3D MONICORE system based December 16, 2004 on the results of reanalysis of the Pilgrim LOCA analysis.

204097