ML052280246

Response to NRC Request for Additional Information License Amendment Request for Single Loop Operation

ML052280246
Person / Time
Site:	Pilgrim
Issue date:	08/09/2005
From:	Balduzzi M Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.05.059, TAC MC4333
Download: ML052280246 (11)

Text

`Entergy Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Michael A. Balduzzi Site Vice President August 9, 2005 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, License Amendment Request for Single Loop Operation (TAC No. MC4333)

REFERENCE:

1. Entergy Letter, 2.04.074, License Amendment Request, Single Loop Operation, dated September 2, 2004.

2. NRC Letter, 1.05.069, Request for Additional Information Regarding Technical Specification Changes for Single Recirculation Loop Operation, Pilgrim Nuclear Power Station (TAC No. MC4333), dated June 27, 2005.

LETTER NUMBER: 2.05.059

Dear Sir or Madam:

By Reference 2, the NRC requested additional information to support review of Entergy's request to revise Pilgrim Station Technical Specifications to allow operation with a single recirculation loop in service (Reference 1). Entergy has evaluated the request and the response is provided in Attachment 1.

This response does not invalidate the no significant hazard conclusions previously submitted in Reference 1. This letter contains no commitments.

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  ? th day of August 2005.

Sincerely, Michael A. Balduzzi Site Vice President

Entergy Nuclear Operations, Inc Letter Number 2.05.059 Pilgrim Nuclear Station Page 2 FM/dm

Attachment:

1. PNPS Response to NRC Request for Additional Information on Single Loop Operation - 9 pages cc: Mr. James Shea, 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 90 Washington Street 1 White Flint North Dorchester, MA 02121 11555 Rockville Pike Rockville, MD 20852 Ms. Christine McCombs, Director U.S. Nuclear Regulatory Commission Mass. Emergency Management Agency Region 1 400 Worcester Road 475 Allendale Road P.O. Box 1496 King of Prussia, PA 19406 Framingham, MA 01702 Senior Resident Inspector Pilgrim Nuclear Power Station to Letter 2.05.059 Page I of 9 Response to NRC Request for Additional Information On Single Loop Operation O.l: Stability:

O.I.A:

We understand that PNPS implemented Stability Option ID during the refueling outage completed in May 2005. Please discuss and justify the effectiveness of Option ID for operation with single recirculation loop operation (SLO).

RESPONSE

Stability Option I-D relies on a protection strategy that involves preventing operation in the power-flow region of potential instabilities (i.e., prevention) and establishment of Average Power Range Monitor (APRM) scram set points which ensure that the Safety Limit Minimum Critical Power Ratio (SLMCPR) is not violated for the anticipated core wide mode oscillations (i.e.,

detection and suppression). This stability protection strategy is described in NEDO-32465-A (Reference 1), which has been reviewed and approved by the NRC.

The PNPS Single Loop Operation Report (Reference 6) was transmitted to the NRC as Attachment I to our submittal dated September 2, 2004. Section 5 of the report discusses stability in relation to SLO. The conclusion is that "stability characteristics are not significantly different from two-loop operation" (TLO). This statement refers to calculated data and test data for decay ratio, and justifies that the Option I-D Exclusion Region (and Buffer Region) applies to both SLO and TLO. Thus observance of the Exclusion Region should prevent high decay ratios and stability events in both SLO and TLO.

Stability Option I-D relies on flow-biased APRM scram to provide SLMCPR protection (detect and suppress). The core flow-drive flow relationship changes when the mode of recirculation pump operation changes from TLO to SLO. For SLO, reverse flow in the idle loop requires APRM flow-biased scram setpoint adjustment (refer to Table 2-1 of Reference 6, the SLO Report). Based on these SLO setpoint adjustments, flow biased APRM scram will occur at a power less than or equal to the power in TLO given the same core flow.

SLO operation also requires an increase in SLMCPR due to increased modeling and process uncertainty. Based on the increase in SLMCPR, the Operating Limit Minimum Critical Power Ratio (OLMCPR) will also be increased for SLO operation to ensure that there is no loss of margin to the SLMCPR provided by the APRM scram between TLO and SLO.

0. LB:

The staff understands that Pilgrim is experiencing recirculation system flow perturbation (bi-stable flow) potentially due to the recirculation system configuration. Provide an evaluation of how PNPS' susceptibility to flow perturbation is accounted for in the Option ID (e.g. flow mapping uncertainties) for SLO. Please submit supporting documentation or the vortexing evaluation that demonstrates the magnitude of the flow oscillations that have been experienced at PNPS.

to Letter 2.05.059 Page 2 of 9 Response to NRC Request for Additional Inforrnation On Single Loop Operation

RESPONSE

A plant specific evaluation (Reference 3) of bi-stable vortexing, as described by GE Service Information Letter (SIL) 467 (Reference 4) and NRC Information Notice (IN) 86-1 10 (Reference 16), was performed for PNPS. This evaluation identifies that the bi-stable vortex phenomenon occurs in both recirculation loops, and that the amplitude of change in loop flow rate is nearly constant and nearly the same in both loops. The report describes bi-stable event frequency (3 events per hour for Loop A versus 3 events per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for Loop B) and duration (up to ten minutes for Loop A events verse up to 50 seconds for Loop B events). The report indicates amplitude from the base recirculation pump flow is between 2% and 3% and that a corresponding change in reactor power of approximately 1% is observed for each loop specific bi-stable event.

The report also identifies that the uncertainty in the core flow measurement system and the Local Power Range Monitor (LPRM) calibrations may be slightly increased; however, resulting accuracy was acceptable and compensating adjustments to operating limits were not necessary.

The principle conclusion identified in the report is that the phenomenon was understood, and that there are no safety issues and no significant impact on the plant.

The impact of bi-stable flow on the monitoring instrumentation during SLO is no different than for two loop operation, though the magnitude is smaller (because only one loop can be affected).

The concurrent increase or decrease in drive flow, core flow and core power resulting from the bi-stable flow is sensed by APRMs and core flow monitoring instrumentation. As a result, the Stability Option I-D protection features (i.e., on-line stability monitoring and APRM scram set points) remain functional and continue to provide SLMCPR protection.

0.1-C:

The instability requirements section of the Enclosure to the September 2, 2004 amendment request provides a discussion on the impact of SLO operation on the instability response of boiling-water reactors (BWRs). The submittal states that as the core flow increases beyond 40%

of rated during SLO, substantial reverse flow is established in the inactive loop. The increase in the system noise increases the total core flow noise, which tends to increase the observed neutron flux noise. However, the discussion did not factor in the PNPS-specific vortexing and the additional system noise this may induce for SLO.

0.1.C.I:

Provide an evaluation of the impact of the PNPS vortexing on the noise and accuracy of the neutron monitoring instrumentations (e.g. low-power range monitors, average power range monitors (APRMs) and traversing in-core probes (TIPs) for SLO, where there is backflow through 10 of the jet pumps. Explain if instrumentation adjustment or filtering of system noise during SLO would be performed. State how it would be ensured that any noise filtering or system adjustment would not result in a delayed flow-biased APRM scram in the event of instability?

RESPONSE

The occurrence of the bi-stable flow phenomenon is well documented for two-loop operation.

This phenomenon is described in SIL-467 and IN 86-110.

If bi-stable vortexing were to occur it would be an anomaly of drive flow to pump speed, and though it may be considered as additional system noise, it is not strictly noise because the power/flow change is of longer duration. SIL467 notes the observed magnitude (0.1 tol.5%),

Attachment I to Letter 2.05.059 Page3of 9 Response to NRC Request for Additional Information On Single Loop Operation duration (several seconds to several hours) and frequency (I to 200 per hour) of the power perturbations. The impact of bi-stable flow on the monitoring instrumentation during SLO is no different than for TLO, though its magnitude is smaller (because only one loop can be affected).

The concurrent increase or decrease in drive flow, core flow and core power is captured by the monitoring instrumentation which does not require adjustment or noise filtering to account for bi-stable flow. As a result, APRM flow-biased scram will not be delayed in the event of thermal hydraulic instability.

0.1 .C.2:

Evaluate the reference stability solution documents and state if the conclusions of the referenced documents would still hold for PNPS, in terms of SLO with a feedwater heater out-of-service (FWHOOS) or final feedwater temperature reduction (FFWTR), and the potential for increased core flow noise due to vortexing.

RESPONSE

As discussed in the l.C.1 response above, the bi-stable flow does not change the drive flow to core flow relationship, but rather the drive flow to pump speed relationship. The effect of the vortexing is not significant in magnitude, compared against an instability event, and is captured in the monitoring function such that the APRM flow-biased trip system will function equally under both normal and reduced feedwater temperature conditions to mitigate any neutron flux increase.

O.L.D:

The application states SLO operation can be combined with FWHOOS or FFWTIlR. Pump trip from SLO conditions with FWHOOS or FFWTR would affect the plant's instability response.

Although the SLO is restricted to a lower rod line and power level, the higher initial subcooling and the faster rate of reaching natural recirculation could lead to a higher susceptibility to instability. It is not clear if the scram setpoints calculations accounted for the transient initiating from a condition with higher subcooling for both two loop operation (TLO) and SLO. Provide an evaluation/discussion on how the PNPS stability option setpoint calculation method accounts for the impact of SLO with FWHOOS or TLO with FWHOOS/FFWTR on the stability performance.

Reference the applicable sections of the NRC-approved licensing topical report (LTR) that addresses this.

RESPONSE

The Option I-D stability analysis (Reference 5) and the Option I-D APRM Flow Biased Setpoints Report (Reference 2) establish the appropriate APRM flow-biased scram trip setpoints to assure that the SLMCPR is not exceeded during an instability event. The stability protection methodology, consistent with Reference 1, includes a relationship between the APRM flow-biased scram trip setpoint and the Operating Limit MCPR (OLMCPR). This methodology is independent of the specific recirculating pump operating condition. While the SLO condition is slightly less stable as discussed in the SLO report (Reference 6) and the FWHOOS or FFWTR also reduces the stability margins, the APRM flow-biased scram trip setpoints (Reference 2) are conservatively established such that the maximum overpower will be mitigated to protect the SLMCPR even under these less stable conditions.

A pump trip from SLO conditions would result in natural circulation flow. Continuous operation in this mode is not currently allowed by technical specifications and the operating license. In this transient, Stability Option I-D continues to provide protection via the APRM flow-biased scram.

Attachment I to Letter 2.05.059 Page 4 of 9 Response to NRC Request for Additional Information On Single Loop Operation FWHOOS and FFWTR are operating modes that are explicitly addressed for OLMCPR. The analyses for these modes result in more restrictive (higher) OLMCPR. A higher OLMCPR would provide added margin for SLMCPR protection in the event that operation is terminated by an APRM scram.

The methods used to obtain the Exclusion Region, as described in Reference 13 for the ODYSY code, are conservative including use of a core decay ratio acceptance criterion of 0.65 (0.80 with a 0.15 adder for conservatism). This approach ensures that the effects of FFWTR or SLO will not significantly increase the probability of instability provided the exclusion region is not entered.

0.2: Safety Limit for Minimum Critical Power and Bi-stable Condition:

0.2.A:

Considering the bi-stable flow condition and the potential increase in the measured flow inaccuracies, explain if the recirculation flow uncertainties should be increased for PNPS. Please submit the uncertainty information supporting your calculations:

RESPONSE

The bi-stable flow phenomenon described in S1L467 affects the drive flow to pump speed relationship and has no impact on jet pump differential pressure readings, which are used to measure the core flow. Therefore, should the drive flow be on either the high or low flow mode for a given pump speed, the core flow will follow the resulting drive flow and will be measured appropriately.

Q.2.B:

Section 3.1.2 of the September 2, 2004, submittal presents progression error analysis to demonstrate the uncertainty analysis procedure used to establish the core flow uncertainty for SLO and concludes that the General Electric Thermal Analysis Basis value remains bounding.

State if the uncertainty analysis provided in Equation 3.3 (Page 3-3 of GE-NE-0000-0027-5301, Revision 1)was previously evaluated by the NRC. If so, provide the applicable reference. If not, expand on the core flow uncertainty analysis provided so that the acceptability of the approach can evaluated (sic).

RESPONSE

The core flow uncertainty of 2.5% for TLO has been reviewed and approved by the NRC as documented in NEDO-10958-A, "General Electric BWR Thermal Analysis Basis (GETAB) Data Correlation and Design Application," January 1977 (Reference 7). The detail derivation of the core flow uncertainty, including the expression used in the SLO Report (Reference 6), is documented in response to Question 3-8 page VII-32 of Reference 7. The core flow uncertainty for SLO is 6% based on application of the same expression with a conservative value for the reverse flow fraction in the inactive jet pumps.

to Letter 2.05.059 Page5 of 9 Response to NRC Request for Additional Information On Single Loop Operation 0.2.C:

Section 3.2, "TIP Reading Uncertainty" cites generic BWR tests performed to establish the TIP noise uncertainty for SLO operation. Several BWRs, including PNPS, experience additional flow fluctuation attributed to the characteristic of the plant-specific recirculation system configuration.

Do these tests include plants experiencing additional noise due to the recirculation flow fluctuations? If not, justify why the TIP random noise should not increase for both SLO and TLO to account for non-typical random neutron, electronic and boiling noise.

RESPONSE

The occurrence of the bi-stable flow phenomenon is well documented in TLO as described in SIL-467 and IN 86-110.

If bi-stable vortexing were to occur, the bi-stable flow is not really noise but rather a small flow increase or decrease with a resulting uniform power increase or decrease of approximately 1%.

The increased noise observed in SLO, due to reverse flow in half of the jet pumps, is conservatively accounted for by an increase in the overall TIP uncertainty from 8.7% to 9.1% as discussed in the SLO Report (Reference 6). Factoring the bi-stable flow effect into the TIP uncertainty is not justified because the instrumentation and calculation will account for either the increase or decrease in power from the bi-stable flow.

0.3: Bi-stable Flow and Vibration:

Explain if the susceptibility to bi-stable flow would increase the pump vibration concerns and if this was taken into account in developing the power/flow ratio that SLO would be allowed.

RESPONSE

The occurrence of the bi-stable flow phenomenon is well documented in TLO as described in SIL-467 and IN 86-110. If bi-stable flow increases did occur during SLO, the magnitude of the flow increase is expected to mirror TLO.

The power and core flow limits for SLO were selected to limit flow-induced jet pump vibration to remain within the operational experience base of the station. PNPS has over thirty years of operational experience with no incidence of abnormal jet pump degradation or deterioration including the twenty-year operating period since bi-stable vortices were first observed in 1984.

PNPS vibration test data was re-evaluated for Pilgrim SLO and it is concluded that the maximum allowable core flow is 52% of rated core flow which corresponds to 65% power on the 100% rod line. The vibration test data evaluated includes pre-operational and startup data taken after the recirculation pipe replacement in 1984. Bi-stable flow incidents emerged after the pipe replacement.

Based on flow measurements, a core flow rate of 52% during SLO requires an active loop flow rate of approximately 140% of rated because of reverse flow through the jet pumps in the idle loop. Measured jet pump displacements during SLO with active loop flow in the range of 138%

to 154% are similar in magnitude to those measured at rated flow during TLO and therefore, active loop flow at the proposed core flow rate does not present an increased threat to jet pump integrity.

to Letter 2.05.059 Page 6 of 9 Response to NRC Request for Additional Information On Single Loop Operation Consideration has been given to the possible effect that the bi-stable flow may have on vibration of the Pilgrim reactor vessel internals. Past experience with flow induced reactor internals vibration has shown the jet pumps are the most critical components. The amplitude of the vibration may increase if the flow velocity is increased. The maximum amplitude measured during PNPS pre-operational startup testing was less than 40% of the displacement criterion. The jet pump flow change produced by the bi-stable would not significantly reduce the available margin to the criterion. Consequently the bi-stable flow increase will not produce a significant change in the vibration amplitude of the jet pumps. The frequency of the flow changes is too low and too irregular to produce any kind of resonance with the natural frequencies of the reactor internals.

Periodic jet pump inspections have shown the jet pumps to be in acceptable condition, and provide empirical evidence that bi-stable vortices and the associated flow increase do not induce pressure fluctuations or excitations that degrade the jet pump assembly. In conclusion, intermittent core flow increases from bi-stable vortices will not subject jet pumps to excitation or pressure fluctuations that threaten jet pump integrity during SLO.

O4: Design Bases Analyses Q.4.A:

For the pump seizure event, the amendment request proposes scaling the SLO Operating Limit Minimum Critical Power Ratio performed for Cycle 14 for the current cycle (Cycle 16). Please state whether PNPS is already loaded with GE14 fuel. If so, why was the pump seizure event not analyzed with the introduction of GE14 fuel? If the reference pump seizure event is based on a different core loaded fuel design, in terms of licensing basis, justify why the pump seizure event based on a different fuel type should be used for the GE14 fuel introduction using a scaling approach.

RESPONSE

Cycle 14 was the cycle where GE14 fuel was first introduced. The pump seizure event analyzed for the Cycle 14 analysis was based on GE14 fuel (Reference 8). This Cycle 14 analysis is referenced in Appendix E of the Supplemental Reload Licensing Report for Cycle 15 (Reference 14). Therefore, it is appropriate to scale the results of Cycle 14.

0.4.B:

The application states that the Rod Withdrawal Error (RWE) evaluations are independent of the source of core flow (i.e., one recirculation loop or two) and consequently, these evaluations are valid for both TLO and SLO. Operation at low-flow conditions rely on different control rod patterns than operation at rated conditions, making rod worth different. Explain why RWE initiated from rated conditions with dual recirculation loops bounds operation with single recirculation loop. If there is an NRC-approved licensing technical review addresses this issue and it is applicable to PNPS, please reference it.

to Letter 2.05.059 Page 7 of 9 Response to NRC Request for Additional Information On Single Loop Operation

RESPONSE

The 1987 APRM, Rod Block Monitor (RBM) and Technical Specification Improvements Analysis (ARTS) Report for PNPS (Reference 9) describes the ARTS and RBM setpoint improvement program. Application of this report was approved via License Amendment 138 (TAC No. 79649). The Pilgrim RBM setpoint is power-biased and it allows a larger increase in local power at low power compared to high power. It is true that at low power the absolute change in MCPR for an RWE can be larger than at or near rated power, but MCPR (and LHGR) limits are more restrictive at low power so margins to the MCPR Safety Limit (SLMCPR) and Linear Heat Generation Rate (LHGR) licensing limits are maintained. Reference Section 4.3 and Figure 4-9 of Reference 9.

Normally a plant operates in SLO due to a recirculation pump problem that occurs while online, so the transition to SLO is from high power and flow to lower power and flow. The power change will occur by a combination of flow reduction and control rod insertion. A typical steady-state operating point would be approximately 45% power and 47% flow which is equivalent to a 70% loadline. At this loadline the rod pattern would not be substantially different from a full power rod pattern. Rods in the operating sequence would be the only rods in use. This typical SLO operating point is also a typical point during a normal startup.

In current cores that use lOx 1o fuel, the RWE has become a much less limiting event than it was when Pilgrim modified their RBM as described in the Reference 9. Operating Limit Minimum Critical Power Ratio (OLMCPR) values are based on pressurization transients (FWCF, LRw/oBP, TTw/oBP) only, and not by the RWE. In fact, analysis of the RWE for the current core shows that the SLMCPR will not be violated even without RBM action at any power.

Q.4.C:

The amendment request states that for SLO, the flow-biased APRM scram trip and rod block setpoints must be adjusted to account for the change in the relationship between drive flow and core flow due to reverse flow in the inactive loop jet pumps and lower core resistance. Evaluate the impact, if any, that the susceptibility to flow oscillation would have on the drive flow to core flow adjustments and the associated correction made to the flow-biased APRM scram and rod block.

RESPONSE

As discussed in the 1.C.1 response above, the bi-stable flow does not change the drive flow to core flow relationship, but rather the drive flow to pump speed relationship. Therefore, the flow-biased scram trip and rod block setpoints remain applicable either in TLO or SLO. For SLO (Reference 2), a correction for the back flow through the inactive jet pumps adjusts the setpoint as a function of drive flow so that setpoint as a function of core flow is unchanged, and this adjustment is also unaffected by the bi-stable flow characteristic.

0.5: Emerzencv Core Cooling System - Loss-of-Coolant Accident (LOCA) Analysis Q.5.A:

The proposed planer linear heat generation rate (PLHGR)/maximum average planer linear heat generation rate (MAPLHGR) multiplier is based on the LOCA analysis performed at rated conditions ("SAFER/GESTR-LOCA Loss of Coolant Accident Analysis for Pilgrim Nuclear to Letter 2.05.059 Page 8 of 9 Response to NRC Request for Additional Information On Single Loop Operation Power Station," NEDC-31852-P, Rev. 2, January 2003). Is the referenced analysis based on GE14 fuel introduction?

RESPONSE

NEDC-31852-P-Rev. 2 was performed to correct accumulated 10 CFR 50.46 errors. This was not the GE14 fuel introduction analysis. The GE14 fuel introduction analysis was in GE-NE-J1 103808-08-02P, "Pilgrim Nuclear Power Station ECCS-LOCA Evaluation for GE14", February 2001 (Reference 10). The current analysis of record is NEDC-31852-P-Rev. 3 (Reference 11),

which is a complete SAFERIGESTR analysis that corrects all accumulated errors.

There are no outstanding 10 CFR 50.46 error corrections.

O.5.B:

Reference the NRC-approved licensing document or amendment to GESTAR II that accepted developing PLHGR/MAPLHGR multipliers that would result in a peak clad temperature (PCT) that is the same as the two-loop PCT, instead of performing a separate SLO LOCA analysis that establishes an SLO MAPLHGR.

RESPONSE

Pilgrim has analyzed PCT for SLO using a multiplier of 0.8 and calculated an Appendix K SLO PCT of 1823 'F for GE14 and 1837 0 F for GEl 1. The calculated Appendix K TLO PCT is 2147 0F for GE14 and 2117 'F for GEl 1. This is identified in Table 5-4 of NEDC-31852-P, Rev. 3 (Reference 11) which utilized the NRC approved methodology defined in Reference 15.

SLO PCT is therefore bounded by TLO PCT. The MAPLHGR limits calculated for TLO with a multiplier of 0.8 are therefore (used conservatively as) SLO MAPLHGR limits.

O.5.C:

The submittal states that using the 0.8 PLHGR/MAPLHGR multipliers with the Appendix K assumptions yields PCT values that are well below the Title 10 of the Code of Federal Regulations (10 CFR) Section 50.46 PCT limit of 2200'F. Please state what these PCT values are for all calculated statepoints (sic) in the licensed maximum extended load line limit analysis domain. Include all applicable increases to the PCT that were performed based on 10 CFR 50.44 reports (<50 degrees).

RESPONSE

Pilgrim has analyzed PCT for SLO using a multiplier of 0.8 and calculated an Appendix K PCT of 1823 'F for GE14 and 18370 F for GEl 1. The calculated Appendix K TLO PCT is 2147 0F for GE14 and 2117 0F for GE1 1. This is identified in Table 5-4 of NEDC-31852 Rev. 3 (Reference 11). There are no outstanding 10 CFR 50.46 errors.

REFERENCES:

1. NEDO-32465-A, "Reactor stability Detect and Suppress Solutions Licensing Basis Methodology for Reload Applications," August 1996.

2. GE-NE-0000-0033-6871-01, Revision 0, "Pilgrim Option l-D APRM Flow Biased Setpoints," October 2004.

3. GE Report MDE 47-0385, DRF A0O- 1713, Rev. 1, "Safety Evaluation of a Recirculation System Flow Anomaly at Pilgrim Station," dated November 1985.

to Letter 2.05.059 Page 9 of 9 Response to NRC Request for Additional Infornation On Single Loop Operation

5. NEDC-33155P, Revisidn 0, DRF-0000-0029-7457, "Application of Long-Term Solution Option 1-D to Pilgrim Nuclear Power Station," October 2004.

6. GE-NE-0000-0027-5301, Revision 1, DRF 0000-0027-4472, Pilgrim Station Single Loop Operation," July 2004.

7. NEDO-10958-A, "General Electric BWR Thermal Analysis Basis (GETAB) Data Correlation and Design Application," January 1977.

8. DRF-J1 1-03808-07, "Pilgrim R13/C14 SLO-Pump Seizure Analysis," September 2000.

9. NEDC-31312-P, "ARTS Improvement Program Analysis for Pilgrim Nuclear Power Station," September 1987.

10. GE-NE-J I103808-08-02P, "Pilgrim Nuclear Power Station ECCS-LOCA Evaluation for GE14," February 2001.

11. NEDC-31852-P-Rev. 3, DRF 0000-0006-2042, "SAFER/GESTR-LOCA, Loss of Coolant Accident Analysis for Pilgrim Nuclear Power Station:' February 2005.

12. GE-NE-0000-0035-9029-RO, eDRF 0000-0035-8621, "Option 1-D Reload Stability Analysis for Pilgrim Cycle 16," February 2005.

13. NEDC-32992P-A, Licensing Topical Report "ODYSY Application for Stability Licensing Calculations," July 2001.

14. GE Report 0000-0008-6613, "Supplemental Reload Licensing Report for Reload 14/

Cycle 15," Rev. 2, November 2004.

15. NEDE-23785-1-P-A, "GESTR-LOCA and SAFER Models for the Evaluation of the Loss-of-Coolant Accident, Volume Iml, SAFERIGESTR Application Methodology," Rev.

1, October 1984.

16. NRC Information Notice 86-110, "Anomalous Behavior of Recirculation Loop Flow in Jet Pump BWR Plants," December 31, 1986.