ML062900231

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Request for Additional Information for the Review of the Pilgrim Nuclear Power Station License Renewal Application
ML062900231
Person / Time
Site: Pilgrim
Issue date: 11/02/2006
From: Perry Buckberg
NRC/NRR/ADRO/DLR/RLRA
To: Kansler M
Entergy Nuclear Operations
Buckberg, P., PM, RLRA, 415-1383
References
%dam200612, TAC MC9669
Download: ML062900231 (8)


Text

November 2, 2006 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601-1839

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE PILGRIM NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION (TAC MC9669)

Dear Mr. Kansler:

By letter dated January 25, 2006, Entergy Nuclear Operations, Inc. submitted an application pursuant to 10 CFR Part 54, to renew the operating license for Pilgrim Nuclear Power Station for review by the U.S. Nuclear Regulatory Commission (NRC). The NRC staff is reviewing the information contained in the license renewal application (LRA) and has identified, in the enclosure, an area where additional information is needed to complete the review. Specifically, the enclosed request for additional information is from the NRC Project Team that performed the aging management program, aging management review, and time-limited aging analysis (TLAA) audits at PNPS.

This issue was discussed with a member of your staff, Bryan Ford, and a mutually agreeable date for this response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-1383 or e-mail phb1@nrc.gov.

Sincerely,

/RA/

Perry Buckberg, Project Manager License Renewal Branch A Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-293

Enclosure:

As Stated cc w/encl: See next page

ML062900231 OFFICE PM:RLRA:DLR PM:RLRC:DLR LA:DLR OGC BC:REBB:DLR NAME PBuckberg JDavis S. Figueroa Uttal LLund DATE 10/20/06 10/19/06 10/18/06 11/2/06 10/19/06

Letter to Michael Kansler from Perry Buckberg dated: November 2, 2006

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE PILGRIM NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION (TAC MC9669)

HARD COPY DLR R/F E-MAIL:

JFair RWeisman AMurphy RPettis GGalletti DShum GBagchi SSmith (srs3)

SDuraiswamy YL (Renee) Li RidsNrrDlr RidsNrrDlrRlra RidsNrrDlrRlrb RidsNrrDe RidsNrrDci RidsNrreEemb RidsNrrDeEeeb RidsNrrDeEqva RidsNrrDss RidsNrrDnrl RidsOgcMailCenter RidsNrrAdes DLR Staff RSubbaratnam SHoffman SUttal JShea AWilliamson JDavis KChang GWilson CAnderson, Region 1 WRaymond, Region 1 NSheehan, Region 1

Pilgrim Nuclear Power Station cc:

Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Senior Resident Inspector U. S. Nuclear Regulatory Commission Pilgrim Nuclear Power Station Post Office Box 867 Plymouth, MA 02360 Chairman, Board of Selectmen 11 Lincoln Street Plymouth, MA 02360 Chairman Nuclear Matters Committee Town Hall 11 Lincoln Street Plymouth, MA 02360 Chairman, Duxbury Board of Selectmen Town Hall 878 Tremont Street Duxbury, MA 02332 Office of the Commissioner Massachusetts Department of Environmental Protection One Winter Street Boston, MA 02108 Office of the Attorney General One Ashburton Place 20th Floor Boston, MA 02108 MA Department of Public Health Radiation Control Program Schrafft Center, Suite 1M2A 529 Main Street Charlestown, MA 02129 Secretary of Public Safety Executive Office of Public Safety One Ashburton Place Boston, MA 02108 Director, Massachusetts Emergency Management Agency Attn: James Muckerheide 400 Worcester Road Framingham, MA 01702-5399 Mr. William D. Meinert Nuclear Engineer Massachusetts Municipal Wholesale Electric Company P.O. Box 426 Ludlow, MA 01056-0426 Mr. Michael A. Balduzzi Site Vice President Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Mr. Stephen J. Bethay Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Mr. Bryan S. Ford Manager, Licensing Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Mr. Gary J. Taylor Chief Executive Officer Entergy Operations 1340 Echelon Parkway Jackson, MS 39213

Pilgrim Nuclear Power Station cc:

Mr. John T. Herron Sr. VP and Chief Operating Officer Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Oscar Limpias Vice President, Engineering Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Christopher Schwarz Vice President, Operations Support Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. John F. McCann Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Ms. Charlene D. Faison Manager, Licensing Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Michael D. Lyster 5931 Barclay Lane Naples, FL 34110-7306 Mr. Michael J. Colomb Director of Oversight Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Kevin H. Bronson General Manager, Plant Operations Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Ms. Stacey Lousteau Treasury Department Entergy Services, Inc.

639 Loyola Avenue New Orleans, LA 70113 Mr. James Sniezek 5486 Nithsdale Drive Salisbury, MD 21801 Mr. Travis C. McCullough Assistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. James Ross Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 Plymouth Public Library Attn: Dinah OBrien 132 South Street Plymouth, MA 02360 Duxbury Free Library ATTN: Ms. Elaine Winquist 77 Alden Street Duxbury, MA 02332 Kingston Public Library ATTN: Reference Librarian 6 Green Street Kingston, MA 02364 Ms. Mary Lampert Duxbury Nuclear Advisory, Chair Pilgrim Watch, Director 148 Washington Street Duxbury, MA 02332 Mr. Garrett D. Edwards 814 Waverly Road Kennett Square, PA 19348

ENCLOSURE REQUESTS FOR ADDITIONAL INFORMATION (RAIs)

PILGRIM NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION SECTIONS 3.6 ELECTRICAL AND INSTRUMENTATION AND CONTROLS 3.6 Electrical and Instrumentation and Controls RAI 3.6.2-1 In RAI 3.6.2-1, by letter dated August 14, 2006, the staff requested the applicant to provide a basis document including an aging management program (AMP) for cable connections with the 10 elements or provide a justification for why an AMP is not necessary.

In your response, by letter dated September 13, 2006, you stated that electrical cable connections at PNPS are inspected under the maintenance rule program as directed by Entergy procedures and therefore no aging management program (AMP) for license renewal is required at PNPS.

It should be noted that the current licensing bases for all power plants require compliance with the requirements of the maintenance rule 10 CFR 50.65. The Statements of Consideration for the license renewal rule state: The license renewal rule excludes active, short-lived structures and components from an aging management review because of the existing regulatory process, existing licensee programs and activities, and the maintenance rule. The staffs understanding has been that under the license renewal rule, existing programs are not, without some explanation or modification, automatically considered adequate to manage aging effects for license renewal by virtue of being part of the current licensing basis. The Commission formulated the following two principles of license renewal: (1) With the possible exception of the detrimental effects of aging on the functionality of certain plant systems, structures, and components in the period of extended operation and possibly a few other issues related to safety only during extended operation, the regulatory process is adequate to ensure that the licensing bases of all currently operating plants provides and maintains an acceptable level of safety so that operation will not be inimical to public health and safety or common defense and security; and (2) The plant-specific licensing basis must be maintained during the renewal term in the same manner and to the same extent as during the original licensing term.

The 10 CFR 50.24 (a)(3) requires an applicant to demonstrate that the effects of aging, of components such as cable connections defined in 10 CFR 50.24 (a)(1), will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation. To demonstrate that the effects of aging will be adequately managed for license renewal, the staff views that an applicant must identify the program relied upon to manage certain aging effects for cable connections. The aging management program for cable connections acceptable to the staff is provided in GALL AMP XI.E6. This AMP states that the aging management program for electrical cable connections (metallic parts) account for the following stressors: thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation.

ENCLOSURE Therefore, the staff requests that the applicant either provide a plant-specific AMP with the AMP elements found in SRP-LR, Appendix A.1, Section A.1.2.3 and SRP-LR Table A.1-1 or an AMP consistent with GALL AMP XI.E6. If you still insist an AMP is not required, explain in detail how the existing program will address the above aging effects and provide a detailed discussion of how each of the 10 elements of the program as described in the SRP sections mentioned above is met by the current program. Also, provide supporting documentation to show that the aging management program elements including appropriate tests are implemented currently and will be continued for the extended period of operation. Without such information, it is not apparent that the staff will be able to present a basis for concluding that actions have been or will be taken to manage the effects of aging during the period of extended operation to ensure the functionality of those structures and components.