ML062900231

2006/11/02-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, 2006Mr. Michael KanslerPresident Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601-1839

SUBJECT:

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

Dear Mr. Kansler:

By letter dated January 25, 2006, Entergy Nuclear Operations, Inc. submitted an applicationpursuant to 10 CFR Part 54, to renew the operating license for Pilgrim Nuclear Power Stationfor 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 agreeabledate 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 ManagerLicense Renewal Branch A Division of License Renewal Office of Nuclear Reactor RegulationDocket No. 50-293

Enclosure:

As Statedcc w/encl: See next page

ML062900231OFFICEPM:RLRA:DLRPM:RLRC:DLRLA:DLROGCBC:REBB:DLRNAMEPBuckbergJDavisS. FigueroaUttalLLund DATE10/20/0610/19/0610/18/0611/2/0610/19/06 Letter to Michael Kansler from Perry Buckberg dated: November 2, 2006

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THEPILGRIM NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION (TAC MC9669)HARD COPYDLR R/FE-MAIL: JFairRWeisman AMurphy RPettis GGalletti DShum GBagchi SSmith (srs3)

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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 IU. S. Nuclear Regulatory Commission

475 Allendale Road King of Prussia, PA 19406-1415Senior Resident InspectorU. S. Nuclear Regulatory Commission Pilgrim Nuclear Power Station Post Office Box 867 Plymouth, MA 02360Chairman, Board of Selectmen11 Lincoln Street Plymouth, MA 02360ChairmanNuclear Matters Committee Town Hall 11 Lincoln Street Plymouth, MA 02360Chairman, Duxbury Board of SelectmenTown Hall 878 Tremont Street Duxbury, MA 02332Office of the CommissionerMassachusetts Department of Environmental Protection One Winter Street Boston, MA 02108Office of the Attorney GeneralOne Ashburton Place 20th Floor Boston, MA 02108MA Department of Public HealthRadiation Control Program Schrafft Center, Suite 1M2A 529 Main Street Charlestown, MA 02129Secretary of Public SafetyExecutive Office of Public Safety One Ashburton Place Boston, MA 02108 Director, Massachusetts Emergency Management Agency Attn: James Muckerheide 400 Worcester Road Framingham, MA 01702-5399Mr. William D. MeinertNuclear Engineer Massachusetts Municipal Wholesale Electric Company P.O. Box 426 Ludlow, MA 01056-0426Mr. Michael A. BalduzziSite Vice President Entergy Nuclear Operations, Inc.

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

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

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

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

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

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

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

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

440 Hamilton Avenue White Plains, NY 10601Mr. Michael D. Lyster5931 Barclay Lane Naples, FL 34110-7306Mr. Michael J. ColombDirector of Oversight Entergy Nuclear Operations, Inc.

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

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

639 Loyola Avenue New Orleans, LA 70113Mr. James Sniezek5486 Nithsdale Drive Salisbury, MD 21801Mr. Travis C. McCulloughAssistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. James RossNuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708Plymouth Public LibraryAttn: Dinah O'Brien 132 South Street Plymouth, MA 02360Duxbury Free LibraryATTN: Ms. Elaine Winquist 77 Alden Street Duxbury, MA 02332

Kingston Public Library ATTN: Reference Librarian 6 Green Street Kingston, MA 02364Ms. Mary LampertDuxbury Nuclear Advisory, Chair Pilgrim Watch, Director 148 Washington Street Duxbury, MA 02332Mr. Garrett D. Edwards814 Waverly Road Kennett Square, PA 19348 ENCLOSUREREQUESTS FOR ADDITIONAL INFORMATION (RAIs)PILGRIM NUCLEAR POWER STATIONLICENSE RENEWAL APPLICATION SECTIONS 3.6 ELECTRICAL AND INSTRUMENTATION AND CONTROLS3.6 Electrical and Instrumentation and Controls RAI 3.6.2-1In RAI 3.6.2-1, by letter dated August 14, 2006, the staff requested the applicant to provide abasis 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 cableconnections 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 withthe 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 staff's 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 Commissionformulated 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 ofsafety 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, ofcomponents 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. ENCLOSURETherefore, 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.