ML063070332

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Fax: from: Ram Subbaratnam to: Brian Ford/ Fred Mogolesko 8/02/2006 Supplement 3
ML063070332
Person / Time
Site: Pilgrim
Issue date: 08/02/2006
From: Subbaratnam R
Office of New Reactors
To: Ford B, Mogolesko F
Entergy Nuclear Operations
References
%dam200612, TAC MD2296
Download: ML063070332 (12)
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                            • -COMM. JOURNAL- DATE AUG-02-2006 ***** TIME 10:*57*****

MODE = MEMORY TRANSMISSION START=AUG-02 10:55 END=AUG-02 10:57 FILE NO.=597 STN COMM. ONE-TOUCH/ STATION NAME/TEL NO. PAGES DURATION NO. ABBR NO. 001 OK a 915088308855 011/011 00:02:17. NRC FORM 386 U.S. NUCLEAR REGULATORY COMMISSION AS *eu DATE 08/0212006 TELECOPIER TRANSMITTAL TIME TO NAME TELEPHONE Brian Ford/Fred Mogolesko 508-830-4403 NAME AND LOCATION OF COMPANY (If other Mhan NRO) PNPS Plymouth, MA TELECOPY NUMBER VERIFICATION NUMBER 508-830-8855 FROM NAME TELEPHONE MAIL STOP Ram Subbaratnam 301-415-1478 0-1lFI TELECOPY DATA NUMBER OF PAGES PRIORITY []IMMEDIATE THIS PAGE + 10 PAGES = 1 TOTALOTE (Specify) SPECIAL INSTRUCTIONS 11ý lcfrCt On NRC ORM3861300E1PRINED N RCYCED APE NRCFORM3N6(3-=40,) PR.INTED ONRECYLED PAPFR

TO Brian Ford/Fred NAME AND LOCATION OF COMPANY (If other than NRC) PNPS Plymouth, MA 508-830-8855 FROM TELECOPY DATA PRIORITY 

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08/02/06 NRC Audit Team Tracking Form for Metal Fatigue TLAA Review Audit Brief Description of the Date Q&A Brief Description of the Status: Basis for Status: Team Issue Raised in Audit Team Database Applicant's Response to the Question # Question Response Audit Team Question 503 TLAA - AMR reconciliation Q&A The project team has only El Open Draft Joint question for Class 1 response: received a draft response at this

  • Accepted Response has (Medoff) components designed to To be point. 11 Closed been accepted Section III requirements received n Supp. LRA but not docketed (TBR) Draft joint (consolidated) Amend. in Q&A database.

response to Questions 503, 0 Supp. LRA Awaiting LRA LRA 504, 505, and 506 will require Commit. amendments of Amend: amendment of the Fatigue El Update FSAR applicable AMR TBR AMRs in LRA Tables 3.1.2-1, Supplement line items 3.1.2-2, and 3.1.2-3. Need-to eliminate first paragraph of Draft resp:. 504 TLAA - AMR reconciliation See Column entry for Question 503 0l Open Column entry for question for Class 1 Column is applicable.

  • Accepted Question 503 is (Medoff) components designed to Entry for El Closed applicable.

B31.1 requirements 503

  • Supp. LRA Amend.

El Supp. LRA Commit. El Update FSAR Supplement 505 TLAA - AMR reconciliation See Column entry for Question 503 El Open Column entry for question for Class 1 Column is applicable.

  • Accepted Question 503 (Medoff) components designed to Entry for [] Closed is applicable.

design codes other than 503

  • Supp. LRA Section III or B31.1 Amend.

requirements El Supp. LRA Commit. El Update FSAR Supplement

Audit Team Tracking Form Audit Brief Description of the Date Q&A Brief Description of the Status: Basis for Status: Team Issue Raised in Audit Team Database/ Applicant's Response to the Question # Question Other Audit Team Question Responses 506 TLAA - AMR reconciliation TBR Column entry for Question 503 0 Open Column entry for question for Non-Class 1 is applicable.

  • Accepted Question 503 (Medoff) components 0:1 Closed is applicable.

U Supp. LRA Amend. El Supp. LRA Commit. El Update FSAR _Supplement 507 RPV Internal Clarification Q&A Response was acceptable to 0l Open Question response: clarify that only the shroud tie 0 Accepted (Medoff) 7/5/2006 rods received CUF calcs and to U Closed propose deletion of a confusing 0 Supp. LRA LRA clause in the LRA text. Amend. Amend: 01 Supp. LRA 7/19/2006 LRA was amended to deleted Commit. the conflicting clause from the [- Update FSAR RPV Internal discussion text. Supplement 508 Question asked which Initial Initial response clarified that 0 Open Awaiting fracture mechanics and Response: three flaw evaluations had 01 Accepted amended (Medoff) flaw evaluations were 07/05/2006 potential to be TLAAs: (1) CRD

  • Closed response. Work TLAAs for the PNPS LRA. nozzle cap weld, (2) recirc 01 Supp. LRA request to send Amended thermal sleeves, and (3) recirc Amend. amended Response: N2F nozzle but did not meet 0l Supp. LRA response to DCI TBR definition for TLAAs. Amend. Commit. for review.

response to provide bases why. 01 Update FSAR Closed to RAI. I _ I_ I_ I Supplement 1 TBR: to be received.

Audit Team Tracking Form Audit Brief Description of the Date Q&A Brief Description of the Status: Basis for Status: Team Issue Raised in Audit Team Database Applicant's Response to the Question # Question Response Audit Team Question 515 Critical question on why Init. Resp. Amended draft response was to E1 Open 1. Accepted but the applicant had not 7/5/2006. indicate that the applicant was m Accepted awaiting)re"6d-sd (Medoff) performed updated 60-year committing to perform updated 0] Closed rre-sponse CUF calculations when Amend 60-year CUF calcs (including

  • Supp. LRA containing final over half the transients are Resp: TBR critical Fen impacts) for the RRS Amend. changes to projected to exceed their piping and either updated calcs,
  • Supp. LRA Comms #31 and maximum allowables inspections or repair/replacment Commit. #35 as basis for before the expiration fo the for RPV components.
  • Update FSAR closing o-uTT A PEO. Supplement
2. LRA and FSAR Supp need updating to include Commits.

517 Reconciliation Question to N/A 0 Open Need for resolve differences 0 Accepted Question was (Medoff) between 40-year CUF m Closed eliminated during values provided in TLA 0 Supp. LRA second TLAA Table 4.3-1 and those listed Amend. Audit of in Class 1 design basis 0 Supp. LRA July 17-19, 2006. CUF calcuations Commit. Issue is closed. 0 Update FSAR Supplement 341 Question on whether the Q&A: Response provides basis why E0 Open Basis accepted cranes for PNPS should be 7/5/2006 cranes do not need to be within 11 Accepted because unlike (Patel) TLAAs for the LRA the scope of TLAAs

  • Closed Brunswick and o Supp. LRA Browns Ferry, Note: Cranes were not TLAAs Amend. Pilgrim RB for Nine Mile Point but were for 0 Supp. LRA Cranes are Brunswick and Browns Ferry Commit. Seismic Cat II -

LRA. Cranes at Brunswick and 01 Update FSAR no CMAA-70 Browns Ferry were Seismic Supplement analysis was Category I. performed. Note: Ken Chang would like to see minor revisions of Commitments 31 and 35.

Audit Team Tracking Form Audit Brief Description of the Date Q&A Brief Description of the Status: Basis for Status: Team Issue Raised in Audit Team Database Applicant's Response to the Question # Question Response Audit Team Question 342 Question requested the Q&A Response to Question provided 0 Open Response was basis for CUF exclusions in 7/5/2006 definitive valid ASME Code

  • Accepted accepted but (Patel) LRA Table 4.3-1 exclusion paragraphs for those C Closed requires an LRA components in LRA Table 4.3-1 m Supp. LRA amendment of Amend: that were excluded from CUF Amend. the LRA.

TBR calculations 0 Supp. LRA July 19, 2006 Commit. Letter does not 11 Update FSAR include LRA Supplement amendment for this question 343 Question asked for Q&A Response provide basis for 11 Open LRA amendment clarification on how 7/5/2006 removing Fen impacted CUFs 0 Accepted received on environmental-fatigue from Table 4.3-3 for three

  • Closed 7/19/06.

analysis are done for Class LRA component locations

  • Supp. LRA 1 components designed to Amend: Amend.

B31.1. TBR C Supp. LRA Commit. El Update FSAR Supplement 344 Question raised the issue Q&A Response provided a basis why C1 Open Commitments why cycle counting alone 7/5/2006 cycle counting alone was m Accepted #31 and #35 would ensure the adequacy sufficient. Improved C Closed appear to require of the Section III LRA Commitments #31 and #35 are 0 Supp. LRA a revised Q&A components evaluated by Amend: now being used as the basis for Amend. response and CUF assessments TBR TLAA acceptance in lieu of C Supp. LRA LRA amendment cycle counting. Staff is Commit. in that they are accepting new Commitments as ECUpdate FSAR relied on for the basis for TLAA acceptance. Supplement acceptance. Therefore, its appears the Current response to Question 344 in the responses July 5, 2006 letter is outdated appear to conflict and needs to be revised and with new updated. commitments

A"HJrit Tanm T fýnlein Pnrm Audit Brief Description of the Date Q&A Brief Description of the Status: Basis for Status: Team issue Raised in Audit Team Database Applicant's Response to the Question # Question Response Audit Team Question 345 Informed applicant that the Q&A Response ties to the revised 11 Open LRA amendment CUF value for the 7/5/2006 Commitment #35. 0l Accepted received in feedwater nozzle was

  • Closed 7/19/06 letter.

inaccurate and requested a LRA , Supp. LRA Q&A response new 60-year calculations Amend: Amend. reflects the newly TBR [] Supp. LRA revised Commit. Commitment #35 El Update FSAR and is Supplement acceptable. Closed. 346 and Ask for clarification on how Q&A Response to Question 346 ties 0l Open LRA 347 the environmental CUF 7/5/2006 to the revised Commitment #31 El Accepted amendments to values for critical Class 1 n Closed these questions components were LRA Response to 347 proposes n Supp. LRA received in calculated Amend: minor adjustements of LRA Amend. 7/19/06 letter. 07/19/2006 Table 4.3-3 El Supp. LRA Q&A response to Commit. 346 reflects the LRA amendments for these El Update FSAR newly revised questions received in the July Supplement Commitment #31 19, 2006 letter. and is acceptable. Closed. 425 Requested information why Q&A Response was tied to response s Open Still open CUF values in LRA Table 7/5/2006 to Question 345. The response El Accepted according to the 4.3-1 did not reflect indicates that LRA Table 4.3-1 El Closed July 5, 2006 Q&A Thermal Power LRA will be updated to provide the n Supp. LRA Database. ptimization impacts in a Amend: CUF values from the thermal Amend. However, the E report used for the TBR optimization report for pertinent El Supp. LRA response to 425 pNPS design basis. components and thus requires a Commit. should reflect I LRA amendment. This license El Update FSAR new amendment was not included in Supplement Commitments the July 19, 2006 letter. #31 and 35. Awaiting LRA 

               -J __________________         ________                                                   amendment.

Audit Team Tracking Form Audit Brief Description of the Date Q&A Brief Description of the Status: Basis for Status: Team Issue Raised in Audit Team Database Applicant's Response to the Question # Question Response Audit Team Question 426 and Questions on metal fatigue Q&A Responses informed staff that El Open Response to 426 427 evaluations for emergency 7/5/2006 the TLAAs for EDG expansion m Accepted-426 was accepted. diesel expansion bellows bellows were done to B31.1 a Closed-427 requirements are valid for PEO. El Supp. LRA Response to 427 Amend. was closed. El Supp. LRA Commit. El Update FSAR Supplement No Consistent with what was During followup audit, project 11 Open Anticipating that Question done for Vermont Yankee - team informed PNPS that the 0l Accepted the next Yearly but Removal of BWRVIP-48 generic analyses only had to be El Closed LRA Update will Pertains to and BWRVIP generic TLAAs if there was a U Supp. LRA remove these the next fatigue analyses as TLAAs correspodnding plant-specific Amend. generic analyses LRA for the PNPS LRA analysis for the RPV interior El Supp. LRA as TLAAs (Refer Update attachment welds and Commit. to LRA Sections instrume'nt penetration nozzles. 13 Update FSAR 4.7.2.2 and This is reflected in the NRC's Supplement 4.7.2.3. This is SEs on the BWRVIP-48 and -49 already reflected Reports. PNPS does not in the draft audit include plant-specific CUF report writeup. analyses for these RPV components. Generic analyses should be sufficient to ensure management of fatigue. El Open El Accepted El Closed El Supp. LRA Amend. 0l Supp. LRA Commit. 0l Update FSAR Supplement

manage1L.: for the EPO, propose an acceptable AMP for the management of the aging effect in accordance with the criterion in 10 CFR 54.21 (c)(1)(iii).

RESPONSE

If no CUF calculation was performed, there is no time-limited aging analysis. Without an analysis, the criterion in 10 CFR 54.21 (c)(1)(iii) cannot apply since this criterion is applied when an analysis cannot be shown valid or projected through the period of extended operation. However, an acceptable AMP to manage the aging effect "cracking-fatigue" is specified under (e the column "Alternate AMP" where applicable for those items without a fatigue analysis. Table 3.1.2-1 is for the reactor vessel. All components in this table are designed to ASME Section III and are included in the reactor vessel fatigue analysis (Altran Technical Report 93177-TR-03, Pilgrim Reactor Vessel Cyclic Load Analyses) in accordance with the 1989 edition of Section III of the ASME code. This analysis specifically calculated CUFs for the limiting locations of the reactor vessel. Although no specific CUFs were calculated for non-limiting reactor vessel locations, these locations are bounded by the limiting locations. Table 3.1.2-1 Reactor Pressure Vessel Component Code Section 4 Alternate AMP Comments All reactor vessel ASME 4.3.1, 4.3.1.1, None - maintain Components with no components listed in Section III 4.3.1.4 for TLAA for reactor calculated CUF are bounded Table 3.1.2-1 main vessel by the limiting components feedwater components. with CUFs fisted in Table nozzles 4.3-1. Section 4.3.1 will be amended to discuss that the TLAA bound these I components. Table 3.1.2-2 is for the reactor vessel internals. The components of the internals that are built to ASME Section III are the welded core support components that were provided by the vessel supplier. Table 3.1.2-2 Reactor Vessel Internals Component Code Section 4 Alternate AMP Comments V(Tý RW Control rod guide N/A N/A BWR Vessel tubes Internals

  • Tube Control rod guide N/A N/A BWR Vessel -v-r -I tubes Internals

- Base Core plate assembly N/A N/A BWR Vessel 9 Plate, beams, Internals alignment assemblies "Alignment bolts/nuts SWedges Core spray lines N/A N/A BWR Vessel Internals -.10r

Entergy Nuclear Operations, Inc. -"'mrg Pilgrim Station 600 Rocky Hill Road Plymouth. MA 02360 July 19, 2006 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 License Renewal Application Amendment 5

REFERENCE:

Entergy letter, License Renewal Application, dated January 25, 2006 (2.06.003) LETTER NUMBER: 2.06.064

Dear Sir or Madam:

In the referenced letter, Entergy Nuclear Operations, Inc. applied for renewal of the Pilgrim Station operating license. During the weeks of May 22, 2006 and June 19, 2006, the NRC performed on-site audits of the License Renewal Application. As a result of these audits, clarifications to the License Renewal Application have been developed and are provided as Attachments B and C to this letter. Attachment A consists of the revised list of regulatory commitments. Attachment B consists of changes to the License Renewal Application. Attachment C consists of the Bolting Integrity Program that is added as a supplement to License Renewal Application Appendix A (UFSAR Supplement) and Appendix B (Aging Management Programs and Activities). Please contact Mr. Bryan Ford, at (508) 830-8403, if you have any questions regarding this subject. I declare under penalty of perjury that the foregoing is true and correct. Executed on July _1_., 2006. Bryan Ford Acting Director, Nuclear Safety Assessment DWElbg / Attachments: (as stated) cc: see next page

0", , a, 

                 #                               COMMITMENT                                 IMPLEMENTATION       SOURCE     Related SCHEDULE                  LRA Section INoJ Comments 31  At least 2 years prior to entering the period of                        June 8, 2012       Letter 4.3.3/ Audit extended operation, for the locations identified in                                      2.06.064 Items 302 &

NUREG/CR-6260 for BWRs of the PNPS vintage, 346 PNPS will implement one or more of the following: June 8, 2010 for (1) Refine the fatigue analyses to determine valid CUFs submitting the less than 1 when accounting for the effects of reactor water aging environment. This includes applying the appropriate Fen management factors to valid CUFs determined in accordance with one of program if PNPS the following: selects the Kso,Eea/rz

1. For locations with existing fatigue analysis valid for the option of period of extended operation, use the existing CUF to managing the 0

determine the environmentally adjusted CUF. affects of aging cyf vw due to

2. ore limiting PNPS-specific locations with a valid CUFo tL'ENR CR-6260-locations' environmentally R epresentative CUF values from other plants, adjusted to assisted fatigue.

or enveloping the PNPS plant specific external loads may be used ifdemonstrated applicable to PNPS.

4. An analysis using an NRC-approved version of the ASME code of NRC-approved alternative (e.g., NRC-approved code case) may be performed to determine a valid CUF.

(2) Manage the effects of aging due. to fatigue at the affected locations by an inspection progra h hab reviewed and approved by the NRC (e.g., ?5e'iodi ic non- - (~e~4~LC dok C\L\ destructive examination of the affected locations at inspection intervals to be determined by a method acceptable to the NRC). (3) Repair or replace the affected locations prior to the period of extended operation and the location exceeding a CUF of 1.0. Should PNPS select the option to manage the aging effects due to environmental-assisted fatigue during the period of extended operation, details of the aging management program such as scope, qualification, method, and frequency will be submitted to the NRC at least 2 years prior to the period of extended operation. 32 Enhance the Bolting Integrity Program in accordance June 8, 2012 Letter Audit items with a license renewal application amendment. 2.06.057 364, 373, 389, 390, 432, 443, & 470 6

COMMITMENT IIMPLEMENTATION" SOURCE Related SCHEDULE LRA Section NoJ Comments 33 PNPS will inspect the inaccessible jet pump thermal As stated in the Letter Audit Item sleeve and core spray thermal sleeve welds if and commitment 2.06.057 488 when the necessary technique and equipment become available and the technique is demonstrated by the vendor, including delivery system. 34 Within the first 6 years of the period of extended June 8, 2018 Letter Audit Item operation and every 12 years thereafter, PNPS will 2406.057 461 inspect the access hole covers with UT methods. Alternatively, PNPS will inspect the access hole covers in accordance with BWRVIP guidelines should such guidance become available.. 35 At least 2 years prior to entering the period of June 8, 2012 Letter Audit Item extended operation, for reactor vessel components, June 8, 2010 for 2.06.064 345 including the feedwater nozzles, PNPS will implement submitting the c.Etcbcuktvi z Lcz one or more of the following: T aging 4A~LL-{ COY~~ ".1 (1) Refine the fatigue analyses to determine valid management CUFs less than 1. Determine valid CUFs based on program if PNPS numbers of transient cycles projected to be valid selects the for the period of. extended operation. Determine option of CUFs in accordance with an NRC-approved managing the version of the ASME. code or NRC-approved alternative (e.g., NRC-approved code case). affects of aging. (2) Manage the effects of aging due to fatigue at the affected locations by an inspection program that has been reviewed and approved by the NR (e.g., periodic non-destructive examination of the affected locations at inspection intervals to be determined by a method acceptable to the NRC). (3) Repair of replace the affected locations prior to the period of extended operation and the location exceeding a CUF of 1.0. Should PNPS select the option to manage the aging effects due to fatigue during the period of extended operation, details of the aging management program such as scope, qualification, method, and frequency will be submitted to the NRC at least 2 years prior to the period of extended operation. 36 To ensure that significant degradation on the bottom June 8, 2012 Letter Audit Item of the condensate storage tank is not occurring, a 2.06.057 363 one-time ultrasonic thickness examination in accessible areas of the bottom of the condensate storage tank will be performed. Standard examination and sampling techniques will be utilized. 7}}

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