ML071730467

License Renewal Application Amendment 18

ML071730467
Person / Time
Site:	Pilgrim
Issue date:	06/21/2007
From:	Bethay S Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.07.060, TAC MC9669
Download: ML071730467 (3)

Text

IEn-?-vl EntergV Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Stephen J. Bethay Director, Nuclear Assessment June 21, 2007 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 (LRA) Amendment 18 1. Entergy letter, License Renewal Application, dated January 25, 2006 (TAC MC9669)2. Entergy letter, LRA Amendment 5, dated July 19, 2006 3. Entergy letter, LRA Amendment 16, dated May 1, 2007

REFERENCES:

LETTER NUMBER: 2.07.060

Dear Sir or Madam:

In Reference 1 Entergy Nuclear Operations, Inc. (Entergy) applied for renewal of the Pilgrim Station operating license. In Reference 2 Entergy submitted several LRA changes, including one to LRA Appendix B, Section B.1.13.1 (NRC audit item 318). In Reference 3 Entergy submitted an LRA change in response to NRC SER Open Item 3.0.3.2.10 that involved the same LRA section revised by Reference 2, audit item 318. Reference 3 did not reflect the wording changes from Reference 2.Attachment A to this LRA amendment combines the changes from References 2 and 3.There are no new commitments made by this letter.Please contact Mr. Bryan Ford, (508) 830-8403, if you have questions regarding this subject.I declare under penalty of perjury that the foregoing is true and correct. Executed on June 21, 2007.Sincerely, StejenJ.Vethay4 Director, Nuclear Safety Assessment ERS/dI Attachment A: Response to SER Open Item 3.0.3.2.10 Afc~N ,Z Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station cc: with Attachments Mr. Perry Buckberg Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Alicia Williamson Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Susan L. Uttal, Esq.Office of the General Counsel U.S. Nuclear Regulatory Commission Mail Stop 0-15 D21 Washington, DC 20555-0001 Sheila Slocum Hollis, Esq.Duane Morris LLP 1667 K Street N.W., Suite 700 Washington, DC 20006 cc: without Attachments Mr. James Kim Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Mr. Jack Strosnider, Director Office of Nuclear Material and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-00001 Mr. Samuel J. Collins, Administrator Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 NRC Resident Inspector Pilgrim Nuclear Power Station Letter Number: 2.07.060 Page 2 Mr. Joseph Rogers Commonwealth of Massachusetts Assistant Attorney General Division Chief, Utilities Division 1 Ashburton Place Boston, MA 02108 Mr. Matthew Brock, Esq.Commonwealth of Massachusetts Assistant Attorney General Environmental Protection Division One Ashburton Place Boston, MA 02108 Diane Curran, Esq.Harmon, Curran, and Eisenberg, L.L.P.1726 M Street N.W., Suite 600 Washington, DC 20036 Mr. Robert Walker, Director Massachusetts Department of Public Health Radiation Control Program Schrafft Center, Suite 1 M2A 529 Main Street Charlestown, MA 02129 Mr. Ken McBride, Director Massachusetts Emergency Management Agency 400 Worchester Road Framingham, MA 01702 Mr. James E. Dyer, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-00001 ATTACHMENT A to Letter 2.07.060 (1 page)Response to SER Open Item 3.0.3.2.10 01 3.0.3.2.10: (SER Section 3.0.3.2.10

-Fire Protection Pro-gram)The applicant is taking an exception to the GALL Report program element "detection of aging effects," specifically:

The NUREG-1801 program states that approximately 10 percent of each type of penetration seal should be visually inspected at least once every refueling outage. The PNPS program specifies inspection of approximately 20 percent of the seals each operating cycle, with all accessible fire barrier penetration seals being inspected at least once every five operating cycles.The LRA states that, because aging effects typically are manifested over several years, this variation in inspection frequency is insignificant.

GALL AMP XI.M26 specifies approximately 10 percent of each type of seal should be inspected visually at least every refueling outage (two years). The applicant clarified that the program specifies inspection of approximately 20 percent of the seals, including at least one seal of each type, each operating cycle, with all accessible fire barrier penetration seals being inspected at least once every five operating cycles. The applicant needs to address how to manage the aging effect of inaccessible fire barrier penetration seals.01 3.0.3.2.10 Response The PNPS requirement to inspect penetration seals applies to 100% of the seals. The word"accessible" is not necessary in the discussion of the exception for Detection of Aging Effects in the PNPS program. All fire barrier penetration seals are inspected at least once every five operating cycles. In LRA Appendix B, Section B.1.13.1, the word "accessible" is removed resulting in the following description of the exception for Detection of Aging Effects.The NUREG-1 801 program states that approximately 10% of each type of penetration seal should be visually inspected at least once every refueling outage. The PNPS program specifies inspection of approximately 20% of the seals, including at least one seal of each type, each operating cycle, with all aGGe6s'ble fire barrier penetration seals being inspected at least once every five operating cycles.