ML071900121

E-MAIL: (NPA-PD) LRA Amendment 18

ML071900121
Person / Time
Site:	Pilgrim
Issue date:	06/21/2007
From:	Edwards S Entergy Nuclear Generation Co
To:	Perry Buckberg NRC/NRR/ADRO/DLR/RLRA
References
2.07.060, TAC MD3698
Download: ML071900121 (5)

Text

li it Perry BuckberQ - LRA Amendment 18 Pa-e 1ie From: "Sanchez, Edward" <esanchl @entergy.com>

To: "Perry Buckberg" <PHB1@nrc.gov>

Date: 6/21/2007 1:33:33 PM

Subject:

LRA Amendment 18 Perry, Attached is a PDF copy of the LRA Amendment 18 letter.

Ed Sanchez Pilgrim Licensing

11c-\tern-p\GW)00002-I c:\temp\GWIQOOO2.TMP Page 1i II Page Mail Envelope Properties (467AB657.122 : 3 : 33058)

Subject:

LRA Amendment 18 Creation Date 6/21/2007 1:32:52 PM From: "Sanchez, Edward" <esanch 1@entergy.com>

Created By: esanch1@entergy.com Recipients nrc.gov OWGWPO01 .HQGWDO01 PHB 1 (Perry Buckberg)

Post Office Route OWGWPO01 .HQGWDO01 nrc.gov Files Size Date & Time MESSAGE 94 6/21/2007 1:32:52 PM 207060.pdf 233144 Mime.822 321385 Options Expiration Date: None Priority: Standard ReplyRequested: No Return Notification: None Concealed

Subject:

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`Ent&W 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

REFERENCES:

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 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, Ste en J. ea Director, Nuclear Safety Assessment ERS/dI Attachment A: Response to SER Open Item 3.0.3.2.10

Entergy Nuclear Operations, Inc. Letter Number: 2.07.060 Pilgrim Nuclear Power Station Page 2 cc: with Attachments Mr. Perry Buckberg Mr. Joseph Rogers Project Manager Commonwealth of Massachusetts Office of Nuclear Reactor Regulation Assistant Attorney General U.S. Nuclear Regulatory Commission Division Chief, Utilities Division Washington, DC 20555-0001 1 Ashburton Place Boston, MA 02108 Alicia Williamson Mr. Matthew Brock, Esq.

Project Manager Commonwealth of Massachusetts Office of Nuclear Reactor Regulation Assistant Attorney General U.S. Nuclear Regulatory Commission Environmental Protection Division Washington, DC 20555-0001 One Ashburton Place Boston, MA 02108 Susan L. Uttal, Esq. Diane Curran, Esq.

Office of the General Counsel Harmon, Curran, and Eisenberg, L.L.P.

U.S. Nuclear Regulatory Commission 1726 M Street N.W., Suite 600 Mail Stop 0-15 D21 Washington, DC 20036 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 Mr. Robert Walker, Director Office of Nuclear Reactor Regulation Massachusetts Department of Public Health U.S. Nuclear Regulatory Commission Radiation Control Program Washington, DC 20555-0001 Schrafft Center, Suite 1M2A 529 Main Street Charlestown, MA 02129 Mr. Jack Strosnider, Director Mr. Ken McBride, Director Office of Nuclear Material and Safeguards Massachusetts Emergency Management Agency U.S. Nuclear Regulatory Commission 400 Worchester Road Washington, DC 20555-00001 Framingham, MA 01702 Mr. Samuel J. Collins, Administrator Mr. James E. Dyer, Director Region I Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 475 Allendale Road Washington, DC 20555-00001 King of Prussia, PA 19406 NRC Resident Inspector Pilgrim Nuclear Power Station

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 Program)

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-1801 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 aGccseible fire barrier penetration seals being inspected at least once every five operating cycles.