ML072190611

License Renewal Application Amendment 19

ML072190611
Person / Time
Site:	Pilgrim
Issue date:	07/30/2007
From:	Bethay S Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML072190611 (15)

Text

En tergy Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Stephen J. Bethay Director, Nuclear Assessment July 30, 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 Amendment 19

REFERENCES:

1. Entergy Letter, License Renewal Application, dated January 25, 2006 (TAC MC9669)2. NRC Request for additional information for review of the Pilgrim License Renewal Application, dated July 26, 2007 LETTER NUMBER: 2.07.064

Dear Sir or Madam:

In Reference 1, Entergy Nuclear Operations, Inc. applied for renewal of the Pilgrim Nuclear Power Station operating license.Attachment A provides a revised listing of regulatory commitments.

Attachment B provides Entergy's response to the request for additional information (RAI) in Reference 2 associated with commitment 31 related to the Pilgrim license renewal application (LRA). Attachment C contains the revision to Commitment 31.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 July 30, 2007.Sincerely, Stephen J. Bethay Director Nuclear Safety Assessment ERS/dI Attachments:

A: Revised List of Regulatory Commitments B: Response to the NRC Request for Additional Information Related to Pilgrim LRA Commitment 31 C: Revision to Pilgrim LRA Commitment 31 AV4 2 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 S. Kim, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission One White Flint North O-8C2 11555 Rockville Pike Rockville, MD 20852 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 Letter Number: 2.07.064 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 Schraft Center, Suite 1 M2A 529 Main Street Charlestown, MA 02129 Mr. Ken McBride, Director Massachusetts Energy Management Agency 400 Worcester Road Framingham, MA 01702 Mr. James E. Dyer, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-00001 NRC Resident Inspector Pilgrim Nuclear Power Station ATTACHMENT A to Letter 2.07.064 (8 pages)Revised List of Regulatory Commitments

"'J 1 -1 ATTACHMENT A to Letter Number 2.07.064 Revised List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document.

Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

Related# COMMITMENT IMPLEMENTATION SOURCE LRA Section SCHEDULE No./Comments 1 Implement the Buried Piping and Tanks Inspection June 8, 2012 Letters B.1.2 / Audit Program as described in LRA Section B.1.2. 2.06.003 Item 320 1_ 2.06.057 2 Enhance the implementing procedure for ASME June 8, 2012 Letters B.1.6 / Audit Section XI Inservice Inspection and testing to specify 2.06.003 Item 320 that the guidelines in Generic Letter 88-01 or 2.06.057 approved BWRVIP-75 shall be considered in determining sample expansion if indications are found in Generic Letter 88-01 welds.3 Inspect fifteen (15) percent of the top guide locations As stated in the Letters B.1.8 / Audit using enhanced visual inspection technique, EVT-1, commitment.

2.06.003 Items 155, within the first 18 years of the period of extended 2.06.057 320 operation, with at least one-third of the inspections to 2.06.064 be completed within the first six (6) years and at least 2.06.081 two-thirds within the first 12 years of the period of extended operations.

Locations selected for examination will be areas that have exceeded the neutron fluence threshold.

4 Enhance the Diesel Fuel Monitoring Program to June 8, 2012 Letters B.1.10 / Audit include quarterly sampling of the security diesel 2.06.003 Items 320, generator fuel storage tank. Particulates (filterable 2.06.057 566 solids), water and sediment checks will be performed 2.06.089 on the samples. Filterable solids acceptance criteria will be = 10 mg/I. Water and sediment acceptance criteria will be = 0.05%.5 Enhance the Diesel Fuel Monitoring Program to June 8, 2012 Letters B.1.10 /Audit install instrumentation to monitor for leakage between 2.06.003 Items 155, the two walls of the security diesel generator fuel 2.06.057 320 storage tank to ensure that significant degradation is not occurring.

6 Enhance the Diesel Fuel Monitoring Program to June 8, 2012 Letters B.1.10 / Audit specify acceptance criterion for UT measurements of 2.06.003 Items 165, emergency diesel generator fuel storage tanks 2.06.057 320 (T-126A&B).

Page 1 of 8

" 1 -ATTACHMENT A to Letter Number 2.07.064 Related# COMMITMENT IMPLEMENTATION SOURCE LRA Section SCHEDULE No,/Comments 7 Enhance Fire Protection Program procedures to state June 8, 2012 Letters B.1.13.1 /that the diesel engine sub-systems (including the fuel 2.06.003 Audit Items supply line) shall be observed while the pump is 2.06.057 320, 378 running. Acceptance criteria will be enhanced to 2.06.064 verify that the diesel engine did not exhibit signs of degradation while it was running; such as fuel oil, lube oil, coolant, or exhaust gas leakage. Also, enhance procedures to clarify that the diesel-driven fire pump engine is inspected for evidence of corrosion in the intake air, turbocharger, and jacket water system components as well as lube oil cooler.The jacket water heat exchanger is inspected for evidence of corrosion or buildup to manage loss of material and fouling on the tubes. Also, the engine exhaust piping and silencer are inspected for evidence of internal corrosion or cracking.8 Enhance the Fire Protection Program procedure for June 8, 2012 Letters B.1.13.1 /Halon system functional testing to state that the 2.06.003 Audit Item Halon 1301 flex hoses shall be replaced if leakage 2.06.057 320 occurs during the system functional test.9 Enhance Fire Water System Program procedures to June 8, 2012 Letters B.1.13.2 /include inspection of hose reels for corrosion.

2.06.003 Audit Item Acceptance criteria will be enhanced to verify no 2.06.057 320 significant corrosion.

10 Enhance the Fire Water System Program to state that June 8, 2012 Letters B.1.13.2/a sample of sprinkler heads will be inspected using 2.06.003 Audit Item guidance of NFPA 25 (2002 Edition) Section 2.06.057 320 5.3.1.1.1.

NFPA 25 also contains guidance to repeat this sampling every 10 years after initial field service testing.11 Enhance the Fire Water System Program to state that June 8, 2012 Letters B.1.13.2 /wall thickness evaluations of fire protection piping will 2.06.003 Audit Item be performed on system components using non- 2.06.057 320 intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion.

These inspections will be performed before the end of the current operating term and at intervals thereafter during the period of extended operation.

Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function.12 Implement the Heat Exchanger Monitoring Program June 8, 2012 Letters B.1.15 / Audit as described in LRA Section B.1.15. 2.06.003 Item 320 2.06.057 Page 2 of 8 ATTACHMENT A to Letter Number 2.07.064 Related# COMMITMENT IMPLEMENTATION SOURCE LRA Section SCHEDULE No./Comments 13 Enhance the Instrument Air Quality Program to June 8, 2012 Letters B.1.17/Audit include a sample point in the standby gas treatment 2.06.003 Item 320 and torus vacuum breaker instrument air subsystem 2.06.057 in addition to the instrument air header sample points.14 Implement the Metal-Enclosed Bus Inspection June 8, 2012 Letters B.1.18 / Audit Program as described in LRA Section B.1.18. 2.06.003 Item 320 2.06.057 15 Implement the Non-EQ Inaccessible Medium-Voltage June 8, 2012 Letters B.1.19/Audit Cable Program as described in LRA Section B.1.19. 2.06.003 items 311, Include developing a formal procedure to inspect 2.06.057 320 manholes for in-scope medium voltage cable.16 Implement the Non-EQ Instrumentation Circuits Test June 8, 2012 Letters B.1.20 / Audit Review Program as described in LRA Section B.1.20. 2.06.003 Item 320 2.06.057 17 Implement the Non-EQ Insulated Cables and June 8, 2012 Letters B.1.21 / Audit Connections Program as described in LRA Section 2.06.003 Item 320 B.1.21. 2.06.057 18 Enhance the Oil Analysis Program to periodically June 8, 2012 Letters B.1.22 / Audit change CRD pump lubricating oil. A particle count 2.06.003 Item 320 and check for water will be performed on the drained 2.06.057 oil to detect evidence of abnormal wear rates, contamination by moisture, or excessive corrosion.

19 Enhance Oil Analysis Program procedures for June 8, 2012 Letters B.1.22 / Audit security diesel and reactor water cleanup pump oil 2.06.003 Item 320 changes to obtain oil samples from the drained oil. 2.06.057 Procedures for lubricating oil analysis will be enhanced to specify that a particle count and check for water are performed on oil samples from the fire water pump diesel, security diesel, and reactor water cleanup pumps.20 Implement the One-Time Inspection Program as June 8, 2012 Letters B.1.23 / Audit described in LRA Section B.1.23. 2.06.003 Items 219, 2.06.057 320 2.07.023 21 Enhance the Periodic Surveillance and Preventive June 8, 2012 Letters B.1.24 / Audit Maintenance Program as necessary to assure that 2.06.003 Item 320 the effects of aging will be managed as described in 2.06.057 LRA Section B.1.24.22 Enhance the Reactor Vessel Surveillance Program to June 8, 2012 Letters B.1.26 / Audit proceduralize the data analysis, acceptance criteria, 2.06.003 Item 320 and corrective actions described in LRA Section 2.06.057 B.1.26.Page 3 of 8 ATTACHMENT A to Letter Number 2.07.064 Related# COMMITMENT IMPLEMENTATION SOURCE LRA Section SCHEDULE No./Comments 23 Implement the Selective Leaching Program in June 8, 2012 Letters B.1.27/Audit accordance with the program as described in LRA 2.06.003 Item 320 Section B.1.27. 2.06.057 24 Enhance the Service Water Integrity Program June 8, 2012 Letters B.1.28 / Audit procedure to clarify that heat transfer test results are 2.06.003 Item 320 trended. 2.06.057 25 Enhance the Structures Monitoring Program June 8, 2012 Letters B.1.29.2/procedure to clarify that the discharge structure, 2.06.003 Audit Items security diesel generator building, trenches, valve 2.06.057 238, 320 pits, manholes, duct banks, underground fuel oil tank foundations, manway seals and gaskets, hatch seals and gaskets, underwater concrete in the intake structure, and crane rails and girders are included in the program. In addition, the Structures Monitoring Program will be revised to require opportunistic inspections of inaccessible concrete areas when they become accessible.

26 Enhance Structures Monitoring Program guidance for June 8, 2012 Letters B.1.29.2 /performing structural examinations of elastomers 2.06.003 Audit Item (seals, gaskets, seismic joint filler, and roof 2.06.057 320 elastomers) to identify cracking and change in material properties.

27 Enhance the Water Control Structures Monitoring June 8, 2012 Letters B.1.29.3 /Program scope to include the east breakwater, jetties, 2.06.003 Audit Item and onshore revetments in addition to the main 2.06.057 320 breakwater.

28 Enhance System Walkdown Program guidance June 8, 2012 Letters B.1.30 / Audit documents to perform periodic system engineer 2.06.003 Items 320, inspections of systems in scope and subject to aging 2.06.057 327 management review for license renewal in accordance with 10 CFR 54.4(a)(1) and (a)(3).Inspections shall include areas surrounding the subject systems to identify hazards to those systems.Inspections of nearby systems that could impact the subject systems will include SSCs that are in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4(a)(2).

29 Implement the Thermal Aging and Neutron Irradiation June 8, 2012 Letters B.1.31 / Audit Embrittlement of Cast Austenitic Stainless Steel 2.06.003 Items 257, (CASS) Program as described in LRA Section B.1.31. 2.06.057 320 Page 4 of 8 ATTACHMENT A to Letter Number 2.07.064 Related# COMMITMENT IMPLEMENTATION SOURCE LRA Section SCHEDULE No./Comments 30 Perform a code repair of the CRD return line nozzle June 30, 2015 Letter B.1.3 / Audit to cap weld if the installed weld repair is not approved 2.06.057 Items 141, via accepted code cases, revised codes, or an 320 approved relief request for subsequent inspection intervals.

31 At least 2 years prior to entering the period of extended operation, for the locations identified in NUREG/CR-6260 for BWRs of the PNPS vintage, PNPS will refine our current fatigue analyses to include the effects of reactor water environment and verify that the cumulative usage factors (CUFs) are less than 1. This includes applying the appropriate Fen factors to valid CUFs determined in accordance with one of the following:

1. For locations, including NUREG/CR-6260 locations, with existing fatigue analysis valid for the period of extended operation, use the existing CUF to determine the environmentally adjusted CUF.2. More limiting PNPS-specific locations with a valid CUF may be added in addition to the NUREG/CR-6260 locations.

3. Representative CUF values from other plants, adjusted to or enveloping the PNPS plant specific external loads may be used if demonstrated applicable to PNPS.4. An analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case) may be performed to determine a valid CUF.During the period of extended operation, PNPS may also use one of the following options for fatigue management if ongoing monitoring indicates a potential for a condition outside the analysis bounds noted above: 1. Update and/or refine the affected analyses described above.2. Implement an inspection program that has been reviewed and approved by the NRC (e.g., periodic nondestructive 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 before exceeding a CUF of 1.0.June 8, 2012 June 8, 2010 for submitting the aging manage-ment program if PNPS selects the option of managing the affects of aging due to environ-mentally assisted fatigue.Letters 2.06.057 2.06.064 2.06.081 2.07.005 2.07.064 4.3.3 / Audit Items 302, 346 32 Implement the enhanced Bolting Integrity Program June 8, 2012 Letters Audit items described in Attachment C of Pilgrim License 2.06.057 364, 373, Renewal Application Amendment 5 (Letter 2.06.064).

2.06.064 389, 390, 2.06.081 432, 443, 470 Page 5 of 8 ATTACHMENT A to Letter Number 2.07.064 Related# COMMITMENT IMPLEMENTATION SOURCE LRA Section SCHEDULE No./Comments 33 PNPS will inspect the inaccessible jet pump thermal As stated inthe Letter Audit Items sleeve and core spray thermal sleeve welds if and commitment.

2.06.057 320, 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 Letters Audit Items operation and every 12 years thereafter, PNPS will 2.06.057 320, 461 inspect the access hole covers with UT methods. 2.06.089 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 Letters Audit Item extended operation, for reactor vessel components, June 8, 2010 for 2.06.057 345 including the feedwater nozzles, PNPS will implement submitting the 2.06.064 one or more of the following:

aging manage- 2.06.081 (1) Refine the fatigue analyses to determine valid ment program if CUFs less than 1. Determine valid CUFs based on PNPS selects numbers of transient cycles projected to be valid the option of for the period of extended operation.

Determine managing the CUFs in accordance with an NRC-approved affects of aging.version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case).(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 NRC (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 before 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 Items of the condensate storage tank is not occurring, a 2.06.057 320, 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.Page 6 of 8 1 .0 .%1 ATTACHMENT A to Letter Number 2.07.064 Related# COMMITMENT IMPLEMENTATION SOURCE LRA Section SCHEDULE No./Comments 37 The BWR Vessel Internals Program includes June 8, 2012 Letter A.2.1.8/inspections of the steam dryer. Inspections of the 2.06.089 Conference steam dryer will follow the guidelines of BWRVIP-139 call on and General Electric SIL 644 Rev. 1. September 25, 2006 38 Enhance the Diesel Fuel Monitoring Program to June 8, 2012 Letter B.1.10/Audit include periodic ultrasonic thickness measurement of 2.06.089 Item 565 the bottom surface of the diesel fire pump day tank.The first ultrasonic inspection of the bottom surface of the diesel fire pump day tank will occur prior to the period of extended operation, following engineering analysis to determine acceptance criteria and test locations.

Subsequent test intervals will be determined based on the first inspection results.39 Perform a one-time inspection of the Main Stack June 8, 2012 Letter B.1.23 / Audit foundation prior to the period.of extended operation.

2.06.094 Item 581 40 Enhance the Oil Analysis Program by documenting June 8, 2012 Letter B.1.22 / Audit program elements 1 through 7 in controlled 2.06.094 Items 553 and documents.

The program elements will include 589 enhancements identified in the PNPS license renewal application and subsequent amendments to the application.

The program will include periodic sampling for the parameters specified under the Parameters Monitored/Inspected attribute of NUREG-1801 Section XI.M39, Lubricating Oil Analysis.

The controlled documents will specify appropriate acceptance criteria and corrective actions in the event acceptance criteria are not met. The basis for acceptance criteria will be defined.41 Enhance the Containment Inservice Inspection (CII) June 8, 2012 Letter A.2.1.17 and Program to require augmented inspection in 2.06.094 B.1.16.1 accordance with ASME Section XI IWE-1240, of the drywell shell adjacent to the sand cushion following indications of water leakage into the annulus air gap.42 Implement the Bolted Cable Connections Program, June 8, 2012 Letter A.2.1.40 and described in Attachment C of Pilgrim License 2.07.003 B.1.34 Renewal Application 11 (Letter 2.07.003), prior to the period of extended operation.

43 Include within the Structures Monitoring Program June 8, 2012 Letter A.2.1.32 and provisions to ensure groundwater samples are 2.07.005 B.1.29.2 evaluated periodically to assess the aggressiveness of groundwater to concrete, as described in Attachment E of LRA Amendment 12 (Letter 2.07.005), prior to the period of extended operation.

Page 7 of 8 ATTACHMENT A to Letter Number 2.07.064 Related# COMMITMENT IMPLEMENTATION SOURCE LRA Section SCHEDULE No./Comments 44 Perform another set of the UT measurements just As stated in the Letter A.2.1.17 and above and adjacent to the sand cushion region prior commitment.

2.07.010 B.1.16.1 to the period of extended operation and once within the first 10 years of the period of extended operation.

45 If groundwater continues to collect on the torus room As stated in the Letters A.2.1.32 and floor, obtain samples and test such water to commitment.

2.07.010 B.1.29.2 determine its pH and verify the water is non- 2.07.027 aggressive as defined in NUREG-1801 Section Ill.A1 2.07.029 item III.A.1-4 once prior to the period of extended operation and once every five years during the period of extended operation.

46 Inspect the condition of a sample of the torus hold- June 8, 2012 Letter A.2.1.32 and down bolts and associated grout and determine 2.07.027 B.1.29.2 appropriate actions based on the findings prior to the period of extended operation.

47 Submit to the NRC an action plan to improve Sept.15, 2007 Letter 4.2.2, benchmarking data to support approval of new P-T 2.07.027 A.2.2.1.1, curves for Pilgrim. and A.2.2.1.2 48 On or before June 8, 2010, Entergy will submit to the June 8, 2010 Letter 4.2, 4.7.1, NRC calculations consistent with Regulatory 2.07.027 A.1.1 and Guide 1.190 that will demonstrate limiting fluence A.2.2.1 values will not be reached during the period of extended operation.

Page 8 of 8 A ATTACHMENT B to Letter Number 2.07.064 (2 pages)Entergy Response to the NRC Request for Additional Information Related to Pilgrim LRA Commitment 31 A ATTACHMENT B to Letter Number 2.07.064 RAI 4.3.3-1: The license renewal application (LRA) for the Pilgrim Nuclear Power Station listed several reactor coolant pressure boundary components that did not receive a plant-specific metal fatigue analysis and cumulative usage factor (CUF). The applicant generated LRA Commitment No. 31 to address this issue. In the commitment, the applicant committed to take one of the following options or a combination of options to ensure that the time-limited aging analysis (TLAA) on environmentally-assisted fatigue (EAF) of these components, and any other Class 1 components requiring reanalysis for EAF, will be acceptable under 10 CFR 54.21 (c)(1) for the period of extended operation:

Option (1): either refine the existing fatigue analyses or perform new fatigue analyses using at least one of four sub options under this option.Option (2): manage aging by an aging management program for the period of extended operation.

Option (3): repair or replace the impacted component prior to exceeding a CUF of 1.0.In order to make a determination on the acceptability of the applicant's TLAA on EAF under the requirements of 10 CFR 54.21 (c)(1), the staff requests that the applicant provide additional information on the option(s) that will be used for LRA Commitment No. 31. The applicant is requested to describe the methodology that will be used for the chosen option(s) in sufficient detail for staff review. Specifically, the staff requests that: A. If Option (1) is chosen, describe the methodology and the process that will be used to ensure that assumptions, transients, cycles, external loadings, Fen values, and analysis methods are valid for the refined or new fatigue analyses.In the event the refined analyses performed under Option (1) result in CUFs greater than 1.0, describe the option(s) that may be used in addition to Option (1).B. If Option (2) is chosen, describe the AMP in sufficient detail with regard to inspection scope, inspection methods, inspection frequency, and inspection qualification techniques.

C. If Option (3) is chosen, describe how the repair or replacement activity will be implemented in accordance with applicable repair or replacement requirements of the ASME Code Section XI.Page 1 of 2 ATTACHMENT B to Letter Number 2.07.064 RAI 4.3.3-1 Response: Pilgrim Nuclear Power Station (PNPS) intends to comply with Commitment 31 by demonstrating, through the implementation of Option (1), that the cumulative usage factors (CUF) of the most fatigue sensitive locations are less than 1.0 throughout the license renewal period, considering both mechanical and environmental effects. The processes that will be used to develop the calculations for Option (1) are established design and configuration management processes.

These processes are governed by Entergy's 10 CFR 50 Appendix B Quality Assurance (QA) program and include design input verification and independent reviews ensuring that valid assumptions, transients, cycles, external loadings, analysis methods, and environmental fatigue life correction factors will be used in the refined or new fatigue analyses.The analysis methods for determination of stresses and fatigue usage will be in accordance with an NRC endorsed Edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section III Rules for Construction of Nuclear Power Plant Components Division 1 Subsection NB, Class 1 Components, Sub articles NB-3200 or NB-3600 as applicable to the specific component.

PNPS will utilize design transients from PNPS Design Specifications as well as design transient information from typical BWR-3 references to bound all operational transients.

The numbers of cycles used for evaluation will be based on the design number of cycles and actual PNPS cycle counts projected out to the end of the license renewal period (60 years).Environmental effects on fatigue usage will be assessed using methodology consistent with the Generic Aging Lessons Learned Report, NUREG-1 801, Rev. 1, (GALL) that states; "The sample of critical components can be evaluated by applying environmental life correction factors (Fen Methodology) to the existing ASME Code fatigue analyses.

Formulae for calculating the environmental life correction factors are contained in NUREG/CR-6583 for carbon and low-alloy steels and in NUREG/CR-5704 for austenitic stainless steels." The Fatigue Monitoring Program currently tracks actual plant transients and evaluates these against the design transients.

Current cycle counts show no limits are approached or are expected to be approached for the current license term. The Fatigue Monitoring Program will ensure that the numbers of transient cycles experienced by the plant remain within the analyzed numbers of cycles and hence, the component CUFs remain below the values calculated in the design basis fatigue evaluations.

If ongoing monitoring indicates the potential for a condition outside that analyzed above, PNPS may perform further reanalysis of the identified configuration using established configuration management processes as described above.If Option (2) of revised Commitment 31 becomes necessary, the inspection program submitted for approval by the NRC will be described in terms of the ten elements specified in Branch Technical Position RLSB-1 (NUREG-1800, Appendix A-i). Parameters monitored will be the presence and sizing of cracks. Frequency of inspection and acceptance criteria will be established such that detection of aging effects will occur before there is a loss of the component intended function(s).

The method of inspection will be a qualified volumetric technique based on plant-specific and industry-wide operating experience.

If Option (3) becomes necessary, repair or replacement of the affected component(s) will be in accordance with established plant procedures governing repair and replacement activities.

These established procedures are governed by Entergy's 10 CFR 50 Appendix B QA program and meet the applicable repair or replacement requirements of the ASME Code Section XI.Page 2 of 2 ATTACHMENT C to Letter Number 2.07.064 Revision to Pilgrim LRA Commitment 31 As a result of the NRC Request for Additional Information (RAI) in Attachment B to this letter, Entergy hereby revises Commitment

31. This revised commitment is listed in Attachment A to this letter and reads as follows: 31 At least 2 years prior to entering the period of extended operation, for the locations identified in NUREG/CR-6260 for BWRs of the PNPS vintage, PNPS will refine our current fatigue analyses to include the effects of reactor water environment and verify that the cumulative usage factors (CUFs) are less than 1. This includes applying the appropriate Fen factors to valid CUFs determined in accordance with one of the following:

1. For locations, including NUREG/CR-6260 locations, with existing fatigue analysis valid for the period of extended operation, use the existing CUF to determine the environmentally adjusted CUF.2. More limiting PNPS-specific locations with a valid CUF may be added in addition to the NUREG/CR-6260 locations.

3. Representative CUF values from other plants, adjusted to or enveloping the PNPS plant specific external loads may be used if demonstrated applicable to PNPS.4. An analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case) may be performed to determine a valid CUF.During the period of extended operation, PNPS may also use one of the following options for fatigue management if ongoing monitoring indicates a potential for a condition outside the analysis bounds noted above: 1. Update and/or refine the affected analyses described above.2. Implement an inspection program that has been reviewed and approved by the NRC (e.g., periodic nondestructive 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 before exceeding a CUF of 1.0.