ML093640058

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License Renewal Application Annual Update
ML093640058
Person / Time
Site: Pilgrim
Issue date: 12/28/2009
From: Bethay S
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
2.09.074, TAC MC9669
Download: ML093640058 (7)


Text

S'En tergy Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Stephen J. Bethay Director, Nuclear Assessment December 28, 2009 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Docket 50-293 License No. DPR-35 Pilgrim Nuclear Power Station License Renewal Application Annual Update (TAC MC9669)

REFERENCE:

Entergy Letter to U.S. NRC, License Renewal Application, dated January 25, 2006 LETTER NUMBER 2.09.074

Dear Sir or Madam:

By the referenced letter, Entergy Nuclear Operations, Inc. (Entergy) submitted the License Renewal Application (LRA) for Pilgrim Nuclear Power Station (PNPS).

Entergy is required by 10 CFR 54.21 (b) to report changes to the current licensing basis (CLB) that materially affect the content of the PNPS LRA, including the Safety Analysis Report (SAR) supplement. In accordance with this requirement, Entergy has completed this review of the CLB.

The changes to the CLB since the last update in 2007 are enclosed. No update for 2008 was submitted to the NRC based on information provided to Entergy by the NRC Office of the General Counsel (OGC).

In October of this year Entergy was notified by the NRC License Renewal Project Manager for Pilgrim Station of the need to submit an update that encompassed 2008 through 2009. This letter provides the requested update.

This letter contains no commitments.

If you have any questions or require additional information, please contact Mr. Joseph R. Lynch, Licensing manager, at (508) 830-8403.

Entergy Nuclear Operations, Inc Letter Number 2.09.074 Pilgrim Nuclear Power Station Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on the "_--Z of December, 2009.

Sincerely, Stephen J. Be a',

MJG/mg

Enclosure:

PNPS License Renewal Changes (4 pages) cc:

Mr. Robert Kuntz 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 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 1 M2A 529 Main Street Charlestown, MA 02129 Sheila Slocum Hollis, Esq. Mr. John Giarrusso Jr.

Duane Morris LLP Nuclear Preparedness Manager, 1667 K Street N.W., Suite 700 Mass. Emergency, Management Agency Washington, DC 20006 400 Worcester Road Framingham, MA 01702 Mr. Michael F. Weber, Director Mr. Eric J. Leeds, Director Office of Nuclear Material and Safeguards Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-00001 Washington, DC 20555-00001 Mr. Samuel J. Collins, Administrator NRC Resident Inspector Region I Pilgrim Nuclear Power Station U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406

Enclosure PNPS License Renewal Changes (4 pages)

PNPS License Renewal Application Changes The review performed as part of the annual update identified the following impacts to the LRA.

(Removals are shown with strikethrough and additions are underlined)

1. LRA Section 2.1.1.1, Application of Safety-Related Scoping Criteria, is revised as follows:

(last paragraph)

"This is the same as 10 CFR 54.4 except that only 10 CFR 100 is cited for dose guidelines. In addition to the guidelines of 10 CFR 100, 10 CFR 54.4(a)(1)(iii) references the dose guidelines of 10 CFR 50.34(a)(1) and 10 CFR 50.67(b)(2).

These guidelines, applicable to facilities seeking a construction permit or facilities which have revised the current accident source term used in their design basis radiological analyses, respectively, are were not applicable to PNPS at the time of the initial submittal of the LRA. PNPS submitted and received approval to use the 10 CFR 50.67 alternate source term for analysis of the fuel handing accident, but this does not change the systems that are within the scope of license renewal."

This change to reflect the use of the 50.67 analysis has no impact on the systems that are in scope and subject to aging management review.

2. Revision to reflect a minor change in the configuration of the nonsafety-related sampling systems at PNPS. A portion of the nonsafety-related crack arrest verification system was removed and replaced with the mitigation monitoring system.

The crack arrest verification system is included in the sampling system in the LRA.

The replacement of the crack arrest verification components with the mitigation monitoring system did not create any additional new component-material-environment-program line items in the tables for the sampling system (Tables 2.3.3-14-30 and 3.3.2-14-30). The change adds a system number to the sampling system entry in Table 2.2-1a and affects the sampling system description in the LRA as follows.

LRA Table 2.2-1a, Mechanical Systems within the Scope of License Renewal, Sampling system line item, is revised as follows.

4, 66, 71,82 Sampling Section 2.3.3.14, Miscellaneous Systems in Scope for (a)(2)

LRA Section 2.3.3.14, Miscellaneous Systems in Scope for (a)(2), description of sampling system is revised as follows.

(first paragraph)

"Sampling systems consists of the process sampling systems, the reactor pressure boundary leak detection system, mitigation monitoring system (MMS),

and the crack arrest verification (CAV) system."

(third paragraph)

"The CAV system monitors water chemistry. It originally receiveed a continuous flow of high temperature reactor water from the sample line connected to the recirculation system. The crack growth monitoring portions of the CAV system have been removed from the plant. The mitigation monitoringq system performs monitoring of tube samples."

209074 Page 1 of 4

PNPS License Renewal Application Changes

3. LRA Section 2.3.3.12, Primary Containment Atmosphere Control, is revised as follows to reflect the deletion of a trailer that was not originally in the scope of license renewal and has no impact on the systems that are in scope and subject to aging management review.

(4 th paragraph Pg 2.3-49)

PCAC uses nitrogen to purge and inert the drywell and suppression chamber.

Nitrogen is supplied from a cryogenic storage tank for normal system operation. -A liquid nitrogcn supply trailcr is available to augmcnt the storago tank during initial containment ffinR-ti-g. Backup nitrogen cylinders are provided for drywell instrumentation. The nitrogen supply subsystem has no intended functions.

4. LRA Section 2.3.3.13, Fuel Pool Cooling and Fuel Handling and Storage Systems, is revised as shown below to identify the addition of Metamic as a neutron absorber material in the spent fuel pools. Both Metamic and Boral are made from aluminum and boron carbide. Metamic is a homogenous variation of Boral without porosity and uses fine, rather than coarse, boron carbide and aluminum particles.

Aging effects for Boral are managed by the Water Chemistry Control - BWR Program which was found acceptable by the staff in section 3.3.2.2.6 of NUREG-1891. Because of the similarity in the Boral and Metamic materials, the aging management program for Boral is appropriate for the management of aging effects for Metamic material and is included in the changes below.

(4 th paragraph Pg 2.3-51)

The spent fuel pool (SFP) stores spent fuel from the reactor. Racks provided in the pool for support of the fuel assemblies contain a neutron absorber. Beth Boraflex, Metamic and Boral neutron absorbers are in use in the SFP racks. Some racks consist of welded stainless steel assemblies in the shape of cruciforms, angles, and tees. Sheets of Boraflex neutron absorber material are sandwiched between the stainless steel sheets. The remaining racks consist of welded stainless steel boxes. Sheets of Boral and Metamic neutron absorber material are sandwiched between the box walls and a stainless steel sheath welded to the box walls to hold the Boral and Metamic material in position.

(3 rd paragraph Pg 2.3-52)

The systems have the following intended functions for 10 CFR 54.4(a)(1).

0 Maintain isolation of the refueling cavity and dryer/separator floor as required.

This function is performed by the seismic Class I components in lines penetrating the refueling cavity and dryer/separator floor.

  • Maintain safe level of pool in the event of a line break. This function is performed by the siphon breakers.
  • Provide criticality protection. This function is performed by Boral, Metamic and Boraflex sheets in the pool racks.

9 Maintain the RBCCW pressure boundary.

209074 Page 2 of 4

PNPS License Renewal Application Changes LRA Table 2.3.3-13, Fuel Pool Cooling and Fuel Handling and Storage Systems Components Subject to Aging Management Review, is revised as follows:

Component Type Intended Function(s)

Bolting Pressure boundary Neutron absorber (boraflex) Neutron absorption Neutron absorber (boral) Neutron absorption Neutron absorber (Metamic) Neutron absorption Orifice Pressure boundary Piping (including sparger) Pressure boundary Tubing Pressure boundary Valve body Pressure boundary LRA Table 3.3.2-13, Fuel Pool Cooling (FPC) and Fuel Handling and Storage v .......... .... ,v of, in,,n. ... . ..... ... .. . , .. ............. d Neutron Neutron Aluminum/boron Treated Loss of Water -- -- H Absorber absorption carbide water material Chemistry (Metamic) Control - BWR Neutron Neutron Aluminum/boron Treated Cracking Water -- -- H Absorber absorption carbide water Chemistry (Metam ic) I _ ______Control - BWR

5. LRA Table 2.3.3-4, Emergency Diesel Generator System Components Subject to Aging Management Review, is revised as follows.

Page 2.3-71 Component Type Intended Function(s)

IU~i~gPressure F-Gý boundar-y, LRA Table 3.3.2-4, Emergency Diesel Generator System Summary of Aging Management Evaluation, is revised as follows.

Page 3.3-79.

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PNPS License Renewal Application Changes

6. LRA Table 3.2.5-6, Bulk Commodities Summary of Aging Management Evaluation, is revised as follows to identify a new material that has no aging effects and requires no further review. The aging management review results for this material and environment are consistent with NUREG-1 801.

Page 3.5-77.

Vents and SNS, Stainless Protected None None I1l.B2-8 3.5.1- C louvers SRE, steel from (TP-5) 59-SSR weather

7. LRA Table 2.3.1-3, Reactor Coolant Pressure Boundary Components Subject to Aging Management Review, is revised as follows.

Page 2.3-11

.I Component Type Intended Function Pump cover thermal barrier(R) Peur bound LRA Table 3.1.2-3, Reactor Coolant Pressure Boundary Summary of Aging Management Evaluation, is revised as follows.

Page 3.1-68.

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