ML110960425
| ML110960425 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/06/2011 |
| From: | Doris Lewis Entergy Nuclear Generation Co, Pillsbury, Winthrop, Shaw, Pittman, LLP |
| To: | Abramson P, Cole R, Austin Young Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| 50-293-LR, ASLBP 06-848-02-LR, RAS 19882 | |
| Download: ML110960425 (4) | |
Text
Pillsbury Winthrop Shaw Pittman LLP 2300 N Street, NW l Washington, DC 20037-1122 l tel 202.663.8000 l fax 202.663.8007 David R. Lewis tel 202.663.8474 david.lewis@pillsburylaw.com April 6, 2011 Administrative Judge Administrative Judge Ann Marshall Young, Esq., Chair Dr. Richard F. Cole Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop T-3 F23 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 Administrative Judge Dr. Paul B. Abramson Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 In the Matter of Entergy Nuclear Generation Co. et al.
Pilgrim Nuclear Power Station (Docket No. 50-293-LR; ASLBP No. 06-848-02-LR)
Dear Administrative Judges:
I am writing to inform the Board and parties of a change in Entergys commitments related to the interior inspection of the Salt Service Water (SSW) discharge lines, which carry SSW that has served its cooling function from the auxiliary building to the bay. During the hearing on Pilgrim Watch Contention 1, Entergy testified that while the current In-Service Inspection (ISI) program for the SSW system requires a complete ultrasonic or visual examination of the Cured In-Place Piping (CIPP) after 20 years of service, Entergy intended to inspect the CIPP piping after ten years of service. The CIPP in Loop B of the SSW discharge line was placed in service in 2001, and the CIPP in Loop A of the discharge line was placed in service in 2003. Accordingly, as Entergy testified and as reflected in Judge Youngs concurring opinion (LPB-08-22, 68 N.R.C. at 637), Entergy contemplated inspecting Loop B in 2011 and Loop A in 2013.
During planning for the 2011 refueling outage (RFO), Entergy determined that performing a complete inspection of the CIPP in Loop B would not be optimal in this outage. Pilgrim conducts its refueling outages, which occur every two years, on an alternating loop basis. That is, A www.pillsburylaw.com
April 1, 2011 Page 2 loop systems are taken out of service for major maintenance one outage and the B loop systems are taken out the next. Thus, in each refueling outage, one loop of the SSW system is kept in operation to support safety related equipment while the other is taken out of service for maintenance. The 2011 refueling outage is an A loop outage; therefore, performing a complete inspection of Loop B during the 2011 outage would require taking Loop B out of service out of sequence, and as consequence, would greatly complicate maintenance on Loop A equipment.
Entergy has therefore decided to align the 10-year, full-length loop inspections with the appropriate loop-specific RFO. Consequently, the full-length inspection of the CIPP in Loop B will occur in the 2013 RFO, and the full-length inspection of the CIPP in Loop A will occur in the 2015 RFO. During the RFO in 2011, Pilgrim plans to perform a visual inspection of approximately 20 feet of the CIPP liner in the A loop. This complements the partial visual inspection of approximately 20 feet of the CIPP liner in the B loop completed in the 2009 RFO, which detected no degradation of the liner.
The ten-year inspection of the CIPPs in the SSW discharge lines was not relied upon in the Initial Decision issued by the Licensing Board majority. LPB-08-22, 68 N.R.C. at 608-10.
While the ten-year inspection was one of a number of aging management activities mentioned in Judge Youngs concurring decision, Entergy does not believe that this minor adjustment in schedule would materially affect the Boards decision. As witness Spataro stated during the hearing, based on his professional experience with similar materials used under more aggressive conditions than at Pilgrim, he expects Pilgrims CIPP liners to last at least thirty-five years.
LPB-08-22, 68 N.R.C. at 632, citing Tr. at 681. NRC witness Davis agreed that the CIPP liners installed in loops A and B have an expected life of approximately thirty-five years. Id., citing Tr. at 669. In light of the Spataro and Davis conclusions and the results of the 2009 inspection, the delay of one operating cycle to complete the full visual inspection of the B loop is not significant.
Sincerely yours,
[Signed electronically by]
David R. Lewis Pillsbury Winthrop Shaw Pittman, LLP 2300 N Street NW Washington, D.C. 20037 Tel. 202 663 8474 Email. david.lewis@pillsburylaw.com Counsel for Entergy cc Service List www.pillsburylaw.com
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
Entergy Nuclear Generation Company and ) Docket No. 50-293-LR Entergy Nuclear Operations, Inc. ) ASLBP No. 06-848-02-LR
)
(Pilgrim Nuclear Power Station) )
CERTIFICATE OF SERVICE I hereby certify that copies of the attached letter was provided to the Electronic Information Exchange for service on the persons listed below this 6th day of April, 2011.
Administrative Judge Administrative Judge Ann Marshall Young, Esq., Chair Dr. Richard F. Cole Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop T-3 F23 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 amy@nrc.gov rfc1@nrc.gov Administrative Judge Atomic Safety and Licensing Board Paul B. Abramson Mail Stop T-3 F23 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mail Stop T-3 F23 Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 pba@nrc.gov Secretary Office of Commission Appellate Adjudication Attn: Rulemakings and Adjudications Staff Mail Stop O-16 C1 Mail Stop O-16 C1 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 ocaamail@nrc.gov secy@nrc.gov; hearingdocket@nrc.gov www.pillsburylaw.com
Susan L. Uttal, Esq. Ms. Mary Lampert Andrea Z. Jones, Esq. 148 Washington Street Brian Harris, Esq. Duxbury, MA 02332 Beth Mizuno, Esq. mary.lampert@comcast.net Office of the General Counsel Mail Stop O-15 D21 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Susan.Uttal@nrc.gov; andrea.jones@nrc.gov; brian.harris@nrc.gov; beth.mizuno@nrc.gov Matthew Brock, Assistant Attorney General Sheila Slocum Hollis, Esq.
Commonwealth of Massachusetts Duane Morris LLP Office of the Attorney General 505 9th Street, NW One Ashburton Place Suite 1000 Boston, MA 02108 Washington, DC 20006 Martha.Coakley@state.ma.us sshollis@duanemorris.com Matthew.Brock@state.ma.us Mr. Mark D. Sylvia Chief Kevin M. Nord Town Manager Fire Chief and Director, Duxbury Emergency Town of Plymouth Management Agency 11 Lincoln St. 688 Tremont Street Plymouth, MA 02360 P.O. Box 2824 msylvia@townhall.plymouth.ma.us Duxbury, MA 02331 nord@town.duxbury.ma.us Richard R. MacDonald Katherine Tucker, Esq.
Town Manager Law Clerk, 878 Tremont Street Atomic Safety and Licensing Board Panel Duxbury, MA 02332 Mail Stop T3-E2a macdonald@town.duxbury.ma.us U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Katie.Tucker@nrc.gov
[Signed electronically by]
David R. Lewis www.pillsburylaw.com