ML11123A122

(PNPS) License Renewal Application (LRA) Supplemental Information

ML11123A122
Person / Time
Site:	Pilgrim
Issue date:	04/21/2011
From:	Bethay S Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.11.027
Download: ML11123A122 (9)

Text

SEn tergy Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Stephen J. Bethay April 21, 2011 Director, NUclear Safety Assurance U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 Pilgrim Nuclear Power Station (PNPS) License Renewal Application (LRA) Supplemental Information

REFERENCES:

1. Entergy Letter No. 2.06.003, to USNRC, "Entergy Nuclear Operations Inc., License No. DPR-35, License Renewal Application," dated January 25, 2006.

2. Summary of Telephone Conference Call Held on April 6, 2011, Between the USNRC and Entergy Nuclear Operations, Inc.,

Concerning the Pilgrim Nuclear Power Station License Renewal Application, dated April 19, 2011.

LETTER NUMBER: 2.11.027

Dear Sir or Madam:

On January 25, 2006, Entergy Nuclear Operations, Inc. (Entergy) submitted the License Renewal Application (LRA) for the Pilgrim Nuclear Power Station (PNPS) as indicated by Reference 1.

Attachment 1 to this letter provides supplemental information to the LRA to address questions discussed with the NRC staff on a teleconference held on April 6, 2011 (Reference 2).

New and revised regulatory commitments are provided in the PNPS License Renewal Commitment List as Attachment 2.

Should you have any questions or require additional information concerning this submittal, please contact Mr. Joseph R. Lynch at 508-830-8403.

I declare under penalty of perjury that the foregoing is true and correct. Executed on April ,_ _, 2011.

Sincerely, S ephen J. B th y Director Nuclear Safety Assurance JRL/ji A,o14

Entergy Nuclear Operations, Inc. Letter Number: 2.11.027 Pilgrim Nuclear Power Station Page 2 Attachments: 1. License Renewal Application Supplemental Information (5 Pages)

2. License Renewal Commitment List (2 Pages) cc:

Mr. William M. Dean Lisa M. Regner Regional Administrator, Region 1 Project Manager U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation 475 Allendale Road U.S. Nuclear Regulatory Commission King of Prussia, PA 19406-1415 Washington, DC 20555-0001 (w/o Attachments)

Mr. Richard V. Guzman, Project Manager Mr. Eric J. Leeds, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-00001 Mail Stop O-8-C2 Washington, DC 20555 Susan L. Uttal, Esq. Mr. Matthew Brock, Esq.

Office of the General Counsel Commonwealth of Massachusetts U.S. Nuclear Regulatory Commission Assistant Attorney General Mail Stop 0-15 D21 Environmental Protection Division Washington, DC 20555-0001 One Ashburton Place Boston, MA 02108 Sheila Slocum Hollis, Esq. Diane Curran, Esq.

Duane Morris L.L.P. Harmon, Curran, and Eisenberg, L.L.P.

505 9 th Street N.W., Suite 1000 1726 M Street N.W., Suite 600 Washington, DC 20004-2166 Washington, DC 20036 Catherine Haney, Director NRC Resident Inspector Office of Nuclear Material and Safeguards Pilgrim Nuclear Power Station U.S. Nuclear Regulatory Commission Washington, DC 20555-00001 Mr. Robert Gallaghar, Acting Director Mr. John Giarrusso, Jr.

Massachusetts Department of Public Health Planning and Preparedness Division Manager Radiation Control Program Massachusetts Emergency Management Agency Schrafft Center, Suite 1 M2A 400 Worcester Road 529 Main Street Framingham, MA 01702 Charlestown, MA 02129

Attachment 1 to Letter No. 2.11.027 Pilgrim Nuclear Power Station License No. DPR-35 (Docket No. 50-293)

License Renewal Application Supplemental Information

Entergy Nuclear Operations, Inc. Letter Number: 2.11.027 Pilgrim Nuclear Power Station Attachment 1, Page 2 Pilgrim Nuclear Power Station License Renewal Application - Supplemental Information Entergy provides the following additional supplemental information to address questions discussed with the NRC staff on a teleconference held on April 6, 2011 regarding the following areas at Pilgrim Nuclear Power Station (PNPS).

• Neutron-Absorbing Material

• Protective Containment Coatings Neutron-Absorbinq Material

Background

In letter dated March 16, 2011, Entergy stated that the Neutron Absorber Monitoring Program will be used to manage loss of material and reduction of neutron absorption capacity of Boral and Metamic neutron absorbing panels in the spent fuel racks. The staff noted that the licensee commitment to manage the aging effects (Commitment No. 49) and portions of the LRA have not been changed to reflect the new program.

Issue The NRC staff cannot adequately evaluate the LRA until portions of it are updated, or a summary of the effected portions of the LRA are provided, to reflect the Neutron Absorber Monitoring Program and the inclusion of Metamic, which was not present in the original LRA. Also, the updated final safety analysis report UFSAR supplement does not reflect the planned number and frequency of inspections and testing prior to, and during, the period of extended operation. The staff believes that this information should be explicitly stated in the UFSAR supplement to ensure that the licensing basis for the period of extended operation is clear.

Request

1. Revise the LRA, or provide a summary of the effected portions of the LRA, to reflect the inclusion of Metamic and the Neutron Absorber Monitoring Program. Portions of the LRA that may be affected by the second material and new aging management program include, but are not necessarily limited to, Table 3.3.1, Table 3.3.2-13, and Section 3.3.2.2.6.

Response

Item No. 3.3.1-13 of LRA Table 3.3.1 is revised to read as follows:

Entergy Nuclear Operations, Inc. Letter Number: 2.11.027 Pilgrim Nuclear Power Station Attachment 1, Page 3 Table 3.3.1 Auxiliary Systems, NUREG-1801 Vol. 1 (Continued)

Aging Effectl Aging Further Item Number Component Mechanism Management Evaluation Discussion Programs Recommended 3.3.1-13 Boral, Metamic, Reduction of Plant specific Yes, plant The Water Chemistry spent fuel neutron specific Control - BWR Program storage racks absorbing manages loss of neutron- capacity and loss material. The Neutron absorbing of material due to Absorber Monitoring sheets exposed general corrosion Program manages to treated water reduction of neutron-or borated absorbing capacity and water loss of material.

See Section 3.3.2.2.6.

LRA Table 3.3.2-13 is revised to read as follows:

Table 3.3.2-13: Fuel Pool Cooling and Fuel Handling and Storage Systems NUREG-Component Intended Aging Effect Aging 1801 Table Type Function Material Environment Requiring Management Vol. 1 Notes Management Programs Vol. 2 Item Item Neutron Neutron Aluminum/ Treated Loss of Water VII.A2-3 3.3.1- E absorber absorption boron water material Chemistry (A-89) 13 (Boral/Metam ic) carbide Control -

BWR and Neutron Absorber Monitoring Neutron Neutron Aluminum/ Treated Cracking Water H absorber absorption boron water Chemistry (Boral/Metam ic) carbide Control -

BWR and Neutron Absorber Monitoring Section 3.3.2.2.6 of the LRA is revised to read as follows:

3.3.2.2.6 Reduction of Neutron-Absorbing Capacity and Loss of Material due to General Corrosion Loss of material and cracking are aging effects requiring management for Boral and Metamic spent fuel storage racks exposed to a treated water environment. These aging effects are managed by the Water Chemistry Control - BWR Program.

The Neutron Absorber Monitoring Program manages the reduction in neutron-absorbing capacity and loss of material.

Entergy Nuclear Operations, Inc. Letter Number: 2.11.027 Pilgrim Nuclear Power Station Attachment 1, Page 4

2. Revise Commitment No. 49 to reflect the Neutron Absorber Monitoring Program.

Response

License Renewal Commitment #49 is revised to read as follows; Commitment # 49 Perform periodic inspection and neutron absorber testing of Boral and Metamic in accordance with the Neutron Absorber Monitoring Program as described in LRA Section B.1.35. One test on each material will be performed within the five years preceding the period of extended operation (PEO), with additional testing performed on each material at least once every 10 years during the PEO.

3. Revise the UFSAR supplement to reflect the number and frequency of inspections and testing prior to, and during, the period of extended operation.

Response

The revised LRA UFSAR Section A.2.1.41 is provided as follows:

A.2.1.41 Neutron Absorber Monitoring Program The Neutron Absorber Monitoring Program is a new program that manages loss of material and reduction of neutron absorption capacity of Boral and Metamic neutron absorption panels in the spent fuel racks. The program will rely on periodic inspection, testing, monitoring of coupons, and analysis of the criticality design to assure that the required five percent subcriticality margin is maintained during the period of extended operation.

The program will be initiated prior to the period of extended operation. One test on each material will be performed within the five years preceding the period of extended operation, with additional testing performed on each material at least once every ten years during the period of extended operation.

Entergy Nuclear Operations, Inc. Letter Number: 2.11.027 Pilgrim Nuclear Power Station Attachment 1, Page 5 Protective Containment Coatings

Background

In letter dated March 16, 2011, Entergy stated that the Protective Containment Coatings Program will be used to manage the effects of aging on Service Level I coatings. The staff noted that the licensee did not provide conforming LRA changes or an UFSAR supplement to reflect the new program.

Issue The staff cannot adequately evaluate the LRA until portions of it are updated or a summary of the effected portions of the LRA are provided to reflect the Protective Containment Coatings Program, which was not present in the original LRA. Also, an UFSAR supplement was not provided which would reflect the addition of this program and appropriate attributes. The staff cannot complete its review to ensure that the licensing basis for the period of extended operation is clear without the UFSAR supplement.

Request Provide the UFSAR supplement to reflect the Protective Containment Coatings Program.

Response

PNPS is providing a new aging management program to provide reasonable assurance that there is proper management of the protective coatings inside primary containment, such that they will not degrade and become a debris source that may challenge ECCS performance during the period of extended operation (PEO).

New LRA UFSAR Section A.2.1.42 is provided as follows.

A.2.1.42 Protective Coating Monitoring and Maintenance Program The Protective Coating Monitoring and Maintenance Program manage the effects of aging on Service Level 1 coatings inside containment by means of periodic visual inspections. The program also includes direction to select and review the suitability of the coatings applied to surfaces inside containment (e.g.,

steel containment shell, structural steel, supports, penetrations, and concrete walls and floors).

Inspection of coatings inside containment is performed of accessible areas in accordance with the IWE requirements of ASME Section Xl during every other refueling outage (once per ASME Section XI IWE period) which is a maximum of four years.

Commitment Entergy is providing the following commitment (Commitment # 53) for the inspection of protective coatings inside containment to be implemented prior to the PEO.

Commitment # 53 Enhance safety-related coatings programs and procedures to be consistent with the recommendations of NUREG-1801,Section XI.S8, Protective Coating Monitoring and Maintenance Program.

Attachment 2 to Letter No. 2.11.027 Pilgrim Nuclear Power Station License No. DPR-35 (Docket No. 50-293)

License Renewal Application License Renewal Commitment List

Entergy Nuclear Operations, Inc. Letter Number: 2.11.027 Pilgrim Nuclear Power Station Attachment 2, Page 2 This table identifies actions discussed in this letter that Entergy commits to perform. Any other actions discussed in this submittal are described for the NRC's information and are not commitments.

TYPE (Check one) SCHEDULED ONE-TIME CONTINUING COMPLETION DATE ITEM COMMITMENT ACTION COMPLIANCE (If Required) 49 Perform periodic inspection and neutron X As stated in the absorber testing of Boral and Metamic in commitment.

accordance with the Neutron Absorber Monitoring Program as described in LRA Section B.1.35. One test on each material will be performed within the five years preceding the PEO, with additional testing performed on each material at least once every 10 years during the PEO.

53 Enhance safety-related coatings X 6/8/2012 programs and procedures to be consistent with the recommendations of NUREG-1801,Section XI.S8, Protective Coating Monitoring and Maintenance Program.