ML11145A113

License Renewal Application List of Commitments

ML11145A113
Person / Time
Site:	Pilgrim
Issue date:	05/18/2011
From:	Bethay S Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML11145A113 (16)

Text

SEn tergy Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 May 18, 2011 Stephen J. Bethay Director, Nuclear Safety Assurance 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

REFERENCES:

Pilgrim Nuclear Power Station (PNPS) License Renewal Application (LRA) List of Commitments

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.

Entergy Letter No. 2.11.001 to USNRC, "Pilgrim Nuclear Power Station (PNPS) License Renewal Application (LRA) Supplemental Information," dated January 7, 2011

3.

Entergy Letter No. 2.11.008 to USNRC, "Pilgrim Nuclear Power Station (PNPS) License Renewal Application (LRA) Additional Supplemental Information," dated January 31, 2011

4.

Entergy Letter No. 2.11.017 to USNRC, "Pilgrim Nuclear Power Station (PNPS) License Renewal Application (LRA) Supplemental Information," dated March 16, 2011

5.

Entergy Letter No. 2.11.027 to USNRC, "Pilgrim Nuclear Power Station (PNPS) License Renewal Application (LRA) Supplemental Information," dated April 21, 2011

6.

Entergy Letter No. 2.11.031 to USNRC, "Pilgrim Nuclear Power Station (PNPS) License Renewal Application (LRA) Supplemental Information," dated April 22, 2011 LETTER NUMBER:

2.11.034

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.

A11,7

Entergy Nuclear Operations, Inc.

Letter Number: 2.11.034 Pilgrim Nuclear Power Station Page 2 On January 7, 2011, January 31, 2001, March 16, 2011, April 21, 2011, and April 22, 2011 (References 2 - 6), Entergy provided additional information that supplemented the LRA as a result of operating experience (OE) and industry activities potentially relevant to aging management in several specific areas. to this letter provides a revision to Commitment 15 to address clarifying questions discussed with the NRC staff on a teleconference held on April 26, 2011. provides a complete listing of all current regulatory commitments.

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 May IS, 2011.

Sincerely, Step ethay Director Nuclear Safety Assessment JRL/jI Attachments: 1. Revised License Renewal Commitment No. 15 (2 Pages)

2. License Renewal Commitment List (11 Pages)

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station cc:

Mr. William M. Dean Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 (w/o Attachments)

Mr. Richard V. Guzman, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8-C2 Washington, DC 20555 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 L.L.P.

505 9 th Street N.W., Suite 1000 Washington, DC 20004-2166 Catherine Haney, Director Office of Nuclear Material and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-00001 Mr. Robert Gallaghar, Acting Director Massachusetts Department of Public Health Radiation Control Program Schrafft Center, Suite 1 M2A 529 Main Street Charlestown, MA 02129 Letter Number: 2.11.034 Page 3 Lisa M. Regner Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Mr. Eric J. Leeds, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-00001 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 NRC Resident Inspector Pilgrim Nuclear Power Station Mr. John Giarrusso, Jr.

Planning and Preparedness Division Manager Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702 to Letter No. 2.11.034 Pilgrim Nuclear Power Station License No. DPR-35 (Docket No. 50-293)

License Renewal Application Revised License Renewal Commitment No. 15 (2 pages)

Page 1 of 2

Entergy Nuclear Operations, Inc.

Letter Number: 2.11.034 Pilgrim Nuclear Power Station Pilgrim Nuclear Power Station License Renewal Application - Supplemental Information Entergy provides the following clarifying information to address questions discussed with the NRC staff on a teleconference held on April 26, 2011 regarding the following areas at Pilgrim Nuclear Power Station (PNPS).

0 Aging Management of Low and Medium-Voltage Cables Commitment No. 15 is being revised to be consistent with the Pilgrim License Renewal Application (LRA) Updated Final Safety Analysis Report (UFSAR) Section A.2.1.21, Non-EQ Inaccessible Medium-Voltage Cable Program revised in Entergy Letter 2.11.031, dated April 22, 2011 [Reference (6)].

License Renewal Commitment #15 is revised to read as follows; Commitment No. 15 Implement the Non-EQ Inaccessible Medium-Voltage Cable Program as described in LRA Section B.1.19.

Inspections for water accumulation in manholes containing in-scope inaccessible low-voltage and medium-voltage cables with a license renewal intended function will be performed at least annually. Additional condition-based inspections of these manholes will be performed based upon natural events for a coastal site. The inspection results will be reviewed to determine the need for more frequent inspections.

Inaccessible medium and low-voltage (400 V to 2 kV) cables with a license renewal intended function are included in this program. Inaccessible medium and low-voltage cables will be tested for cable insulation degradation prior to the period of extended operation (PEO) and at least once every six years after entering the PEO. A proven, commercially available test will be used for detecting deterioration of the insulation system of low and medium-voltage inaccessible cables with a license renewal function. Review test results to determine the need for more frequent testing.

Page 2 of 2 to Letter No. 2.11.034 Pilgrim Nuclear Power Station License No. DPR-35 (Docket No. 50-293)

License Renewal Application Complete List of License Renewal Commitments (11 Pages)

Page 1 of 11

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Letter Number: 2.11.034 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.

COMMITMENT IMPLEMENTATION SOURCE SCHEDULE 1

Implement the Buried Piping and Tanks Inspection June 8, 2012 Letters Program as described in LRA Section B.1.2.

2.06.003 2.06.057 2

Enhance the implementing procedure for ASME June 8, 2012 LettersSection XI Inservice Inspection and testing to 2.06.003 specify that the guidelines in Generic Letter 88-01 2.06.057 orapproved 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 As stated in the Letters locations using enhanced visual inspection commitment.

2.06.003 technique, EVT-1, within the first 18 years of the 2.06.057 period of extended operation, with at least one-2.06.064 third of the inspections to be completed within the 2.06.081 first six (6) years and at least 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 include quarterly sampling of the security diesel 2.06.003 generator fuel storage tank. Particulates (filterable 2.06.057 solids), water and sediment checks will be 2.06.089 performed 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 install instrumentation to monitor for leakage 2.06.003 between the two walls of the security diesel 2.06.057 generator fuel storage tank to ensure that significant degradation is not occurring.

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

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Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Letter Number: 2.11.034 COMMITMENT IMPLEMENTATION SOURCE SCHEDULE 7

Enhance Fire Protection Program procedures to June 8, 2012 Letters state that the diesel engine sub-systems (including 2.06.003 the fuel supply line) shall be observed while the 2.06.057 pump is running. Acceptance criteria will be 2.06.064 enhanced to 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 June 8, 2012 Letters for Halon system functional testing to state that the 2.06.003 Halon 1301 flex hoses shall be replaced if leakage 2.06.057 occurs during the system functional test.

9 Enhance Fire Water System Program procedures June 8, 2012 Letters to include inspection of hose reels for corrosion.

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

10 Enhance the Fire Water System Program to state June 8, 2012 Letters that a sample of sprinkler heads will be inspected 2.06.003 using guidance of NFPA 25 (2002 Edition) Section 2.06.057 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 June 8, 2012 Letters that wall thickness evaluations of fire protection 2.06.003 piping will be performed on system components 2.06.057 using non-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.

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Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Letter Number: 2.11.034 COMMITMENT IMPLEMENTATION SOURCE SCHEDULE 12 Implement the Heat Exchanger Monitoring June 8, 2012 Letters Program as described in LRA Section B.1.15.

2.06.003 1 _2.06.057 13, Enhance the Instrument Air Quality Program to June 8, 2012 Letters include a sample point in the standby gas 2.06.003 treatment and torus vacuum breaker instrument air 2.06.057 subsystem in addition to the instrument air header sample points.

14 Implement the Metal-Enclosed Bus Inspection June 8, 2012 Letters Program as described in LRA Section B.1.18.

2.06.003 2.06.057 15 Implement the Non-EQ Inaccessible Medium-Voltage Cable Program as described in LRA Section B.1.19.

Inspections for water accumulation in manholes containing in-scope inaccessible low-voltage and medium-voltage cables with a license renewal intended function will be performed at least annually. Additional condition-based inspections of these manholes will be performed based upon natural events for a coastal site. The inspection results will be reviewed to determine the need for more frequent inspections.

Inaccessible medium and low-voltage (400 V to 2 kV) cables with a license renewal intended function are included in this program. Inaccessible medium and low-voltage cables will be tested for cable insulation degradation prior to the period of extended operation (PEO) and at least once every six years after entering the PEO. A proven, commercially available test will be used for detecting deterioration of the insulation system of low and medium voltage inaccessible cables with a license renewal function. Review test results to determine the need for more frequent testing.

June 8,2012 Letters 2.06.003 2.06.057 2.11.001 2.11.031 2.11.034 16 Implement the Non-EQ Instrumentation Circuits June 8, 2012 Letters Test Review Program as described in LRA Section 2.06.003 B.1.20.

2.06.057 17 Implement the Non-EQ Insulated Cables and June 8, 2012 Letters Connections Program as described in LRA Section 2.06.003 B.1.21.

2.06.057 Page 4 of 11

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Letter Number: 2.11.034 COMMITMENT IMPLEMENTATION SOURCE SCHEDULE 18 Enhance the Oil Analysis Program to periodically June 8, 2012 Letters change CRD pump lubricating oil. A particle count 2.06.003 and check for water will be performed on the 2.06.057 drained 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 security diesel and reactor water cleanup pump oil 2.06.003 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 described in LRA Section B.1.23 2.06.003 2.06.057 Entergy will perform volumetric examination of 10%

2.07.023 of the population of Class 1 ISI small-bore socket 2.11.001 welds at PNPS. In lieu of volumetric examinations, destructive examinations may be performed. The total welds inspected will be any combination of volumetric and destructive examinations, where one destructive examination may be substituted for two volumetric examinations. In addition to the destructive examination performed in 2005, Entergy will schedule four volumetric examinations for 2013. The remaining inspections will be completed no later than 2017.

As a further enhancement, Entergy will inspect three small-bore butt welds in 2011 and another one in 2015.

21 Enhance the Periodic Surveillance and Preventive June 8, 2012 Letters Maintenance Program as necessary to assure that 2.06.003 the effects of aging will be managed as described 2.06.057 in LRA Section B.1.24.

22 Enhance the Reactor Vessel Surveillance Program June 8, 2012 Letters to proceduralize the data analysis, acceptance 2.06.003 criteria, and corrective actions described in LRA 2.06.057 Section B.1.26.

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Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Letter Number: 2.11.034 COMMITMENT IMPLEMENTATION SOURCE SCHEDULE 23 Implement the Selective Leaching Program in June 8, 2012 Letters accordance with the program as described in LRA 2.06.003 Section B.1.27.

2.06.057 24 Enhance the Service Water Integrity Program June 8, 2012 Letters procedure to clarify that heat transfer test results 2.06.003 are trended.

2.06.057 25 Enhance the Structures Monitoring Program June 8, 2012 Letters procedure to clarify that the discharge structure, 2.06.003 security diesel generator building, trenches, valve 2.06.057 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 June 8, 2012 Letters for performing structural examinations of 2.06.003 elastomers (seals, gaskets, seismic joint filler, and 2.06.057 roof elastomers) to identify cracking and change in material properties.

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

28 Enhance System Walkdown Program guidance June 8, 2012 Letters documents to perform periodic system engineer 2.06.003 inspections of systems in scope and subject to 2.06.057 aging 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 June 8, 2012 Letters Irradiation Embrittlement of Cast Austenitic 2.06.003 Stainless Steel (CASS) Program as described in 2.06.057 LRA Section B.1.31.

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Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Letter Number: 2.11.034 COMMITMENT IMPLEMENTATION SOURCE SCHEDULE 30 Perform a code repair of the CRD return line June 30, 2015 Letter nozzle to cap weld if the installed weld repair is not 2.06.057 approved via accepted code cases, revised codes, or an 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 exceedinq a CUF of 1.0.

June 8, 2012 June 8, 2010 for submitting the aging management program if PNPS selects the option of managing the affects of aging due to environmentally assisted fatigue.

Letters 2.06.057 2.06.064 2.06.081 2.07.005 2.07.064 32 Implement the enhanced Bolting Integrity Program June 8, 2012 Letters described in Attachment C of Pilgrim License 2.06.057 Renewal Application Amendment 5 (Letter 2.06.064 2.06.064).

2.06.081 Page 7 of 11

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Letter Number: 2.11.034 COMMITMENT IMPLEMENTATION SOURCE SCHEDULE 33 PNPS will inspect the inaccessible jet pump As stated in the Letter thermal sleeve and core spray thermal sleeve commitment.

2.06.057 welds if and 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 operation and every 12 years thereafter, PNPS will 2.06.057 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 extended operation, for reactor vessel components, including the feedwater nozzles, PNPS will implement one or more of the following:

(1) Refine the fatigue analyses to determine valid CUFs less than 1. Determine valid CUFs based on numbers of transient cycles projected to be valid for the period of extended operation.

Determine CUFs in accordance with an NRC-approved 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.

June 8, 2012 June 8, 2010 for submitting the aging management program if PNPS selects the option of managing the affects of aging.

Letters 2.06.057 2.06.064 2.06.081 36 To ensure that significant degradation on the June 8, 2012 Letter bottom of the condensate storage tank is not 2.06.057 occurring, a 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.

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Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Letter Number: 2.11.034 COMMITMENT IMPLEMENTATION SOURCE SCHEDULE 37 The BWR Vessel Internals Program includes June 8, 2012 Letter inspections of the steam dryer. Inspections of the 2.06.089 steam dryer will follow the guidelines of BWRVIP-139 and General Electric SIL 644 Rev. 1.

38 Enhance the Diesel Fuel Monitoring Program to June 8, 2012 Letter include periodic ultrasonic thickness measurement 2.06.089 of 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 foundation prior to the period of extended 2.06.094 operation.

40 Enhance the Oil Analysis Program by documenting June 8, 2012 Letter program elements 1 through 7 in controlled 2.06.094 documents. The program elements will include 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 June 8, 2012 Letter (CII) Program to require augmented inspection in 2.06.094 accordance with ASME Section Xl 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 described in Attachment C of Pilgrim License 2.07.003 Renewal Application 11 (Letter 2.07.003), prior to the period of extended operation.

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Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Letter Number: 2.11.034 COMMITMENT IMPLEMENTATION SOURCE SCHEDULE 43 Include within the Structures Monitoring Program June 8, 2012 Letter provisions to ensure groundwater samples are 2.07.005 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.

44 Perform another set of the UT measurements just As stated in the Letter above and adjacent to the sand cushion region commitment.

2.07.010 prior 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 As stated in the Letters room floor, obtain samples and test such water to commitment.

2.07.010 determine its pH and verify the water is non-2.07.027 aggressive as defined in NUREG-1801 Section 2.07.029 Ill.A1 item II1.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 down bolts and associated grout and determine 2.07.027 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 benchmarking data to support approval of new P-T 2.07.027 curves for Pilgrim.

48 On or before June 8, 2010, Entergy will submit to thE June 8, 2010 Letter NRC calculations consistent with Regulatory 2.07.027 Guide 1.190 that will demonstrate limiting fluence values will not be reached during the period of extended operation.

49 Perform periodic inspection and neutron absorber s stated in the Letters testing of Boral and Metamic in accordance with commitment 2.11.001 the Neutron Absorber Monitoring Program as 2.11.027 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.

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Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Letter Number: 2.11.034 COMMITMENT IMPLEMENTATION SOURCE SCHEDULE 50 Buried carbon steel (CS) piping in all in-scope As stated in the Letter systems except fire protection will be inspected by commitment 2.11.001 12/31/2013, using a direct visual inspection of the 2.11.031 entire circumference of at least ten linear feet of exposed pipe. Results not meeting the inspection acceptance criteria will be entered into the PNPS corrective action program for evaluation and corrective actions.

Prior to the period of extended operation, Entergy will implement the corporate Buried Piping and Tanks Inspection and Monitoring Program which defines the requirements for continuing inspection of buried and underground piping and tanks.

51 Enhance the Structures Monitoring Program to As stated in the Letter invoke quantitative acceptance criteria for commitment 2.11.008 inspections of concrete structures in accordance with ACI 349.3R, "Evaluation of Existing Nuclear Safety-Related Concrete Structures" prior to the period of extended operation (PEO).

52 Entergy will review design basis ASME Code Class June 8, 2012 Letter 1 fatigue evaluations to determine whether the 2.11.017 NUREG/CR-6260 locations that have been evaluated for the effects of the reactor coolant environment on fatigue usage are the limiting locations for the Pilgrim plant configuration. If more limiting locations are identified, the most limiting location will be evaluated for the effects of the reactor coolant environment on fatigue usage.

PNPS will use the NUREG/CR-6909 methodology in evaluation of the limiting locations consisting of nick(

alloy, if any. This evaluation will be completed prior t period of extended operation.

53 Enhance safety-related coatings programs and June 8, 2012 Letter procedures to be consistent with the 2.11.027 recommendations of NUREG-1801,Section XI.S8, Protective Coating Monitoring and Maintenance Program.

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