ML12130A227
| ML12130A227 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/24/2012 |
| From: | Dodds R Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 2.12.031 | |
| Download: ML12130A227 (8) | |
Text
Entergy Nuclear Operations, Inc.
SEntergy Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Ralph A. Dodds, Ill Director, Nuclear Safety ASSUrance April 24, 2012 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Pilgrim Nuclear Power Station (PNPS) License Renewal Application (LRA) Supplemental Information Entergy Nuclear Operations Inc.
Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35
REFERENCE:
- 1. Entergy Letter No. 2.06.003, to the USNRC, "Entergy Nuclear Operations, Inc., License No, DPR-35, License Renewal Application," dated January 25, 2006
- 2. Final License Renewal Interim Staff Guidance (LR-ISG-2011-05),
"Ongoing Review of Operating Experience" LETTER NUMBER 2.12.031
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.
In Reference 2, the NRC provided additional information about the use of operating experience (OE) to confirm the effectiveness of the aging management programs (AMP) or indicate the need to develop new AMPs.
Attachment 1 to this letter provides supplemental information to the LRA addressing the ongoing use of operating experience at PNPS. Attachment 2 provides an update to the LRA - Updated Final Safety Analysis Report (UFSAR) Supplement to include provisions for use of OE during the period of extended operation.
Should you have any questions or require additional information concerning this submittal, please contact Mr. Joseph R. Lynch at 508-830-8403.
There are no regulatory commitments being made in this submittal.
pill
PNPS Letter 2.12.031 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on 2 U of April, 2012.
Sincerely,
-F-rm Ralph A. Dodds, III Director, Nuclear Safety Assurance
[RAD/rmb]
Attachments: 1. License Renewal Application Supplemental Information (4 pages)
- 2. License Renewal Application - Appendix A Revision (2 pages) cc:
Nathaniel B. Ferrer 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. Richard Guzman Mr. Robert Gallaghar, Acting 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 L.L.P. Planning, Preparedness & Nuclear Section Chief 505 9 th Street N.W., Suite 1000 Mass. Emergency Management Agency Washington, DC 20004-2166 400 Worcester Road Framingham, MA 01702 Catherine Haney, 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. William Dean, Administrator NRC Resident Inspector Region I Pilgrim Nuclear Power Station U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406
Attachment 1 PNPS Letter 2.12.031 License Renewal Application Supplemental Information
PNPS Letter 2.12.031 Page 2 of 4 License Renewal Application Supplemental Information Pilgrim Nuclear Power Station (PNPS) Operating Experience (OE) Review Entergy procedures specify reviews of site and relevant industry OE for PNPS. These procedures implement two programs that monitor, on an ongoing basis, industry and plant-specific operating experience that includes, but is not limited to, operating experience dealing with the effects of aging. These programs are the Operating Experience Program (OEP) and the Corrective Action Program (CAP). Evaluations completed under these two programs ensure that aging management programs continue to be effective in managing the effects of aging for which they are credited.
Description of the Operating Experience Program The OEP implements the requirements of NRC NUREG 0737, "Clarification of TMI Action Plan Requirements,"Section I.C.5, and is consistent with guidance contained in INPO 10-006, Revision 1, "Operating Experience (OE) Program and Construction Experience (CE) Program Descriptions" and INPO 97-011, "Guidelines for the Use of Operating Experience." As such, the OEP monitors industry operating experience.
Information sources monitored under the OEP include the following; NRC licensee event reports (LERs) from other plants NRC generic communications (bulletins, generic letters, regulatory issue summaries, information notices)
INPO industry event reports (IERs)
INPO download of industry operating experience NSSS owners group reports Vendor bulletins 10CFR Part 21 reports Operating experience from other Entergy Nuclear sites Incoming OE items are screened by a team of OE coordinators for impact on Entergy plants. A series of team meetings, inter-site conference calls, and condition review group meetings are used to ensure the proper consideration of OE source documents.
Personnel responsible for submitting, screening, assigning, evaluating, or otherwise processing plant-specific and industry operating experience are trained commensurate with their responsibilities.
Further documentation in the Corrective Action Program is required when the initial OEP evaluation identifies a condition adverse to quality, a non-conformance, the potential inoperability of any structures, systems or components, degraded equipment, or equipment not performing as expected or per design. Degradation of affected equipment includes degradation due to the effects of aging.
PNPS Letter 2.12.031 Page 3 of 4 Issues with potential plant impact require the initiation of an OEP written review. Timely determination of plant impact is ensured by assigning due dates for OEP written reviews, not to exceed 90 days. Extensions past the due date require management approval.
The result of an OEP written review can include enhancement of existing aging management programs or development of new aging management programs.
Issues considered to have no impact (or only a low probability of impact), yet considered to be of informational value, are sent to the appropriate departmental point of contact for review.
Description of the Corrective Action Program The CAP implements the requirements of 10 CFR 50, Appendix B, Criterion XVI. The CAP is used to monitor plant-specific operating experience and to evaluate industry operating experience that is relevant to the plant.
The CAP is entered upon identification of a condition adverse to quality, a non-conformance, the potential inoperability of any structures, systems or components, degraded equipment, or equipment not performing as expected or per design.
Degradation of affected equipment includes degradation due to the effects of aging.
Issues addressed in the corrective action process include adverse conditions and conditions adverse to quality and minor problems that may be precursors to more significant events. This includes a broad range of problems and areas for improvement.
Information sources monitored under the CAP include the following; Licensee event reports System health reports Results of inspections performed under plant aging management programs Results of the operating experience program Reports of assessments of the effectiveness of plant aging management programs Under the CAP, conditions are coded to enable trending for the purpose of addressing broader programmatic or process weaknesses. Site management is responsible for ensuring that trend codes are provided for conditions assigned to their department.
Aging-related trend code criteria include the following.
CA - This code is used to identify trends indicating a deviation from the licensing or design basis with respect either to design basis analysis (as the design is changed, plant aging occurs or new analysis techniques are employed) or an actual decrease in the margin between current operating parameters and the most limiting corresponding design parameter.
EO - This code is used to identify repeat equipment or system problems due to design, aging or obsolete components/parts or for unknown reasons that are not attributed to inadequate maintenance.
PNPS Letter 2.12.031 Page 4 of 4 EV - This code is used to document issues concerning damage to plant buildings and structures. This includes aging issues such as roof leaks, cracks due to settling or similar problems.
Conditions are then evaluated and corrected. Evaluation includes consideration of the need for the adjustment of the frequency of future inspections, whether new or different inspections are needed, and whether the inspections include adequate depth and breadth of component, material, and environment combinations. Engineering evaluation of age-related conditions, including engineering actions to implement aging management programs, is performed by engineering personnel who are trained and qualified to perform engineering activities.
Extent of condition reviews evaluate related operating experience to determine the scope of corrective actions. Corrective actions can include enhancement of existing aging management programs or development of new aging management programs. For significant conditions adverse to quality, the cause of the condition is determined and corrective actions to preclude recurrence are implemented.
Timely implementation of identified enhancements is ensured through assignment of responsibility to specific site organizations for monitoring and reporting on the status of work completion. Prescribed guidelines are used to set the timeframe for implementation due dates. A focused self-assessment of the CAP is performed on a regular basis.
Description of Elements Common to the OEP and the CAP The administrative controls'for the review of operating experience provide a formal review and approval process and are applicable to both the OEP and the CAP.
Attachment 2 PNPS Letter 2.12.031 License Renewal Application - Appendix A Revision
PNPS Letter 2.12.031 Page 2 of 2 Pilgrim Nuclear Power Station License Renewal Application - Appendix A Revision Appendix A Updated Final Safety Analysis Report Supplement Add to the end of Section A.2.1 Operating experience is used at PNPS to enhance plant aging management programs.
External nuclear industry operating experience, including operating experience related to the effects of aging, is screened, evaluated, and acted on to prevent or mitigate the consequences of similar events or conditions. External operating experience includes NRC generic communications (e.g., generic letters, bulletins, information notices, regulatory information summaries) and other documents (e.g., 10 CFR 21 reports, licensee event reports, vendor bulletins, information from INPO and other industry groups). Internal operating experience includes information from event investigation reports, trending reports, lessons learned from in-house events, self-assessments, and the 10 CFR 50 Appendix B corrective action process. Operating experience is operating information pertinent to plant safety and reliability originating both within and outside the Entergy organization. Operating experience information describes events, issues, equipment failures, etc., including those resulting from the effects of aging, that represent opportunities to apply lessons-learned to avoid negative consequences or to recreate positive experiences.
Entergy procedures provide direction for the evaluation of operating experience continuing through the period of extended operation. These procedures implement two programs that monitor, on an ongoing basis, industry and plant-specific operating experience that includes, but is not limited to, operating experience related to the effects of aging on in-scope structures and components. These programs are the Operating Experience Program and the Corrective Action Program. Procedures for these programs provide a method for evaluating and initiating action for operating experience information at all Entergy nuclear stations. The primary objective of assessing operating experience is to identify and transfer lessons learned into actions that enhance the safety and reliability of Entergy's nuclear plants. Operating experience involving age-related degradation mechanisms or aspects of programs that manage the effects of aging is provided to the respective program point of contact. Operating experience involving age-related degradation mechanisms for which no program can be readily identified is reviewed as documented in a written evaluation by the aging management operating experience point of contact for the station. The evaluations completed under these two programs ensure that aging management programs remain effective in managing the effects of aging for which they are credited.