ML070380551

E-MAIL: (PA) Pilgrim LRA Amendment 11

ML070380551
Person / Time
Site:	Pilgrim
Issue date:	01/10/2007
From:	Perry Buckberg NRC/NRR/ADRO/DLR
To:	Rajender Auluck, Ganesh Cheruvenki, Jennifer Davis, Forrest E, Greg Galletti, Dan Hoang, Naeem Iqbal, Brian Lee, Lois L, James Medoff, Dang Nguyen, Pal A, Rajan J, Muhammad Razzaque, Bill Rogers, Sheng C, Stubbs A, Christopher Sydnor Office of New Reactors, Office of Nuclear Reactor Regulation
References
TAC 3698
Download: ML070380551 (22)

Text

Page 1 of I Perry Buckberg - Pilgrim LRA Amendment 11 From: Perry Buckberg To: Pilgrim Staff Date: 1/10/2007 2:23:35 PM

Subject:

Pilgrim LRA Amendment 11 Gentlemen, The attached document is an advance copy that just came in via e-mail. Please check if any changes are pertinent to your SER input.

Thanks, Perry Buckberg Project Manager - Division of License Renewal phone: (301)415-1383 fax: (301)415-3031 phbl nrc.gov file ://C :\temp\G W }00001. HTM 2/1/2007

I c:\temp\G\A./J000101.TMP ..... .. ...... .. ... ... T M.P a 1 Mail Envelope Properties (45A53D37.BB1 9: 8248)

Subject:

Pilgrim LRA Amendment 11 Creation Date 1/10/2007 2:23:35 PM From: Perry Buckberg Created By: PHB 1 @nrc.gov Recipients Action Date & Time nrc.gov OWGWPO01 .HQGWDOOI Delivered 1/10/2007 2:23:38 PM RCA CC (Rajender Auluck) nrc.gov OWGWPOO2.HQGWDOOI Delivered 1/10/2007 2:23:38 PM EBF (Edwin Forrest)

GSG (Greg Galletti)

NXI (Naeem IQBAL) nrc.gov

' OWGWPOO3.HQGWDOOI Delivered 1/10/2007 2:23:38 PM GSC (Ganesh Cheruvenki)

JAD (James Davis)

,.-WGWPO04.HQGWDOO1 Delivered

• 1/10/2007 2:23::38 . .. ;.(.. -

PM DVH (Dan Hoang) nrc.gov TWGWPO01 .HQGWDOOI Delivered 1/10/2007 2:23:38 PM BEL (Brian Lee)

DTN I (Duc Nguyen)

JXM (James Medoff)

LXLI (Lambros Lois) nrc.gov TWGWPO02.HQGWDOOI Delivered 1/10/2007 2:23:38 PM AXS8 (Angelo Stubbs)

c:\temp\GW}O0001 .TMP .Page 2 1 CFS (Chia-Fu Sheng)

CRS (Christopher Sydnor) nrc.gov TWGWPO03.HQGWDO01 Delivered 1/10/2007 2:23:39 PM ANP (Amar Pal)

BHR (Billy Rogers)

JRR (Jai Rajan)

MMR1 (Muhammad Razzaque)

Post Office Delivered Route OWGWPO01 .HQGWDO0 I 1/10/2007 2:23:38 PM nrc.gov OWGWPO02.HQGWDO01 1/10/2007 2:23:38 PM nrc.gov OWGWPOO3.HQGWDO01 1/10/2007 2:23:38 PM nrc.gov OWGWPO04.HQGWDO01 1/10/2007 2:23:38 PM nrc.gov TWGWPO01 .HQGWDO01 1/10/2007 2:23:38 PM nrc.gov TWGWPO02.HQGWDO01 1/10/2007 2:23:38 PM nrc.gov TWGWPO03.HQGWDO01 1/10/2007 2:23:39 PM nrc.gov Files Size Date & Time MESSAGE 1001 1/10/2007 2:23:33 PM TEXT.htm 739 Pilgrim LRA Amendment 11 1102007.pdf 1410446 1/10/2007 2:18:18 PM Options Auto Delete: No:Y

. Expiration Date: None NotifyRecipients: Yes Priority: Standard ReplyRequested: No Return Notification: None Concealed

Subject:

No Security: Standard To Be Delivered: Immediate Status Tracking: Delivered

Entergy Nuclear Operations, Inc.

Pilgri6':m Sc ftlon v600 Rockv Hilt Road PlymcIth, MA 02360 Stephen J. Bethay January 10, 2007 Director. Nuclear Assessment 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 License Renewal Application Amendment 11

REFERENCE:

Entergy letter, License Renewal Application, dated January 25, 2006 (2.06.003)

LETTER NUMBER: 2.07.003

Dear Sir or Madam:

In the referenced .letter, Entergy Nuclear Operations, Inc. applied for renewal of the Pilgrim Station operating license. NRC TAC NO. MC9669 was assigned to the application.

This License Renewal Application (LRA) amendment consists of three attachments.

Attachment A contains the list of revised regulatory commitments. Attachment B contains the response to the request for additional information (RAI) on LRA Amendment 8 Attachment C concerning LRA Section 3.6.2 Electrical and Instrumentation and Controls, conveyed in NRC letter dated November 2, 2006. Attachment C contains changes to the LRA.

Please cojhtact Mr. Bryan Ford, (508) 830-8403, if you have any questions regarding this: t subject-I declare .under penalty of.perjury that the foregoing is'trueand .correct.. Executed on January (0,.2007.

Step enJ. hay Director, Nue1ear Safety Assessment DWE/dl Attachments: (as stated) cc: see next page

Entergy Nuclear Operations, Inc. Letter Number: 2.07.003 Pilgrim Nuclear Power Station Page 2 cc: with Attachments Mr. Perry Buckberg Mr. Joseph Rogers Project Manager Commonwealth of Massachusetts Office of Nuclear Reactor Regulation Assistant Attorney General U.S. Nuclear Regulatory Commission Division Chief, Utilities Division Washington, DC 20555-0001 1 Ashburton Place Boston, MA 02108 Alicia Williamson 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 Sheila Slocum Hollis, Esq. Molly H. Bartlett, Esq.

Duane Morris LLP 52 Crooked Lane 1667 K Street N.W., Suite 700 Duxbury, MA 02332 Washington, DC-Ž0006 cc: without Attachments Mr. James Shea' r. Robe*rt' biker 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 Mr. Jack Strosnider, Director Ms. Cristine McCombs, Director Office of Nuclear Material and Safeguards Massachusetts Emergency Management Agency

.S. Nuclear Regulat ory Commission 400 Worchester R-oa Washington, DC 20555-00001 Framingham, MA 01702 Mr. Samuel J. Collins, Administrator Mr. James E. Dyer, Director Region I Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 475 Allendale Road Washington, DC 20555-00001 King of Prussia, PA 19406 NRC Resident Inspector Pilgrim Nuclear Power Station

ATTACHMENT A to Letter 2.07.003 (7 pages)

Revised List of Regulatory Commitments 0 - - -

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.

1. COMMITMENT IMPLEMENTATION SOURCE Related SCHEDULE LRA Section NoJ Comments 1 Implement the Buried Piping and Tanks Inspection June 8, 2012 Letter B.1.2/ Audit Program as described in LRA Section B.1.2. 2.06.003 Item 320 2 Enhance the implementing procedure for ASME June 8, 2012 Letter B.1.6/ Audit Section Xl inservice inspection and testing to specify 2.06.003 Item 320 that the guidelines in Generic Letter 88-01 or approved 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 locations As stated in the Letters B.1.8/ Audit using enhanced visual inspection technique, EVT-1, commitment 2.06.064 Items 155, within the first 18 years of the period of extended and 320 operation, with at least one-third of the inspections to 2.06.081 be completed within the 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 B.1.10/Audit include quarterly sampling of the security diesel 2.06.003 Items 320, generator fuel storage tank. Particulates (filterable and 566 solids), water and sediment checks will be performed 2.06.089 on the samples., Filterable. solids acceptance criteria ,. -

will be =10 mg/I. Water and sediment acceptance r.

criteria will be = 0.05%.

'5 Enhance the Diesel Fuel Monitoring Program to June 8, 2012 Letter B.1.10/Audit install instrumentation to monitor for leakage between 2.06.057 Items 155, the two walls of the security diesel generator fuel 320 storage tank to ensure that significant degradation is not occurring.

6 Enhance the Diesel Fuel Monitoring Program to June 8, 2012 Letter B.1 in/ Aj dit specify acceptance criterion for UT measurements of 2.06.003 Items 165, emergency diesel generator fuel storage tanks (T- 320 126A&B).

I

1. COMMITMENT IMPLEMENTATION SOURCE Related SCHEDULE LRA Section No./

Comments 7 Enhance Fire Protection Program procedures to state June 8, 2012 Letter B.1.13.1/

that the diesel engine sub-systems (including the fuel 2.06.064 Audit Items supply line) shall be observed while the pump is 320, 378 running. Acceptance criteria will be 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 for June 8, 2012 Letter B.1.13.1/

Halon system functional. testing to state that the 2.06.003 Audit Item Halon 1301 flex hoses shall be replaced if leakage 320

..occurs during the system functional test......................... _

9 Enhance Fire Water System Program procedures to June 8, 2012 Letter B.1.13.2/

include inspection of hose reels for corrosion. 2.06.003 Audit Item Acceptance criteria will be enhanced to verify no 320 significant corrosion.

10 Enhance the Fire Water System Program to state that June 8, 2012 Letter B.1.13.2/?

.. a sample of sprinkler heads will be inspected using .... 2'.06.003 Audit Item T guidance of NFPA 25 (2002 Edition) Section 32 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 that.. June 8, 2012 Letter B.1.13.2/

.wall thickness evaluations of fire protection piping will' 2.06.003 Audit Item be performed on system components using non- 320 intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion.

These inspections rwill 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.

12 Implement the Heat Exchanger Monitoring Program June 8, 2012 Letter B.1.15/Audil I as described in LRA Section B.1.15. 2.06.003 Item 320 2

1. COMMITMENT IMPLEMENTATION SOURCE Related SCHEDULE LRA Section NoJ Comments 13 Enhance the Instrument Air Quality Program to June 8, 2012 Letter B.1.17/Audit include a sample point in the standby gas treatment 2.06.003 Item 320 and torus vacuum breaker instrument air subsystem in addition to the instrument air header sample points.

14 Implement the Metal-Enclosed Bus Inspection June 8, 2012 Letter B.1.18/Audit Program as described in LRA Section B.1.18. 2.06.003 Item 320 15 Implement the Non-EQ Inaccessible Medium-Voltage June 8, 2012 Letter B.1.19/Audit Cable Program as described in LRA Section B. 1.19. 2.06.003 items 311, Include developing a formal procedure to inspect 320 manholes for in-scope medium voltage cable.

16 Implement the Non-EQ Instrumentation Circuits Test June 8, 2012 Letter B.1.20/Audit Review Program as described in LRA Section B.1.20. 2.06.003 Item 320 17 Implement the Non-EQ Insulated Cables and June 8, 2012 Letter B.1.21/Audit Connections Program as described in LRA Section 2.06.003 Item 320 B.1.21.

18 Enhance the Oil Analysis Program to periodically June 8, 2012 Letter B.1.22/Audit change CRD pump lubricating oil. A particle count 2.06.003 Item 320 and check for water will be performed on the 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 Letter B.1.22/Audit 2.06.003 Item 320 security diesel and reactor water cleanup pU.qP oil changes to obtain oil samples from the draine6d, oil.

Procedures for lubricatingqoil analysis wiltlb,e15,61 .

-enharced to specify that a particle count and'check for water ared)performed on oil samples from the fire .

wateir pump diesel, security diesel, and reactor water

. cleanup pumps. _'.___ . . - " . . . -

Implement the One-Time Inspection Program as I0., June 8, 2012. Lette.r B123/3AudIt

-described in LRA Section. B..123. This includes 2.06.003 Items.219, destructive or non-destructive examination of one (1) 320 socket welded connection using techniques proven by past industry experience to be effective for the identification of cracking in small bore socket welds.

Should an inspection opportunity not occur (e.g.,

socket weld failure or socket weld replacement), a susceptible small-bore socket weld will be examined either destructively or non-destructively prior to entering the period of extended operation.

21 Enhance the Periodic Surveillance and Preventive June 8, 2012 Letter B.1.24/Audit Maintenance Program as necessary to assure that 2.06.003 Item 320 the effects of aging will be managed as described in LRA Section B.1.24. I 3

1. COMMITMENT IMPLEMENTATION SOURCE Related SCHEDULE LRA Section NoJ Comments 22 Enhance the Reactor Vessel Surveillance Program to June 8, 2012 Letter B.1.26/Audit proceduralize the data analysis, acceptance criteria, 2.06.003 Item 320 and corrective actions described in LRA Section B.1.26.

23 Implement the Selective Leaching Program in June 8, 2012 Letter B.1.27/Audit accordance with the program as described in LRA 2.06.003 Item 320 Section B.1.27.

24 Enhance the Service Water Integrity Program June 8, 2012 Letter B.1.28/ Audit procedure to clarify that heat transfer test results are 2.06.003 Item 320 trended.

25 Enhance the Structures Monitoring Program June 8, 2012 Letter B.1.29.2/

procedure to clarify that the discharge structure, 2.06.003 Audit Items security diesel generator building, trenches, valve 238, 320 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 for June 8, 2012 Letter B. 1.29.2/

performing structural examinations of elastomers .2.06.003 Audit Item (seals, gaskets, seismic joint filler, and roof 320 elastomers) to identify cracking and changen..:

material properties. . ,-___,_.____- ,

27 Enhanhe the W..

WaterControl StUtires Monitoring June 8, 2012 Letter -n1.,29.3/ ~LI Program scopeto0include'the east breakwater, jett6ies, 2.06.003 Audit, Item:

anddonshore revetments in addition to-the main F,320,:

breakwater.-,.? ___________ _____

28 Enhance System Walkdown Program" guidance June 8,2012 Letter B.1.30/ Audit documents to perform periodic system engineer 2.06.057 Items 320, inspections of systems in scope and subject to aging 327 management review for license renewal in accordance with 10 CFR 4A.4(A,1) ad (/a(3\/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 Irradiation June 8, 2012 Letter B.1.31/ Audit Embrittlement of Cast Austenitic Stainless Steel 2.06.003 Items 257, (CASS) Program as described in LRA Section B.1.31. 320 4

1. COMMITMENT IMPLEMENTATION SOURCE Related SCHEDULE LRA Section No./

Comments 30 Perform a code repair of the CRD return line nozzle June 30, 2015 Letter B.1.3/ Audit to cap weld if the installed weld repair is not approved 2.06.057 Items 141, via accepted code cases, revised codes, or an 320 approved relief request for subsequent inspection intervals.

31 At least 2 years prior to entering the period of June 8, 2012 Letters 4.3.3/ Audit extended operation, for the locations identified in 2.06.064 Items 302, NUREG/CR-6260 for BWRs of the PNPS vintage, and . 346 PNPS will implement one or more of the following: June 8, 2010 for 2.06.081 (1) Refine the fatigue analyses to determine valid CUFs submitting the less than 1 when accounting for the effects of reactor water aging environment. This includes applying the appropriate Fen management factors to valid CUFs determined in accordance with one of program if PNPS the following: selects the

1. For locations, including NUREG/CR-6260 locations, with option of existing fatigue analysis valid for the period of extended managing the operation, use the existing CUF to determine the affects of aging environmentally adjusted CUF. due to

2. More limiting PNPS-specific locations with a valid CUF environmentally may be added in addition to the NUREG/CR-6260 locations. assisted fatigue.

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-approv.ed version of the ASME code of NRC-approved alternative ('g?,, NRC-approved code case) may be performed to0determine a valid CUF.

.(2) Manage6 the ffects of aging dueto fatigue at the affected locations by an inspeCti n"prdgram that has been 4 . ~- 44.

.revibwed a:ndapp'r6ved by the NRC(eg., periodic non-.

-destructive exam ination of the affectedlbcations at inspection intervals to be determined bly'a-methodd."

acceptable toth.e NRC).

(3) Repair or replace the affected locations before exceeding a CUF. of 1.0.

Should PNPS select the option to manage the aging effects due to environmental-assisted 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.

32 Implement the enhanced Bolting Integrity Program June 8, 2012 Letters Audit items described in Attachment C of Pilgrim License 2.06.064 364, 373, Renewal Application Amendment 5 (Letter 2.06.064). and 389, 390, 2.06.081 432, 443, 470 5

COMMITMENT IMPLEMENTATION SOURCE Related SCHEDULE LRA Section No./

Comments 33 PNPS will inspect the inaccessible jet pump thermal As stated in the Letter Audit Items sleeve and core spray thermal sleeve welds if and commitment 2.06.057 320, 488 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 Letter Audit Items operation and every 12 years thereafter, PNPS will 2.06.057 320, 461 inspect the access hole covers with UT methods. and Alternatively, PNPS will inspect the access hole 2.06.089 covers in accordance with BWRVIP guidelines should such guidance become available.

35 At least 2 years prior to entering the period of June 8, 2012 Letters Audit Item extended operation, for reactor vessel components, June 8, 2010 for 2.06.064 345 including the feedwater nozzles, PNPS will implement submitting the and one or more of the following: aging 2.06.081 (1) Refine the fatigue analyses to determine valid management CUFs less than 1. Determine valid CUFs based on program if PNPS numbers of transient cycles projected to be valid selects the for the period of extended operation. Determine option of CUFs in accordance with an NRC-approved otmanagingo version of the ASME code or NRC-approved anagingt alternative (e.g., NRC-approved code case). affects of aging.

(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 interv'alstobe' - . .

• j.

A

• "" determined by a-method-acceptable to the NRQ,). . .

T: (3)yeR~pair of replace the affected'locations before . ',

exceeding ACUF 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.

36 To ensure that significant degradation on the bottom June 8, 2012 Letter Audit Items of the condensate storage tank is not occurring, a 2.06.057 320, 363 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.

6

COMMITMENT IMPLEMENTATION SOURCE Related SCHEDULE LRA Section NoJ Comments 37 The BWR Vessel Internals Program includes June 8, 2012 Letter A.2.1.8/

inspections of the steam dryer. Inspections of the 2.06.089 Conference steam dryer will follow the guidelines of BWRVIP-139 call on and General Electric SIL 644 Rev. 1. September 25, 2006 38 Enhance the Diesel Fuel Monitoring Program to June 8, 2012 Letter B.1.10/ Audit include periodic ultrasonic thickness measurement of 2.06.089 Item 565 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 B.1.23/Audit foundation prior to the period of extended operation. 2.06.094 Item 581 40 Enhance the Oil Analysis Program by documenting June 8, 2012 Letter B.1.22/

program elements. 1through 7in con.ttrolled .2.06.094. Inspection documents. The program elements will include Items 553, enhancements identified in the PNPS license renewal 589 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 rSectionXXI.M39, Lubricating.Oil Analysis. The

,controlled documents will specify appropriate acceptance* riter ia and corrective actions in the event

• .acceptance criteria are not met.. The basis for

acceptance cr'iteria will be defined.!, . _,. --. . * .. ,

41 Enhance the Containment Inservice Inspection (CII) ' June 8, 201-2,- Letter A.2*.117 and Program to require augmented inspection in 2.06.094 -,B.1.16.1:

accordance with ASME Section XI 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, U,201* 2 Letter A.2.1.40 and described in Attachment C of Pilgrim License 2.07.003 B.1.34 Renewal Application Amendment 11 (Letter 2.07.003), prior to the period of extended operation.

7

ATTACHMENT B to Letter 2.07.003 (2 pages)

Response to Request for Additional Information on LRA Amendment 8 Attachment C Concerning LRA Section 3.6.2 Electrical and Instrumentation and Controls

RAI 3.6.2-1 In RAI 3.6.2-1, by letter dated August 14, 2006, the staff requested the applicant to provide a basis document including an aging management program (AMP) for cable connections with the 10 elements or provide a justification for why an AMP is not necessary.

In your response, by letter dated September 13, 2006, you stated that electrical cable connections at PNPS are inspected under the maintenance rule program as directed by Entergy procedures and therefore no aging management program (AMP) for license renewal is required at PNPS.

It should be noted that the current licensing bases for all power plants require compliance with the requirements of the maintenance rule 10 CFR 50.65. The Statements of Consideration for the license renewal rule state: The license renewal rule excludes "active, short-lived structures and components" from an aging management review because of the existing regulatory process, existing licensee programs and activities, and the maintenance rule. The staff's understanding has been that under the license renewal rule, existing programs are not, without some explanation or modification, automatically considered adequate to manage aging effects for license renewal by virtue of being part of the current licensing basis. The Commission formulated the following two principles of license renewal: (1) With the possible exception of the detrimental effects of aging on the functionality of certain plant systems, structures, and components in the period of extended operation and possibly a few other issues related to safety only during extended operation, the regulatory process is adequate to ensure that the

• licensing bases of all currently operating plants provides and maintains an acceptable level of safety so that operation will not be inimical to public health and safety or common defense and security; and (2) The plant-specific licensing basis must be maintained during the renewal term in the same manner and to the same extent as during the original licensing term.

The 10 CFR 50.24 (a)(3) [sic] requires an applicant to demonstrate that the e*ffets of aging, of components such as cable connections defined in 10 CFR 50.24 (a)(1) [sic].' ll`be adequately managed so that the intended function(s) will be mainitained 6bnsistent with th* CLB for the period of extended operation. -,Todemonstrate that the effects of aging will e adequately managed for license renewal, the staff views: that an applicant must ide ti th *roa relied uponto manage certain aging effects for cable. connections. The aging managementprogram for cable connections acceptable to the staff is provided in'GALL AMP XI.E6. This AMPostatesr-*-., .:,..'.

that the agirig management program for electrical cable Connections (metallic parts) account for the following stressors: thermal cdcling;,ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation.

Therefore, the staff requests that the applicant either provide a plant-specific AMP with the AMP elements found in SRP-LR, Appendix A.1, Section A.1.2.3 and SRP-LR Table A.1-1 or an AMP consistent with GALL AMP XI.E6. If you still insist an AMP is not required, explain in detail how the existing program will address the above aging effects and provide a detailed discussion of how each of the 10 elements of the program as described in the SRP sections mentioned above is met by the current program. Also, provide supporting documentation to show that the aging management program elements including appropriate tests are implemented currently and will be continued for the extended period of operation. Without such information, it is not apparent that the staff will be able to present a basis for concluding that actions have been or will be taken to manage the effects of aging during the period of extended operation to ensure the functionality of those structures and components.

I

RAI 3.6.2-1 Response Clarification LRA Amendment 8, in response to RAI 3.6.2-1, stated that an XI.E6 program was not required.

Based on the November 30, 2006 meeting with the NRC, an alternate plant-specific program, which will be a one-time inspection of a representative sample of cable connections subject to aging management review, will be used at PNPS.

Basis for Clarification Based on the November 30, 2006 meeting with the NRC, the Pilgrim Bolted Cable Connections Program will be a one-time inspection of a representative sample of cable connections subject to aging management review.

Switchyard connections are not addressed in this program. Since these connections operate at a much higher voltage (>35 kV), they are addressed separately as part of the switchyard commodity types. Cable connections for medium and low voltage levels are included in this program. As discussed during the November 30, 2006 NEI-NRC meeting, bolted connections are the main concern. High load bolted connections are included in this program.

For low load connections, thermal cycling, ohmic heating, and electrical transients are not potential stressors. In addition, vibration, chemical contamination, corrosion and oxidation are not a concern for low load connections located in a controlled environment. Low load in-scope field instrumentation connections, such as those for pressure transmitters, RTDs, and flow transmitters, are not subject to AMR because the in-scope instruImentation located in a harsh environment is typically EQ. The non-EQ sensitive instrument circuit (high radiation and neutron monitoring) connections are included in the XI.E2 program. Connections associated with circuits that do not have an intended function, such as general lighting, are not subject to AMR.

Refer to Attachment C of this LRA amendment for chan'Ws;Yo-the LRA stemming from this clarification. - t -.

2

ATTACHMENT C to Letter 2.07.003 (5 pages)

Changes to the LRA

LRA Section 3.6.2.1, Aging Effects Requiring Management, is revised to add the following:

• Loosening of Bolted Connections LRA Section 3.6.2.1, Aging Management Programs, is revised to add the following AMP:

• Bolted Cable Connections Program LRA Table 3.6.1, Item 3.6.1-13, is revised as shown below (strike-outs deleted, underlined text added).

Item Component Aging Effect / Mechanism AMP Further Discussion Number Evaluation Recommended 3.6.1-13 Cable Loosening of bolted Electrical Cable No NUREG 1801 aging f*8ct Connections connections due to thermal Connections Not icsnot applicablo to metallic parts cycling, ohmic heating, Subject To 10 CFR PilgP Gable electrical transients, 50.49 coGnections utsido

-- of vibration, chemical Environmental activ* devices a*r taped contamination, corrosion, Qualification or ,*ooVod for protectin.

and oxidation Requirements Operatf.ig 9X19808AG8 With me~tallic part6 Gf electrical Gable connactions at PISPS'indibatod no aging maagemen.

PNPS is providing a plant specific program (Bolted Cable Connections Proqram) as an alternate to the NUREG-1801.

__XI.E6 roqram.

LRA Table 3.6.2-1 is revised as shown below (strike-outs deleted, underlined text added).;'

Component Intended Material Environment AERM, AMP NUREG- Table 1 Notes Type Function 1801, Vol.2 Item Item Cable CE Various Indoor and NRe9 NAAR VI.A-1 3.6.1-13 -

Connections metals Outdoor (LP-12)

(metallic parts) usedfor Loosening of Bolted Cable electrical Bolted Connections connection Connections Program s

Notes for Table 3.6.2-1 No changes required.

LRA Appendix A is revised to add the following:

A.2.1.40 BOLTED CABLE CONNECTIONS PROGRAM The Bolted Cable Connections Program will focus on the metallic parts of the cable connections. This sampling program provides a one-time inspection to verify that the loosening of bolted connections due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation is not an aging issue that requires a periodic aging management program. A representative sample of the electrical cable connection population subject to aging management review will be inspected or tested. Connections covered under the EQ program, or connections inspected or tested as part of a preventive maintenance program are excluded from aging management review.

The factors considered for sample selection will be application (medium and low voltage),

circuit loading (high loading), and location (high temperature, high humidity, vibration, etc.).

The technical basis for the sample selection will be documented.

This program will be implemented prior to the period of extended operation. License renewal commitment 42 governs implementation of this program.

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LRA Appendix B is revised to add the following:

B.1.34 BOLTED CABLE CONNECTIONS PROGRAM Program Description Cable connections are used to connect cable conductors to other cables or electrical devices. Connections associated with cables within the scope of license renewal are considered for this program. The most common types of connections used in nuclear power plants are splices (butt or bolted), crimp-type ring lugs, connectors, and terminal blocks. Most connections involve insulating material and metallic parts. This program for electrical cable connections (metallic parts) accounts for loosening of bolted connections due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation. This program does not apply to the high voltage switchyard connections.

NUREG-1801, XI.E4; "Metal Enclosed Bus," manages the aging effects for the connections associated with metal enclosed bus. XI.E4 manages the aging effects from thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation on the metallic parts of metal enclosed bus (MEB) connections. Therefore, MEB connections are not included in this program.

Circuits exposed to appreciable ohmic or ambient heating during operation may experience loosening related to repeated cycling of connected loads or cycling of the ambient temperature environment. Bolted connectors, splices, and terminal blocks may loosen if subjected to significant thermally induced stress and cycling.

The design of these connections will account for the stresses associated with ohmic heating, thermal cycling, and dissimilar metal connections. Therefore, these stressors/mechanisms should not be a significant aging issue. However, confirmation of the lack of aging effects will be required.

This sampling program provides for one-time inspections that-will be completed priorJoitheý.

period of extended operation. The factors considered for sample selection are application:

(medium and low voltage), circuit loading (high loading), and location (high temperature;,:

high humidity, vibration, etc.). The-technical basis for the sample selection will be*-h *-r-,

documented. If an unacceptable condition or situation is identified in the selected sample, the corrective action program will be used to evaluate the condition and determine, appropriate' corrective action.

None of the connections in this program are subject to the environmental qualification requirements of 10 CFR 50.49. This plant-specific aging management program has been developed as an alternate to NUREG-1 801, XI.E6, to provide additional assurance that electrical cable connections will perform their intended function for the period of extended operation.

Evaluation and Technical Basis

1. Scope of Program: Non-EQ connections associated with cables in-scope of license renewal are part of this program. This program does not include the high voltage (> 35kV)'

switchyard connections. In-scope connections are evaluated for applicability of this program. The criteria for including connections in the program are that the connection is a bolted connection and is not covered under the EQ program or an existing preventive maintenance program.

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2. Preventive Actions: This one-time inspection program is a condition monitoring program; therefore, no actions are taken as part of this program to prevent or mitigate aging degradation.

3. ParametersMonitored/Inspected This program will focus on the metallic parts of the cable connections. The one-time inspection verifies that the loosening of bolted connections due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation is not an aging effect that requires a periodic aging management program.

4. Detection of Aging Effects: A representative sample of electrical connections within the scope of license renewal and subject to aging management review will be inspected or tested prior to the period of extended operation to verify there are no aging effects requiring management during the period of extended operation. The factors considered for sample selection will be application (medium and low voltage), circuit loading (high loading), and location (high temperature, high humidity, vibration, etc.). The technical basis for the sample selection will be documented. Inspection methods may include thermography, contact resistance testing, or other appropriate methods including visual inspection based on plant configuration and industry guidance. The one-time inspection provides additional confirmation to support industry operating experience that shows electrical connections have not experienced a high degree of failures, and that the existing installation and maintenance practices are effective.

5. Monitoring and Trending. Trending actions are not included as part of this program because this is a one-time inspection program.

6. Acceptance Criteria: The acceptance criteria for each inspection/surveillance are defined by the specific type of inspection or test performed for the specific type of cable connection.

Acceptance criteria ensure that the intended functions of the cable connections can be maintained consistent with the current lice*nsing basis.

7. Corrective Actions: Ifthe inspection or'.test acceptance criteria are not met, the corrective action. programr will be used to perform, an. evaluation that will consider extent of condition,-:'!

Sthe inications. ofagiig ý-effects, possible cha`n'ges to the one-timpinspection programi{Such" ii,iii.%:! ,ri*:i!;i'!

• ýas increased freqiiorcy an sapesz.As discussed. in the. appendix to.NURýEG~18Qtf tý,_he req u irem ents.,of 10, CFR Part 5,0, Apendix Bar acetbe tadrs.-the,.corrective.

atosThe Pilgrim Corrective Action Program,-which :i's ,implemented in accordance with..

the, .10,CFR 50 Appenfdix B requirements, applies to the Bolted Cable Connections-Program.

8. Confirmation Process: This attribute is discussed in Section B.0.3.

9. Administrative Controls: This attribute is discussed in Section B.0.3.

10. OperatingExperience: Operating experience has shown that loosening of connections and corrosion of connections could be a problem without proper installation and maintenance activities. Industry operating experience supports performing this one-time inspection program in lieu of a periodic testing program. This one-time inspection program will verify that the installation and maintenance activities are effective..

The Bolted Cable Connections Program is a new program. Plant and industry operating experience was considered when this program was developed. Industry operating experience that forms the basis for the program is described in the operating experience element of the NUREG-1801 Section XI.E6 program description. Pilgrim-specific operating 4

experience is consistent with the operating experience in the NUREG-1 801 Section XI.E6 program description.

Conclusion The Bolted Cable Connections Program will be effective for managing aging effects since it will incorporate proven monitoring techniques, acceptance criteria, corrective actions, and administrative controls. The Bolted Cable Connections Program will provide reasonable assurance that applicable cable connections will continue to perform their intended function consistent with the current licensing basis for the period of extended operation.

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