ML060170119

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Pilgrim, Issuance of Amendment Single Recirculation Loop Operation (TAC No. MC4333)
ML060170119
Person / Time
Site: Pilgrim
Issue date: 04/12/2006
From: Shea J J
NRC/NRR/ADRO/DORL/LPLA
To: Kansler M R
Entergy Nuclear Generation Co
SHea J J, 415-1388, NRR/DLPM
References
TAC MC4333
Download: ML060170119 (24)
v • d • e


Text

April 12, 2006 Mr. Michael KanslerPresident Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

PILGRIM NUCLEAR POWER STATION - ISSUANCE OF AMENDMENT RE: SINGLE RECIRCULATION LOOP OPERATION (TAC NO. MC 4333)

Dear Mr. Kansler:

The Commission has issued the enclosed Amendment No. 219 to Facility Operating License No. DPR-35 for the Pilgrim Nuclear Power Station (Pilgrim). The amendment consists of changes to the facility operating license, technical specifications (TSs) and surveillancerequirements in response to your application dated September 2, 2004, as supplemented byletters dated August 9, 2005, December 29, 2005 and March 22, 2006. This amendment allowscontinued plant operation with a single recirculation loop in-service at Pilgrim.A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included inthe Commission's biweekly Federal Register Notice. Sincerely,/RA/James J. Shea, Project ManagerPlant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-293

Enclosures:

1. Amendment No. 219 to License No. DPR-35
2. Safety Evaluationcc w/encls: See next page April 12, 2006Mr. Michael KanslerPresident Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

PILGRIM NUCLEAR POWER STATION - ISSUANCE OF AMENDMENT RE: SINGLE RECIRCULATION LOOP OPERATION (TAC NO. MC 4333)

Dear Mr. Kansler:

The Commission has issued the enclosed Amendment No. 219 to Facility Operating License No. DPR-35 for the Pilgrim Nuclear Power Station (Pilgrim). The amendment consists of changes to the facility operating license, technical specifications (TSs) and surveillancerequirements in response to your application dated September 2, 2004 as supplemented byletters dated August 9, 2005, December 29, 2005 and March 22, 2006. This amendment allowscontinued plant operation with a single recirculation loop in-service at Pilgrim.A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included inthe Commission's biweekly Federal Register Notice. Sincerely,/RA/James J. Shea, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-293

Enclosures:

1. Amendment No. 219 to License No. DPR-35
2. Safety Evaluationcc w/encls: See next page DISTRIBUTION
RidsNrrDorlLpLARidsRgn1MailCenterRidsOgcRPPUBLICLPLI-1 R/FRidsNrrLASLittleRidsNrrPMJSheaGHill (2)RidsAcrsAcnwMailCenter RidsNrrLADClarkeRidsNrrDirsItsbTFord RidsNrrDssSbwb RidsNrrDorlDprPackage Number: MLAmendment Number: ML060170119 TS Pages:OFFICELPL1-1/PMLPL1-1/LASBWB/BCITSB/BCOGCLPL1-1/BCNAMEJSheaSLittle(DClarke for)GCranstonTBoyceSHamrickRLauferDATE 1/26/06 1/26/0602/14/063/29/064/07/064/12/06 OFFICIAL RECORD COPY ENTERGY NUCLEAR GENERATION COMPANYENTERGY NUCLEAR OPERATIONS, INC.DOCKET NO. 50-293PILGRIM NUCLEAR POWER STATIONAMENDMENT TO FACILITY OPERATING LICENSEAmendment No. 219License No. DPR-351.The Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment filed by Entergy Nuclear Operations, Inc. (thelicensee) dated September 2, 2004, as supplemented by letters datedAugust 9, 2005, December 29, 2005 and March 22, 2006, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter1;B.The facility will operate in conformity with the application, the provisions of theAct, and the rules and regulations of the Commission;C.There is reasonable assurance: (i) that the activities authorized by thisamendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with theCommission's regulations;D.The issuance of this amendment will not be inimical to the common defense andsecurity or to the health and safety of the public; andE.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied.

2.Accordingly, the license is amended by changes to the Technical Specifications asindicated in the attachment to this license amendment, and paragraph 3.B of FacilityOperating License No. DPR-35 is hereby amended to read as follows:B.Technical SpecificationsThe Technical Specifications contained in Appendix A, as revised throughAmendment No. 219, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.3.This license amendment is effective as of the date of issuance and shall beimplemented within 120 days.FOR THE NUCLEAR REGULATORY COMMISSION/RA/Richard J. Laufer, ChiefPlant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License and Technical SpecificationsDate of Issuance: April 12, 2006 ATTACHMENT TO LICENSE AMENDMENT NO. 219FACILITY OPERATING LICENSE NO. DPR-35DOCKET NO. 50-293Replace the following page of the Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

RemoveInsert 33Replace the following pages of the Appendix A Technical Specifications with the attachedrevised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

RemoveInsert iiii 2-12-1 3/4.1-43/4.1-4 3/4.6-23/4.6-2 3/4.6-7 3/4.6-7 3/4.6-8 3/4.6-8 3/4.11-13/4.11-1 3/4.11-23/4.11-2 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TO AMENDMENT NO. 219 TO FACILITY OPERATING LICENSE NO. DPR-35ENTERGY NUCLEAR GENERATION COMPANYENTERGY NUCLEAR OPERATIONS, INC.PILGRIM NUCLEAR POWER STATIONDOCKET NO. 50-29

31.0INTRODUCTION

By letter to the Nuclear Regulatory Commission (NRC or Commission) dated September 2,2004 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML042640024) as supplemented by letters dated August 9, 2005 (ADAMS Accession No. ML052280246), December 29, 2005 (ADAMS Accession No. ML060090365) and March 22, 2006 (ADAMS Accession No. ML060900430), Entergy Nuclear Operations, Inc. (the licensee) submitted a request for changes to the Pilgrim Nuclear Power Station (Pilgrim) FacilityOperating License, Technical Specifications (TSs), and Surveillance Requirements (SRs). Therequested changes would allow continued plant operation with a single recirculation loop in service under certain specified conditions. The current Pilgrim Facility Operating License allowsfor 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in single-loop operation (SLO). The proposed changes would provide enhanced plant operations flexibility and are consistent with the improved standard technical specifications(STS), NUREG-1433, "Standard Technical Specifications - General Electric Plants, BWR/4,Revision 3."

2.0REGULATORY EVALUATION

The Commission's regulatory requirements related to the content of the TSs are set forth inTitle 10 of the Code of Federal Regulations (10 CFR) Section 50.36, "Technical specifications." This regulation requires that the TS include items in five specific categories. These categories include (1) safety limits, limiting safety system settings and limiting control settings, (2) limitingconditions for operation (LCOs), (3) SRs, (4) design features, and (5) administrative controls.

Additionally, Criterion 2 of 10 CFR 50.36(c)(2)(ii) requires a limiting condition for operation to be established for a process variable, design feature, or operating restriction that is an initialcondition of a design-basis accident (DBA) or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.Appendix A, "General Design Criteria [GDC] for Nuclear Power Plants," to 10 CFR Part 50, Criterion 10, "Reactor Designs," requires that the reactor core and associated coolant, control, and protective systems be designed with appropriate margins to assure that specifiedacceptable fuel design limits (SAFDLs) are not exceeded during normal operation and anticipated operational occurrences. Section 50.46, "Acceptance criteria for emergency core cooling systems [ECCS] for light-waternuclear power reactors," establishes the acceptance criteria for the design-basis loss-of-coolant accident (LOCA). Specifically, paragraph (b)(1) requires the calculated maximum fuel element cladding temperature to not exceed 2200 F.NUREG-0800, "Standard Review Plan (SRP)," Section 4.2, "Fuel System Design," defines thebasis for the acceptance criteria for NRC staff reviews. These criteria include three parts: (1) design bases that describe SAFDLs as depicted in GDC 10 to 10 CFR Part 50 Appendix A, (2) design evaluation that demonstrates that the design bases are met, and (3) testing,inspection, and surveillance plans that show that there is adequate monitoring and surveillanceof irradiated fuel. The design bases include (1) fuel system damage, (2) fuel rod failure, and (3) fuel coolability. The linear heat generation rate (LHGR) and average planar linear heatgeneration rate (APLHGR) limits are part of the SAFDLs.

3.0TECHNICAL EVALUATION

Power generation with a single recirculation loop in service is a recognized mode of operation forboiling water reactors (BWRs). Reactor control and operation in single-loop is very similar to that in two-loop recirculation mode. The primary difference is that as the drive flow on theoperating pump is increased, part of the total flow from the active jet pump loop will backflowthrough the inactive jet pumps. This effect reduces the net achievable core flow and limits the power level that can be achieved. The NRC staff previously disallowed this mode of operation for most plants. Accordingly, ingeneral, BWR TSs initially required shutdown within several hours if one of the reactor coolant loops became inoperable. The NRC staff primarily disallowed single recirculation loop operationbecause of jet pump vibration problems, and thermal-hydraulic stability concerns at certain highthermal power and low core flow operating conditions. Subsequently, the NRC staff issuedGeneric Letter (GL) 86-09, "Technical Resolution of Generic Issue No. B-59-(N-1) Loop Operation in BWRs and PWRs," dated March 31, 1986, to inform licensees that SLO would be acceptable provided operating limitations are imposed for the detection and suppression of thermal hydraulic instabilities.As part of the amendment submittal, the licensee included the General Electric (GE) Pilgrim SLOsafety evaluation (GE-SE), GE Report GE-NE-0000-0027-5301, "Pilgrim Nuclear Power Station Single Loop Operation," dated July 2004, that utilized NRC-approved methodologies andincluded operational restrictions on SLO at Pilgrim. The GE-SE report addressed specific Pilgrim jet pump vibration concerns, Pilgrim thermal-hydraulic stability concerns in addition to theSLO flow uncertainties and fuel thermal limits. 3.1 Existing and Proposed Pilgrim TS RequirementsThe following changes are proposed as part of this license amendment request:

3.2License Condition 3.EThe existing License Condition 3.E requires that the reactor not be operated for more than24 hours if one recirculation loop is out of service.

The licensee has proposed to delete this license condition that limits single recirculation loop operation at Pilgrim.3.3Safety Limit Minimum Critical Power Ratio (SLMCPR)The existing TS 2.1.2 requires that SLMCPR be greater than or equal to 1.06 for two-loopoperation (TLO) when reactor core flow is greater than or equal to 10 percent and steam dome pressure is greater than or equal to 785 pounds per square inch (psig) for the current fuel cycle. With single recirculation loop operation, there are increased uncertainties in total core flow andtraversing in-core probe (TIP) readings, therefore the licensee has proposed a conservative increase to the minimum critical power ratio (MCPR) for SLO. The licensee has proposed a MCPR increase of 0.02 for SLO. This would revise Pilgrim TS 2.1.2 SLMCPR to be greater than or equal to 1.08 for SLO in the current operating cycle (cycle-16) and would add a similarconservative value to subsequent fuel reload operating cycle SLMCPR values for Pilgrim SLO.3.4Thermal-Hydraulic StabilityThe existing TS 3.6.A.6, "Thermal-Hydraulic Stability," requires forced recirculation when corethermal power exceeds 25 percent. The licensee has proposed that this requirement be removed and incorporated into the proposedrevised TS 3/4.6.F, "Recirculation Loops Operating," which would ensure forced recirculationduring power operation with associated actions and SRs. The proposed revision to TS 3/4.6.F will apply when the plant is operating in either the Run orStart-up Mode. The proposed TS revision would therefore ensure thermal-hydraulic stability withforced recirculation during power operation at Pilgrim. The proposed changes are consistent with STS 3.4.1 and are more restrictive than the existing requirements in TS 3/4.6.A, "Thermaland Pressurization Limitations." 3.5Jet PumpsThe existing TS 3/4.6.E, "Jet Pumps," establishes the LCOs and SRs that ensure each jet pumpremains operable whenever the reactor is in the Startup or Run Mode. The licensee has proposed changes to the existing TS SR 3/4.6.E.1 based on the proposedremoval of License Condition 3.E. The existing SR can not be performed when the plant is operating in extended SLO. The proposed surveillance revision would provide for threeseparate, loop specific options for verifying jet pump operability. The proposed SRs areconsistent with STS SR 3.4.2.1.3.6Recirculation Loops OperatingThe existing TS 3/4.6.F, "Jet Pump Flow Mismatch," establishes the operating restrictionsapplicable to recirculation loop operation. The licensee has proposed changes to these requirements based on theproposed removal ofLicense Condition 3.E. The licensee would include additional recirculation loop operating restrictions to address SLO conditions. The proposed changes would incorporate SLOrestrictions, revise the TS title, and identify revised actions and action time limits if compliance is not achieved. The proposed TS changes are based on STS 3.4.1, "Recirculation Loops Operating."3.7TS 3/4.11 - Reactor Fuel AssemblyThe existing TS 3/4.11, "Reactor Fuel Assembly," establishes operating restrictions applicable tofuel rod thermal limits. The proposed revisions to TS 3/4.11.A, "Average Planar Linear Heat Generation Rate(APLHGR)," TS 3/4.11.B, "Linear Heat Generation Rate (LHGR)," and TS 3/4.11.C, "MinimalCritical Power Ratio (MCPR)," would clarify applicability for SLO and would be more consistentwith STS 3.2.1, 3.2.2, and 3.2.3.3.7.1Average Planar Linear Heat Generation Rate (APLHGR)

The existing TS 3/4.11.A is applicable during operation with both recirculating pumps operating. The licensee has proposed changes to these requirements based on the proposed removal ofLicense Condition 3.E. TS LCO 3/4.11.A would require a change to delete the reference to"both recirculation pumps operating." Additionally, APLHGR restrictions only apply when the reactor is operating and rated thermal power is greater than or equal to 25 percent. The licensee proposed to change the LCO wording to include a statement that the TS applies whenrated thermal power is greater than or equal to 25 percent. This would make the LCO consistent with STS 3.2.1. The existing TS also requires a plant shutdown to cold shutdown conditions within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> if itis determined that the APLHGR limit is exceeded. The proposed revised TS would require a thermal power reduction to less than 25 percent if the limiting value for APLHGR is exceeded, thermal power must be reduced to the point where the TS is not applicable within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> in the proposed TS change. This proposed TS revision would also be consistent with STS 3.2.1.3.7.2Linear Heat Generation Rate (LHGR) and Minimum Critical Power Ratio (MCPR)

The existing TS 3/4.11.B and 3/4.11.C, are applicable during power operation that is notspecified but is implied to be greater than or equal to 25 percent power because the SR requires a daily check of these limits when reactor thermal power is greater than or equal to 25 percent.The licensee proposed to make TS 3/4.11.B and TS 3/4.11.C.1 consistent with STS 3.2.2 andSTS 3.2.3 by incorporating the 25 percent thermal power applicability for these TS in the LCO. The licensee also proposed an administrative change to update SR 4.11.C.1, "Minimum CriticalPower Ratio (MCPR)," to identify that MCPR shall be determined daily during reactor operation at greater than or equal to 25 percent rated thermal power. The existing TS 4.11.C.1inadvertently required the MCPR surveillance only to be performed at greater than 25 percentrated thermal power.3.8Table of Contents Administrative Changes The Table of Contents would be updated to reflect the title revision to TS 3/4.6.F and to removereference to two previously deleted TS sections, TS 3/4.6.H and TS 3/4.6.I. The TS reference to TS 3/4.6.H would also be deleted from TS page 3/4.6.8.4.0STAFF EVALUATION The reactor coolant recirculati on system provides forced coolant flow through the reactor coreand, in combination with control rods, provides a means to control and change reactor power and power distribution over a broad range. The recirculation system consists of two recirculationpump loops and drive units, each with a separate variable speed motor generator (MG) set, recirculation pump, and piping loop. The individual recirculation pumps are located in the drywelland provide drive flow to the jet pumps, inside the reactor vessel, which in turn provide core recirculation flow.During normal power operation both recirculation pumps are operated at near-matched speedsto provide forced recirculation flow. Recirculation pump speed and flow can be changed using the variable speed recirculation system MG se t and, thus, be used to change core power.Chapter 4.3 of the Pilgrim Final Safety Analysis Report (FSAR) states that operation with asingle recirculation loop is possible at reduced power. Power generation with a single recirculation loop in service is also a recognized mode of operation for BWRs and many BWRs have TSs that allow for SLO.The most obvious benefit of adding an allowance for SLO is the ability to continue poweroperation in the event of the loss of a recirculation loop due to component malfunction. Severalactive components in the recirculation system are located in the reactor building and are readilyaccessible during power operation. These include the MG set drive motors, fluid couplers, generators, and associated oil coolers. Also accessible are the recirculation system controllers,logic relaying, and system electrical panels and breakers. Typically, most of these componentscan be repaired with the reactor in service with no impact on power operation other than the unavailability of the affected loop itself.While the reactor recirculation system is a reliable system, temporary unavailability of arecirculating loop is occasionally experienced. Current Facility Operating License Condition 3.Erestricts reactor operation with one recirculation loop out of service for a period up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

It is not always possible to diagnose and repair the accessible recirculation system components within these time frames. The most recent unplanned recirculati on system TS requiredshutdown at Pilgrim occurred in February 2002 due to an MG set generator field wiring failure.

The repair could not be diagnosed, planned, and implemented within the LCO time frame currently allowed. The primary difference between SLO and TLO concerning reactor control and operation is thatthe maximum achievable power level is reduced for SLO because of the reduction in total core flow. Drive flow on the operating pump is increased and part of the total flow from the active jet pump loop will backflow through the inactive jet pumps. This affects the normal relationshipbetween drive flow and core flow as compared to TLO.The primary analysis of the safety considerations in support of the proposed Pilgrim SLO TS ispresented in the GE-SE report. This report was prepared for the purpose of evaluating the effects of SLO on the plant transient and accident analyses. The basic conclusion of this reportis that the plant can be operated safely in SLO mode for an unrestricted period of time provided that operation is controlled in accordance with specified operational restrictions and safety settings established for SLO operation at Pilgrim.Although it is not a currently permitted mode of operation, SLO has been included as anoperating flexibility option in the cycle-specific core reload analyses that are performed for eachfuel cycle. These analyses are performed in accordance with the latest NRC-approved versionof GE Licensing Topical Report, NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel."4.1Pilgrim Extended Single Loop Operation4.1.1Pilgrim and BWR Reactor Stability ConsiderationsThe primary contributing factors to the stability performance with one recirculation loop not inservice are the power-flow ratio and the recirculation loop characteristics. For low core flows occurring at minimum pump speed, the jet pumps for both recirculation loops will exhibit forwardflow. At higher pump speeds, the core flow is increased in SLO and the inactive jet pump forward flow decreases with increasing core flow. The reduced flow in the inactive loop reduces the resistance that the recirculation loops impose on the reactor water flow perturbations,thereby adding a destabilizing effect. At the same time, the increased flow results in a lowerpower-flow ratio, which has a stabilizing effect. These countering effects result in a slightlydecreased stability margin (higher decay ratio) initially as core flow is increased (from minimum)in SLO, and then an increase in stability margin (lower decay ratio) as the core flow is increasedfurther and reverse flow in the inactive loop is established.As core flow is increased beyond 40 percent of rated flow during SLO, reverse flow begins in theinactive loop. A cross flow is established in the annular downcomer region near the jet pump suction entrance caused by the reverse flow of the inactive recirculation loop. At higher flow, with substantial reverse flow in the inactive recirculation loop, the effect of cross flow results in an increase in system noise which increases the total core flow noise which tends to increaseobserved neutron flux noise.GE has evaluated the SLO effects on stability, including increased noise, and determined thatstability characteristics are not significantly different from TLO conditions. At low core flow, SLOmay be slightly less stable than TLO, but as core flow increased and reverse flow is established, the stability performance of TLO and SLO is similar.Because of generic stability concerns and the experience of some BWRs regarding the potentialfor power oscillations at low flow/high power operating map conditions, the NRC staff issuedBulletin No. 88-07, "Power Oscillations in Boiling Water Reactors," which was supplemented inDecember 1988.Bulletin 88-07, Supplement 1, requested licensees to adopt the BWR OwnersGroup (BWROG) stability monitoring guidelines similar to those originally issued by GE inServices Information Letter (SIL) 380, Revision 1, "BWR Thermal-Hydraulic Stability," datedFebruary 1984. The NRC staff later requested licensees to address long-term solutions forthermal-hydraulic instabilities in GL 94-02, "Long-Term Solutions and Upgrade of InterimOperating Recommendations for Thermal-Hydraulic Instabilities in BWRs," dated July 11, 1994. In GL 94-02, the NRC staff requested licensees to update operating procedures and provide operator training to address detection and suppression of power oscillations based on morerecent operating experiences and revised BWROG guidelines.In response to the above-referenced NRC staff operating guidance, the BWROG developedlicensing strategies and methodologies to provide a long-term resolution for thermal-hydraulic instability. Initially, NEDO-31960-A and NEDO-31960-A, Supplement 1, "BWR Owners GroupLong-Term Stability Solutions Licensing Methodology," dated November 1995, were submitted toand approved by the NRC staff in 1993. The BWROG subsequently developed specific reportsto address selected options for addressing thermal-hydraulic stability. NEDO-32339-A, "ReactorStability Long Solution: Enhanced Option 1-A," and associated Supplements 1, 2, 3, and 4,dated April 1998, addresses Stability Option E1A, and NEDO-32465-A, "Reactor Stability Detectand Suppress Solutions Licensing Basis Methodology for Reload Applications (Options 1D and III)," dated August 1996, addresses Stability Option 1D. The NRC staff has specifically reviewedthese reports and has approved the referenced stability monitoring and protectionmethodologies.At the time the license amendment request was submitted, Pilgrim relied on administrativecontrols and plant hardware to enforce the protection methods described in Stability Option E1A. The licensee stated in its amendment request that it was pursuing a plant modification to adopt the protection features defined in Stability Option 1D. The NRC staff understands that Pilgrim implemented Stability Option 1D during the refuelingoutage completed in May 2005. Since thermal-hydraulic stability protection is not predicated onthe number of recirculation loops in service, either Stability Option E1A or 1D will provideadequate core protection from thermal-hydraulic instabilities when operating in the SLOoperating mode.Current Pilgrim TS 3.11.D - Power / Flow Relationship During Power Operation, requires that thePilgrim power to flow relationship shall not exceed the limiting values specified in the COLR.

Power and flow restrictions determined from the stability analysis are incorporated in the PilgrimCOLR power-flow map. This TS is not changing as part of this amendment. 4.1.2Reactor Internal Vibration during SLO In SLO mode, increases in average power range monitor (APRM) noise and core delta-pfluctuations have been observed in some plants while operating at high drive flows which may be associated with increased vibration of the active jet pumps. The impact of jet pump vibration during SLO was evaluated to ensure reactor internal vibration levels are maintained at acceptable levels.The GE-SE report, Section 7, identifies that SLO operation will be restricted to operation belowthe 100 percent current licensed thermal power (CLTP) rod line with a maximum power limit of 65 percent of rated power (2028 MegaWatts thermal (MWt)) and a maximum core flow limit of 52 percent of rated flow (69 million pound mass per hr (Mlb/hr)) to ensure vibration is maintainedat acceptable levels. These SLO operating limits will be identified in the COLR. TS 3.11.Daddresses the power-flow map and ensures that the limiting values identified in the COLR arenot exceeded. The SLO pump operating restrictions defined in the COLR will be reviewed foradequacy by the licensee for each subsequent reload cycle and these limits would beincorporated into appropriate operating procedures as required. In addition to the GE evaluation, a separate evaluation of the effects of SLO on the structuralintegrity of the reactor vessel and associated internal components was performed and documented in Structural Integrity Associates (SIA) Inc., Report SIR-04-026, Rev. 2, "Evaluation of Single Loop Operation at Pilgrim Nuclear Power Station," dated June 2004. The SIA reportaddresses structural integrity via the evaluation of TLO and SLO vibration data. This data wasobtained from the plant start-up program, 30 years of successful operation at 100 percent power, operating data obtained with the plant operating in SLO mode, and detailed jet pumpinspections performed during recent refueling outages (RFOs). The report concludes that SLO operation is acceptable from a structural analysis standpoint since the vibration levels observed in the core for a single operating recirculation pump are enveloped by the vibration levels observed for TLO at 100 percent power.The SIA report also identifies that the jet pumps are typically the component of most concernwith respect to vibration because of high internal flow and RPV annulus downcomer flow rates, which can lead to significant vibratory response. The report documents that jet pump inspection history since RFO-11 (February 1996) has been extensive and has not detected the presence of any cracking in the jet pump welds. A detailed evaluation of the jet pump swing gate gaps was also performed and found to be structurally acceptable based on vibration frequency and harmonic analyses, which revealed that the jet pumps are nominally stressed to acceptable levels.The evaluations of the Pilgrim vibration response provide reasonable assurance that SLO wouldnot result in significant adverse vibration effects. Therefore, the NRC staff finds that conti nuedplant operation with a single recirc loop in-service is acceptable. 4.1.3Abnormal Operational Transients Analyzed for SLO The reactor response to abnormal operational transients (AOOs) are generally independent ofthe source of the core flow. Therefore, the consequences of an event initiated while in SLO willbe the same as the consequences of an event initiated from TLO. The highest allowable core flow, with one active pump is 52 percent and the maximum power is limited to 65 percent due to vessel internal vibration limitations. The core-wide transients potentially impacted by SLO were evaluated in Section 4 of the GE-SE report. The evaluation concludes that the consequences ofthe abnormal operating transients (pressurization, flow increase, cold water injection events) were less severe than the same events analyzed for two-loop mode, and thus were bounded by the two-loop analyses in the updated final safety analysis report (UFSAR).The cycle-specific reload analyses performed by Global Nuclear Fuels Inc. (GNF) considers SLOan operating flexibility option that is evaluated in accordance with the methods described inNEDE-24011-P-A. The operational limiting MCPR (OLMCPR) with an SLO MCPR adder, as specified in the COLR,was evaluated by the NRC staff and found to provide adequate protection for transients initiatedduring SLO.4.1.4Accident Evaluation for SLO An evaluation of the SLO effects on applicable accident analyses is provided in GE-SE report. The LOCA and recirculation pump seizure events were evaluated since the remaining Chapter14 UFSAR accidents are not significantly affected by recirculation mode or are bounded by two-loop accident analysis.The postulated recirculation pump seizure accident is evaluated in GE-SE report, Section 4.1.5,and is characterized by a near instantaneous stoppage of the pump and the associated pump flow. With sudden stagnation of the drive flow, the active loop flow rapidly decreases, and the resultant core flow decreases causing the core void fraction to increase which in turn causes a rapid decrease in core power. The purpose of the analysis is to ensure that the radiological consequences of the event are acceptable. The analyses referenced in the GE report indicate that the MCPR will remain greater than the SLMCPR, and that the event will terminate with thereactor continuing to operate in natural circulati on. A cycle independent OLMCPR wascalculated for a recirculation pump seizure event when operating in SLO. This value was verified for Cycle 15 and will be reevaluated for each subsequent core reload in the cyclespecific supplemental reload licensing report. Based on the analyses performed, recirculation pump seizure is not a limiting event and will not result in fuel entering boiling transition. Consequently, radiological release is avoided and there is no challenge to 10 CFR 100, "Reactor Site Criteria," radiation release limits.A summary of ECCS performance during a LOCA when operating in SLO is provided inSection 6 of the GE-SE report. This report references NEDC-31852 Revision 2, which describes the SAFER/GESTR-LOCA analysis performed for Pilgrim. The DBA-LOCA analysis for Pilgrim relied on SAFER/GESTR codes and methodology for performing LOCA analyses. With breaks smaller than the DBA, there is a longer period of nucleate and/or film boiling prior to fueluncovery to remove the fuel's stored energy. This analysis report provides the results of LOCA analysis for SLO and concludes that the DBA (large breaks) are more severe than small break sequences and, therefore, the large break results are bounding for SLO. The analysis resulted in an SLO planar linear heat generation rate/maximum average planar heat generation rate (PLHGR/MAPLHGR) multiplier of 0.8 for both GE-11 and GE-14 fuel. The calculated Appendix K peak cladding temperatures (PCT's) using these PLHGR/MAPLHGR multipliers are below the 10 CFR 50.46 limit of 2200 F. Therefore, the calculated SLO PLHGR/MAPLHGR multipliersare conservative and assure that the SLO results satisfy the acceptance criteria of 10 CFR 50.46

and NRC safety evaluation report (SER) requirements for the SAFER/GESTR applicationmethodology.Following approval of the proposed SLO TS, the PLHGR/MAPLHGR SLO multiplier will bedocumented in the COLR report and the plant process computer will be programmed to applythe SLO PLHGR/MAPLHGR multiplier when calculating core thermal limits while in SLO mode to support the analysis assumptions. Based on the discussion above, the NRC staff found that the DBA analysis for SLO at Pilgrimwas bounding and that approved NRC methodologies were used to determine a conservativePLHGR/MAPLHGR multiplier that when coupled with the Appendix K assumptions yields PCT values below the 10 CFR 50.46 PCT limit of 2200 F for Pilgrim SLO. 4.1.5 Rod Withdrawal Error Analysis for SLO The rod withdrawal error (RWE) evaluations are independent of the source of core flow (i.e., onerecirculation loop or two) and consequently, these evaluations are valid for both TLO and SLO.

RWE is evaluated each fuel cycle as part of the cycle-specific reload analysis. The NRC staff reviewed the Pilgrim RWE event for SLO and like the AOOs, this postulatedevent is bounded by the TLO RWE evaluations. 4.1.6 Flow-Biased APRM Scram and Rod Block Limits during SLO Cycle-specific flow-biased APRM rod block and scram setpoints are calculated to define thescram trip and rod block limits. The cycle-specific APRM scram trip and rod block limits aredefined on the power-flow map provided in the COLR. For SLO, the flow-biased APRM scram trip and rod block setpoints must be adjusted to account for the change in the relationship between drive flow and core flow due to reverse flow in the inactive loop jet pumps and lower core hydraulic resistance. GE-SE report, Section 4.1.6 identifies the equations used to correct the flow-biased APRM scram trip and rod block set-points for extended SLO at Pilgrim.Pilgrim is currently in operating cycle 16. When the amendment is implemented the COLR willidentify the revised SLO APRM setpoints. Pilgrim TS 3.11.D and the revised TS 3.6.F.2.censures that the plant will be operated in accordance with the power-flow map, which will bereset, in accordance with TS table 3.1.1. note 15, to reflect APRM setpoint revisions for SLO. In the plant, flow control trip reference (FCTR) cards will be updated to enforce SLO. After loss ofa recirculation loop, operator action will be required to manipulate a FCTR card toggle switchwithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to adjust or reset the APRM scram trip and rod block setpoint limits for SLO operation. The time period to make the SLO adjustments is consistent with STS 3.4.1.The APRM setpoint revision process for SLO utilizes a verified 10 percent bounding drive flowvalue difference between SLO and TLO at the same core flow. The NRC staff considers this aconservative and appropriate means to determine SLO APRM flow-biased setpoints. 4.2Pilgrim License Condition 3.E The proposed license condition change would eliminate the 24-hour SLO restriction on Pilgrimplant operations. The NRC staff has previously determined that SLO is generically acceptableas described in GL 86-09 and is recognized as a standard mode of operation addressed in the STS. Specifically, Pilgrim SLO was evaluated by GE in the GE-SE report which considered fuelcladding SLMCPR, plant transients, reactor stability, reactor internal vibrations, abnormaloperational transients (AOOs), and accident analysis. These analyses applied conservative core flow and TIP reading uncertainties to determine applicable operational restrictions. The analysis methods employed were also based on NRC-approved methodologies. The results of these evaluations justifies extended SLO for Pilgrim within the restrictions as outlined in the GE-SEreport and the licensee's submittal. The NRC staff, therefore, finds this change to the PilgrimFacility Operating License acceptable. 4.3Safety Limit Minimum Critical Power Ratio4.3.1Pilgrim Safety Limit TS 2.1.2 The SLMCPR is established such that during abnormal operational reactor transients, no fueldamage will occur due to transition boiling if the SLMCPR limit is not violated. The SLMCPRlimit is calculated using a statistical model that includes considerations for uncertainties. For SLO, as discussed in the GE-SE report, the SLMCPR would increase by 0.02 to provide additional margin due to uncertainties in the total core flow and TIP readings compared to TLO.

Pilgrim states that except for these readings, the uncertainties used in the statistical analysis forSLMCPR are not dependent on whether core flow is provided by one or two recirculation pumps.The net effect of the revised core flow and TIP uncertainties is an increase in SLMCPR of 0.02for SLO operation. This is the value included in the proposed change to TS 2.1.2 for the currentoperating cycle (cycle -16). This SLO SLMCPR limit will be revised, should the proposedSLMCPR limit of 0.02 become non-conservative, based on the evaluations performed for each subsequent core reload.The plant process computer will be updated with revised input data to allow for calculation ofMCPR and fuel-specific MCPR operating limits applicable to SLO. Existing TS 3.11.C provides the requirements for monitoring MCPR and relies on the core operating limits report (COLR) to define the fuel OLMCPR limits. Pilgrim states that by maintaining MCPR greater than or equal to the OLMCPR, the SLMCPR specified in TS 2.1.2 will not be challenged in the event of themost limiting transient.The NRC staff finds that an SLMCPR increase of 0.02 along with the fuel-specific changes tothe OLMCPR limits is a conservative adjustment to account for the core flow and TIP reading uncertainties while in extended SLO. Therefore the proposed change to Pilgrim TS 2.1.2 SLMCPR to greater than or equal to 1.08 for SLO in the current operating cycle (cycle -16) isacceptable. Subsequent operating cycle evaluations will be done to ensure that the SLMCPRand SLO SLMCPR remains conservative. 4.4Thermal-Hydraulic Stability TS 3.6.A.6 The licensee has proposed that the current requirement of forced circulation when rated thermalpower is above 25 percent be deleted and incorporated into the revised TS 3.6.F. The currentTS did not identify a required action or required surveillance if the LCO was not met. RevisedTS 3.6.F includes the requirement for ensuring core flow during power operation as well as a required shutdown action and associated completion time limit. The revised Pilgrim TS 3.6.F is more restrictive because forced recirculation would be required at power operations, prior to reaching 25 percent power; this change is also consistent with the STS. The NRC staff,therefore, finds these changes to the Pilgrim stability TS acceptable. 4.5Jet Pump Operability 4.5.1Jet Pump SLO ConsiderationsThe recirculation pump speed operating characteristics (pump flow and loop flow versus pumpspeed) are determined by the flow resistance from the loop suction through the jet pump nozzles. A change in the relationship indicates a plug, flow restriction, loss in pump hydraulic performance, leakage, or new flow path between the recirculation pump discharge and jet pumpnozzle. For this criterion, the pump flow and loop flow versus pump speed relationship must be verified.Individual jet pumps in a recirculation loop normally do not have the same flow. The unequalflow is due to the drive flow manifold, which does not distribute flow equally to all risers. The flow (or jet pump diffuser to lower plenum differential pressure) pattern or the relationship of one jet pump to the loop average is repeatable. An appreciable change in this relationship is an indication that increased (or reduced) resistance has occurred in one of the jet pumps. This may be indicated by an increase in the relative flow for a jet pump that has experienced beam cracks.The deviations from normal are considered indicative of a potential problem in the recirculationdrive flow or jet pump system. Normal flow ranges and established jet pump flow and differentialpressure patterns are established by plotting historical data as discussed in GE SIL No. 330, "Jet Pump Beam Cracks," dated June 9, 1980.4.5.2Jet Pump TS 4.6.E The licensee has proposed a change to the Pilgrim jet pump TSs to ensure that jet pump SRscan be performed under either SLO or TLO operating conditions. With the proposed removal of License Condition 3.E, existing TS SR 4.6.E.1 can not be performed when the plant is operatingin SLO. The proposed TS SR revision would provide three separate, loop-specific options to verify jet pump operability. The changes to TS SR 4.6.E.1 will provide adequate indications ofjet pump operability and are consistent with STS. Therefore, the NRC staff finds these c hangesare acceptable for Pilgrim SLO. 4.5.3Jet Pump TS 3.6.E The licensee proposed to change the Pilgrim TS 3.6.E.1, LCO action time limit from "be in ColdShutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" to "be in Hot Shutdown in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />." The completion time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is reasonable based on operating experience to complete shutdown actions in an orderly manner without challenging plant systems. These revisions are more restrictive and areconsistent with STS 3.4.2 actions and required time limits. Therefore, the NRC staff finds thesechanges are acceptable.An editorial change was also proposed that would capitalize "Startup and Run Modes" and"Operable" in TS 3.6.E.1. The NRC staff finds these minor editorial changes acceptable. 4.6Recirculation Loop Operating Restrictions4.6.1TS 3/4.6.F - Jet Pump Flow MismatchThese TSs contain the LCO and SR conditions applicable to the Pilgrim recirculation loopsduring power operation. Based on the proposed removal of License Condition 3.E, the licenseewould modify TS 3/4.6.F to incorporate the SLO requirements identified in STS 3.4.1. The titles of TS 3/4.6.F were changed to "Recirculation Loops Operating" and a mode switchrestriction was also incorporated into revised TS 3.6.F, consistent with STS 3.4.1. The LCOapplies when the reactor mode switch is in either Run or Startup, which are the operating modeswhere control of the recirculation pumps is required.TS 3.6.F.1 will not be revised. This TS ensures that recirculation loop TLO operation isconforming to the accident analyses previously evaluated for LOCA and low pressure core injection (LPCI) loop select logic. Maintaining matched recirculation pump speeds (and drive flows) within limits is consistent with the restrictions defined in STS 3.4.1 for TLO operation.New TS limits applicable to recirculation loop operating restrictions for SLO were determinedbased on the LCO limits defined in STS 3.4.1. These new SLO limits reference reactor fuel LCO limits established for APLHGR (TS 3/4.11.A) and MCPR (TS 3/4.11.C), and the APRM high fluxtrip setting (as defined in TS Table 3.1.1). In accordance with the proposed TS, calculated values for SLO will be located in the COLR.The revised TS 3.6.F.3 identifies the required actions for restoration of compliance to TS 3.6.F.1and TS 3.6.F.2. A 24-hour completion time limit to restore compliance is proposed. If compliance cannot be achieved or no recirculation pumps are operating, action to be in hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is required. The required action and completion times are consistent with STS 3.4.1. The 24-hour limit to achieve compliance is justified based on engineering judgment of the likelihood of a transient or DBA occurring, while providing time for deliberate controlled operator action. The 12-hour shutdown requirement is acceptable based on operatingexperience related to actions necessary to shutdown the plant in an orderly manner without challenging plant systems. The NRC staff finds the revised Pilgrim recirculation loop operability requirements are lessrestrictive than the current TSs, with regards to allowed out of service time. However, the revision puts specific restrictions on SLO consistent with the GE-SE report and the STS, therefore the NRC staff finds these changes to TS Section 3/4.6.F acceptable. 4.7Reactor Fuel Assembly4.7.1Pilgrim TS 3/4.11 The licensee has proposed revisions to TS 3.11.A, TS 3.11.B, and TS 3.11.C to clarify TS LCOapplicability and to provide for consistency with STS 3.

2.1, 3.2.2, and 3.2.3. TS 4.11.C wasrevised to make an editorial correction to the specified power level. 4.7.2Pilgrim TS 3/4.11 ApplicabilityThe proposed revisions would explicitly state that when the reactor is operated below 25 percentrated thermal power, compliance with the reactor fuel limit LCOs are not required. APLHGR, MCPR and LHGR limits are derived from fuel design evaluations and LOCA and transient analyses that are assumed to occur at high power levels. Design calculations and operating experience have shown that when power is reduced, the margin to the required fuel limits increases. When below 25-percent rated thermal power, the reactor is operating with substantialmargin and as a result, the LCO is not required. This LCO applicability restriction is consistentwith the STS.4.7.3Pilgrim TS 3/4.11 Action Requirements The proposed revisions would also specify prompt action if the reactor fuel limits are not incompliance with TSs. The 2-hour requirement to restore fuel limits to prescribed TS limits is sufficient. If compliance can not be achieved, a 4-hour action to bring the plant to a safe condition, less than 25 percent power, would be required. The LCO is not applicable when power is less than 25 percent. These time limitations are more restrictive than the current TS required shutdown in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> if thermal limits cannot be restored. The time to take the action is acceptable due to the reduced likelihood of a transient or DBA occurring within these imposed time constraints. The proposed revisions to Pilgrim's reactor fuel assembly themal limit TSs are more restrictiveand the applicable plant thermal limits for SLO were based on NRC-approved methodologiesand the GE-SE report. The GE-SE report describes the process for determining the conservative correction factors used to calculate the thermal limits for SLO, these would be included in the Pilgrim COLR for the current cycle (cycle -16) and subsequent fuel cycles. These changes are consistent with the STS and therefore, the NRC staff finds the revisions toPilgrim TS 3.11.A, B, C and 4.11.C acceptable.

4.8Editorial TS ChangesA revision to the Table of Contents was proposed to remove reference to two previously deleted TS sections, TS 3/4.6.H and TS 3/4.6.I. These TS sections were deleted and the TS sectionnumber is not required to maintain the TS 3/4.6 number sequence. Reference to TS 3/4.6.Hwas also deleted from TS page 3/4.6.8.4.9NRC Staff Evaluation SummaryThe NRC staff has reviewed the reports submitted by Pilgrim for SLO operation and concludesthat appropriate material was submitted and that the fuel design, the nuclear design, thethermal-hydraulic design, and the transient and accident analyses are acceptable. Further, theNRC staff reviewed the licensee's submittal and determined the licensee's analyses were basedon NRC-approved methodologies. Based on the above discussion, the NRC staff concludes that the proposed SLO operation withthe proposed operating limits are adequate to detect and suppress thermal-hydraulic instabilities. Therefore, the NRC staff finds the licensee's proposed TS changes acceptable.

5.0STATE CONSULTATION

In accordance with the Commission's regulations, the Massachusetts State official was notifiedof the proposed issuance of the amendment. The State official had no comments.

6.0ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facilitycomponent located within the restricted area as defined in 10 CFR Part 20 and SRs. The NRC staff has determined that the amendment involves no significant increase in the amounts, andno significant change in the types, of any effluents that may be released offsite, and that there isno significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (69 FR 76490; December 21, 2004). Accordingly, the amendment meets the eligibility criteria forcategorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

7.0 CONCLUSION

The NRC staff concludes, based on the considerations discussed above, that: (1) there isreasonable assurance that the health and safety of the public will not be endangered byoperation in the proposed manner, (2) such activities will be conducted in compliance with theCommission's regulations, and (3) the issuance of the amendment will not be inimical to thecommon defense and security or to the health and safety of the public.Principal Contributor: T. Ford Date: April 12, 2006 Pilgrim Nuclear Power Station cc:

Regional Administrator, Region IU. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415Senior Resident InspectorU. S. Nuclear Regulatory Commission Pilgrim Nuclear Power Station Post Office Box 867 Plymouth, MA 02360Chairman, Board of Selectmen11 Lincoln Street Plymouth, MA 02360ChairmanNuclear Matters Committee Town Hall 11 Lincoln Street Plymouth, MA 02360Chairman, Duxbury Board of SelectmenTown Hall 878 Tremont Street Duxbury, MA 02332Office of the CommissionerMassachusetts Department of Environmental Protection One Winter Street Boston, MA 02108Office of the Attorney GeneralOne Ashburton Place 20th Floor Boston, MA 02108Director, Radiation Control ProgramCommonwealth of Massachusetts Executive Offices of Health and Human Services 174 Portland Street Boston, MA 02114Secretary of Public SafetyExecutive Office of Public Safety One Ashburton Place Boston, MA 02108 Director, Massachusetts EmergencyManagement Agency Attn: James Muckerheide 400 Worcester Road Framingham, MA 01702-5399Mr. William D. MeinertNuclear Engineer Massachusetts Municipal Wholesale Electric Company

P.O. Box 426 Ludlow, MA 01056-0426Mr. Michael A. BalduzziSite Vice President Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill RoadPlymouth, MA 02360-5508Mr. Stephen J. BethayDirector, Nuclear Assessment Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill RoadPlymouth, MA 02360-5508Mr. Bryan S. FordManager, Licensing Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill RoadPlymouth, MA 02360-5508Ms. Charlene D. FaisonManager, Licensing Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

Pilgrim Nuclear Power Station cc:

Mr. Gary J. Taylor Chief Executive Officer Entergy Operations 1340 Echelon Parkway Jackson, MS 39213Mr. John T. HerronSr. VP and Chief Operating Officer Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. Danny L. PaceVice President, Engineering Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. Brian O'GradyVice President, Operations Support Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. John F. McCannDirector, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

Mr. Michael J. Colomb Director of Oversight Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. Travis C. McCulloughAssistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. John M. Fulton Assistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Ms. Stacey LousteauTreasury Department Entergy Services, Inc.

639 Loyola Avenue New Orleans, LA 70113Mr. James SniezekBWR SRC Consultant 5486 Nithsdale Drive Salisbury, MD 21801Mr. Michael D. LysterBWR SRC Consultant 5931 Barclay Lane Naples, FL 34110-7306

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