ML072470403

License Renewal Application Amendment 20

ML072470403
Person / Time
Site:	Pilgrim
Issue date:	08/28/2007
From:	Bethay S Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.07.073, TAC MC9660
Download: ML072470403 (4)

Text

5088308055 LICENSING 09:14:40 a.m. .09-04-2007 1/4 EEntergy Nuclear Operations, Inc.Pilgrim Nuclear Power Statior 600 Rocky Hill Road Plymouth, MA 02360 Stephen J. Bethay August 28, 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 20

REFERENCES:

1. Entergy Letter, License Renewal Application, dated January 25, 2006 (TAC MC9669)2. Entergy Letter, License Renewal Application Amendment 19, dated July 30, 2007 LETTER NUMBER: 2.07.073

Dear Sir or Madam:

In Reference 1, Entergy Nuclear Operations, Inc. applied for renewal of the Pilgrim Nuclear Power Station operating license.Attachment A provides supplemental information for Entergy's response to NRC request for additional information (RAI) provided by Reference 2 associated with license renewal application (LRA) commitment

1. 31. Attachment B provides changes to LRA Appendix A.2.2.2.3.

This letter contains no regulatory commitments.

If you have questions regarding this subject, please contact me at (508) 830-7800.I declare under penalty of perjury that the foregoing is true and correct. Executed on August 28, 2007.Sincerely, 6Stee J.Bthay4 Director, Nuclear Safety Assessment ERS/dI Attachments Attachment A: Supplemental Information for the Entergy Response to the NRC Request for Additional Information 4.3.3-1 Related to Pilgrim LRA Commitment

1. 31 Attachment B: Changes to LRA Appendix A.2.2.2.3 5088308055 LICENSING 09:15:08 a~m. 09-04-2007 2/4 Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station Letter Number: 2.07.073 Page 2 cc: with Attachments Mr. Perry Buckberg Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Alicia Williamson Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Susan L. Uttal, Esq.Office of the General Counsel U.S. Nuclear Regulatory Commission Mail Stop 0-15 D21 Washington, DC 20555-0001 Sheila Slocum Hollis, Esq.Duane Morris LLP 1667 K Street N.W., Suite 700 Washington, DC 20006 cc: without Attachments Mr. James S. Kim, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission One White Flint North O-8C2 11555 Rockville Pike Rockville, MD 20852 Mr. Jack Strosnider, Director Office of Nuclear Material and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-00001 Mr. Samuel J. Collins, Administrator Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 NRC Resident Inspector Pilgrim Nuclear Power Station Mr. Joseph Rogers Commonwealth of Massachusetts Assistant Attorney General Division Chief, Utilities Division 1 Ashburton Place Boston, MA 02108 Mr. Matthew Brock, Esq.Commonwealth of Massachusetts Assistant Attorney General Environmental Protection Division One Ashburton Place Boston, MA 02108 Diane Curran, Esq.Harmon, Curran, and Eisenberg, L.L.P.1726 M Street N.W., Suite 600 Washington, DC 20036 Mr. Robert Walker, Director Massachusetts Department of Public Health Radiation Control Program Schraft Center, Suite 1 M2A 529 Main Street Charlestown, MA 02129 Mr. Ken McBride, Director Massachusetts Energy Management Agency 400 Worcester Road Framingham, MA 01702 Mr. James E. Dyer, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-00001 5088308055 LICENSING 09:15:31 a.m. 09-04-2007 3/4 Attachment A to Letter 2.07.073 (1 page)Supplemental Information for the Enteray Response to NRC Request for Additional Information 4.3.3-1 Related to Pilqrim LRA Commitment

1. 31 Pilgrim Nuclear Power Station (PNPS) will comply with Commitment

1. 31 as part of the Fatigue Monitoring Program (FMP) in accordance with 10 CFR 54.21(c)(1)(iii).

This is accomplished as follows.(1) NU REG- 1801, Program X. M1, Metal Fatigue of Reactor Coolant Pressure Boundary, Element 4, Detection of Aging Effects, states "The program provides for periodic update of the fatigue usage calculations." Commitment

1. 31 to refine the current fatigue analyses to include the effects of reactor water environment specifies details for updating the fatigue usage calculations consistent with this element (Element 4) of NUREG-1801, X.M1. The refined analyses will be accomplished as described in Commitment

1. 31 with the clarifying details described in our July 30, 2007 response to RAI 4.3.3-1.(2) NUREG-1801, Program X.M1, Element 7, Corrective Actions, states "The program provides for corrective actions to prevent the usage factor from exceeding the design code limit during the period of extended operation.

Acceptable corrective actions include repair of the component, replacement of the component, and a more rigorous analysis of the component to demonstrate that the design code limit will not be exceeded during the extended period of operation.

For programs that monitor a sample of high fatigue usage locations, corrective actions include a review of additional affected reactor coolant pressure boundary locations." Commitment

1. 31 includes corrective actions to prevent the usage factor from exceeding the design code limit during the period of extended operation consistent with this element (Element 7) of the NUREG-1 801, X.M1. Those corrective actions are the three options specified in the commitment for fatigue management if ongoing monitoring indicates a potential for a condition outside the analyses bounds.The LRA and subsequent amendments treated the actions specified under Commitment

1. 31 as separate from the PNPS Fatigue Monitoring Program and took exception to the consideration of reactor water environment in the program. Combining Commitment

1. 31 with the FMP combines activities that the staff has reviewed as separate items. No new technical information or activities are introduced by combining these items. By considering the actions specified in Commitment

1. 31 part of the FMP, the FMP becomes consistent with NUREG-1801 with no exceptions.

5088308055 LICENSING 09:16:00 a.m. 09-04-2007 4/4 Attachment B to Letter 2.07.073 (1 page)Chanaes to LRA Appendix A.2.2.2.3 A.2.2.2.3 Environmental Effects on Fatigue The effects of reactor water environment on fatigue were evaluated for license renewal.Projected cumulative usage factors (CUFs) were calculated for the limiting locations identified in NUREG/CR-6260.

Several locations may exceed a CUF of 1.0 with consideration of environmental effects during the period of extended operation.

For these locations, PrA to thoS Perid of oxtndod oporatio, PNPS will (1) rofino !he figupto lowor the CUE tW 18co than 4.0; (2) m'naAag atigue at the affoIcd lcatlonc v.1th anR inSpOctOn prOgramA that haS 198on Foviowed and approyed by the NRC (e.g., poriodic o GAdectructi;Vo oX-AMnA tion of the affected locations at icoto into~als to be doteomined by a method accoptablo to the NRC);, or (3) repair Or replace the affctoGd at least 2 years prior to entering the period of extended operation, for the locations identified in NUREG/CR-6260 for BWRs of the PNPS vintage, PNPS will refine our current fatigue analyses to include the effects of reactor water environment arnd verify that the cumulative usagqe factors (CUFs) are less tha n 1. This includes applying the appropriate Fen factors to valid CUFs determined in accordance with one of the following:

1. For locations, including NUREG/CR-6260 locations, with existing fatigue analysis valid for the period of extended operation, use the existing CUF to determine the environmentally adiusted CUF.2. More limiting PNPS-specific locations with a valid CUF may be added in addition to the NUREG/CR-6260 locations.

3. Representative CUF values from other plants, adiusted to or enveloping the PNPS plant specific external loads may be used if demonstrated applicable to PNPS.4. An analysis using an NRC-approved version of the ASME code or NRC-aproved alternative (e.g., NRC-approved code case) may be performed to determine a valid CUF.During the period of extended operation.

PNPS may also use one of the following options for fatigue management if ongoing monitoring indicates a potential for a condition outside the analysis bounds noted above: 1) Update and/or refine the affected analyses described above.2) Implement an inspection proaram that has been reviewed and approved by the NRC (e.g.. periodic nondestructive examination of the affected locations at inspection intervals to be determined by a method acceptable to the NRC).3) Repair or replace the affected locations before exceeding a CUF of 1.0.License renewal commitment 31 addresses environmental-assisted fatigue for the locations identified in NUREG/CR-6260 for BWRs of the PNPS vintage.