ML063060595

2006/09/07-E-mail: Final RAI on Section 4.3.2.1 on Pilgrim LRA

ML063060595
Person / Time
Site:	Pilgrim
Issue date:	09/07/2006
From:	Subbaratnam R Office of New Reactors
To:	Ellis D, Ford B, Mogolesko F Entergy Corp
References
%dam200612, TAC MD2296
Download: ML063060595 (10)

Text

It Ke- ht How- ard -Final RAI on S ection- 4.3.2.1 on Pilgrim LRA Page 1 Kent Howard -Final RAI on Section 4.3.2.1 on Pilgrim LRA P~6TI From: Ram Subbaratnam To: bford@entergy.com; Dellisl @entergy.com; fmogole@entergy.com Date: 9/7/2006 10:34:33 AM

Subject:

Final RAI on Section 4.3.2.1 on Pilgrim LRA Folks: Please find attached one set of formal RAis on section 4.3.2.1 from the NRC staff on the Pilgrim LRA. I am sending you an advance copy so that Entergy can work on the lead in responding to the RAIs. As previously agreed upon, you formal response on docket will be due 30 days from the date of receipt of the RAIs in mail.Thanking you.Sincerely yours Ram Subbaratnam PM Pilgrim LRA US NRC, (301) 415 1478 P.S I owe you two more set of RAIs that will conclude the milestone on issuing Final RAIs (Schedule September 10, 2006). I am planning to send them by COB today.CC: Anissa Coates; Twana Ellis 11 C.\tem D\GW 10000 1.TM P Pacie 111I....em,\.. .. .....TM P..a "e 1 Mail Envelope Properties (45002DF9.903:

19: 10294)

Subject:

Creation Date From: Created By: Final RAI on Section 4.3.2.1 on Pilgrim LRA 9/7/2006 10:34:33 AM Ram Subbaratnam RXS2@nrc.gov Recipients entergy.com bford (bford@entergy.com) dellisl (Dellisl @entergy.com) fmogole (fmogole @entergy.com) nrc.gov OWGWPOO2.HQGWDO01 TYE CC (Twana Ellis)nrc.gov OWGWPOO3.HQGWDO01 ARC3 CC (Anissa Coates)Post Office OWGWPOO2.HQGWDO01 OWGWPOO3.HQGWDO01 Files Size MESSAGE 1132 EFGBectio4.3.2.1RAIsFinal.wpd AM Action Date & Time Delivered Pending Pending Pending Route entergy.com nrc.gov nrc.gov AM 9/7/2006 10:28:30 Date & Time 9/7/2006 10:34:33 34630 Options Auto Delete: Expiration Date: Notify Recipients:

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& Opened August 25, 2006 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.440 Hamilton Avenue White Plains, NY 10601-1839

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE PILGRIM NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. MC9669)

Dear Mr. Kansler:

By letter dated January 25, 2006, Entergy Nuclear Operations, Inc., submitted an application pursuant to Title 10 of the Code of Federal Regulations (10 CFR Part 54), to renew the operating license for Pilgrim Nuclear Power Station for review by the U.S. Nuclear Regulatory Commission (NRC). The NRC staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review. These requests for additional information address License Renewal Section: 4.3.1.2 Reactor Vessel Internals.

These questions were discussed with a member of your staff, Bryan Ford, and a mutually agreeable date for this response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-1478 or by e-mail at RXS2@nrc.q-ov.

Sincerely, IRN Ram Subbaratnam, Project Manager License Renewal Branch A Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-293

Enclosure:

Requests for Additional Information cc w/encl: See next page August 25, 2006 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.440 Hamilton Avenue White Plains, NY 10601-1839

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE PILGRIM NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION (TAC MC9669)

Dear Mr. Kansler:

By letter dated January 25, 2006, Entergy Nuclear Operations, Inc., submitted an application pursuant to Title 10 of the Code of Federal Regulations (10 CFR Part 54), to renew the operating license for Pilgrim Nuclear Power Station for review by the U.S. Nuclear Regulatory Commission (NRC). The NRC staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review. These requests for additional information address License Renewal Section: 4.3.1.2 Reactor Vessel Internals.

These questions were discussed with a member of your staff, Bryan Ford, and a mutually agreeable date for this response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-1478 or by e-mail at RXS2@nrc.Cqov.

Sincerely, IRN Ram Subbaratnam, Project Manager License Renewal Branch A Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-293

Enclosure:

Requests for Additional Information cc w/encl: See next page-ADAMS Accession No.: ML062490501 C:\temp\EFG Bectio4.3.2.1 RAIsFinal.wpd OFFICE PM:RLRA:DLR PM:CFEB:DCI LA:RLRA:DLR BC:REBB:DLR NAME RSubbaratnam Chia-Fu Sheng YEdmonds Llund R. Auluck for DATE 8/25/06 8/24/06 8/24/06 8/25/06 OFFICIAL RECORD COPY Letter to Michael Kansler from Ram Subbaratnam dated: August 25, 2006

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE PILGRIM NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION (TAC MC9669)HARD COPY DLR R/F E-MAIL: JFair RWeisman AMurphy RPettis GGalletti DShum GBagchi SSmith (srs3)SDuraiswamy YL (Renee) Li RidsNrrDIr RidsNrrDIrRlra RidsNrrDIrRlrb RidsNrrDe RidsNrrDci RidsNrreEemb RidsNrrDeEeeb RidsNrrDeEqva RidsNrrDss RidsNrrDnrl RidsOgcMailCenter RidsNrrAdes DLR Staff RSubbaratnam Shoffman SUttal JShea AWilliamson Chia-Fu Sheng KGruss GWilson CAnderson, Region 1 WRaymond, Region 1 NSheehan, Region 1 Pilgrim Nuclear Power Station cc: Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475.Allendale Road King of Prussia, PA 19406-1415 Senior Resident Inspector U. S. Nuclear Regulatory Commission Pilgrim Nuclear Power Station Post Office Box 867 Plymouth, MA 02360 Chairman, Board of Selectmen 11 Lincoln Street Plymouth, MA 02360 Chairman Nuclear Matters Committee Town Hall 11 Lincoln Street Plymouth, MA 02360 Chairman, Duxbury Board of Selectmen Town Hall 878 Tremont Street Duxbury, MA 02332 Office of the Commissioner Massachusetts Department of Environmental Protection One Winter Street Boston, MA 02108 Office of the Attorney General One Ashburton Place 20th Floor Boston, MA 02108 Director, Radiation Control Program Commonwealth of Massachusetts Executive Offices of Health and Human Services 174 Portland Street Boston, MA 02114 Secretary of Public Safety Executive Office of Public Safety One Ashburton Place Boston, MA 02108 Director, Massachusetts Emergency Management Agency Attn: James Muckerheide 400 Worcester Road Framingham, MA 01702-5399 Mr. William D. Meinert Nuclear Engineer Massachusetts Municipal Wholesale Electric Company P.O. Box 426 Ludlow, MA 01056-0426 Mr. Michael A. Balduzzi Site Vice President Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Mr. Stephen J. Bethay Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Mr. Bryan S. Ford Manager, Licensing Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station 600 Rocky Hill Road-Plymouth, MA 02360-5508 Mr. Gary J. Taylor Chief Executive -Officer Entergy Operations 1340 Echelon Parkway Jackson, MS 39213 Pilgrim Nuclear Power Station-2-cc: Mr. John T. Herron Sr. VP and Chief Operating Officer Entergy Nuclear Operations, Inc.440 Hamilton Avenue White Plains, NY 10601 Mr. Oscar Limpias Vice President, Engineering Entergy Nuclear Operations, Inc.440 Hamilton Avenue White Plains, NY 10601 Mr. Christopher Schwarz Vice President, Operations Support Entergy Nuclear Operations, Inc.440 Hamilton Avenue White Plains, NY 10601 Mr. John F. McCann Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.440 Hamilton Avenue White Plains, NY 10601 Ms. Charlene D. Faison Manager, Licensing Entergy Nuclear Operations, Inc.440 Hamilton Avenue White Plains, NY 10601 Mr. Michael D. Lyster 5931 Barclay Lane Naples, FL 34110-7306 Mr. Michael J. Colomb Director of Oversight Entergy Nuclear Operations, Inc.440 Hamilton Avenue White Plains, NY 10601 Ms. Stacey Lousteau Treasury Department Entergy Services, Inc.639 Loyola Avenue New Orleans, LA 70113 Mr. James Sniezek 5486 Nithsdale Drive Salisbury, MD 21801 Mr. Travis C. McCullough Assistant General Counsel Entergy Nuclear Operations, Inc.440 Hamilton Avenue White Plains, NY 10601 Mr. James Ross Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 Plymouth Public Library Attn: Dinah O'Brien 132 South Street Plymouth, MA 02360 Duxbury Free Library ATTN: Ms. Elaine Winquist 77 Alden Street Duxbury, MA 02332 Kingston Public Library ATTN: Reference Librarian 6 Green Street Kingston, MA 02364 Ms. Mary Lampert Duxbury Nuclear Advisory, Chair Pilgrim watch, Director 148 Washington Street Duxbury 02332 REQUESTS FOR ADDITIONAL INFORMATION PILGRIM LICENSE RENEWAL APPLICATION (LRA)SECTION: 4.3.1.2 REACTOR VESSEL INTERNALS 4.3.1.2 Reactor Vessel Internals RAI 4.3.1.2-1 Control rod drive (CRD) return line nozzle-to-end cap weld: Regarding the CRD return line nozzle-to-end cap weld repair, your Project Report LRPD-06, "Pilgrim NPS License Renewal Project -Time-Limited Aging Analyses, Mechanical Fatigue," Response 2.4 refers to Relief Request PRR-36 and concludes, "This relief did not involve any analyses based on time-limited assumptions and therefore is not a TLAA." PRR-36 was submitted by letters dated October 1, 3, and 8, 2004, and July 12, 2004, for relief from certain American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) requirements pertaining to the repair of the nozzle-to-end cap weld with a detected flaw and the associated non-destructive examinations.

Alternatively, PRR-36 proposed to use ASME Code Case N-504-2, "Alternative Rules for Repair of Class 1, 2, and 3 Austenitic Stainless Steel Piping," with modifications to perform the repair. The request was approved in a safety evaluation (SE) dated February 25, 2005. ASME Code Case N-504-2 (g)(2) requires a flaw evaluation be performed on the repaired component such that "The evaluation should demonstrate that the requirements of IWB-3640...

are satisfied for the design life of the repair, considering potential flaw growth due to fatigue and the mechanism believed to have caused the flaw. The flaw growth evaluation shall be performed in accordance with Appendix C." Explain how Entergy meets the ASME Code Case N-504-2 requirement on performing a flaw evaluation that considers fatigue and the mechanism believed to have caused the flaw. If applicable, you may provide a document showing that the weld overlay region adjacent to the interface is in the compressive stress zone.RAI 4.3.1.2-2 Reactor recirculation nozzle thermal sleeves regarding the flaws on reactor recirculation nozzle thermal sleeves, LRPD-06 Response 2.4 refers to a flaw growth analysis in NEDC-30730 and concludes, "The NRC reviewed and accepted the analysis as documented in an SER (Ref.4.2.21). As this analysis is only based on 18 months, it is not a TLAA." The cited SE was issued on December 4, 1984. As you stated, the crack growth analysis is for 18 months. One of the six criteria specified in 10 CFR 54.3(a) for classifying an analysis as a TLAA is the analysis "[i]nvolve time-limited assumptions defined by the current operating term, for example, 40 years." The meaning of a crack growth analysis based on 18 months is that the structural integrity of reactor recirculation nozzle thermal sleeves is not only a concern for the extended period of operation but also a concern for the remaining period of operation under the current 40-year license. Therefore, Entergy needs to consider this as a TLAA and address the following:

For the License Renewal Application:

(1) Confirm whether Report PMA86-07, "Pilgrim Nuclear Power Station Recirculation Inlet Thermal Sleeve Mock Up Fabrication and Evaluation," dated October 1986 had been reviewed by NRC staff.ENCLOSURE (2) Identify the SE which accepts use of hydrogen water chemistry as the mitigating method and as the basis for Entergy to operate with the flaws on the thermal sleeves beyond 1987.(3) Provide an analysis of the inspection results on these thermal sleeves obtained from 1987 to date.(4) Provide the end-of-extended-period-of-operation (60 years) flaw length of the circumferential through-wall flaw which was 32 percent circumference in 1987 (per the December 4,1984, SE for the worst flaw among the detected recirculation nozzle thermal sleeve cracks) and perform a stability analysis for this flaw.(5) If the stability analysis of effort (4) shows that the predicted end-of-extended-period-of-operation through-wall flaw length does not meet the ASME Code Section XI margin, provide an impact evaluation on operation and structural integrity of other components due to a broken thermal sleeve piece of a reasonable size.(6) Provide an inspection plan for these detected thermal sleeve flaws in the extended period of operation.

For current operation till the end of the 40-year operation:

(7) Discuss the adequacy of the inspection plan for recirculation nozzle thermal sleeves for the remaining period of 40-year operation.

(8) Provide the end of the 40-year operation flaw length of the circumferential through-wall flaw which was 32 percent circumference in 1987 and perform a stability analysis for this flaw.