ML042650146
| ML042650146 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/21/2004 |
| From: | Licata L NRC/NRR/DLPM/LPD1 |
| To: | Clifford J NRC/NRR/DLPM/LPD1 |
| Licata L ,NRR/DLPM/LPDI, 415-4090 | |
| References | |
| TAC MC2706 | |
| Download: ML042650146 (5) | |
Text
September 21, 2004 MEMORANDUM TO:
James W. Clifford, Chief, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation FROM:
Lee A. Licata, Project Manager, Section 2
/RA/
Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation
SUBJECT:
PILGRIM NUCLEAR POWER STATION - DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING A ONE-TIME INTEGRATED LEAK RATE TEST INTERVAL EXTENSION (TAC NO. MC2706)
By letter dated April 14, 2004, Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted a license amendment request to revise Pilgrim Nuclear Power Stations (Pilgrims)
Technical Specification section 4.7.A.2.a, Primary Containment Integrity, to allow for a one-time interval extension of no more than five years for a Type A integrated leak rate test.
The attached draft request for information (RAI) was transmitted on September 21, 2004, to Mr. Edward Sanchez of Entergy. This draft RAI was transmitted to facilitate the technical review being conducted by the Office of Nuclear Reactor Regulation and to support a conference call with the licensee to discuss the RAI.
Review of this RAI would allow the licensee to determine and agree upon a schedule to respond to it. This memorandum and the attachment do not convey or represent a Nuclear Regulatory Commission staff position regarding the licensee's request.
Docket No. 50-293
Attachment:
Draft RAI
September 21, 2004 MEMORANDUM TO:
James W. Clifford, Chief, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation FROM:
Lee A. Licata, Project Manager, Section 2
/RA/
Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation
SUBJECT:
PILGRIM NUCLEAR POWER STATION - DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING A ONE-TIME INTEGRATED LEAK RATE TEST INTERVAL EXTENSION (TAC NO. MC2706)
By letter dated April 14, 2004, Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted a license amendment request to revise Pilgrim Nuclear Power Stations (Pilgrims)
Technical Specification section 4.7.A.2.a, Primary Containment Integrity, to allow for a one-time interval extension of no more than five years for a Type A integrated leak rate test.
The attached draft request for information (RAI) was transmitted on September 21, 2004, to Mr. Edward Sanchez of Entergy. This draft RAI was transmitted to facilitate the technical review being conducted by the Office of Nuclear Reactor Regulation and to support a conference call with the licensee to discuss the RAI.
Review of this RAI would allow the licensee to determine and agree upon a schedule to respond to it. This memorandum and the attachment do not convey or represent a Nuclear Regulatory Commission staff position regarding the licensee's request.
Docket No. 50-293
Attachment:
Draft RAI DISTRIBUTION PUBLIC JClifford LLicata DJeng PD1-2 Reading ACCESSION NO.: ML042650146 OFFICE PD1-2/PM NAME LLicata DATE 9/21/04 OFFICIAL RECORD COPY
Attachment DRAFT REQUEST FOR ADDITIONAL INFORMATION ONE-TIME INTEGRATED LEAK RATE TEST INTERVAL EXTENSION PILGRIM STATION DOCKET NO. 50-293 By reference 1, Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted a license amendment request to revise Pilgrim Nuclear Power Stations (Pilgrim) Technical Specification section 4.7.A.2.a, Primary Containment Integrity, to allow for a one-time interval extension of no more than five years for a Type A integrated leak rate test (ILRT).
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed reference 1, and requests the following additional information to clarify the license amendment request:
1.
In the last paragraph of page 7 of reference 1, Entergy stated that augmented examinations documented corrosion in the drywell-to-torus main vent low points, which were below minimum wall thickness but were found acceptable by evaluation.
a.
Describe the basis for Entergys determination that the below minimum wall thickness is acceptable. The following information is needed: location and size of the areas in question, their nominal design thickness and the actual measured thickness.
b.
Discuss the potential impact of the proposed one-time ILRT interval extension upon Entergys continued ability to timely identify and evaluate containment degradation to reasonably assure the leak-tightness and structural integrity of Pilgrims containment 2.
Section 5.1.3 of attachment 5 to reference 1, Entergys First Ten-Year Interval IWE Containment Inspection Program, also describes Code Category E-C augmented examinations for Pilgrims containment. Please discuss the containments key augmented examination results beyond those reported in Section 5.1.3 that would provide additional performance based justifications for the staffs acceptance of the proposed one-time ILRT interval extension.
3.
In attachment 5 to reference 1, Table 5.3.2, Pilgrim Nuclear Power Station IWE Components Scheduled for Examination During 1st IWE Interval only addresses the first 10-year interval.
a.
Please document Entergys ISI methods and plans for the additional 5-year extended period that would provide assurance that in the absence of an ILRT for fifteen years, the containment structural and leak tight integrity will be maintained.
b.
Additionally, many plant specific inspection activities listed in this table must have been completed to date. Provide a detailed summary of ISI and related containment testing activities listed in the table that have been completed to date including inspection/testing dates, findings, corrective actions, and maintenance/repair as well as containment modifications.
c.
Based on the above plant specific ISI results, discuss Entergys performance based justifications for staffs acceptance of the proposed one-time ILRT interval extension from ten to fifteen years.
a.
Table 5.3.2 also lists projected examination schedules covering the first IWE interval for the listed plant components. Discuss how these component examination schedules would be impacted or revised during the proposed extended period after September 2008.
4.
Inspections of some reinforced concrete and steel containment structures have found degradation on the non-inspectable (embedded) side of the drywell steel shell and steel liner of the primary containment. These degradations cannot be found by visual (i.e.,
VT-1 or VT-3) examinations unless the degradation is through the thickness of the shell or liner, or 100% of the non-inspectable surfaces are periodically examined by ultrasonic testing.
a.
Document how potential leakage under high pressure during core damage accidents is factored into the risk assessment implemented for justifying the proposed one-time ILRT interval extension.
b.
Discuss the potential impact of the proposed ILRT interval extension upon the Entergys continued ability to reasonably assure the leak tightness and structural integrity of Pilgrims containment.
- 5.
Per Information Notice 92-20, stainless steel bellows have been found to be susceptible to trans-granular stress corrosion cracking (SCC) and the leakage through them is not readily detectable by Type B testing. If applicable, document the inspection and testing of Pilgrims bellows, and discuss how such potential SCC behavior has been factored into the risk assessment implemented for justifying the proposed one-time ILRT interval extension.
6.
For the examination of seals and gaskets, and examination and testing of bolted connections associated with the primary containment pressure boundary (Examination Categories E-D and E-G), reference 2 granted relief from the codes requirements. As an alternative, it was proposed to examine these items during the leak rate testing of the primary containment. However, Option B of Appendix J for Type B and Type C testing (as per Nuclear Energy Institute 94-01 and Regulatory Guide 1.163) and the ILRT interval extension requested in this amendment request for Type A testing, provides flexibility in the scheduling of these inspections. Please document your schedule for examination and testing of seals, gaskets, and bolts beyond the first ten-year period that would provide assurance regarding the integrity of the containment pressure boundary.
7.
REFERENCES:
1.
Letter from Michael A. Balduzzi (Entergy), to NRC, Request for Amendment to the Technical Specifications to provide a One-Time Integrated Leak Rate (ILRT) Interval Extension, April 14, 2004 2.
Letter from James W. Clifford of NRC to Theodore A. Sullivan of Entergy, Evaluation of Requests for Relief from ASME Section XI Requirements for Containment Inspection for Pilgrim Power Station (TAC No. MA4285), dated September 16, 1999