ML102630234
| ML102630234 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/03/2010 |
| From: | Schwarz C Entergy Nuclear Operations |
| To: | Schwarz C Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML102630234 (6) | |
Text
aEntergy Nuclear Operations, Inc.
En tPalisades Nuclear Plant 27780 Blue Star Memorial Highway Entffgy Covert, MI 49043 Tel 269 764 2000 Christopher J. Schwarz Site Vice President September 3, 2010 10 CFR 54 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Revision to License Renewal Commitments Palisades Nuclear Plant Docket 50-255 License No. DPR-20
References:
- 1.
Letter dated March 22, 2005, "Application for Renewed Operating License"
- 2.
NUREG-1871, dated January 2007, "Safety Evaluation Report Related to the License Renewal of Palisades Nuclear Plant"
Dear Sir or Madam:
The purpose of this letter is to inform the Nuclear Regulatory Commission (NRC) that Entergy Nuclear Operations, Inc (ENO) is revising five commitments identified in Reference 2, Appendix A, for the Palisades Nuclear Plant (PNP).
The revised commitments are provided in Attachment 1.
Sincerely,.
cjs/bed : Revision to Long Term Commitments for License Renewal of Palisades Nuclear Plant CC Administrator, Region Ill, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC
ATTACHMENT 1 REVISION TO LONG TERM COMMITMENTS FOR LICENSE RENEWAL OF PALISADES NUCLEAR PLANT 4 Pages Follow
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REVISION TO LONG TERM COMMITMENTS FOR LICENSE RENEWAL OF PALISADES NUCLEAR PLANT No.
Original Commitment Revised Commitment Comments 23 Develop and implement procedures Develop and implement NRC Interim Staff Guidance (ISG)-04:
for inspection of below grade fire procedures for inspection of Aging Management of Fire protection system piping.
below grade fire protection (FP)
Protection Systems for License Inspections shall occur when below system piping. Inspections shall Renewal, dated December 3, 2002, grade piping is excavated for be implemented under the Buried allowed extrapolation of results of maintenance, and shall include pipe Services Corrosion Monitoring inspections of above grade FP piping wall thickness (NDE or direct Program. In addition, results of to evaluate the condition of the below measurement) and documentation wall thickness inspections of grade FP piping if the environmental of aging related degradation of above grade fire protection and material conditions that exist on pipes. Procedures shall include system piping shall be the interior surface of below grade acceptance criteria, and criteria for extrapolated to evaluate the wall piping are similar to the conditions that further corrective actions if thickness condition of below exist within the interior surface of the acceptance criteria are not met.
grade fire protection system above grade piping. The below grade piping. Procedures shall include piping is either cast iron or carbon acceptance criteria and criteria for steel, which is the same as above further corrective actions, if grade piping, and the environmental acceptance criteria are not met.
conditions are the same throughout the system. Exterior inspections of the piping are already included in the Buried Services Corrosion Monitoring Program.
Page 2 of 4
REVISION TO LONG TERM COMMITMENTS FOR LICENSE RENEWAL OF PALISADES NUCLEAR PLANT No.
Original Commitment Reyised Commitment Comments 26 A Non-EQ Electrical Commodities A Non-EQ Electrical Commodities NMC letter dated August 25, 2005, Condition Monitoring Program will Condition Monitoring Program will "Supplementary Information for the-be developed and implemented.
be developed and implemented.
Palisades Application for Renewed Features of the program will Features of the program will Operating License Resulting from Aging include development and include development and Management Programs Audit," added implementation of procedures to implementation of procedures to inspection of non-segregated phase conduct periodic inspection of conduct periodic inspection of bus and connections to the Non-EQ insulated cables and connectors, insulated cables and connectors, Electrical Commodities Condition test sensitive instrumentation test sensitive instrumentation Monitoring Program as a result of.a circuits, test medium voltage circuits, test medium voltage NRC audit of the PNP License Renewal cables, and inspect manhole water cables, inspect manhole water Application (LRA).
levels.
levels, and inspect non-segregated phase bus and connections.
40 NMC will enhance the preventive ENO will enhance the preventive The service water system (SWS) is maintenance program to maintenance program to being removed from the commitment.
periodically periodically inspect, and replace NMC letter dated November 18, 2005, inspect, and replace as necessary, as necessary, the expansion "Response to NRC Requests for the expansion joints/flexible joints/flexible connections in the Additional Information Relating to connections in the portions of the portions of the heating, ventilation License Renewal dated October 24, Heating, Ventilation and Air and air conditioning system that 2005," specifically stated that the Conditioning System, and the are in-scope for license renewal.
elastomers in the SWS Aging Service Water System, that are in-Management Review tables of the LRA scope for license renewal.
are not long lived components that require aging management because they are replaced on a periodic basis.
Since there are no elastomers in the SWS that are required to be managed by an Aging Management Program, inclusion of the SWS in this commitment is not warranted.
Page 3 of 4
REVISI,ON TO LONG TERM COMMITMENTS FOR LICENSE RENEWAL OF PALISADES NUCLEAR PLANT No.
Original Commitment Revised Commitment Comments 43 NMC will perform a neutron ENO will perform a neutron Initial testing was completed prior to absorption ("blackness") test of absorption ("blackness") test of March 2011, in accordance with the-selected cells in the NUS spent fuel selected cells in the NUS spent commitment. The testing showed racks prior to March 24, 2011, to fuel racks prior to March 24, excessive degradation. As a result, validate that there is no significant 2011, to validate that there is no the criticality analysis was revised such degradation of the neutron significant degradation of the that it no longer takes credit for the absorption capability. An additional neutron absorption capability. If neutron absorber in the NUS spent test will be performed within the first degradation is identified, an fuel pool racks to maintain sufficient 10 years following the start of the evaluation of the condition will be margin to criticality. Therefore, since period of extended operation. If performed under the ENO no credit is taken for the neutron degradation is identified in either corrective action program. If absorber in the NUS racks, there is no test, an evaluation of the condition applicable, this evaluation will need for additional testing.
will be performed under the NMC determine the need for additional Corrective Action Program. If testing.
License Amendment 236 revised the applicable, this evaluation will Technical Specifications to apply spent consider the potential need for fuel pool storage restrictions for the additional or more frequent testing.
NUS racks.
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