PNP 2017-018, Notification of Change to Regulatory Commitment Re NRC Request for Information Per 10 CFR 50.54(f) Re the Seismic Aspects of Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident
| ML17103A007 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/13/2017 |
| From: | Hardy J Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PNP 2017-018 | |
| Download: ML17103A007 (8) | |
Text
--
~Entergy Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 PNP 2017-018 April 13, 2017 Tel 269 764 2000 Jeffery A. Hardy Regulatory Assurance Manager U. S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852
SUBJECT:
Notification of Change to Regulatory Commitment Concerning NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding the Seismic Aspects of Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident Palisades Nuclear Plant Docket No. 50-255 Renewed Facility Operating License No. DPR-20
REFERENCES:
- 1. NRC letter, "Request for information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated March 12, 2012 (ADAMS Package Accession Number ML12056A046)
- 2. Entergy Nuclear Operations, Inc. letter, PNP 2014-108, "Palisades Nuclear Plant Expedited Seismic Evaluation Process Report (CEUS Sites), Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated December 18, 2014 (ADAMS Accession Number ML14357A165)
Dear Sir or Madam:
On March 12, 2012, the NRC issued "Request for information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident" to all NRC power reactor licensees and holders of construction permits in active or deferred status (Reference 1).
PNP 2017-018 Page 2 of 2 In response to Enclosure 1, "Recommendation 2.1: Seismic," of Reference 1, ENO made the following commitment in Reference 2:
"ENO will perform seismic walkdowns, generate High Confidence of a Low Probability of Failure calculations, and design and implement any necessary modifications for inaccessible items listed in Section 7.1 of the Expedited Seismic Evaluation Process (ESEP) Report for Palisades Nuclear Plant."
The scheduled completion date for this commitment was no later than the end of the second planned refueling outage after December 31,2014.
The scheduled completion date for this commitment has been changed to September 30, 2019, as discussed in Attachment 1. contains a discussion of the commitment change. Attachment 2 contains the revised commitment.
Sincerely, JAH/jse Attachments: 1. Discussion of Regulatory Commitment Change
- 2. Revised Regulatory Commitment cc:
Director of Office of Nuclear Regulation Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC
PNP 2017-018 Discussion of Regulatory Commitment Change 3 pages follow Discussion of Regulatory Commitment Change
Background
On March 12, 2012, the NRC issued "Request for information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near Term Task Force Review of Insights from the Fukushima Dai-ichi Accident" to all NRC power reactor licensees and holders of construction permits in active or deferred status (Reference 1).
Reference 1, Enclosure 1, titled "Recommendation 2.1: Seismic," requested licensees to provide interim evaluations and actions taken or planned to address the higher seismic hazard relative to the design basis, as appropriate, prior to completion of a seismic risk evaluation. Entergy Nuclear Operations, Inc. (ENO) responded by submitting an Expedited Seismic Evaluation Process (ESEP) report for Palisades Nuclear Plant (PNP) in Reference 2, which was prepared in accordance with the NRC-endorsed guidance in Reference 3.
The intent of the ESEP was to demonstrate seismic margin by reviewing a subset of plant equipment that can be relied upon to protect the reactor core following beyond design basis seismic events.
Included in Reference 2 were the following commitments:
ENO will perform seismic walkdowns, generate High Confidence of a Low Probability of Failure (HCLPF) calculations, and design and implement any necessary modifications for inaccessible items listed in Section 7.1 of the Expedited Seismic Evaluation Process (ESEP) Report for Palisades Nuclear Plant.
Scheduled Completion Date: No later than the end of the second planned refueling outage after December 31,2014.
Modify Primary Makeup Storage Tank (T-81) such that the HCLPF capacity is greater than the demand characterized by the RLGM Peak Ground Acceleration.
Scheduled Completion Date: No later than the end of the second planned refueling outage after December 31,2014.
In Reference 4, the commitment to modify the Primary Makeup Storage Tank (T-81) was cancelled and a new commitment was established, as described below:
ENO will use the insights gained through the performance of the Seismic Probabilistic Risk Assessment for Palisades Nuclear Plant to determine what modifications, procedure changes, or strategy changes would provide the optimal safety improvement.
Scheduled Completion Date: September 30, 2019.
1 of 3 Discussion of Regulatory Commitment Change Commitment Change Discussion The scheduled completion date for the commitment to perform seismic walkdowns, generate HCLPF calculations, and design and implement any necessary modifications for inaccessible items has been revised. The scheduled completion date previously was "no later than the end of the second planned refueling outage after December 31, 2014," which is planned to occur in the spring of 2017. The scheduled completion date for this commitment has been changed to September 30, 2019, as described in Attachment 2. This revised scheduled completion date aligns with the scheduled completion date for the commitment to modify tank T-81.
Even though the scheduled completion date for this commitment is being extended, work to complete the actions described in this commitment is progressing. The seismic walkdowns for inaccessible items have been completed, and the HCLPF calculations have been developed and preliminarily reviewed by ENO. To date, no additional modifications have been identified as a result of this work.
Since this commitment was made, ENO notified the NRC, in accordance with 10 CFR 50.82, of its decision to permanently cease power operations at PNP effective October 1, 2018 (Reference 5). This notification compelled ENO to revise the scheduled completion date for the commitment because completing the HCLPF calculations by the previous scheduled commitment completion date was not deemed to be a prudent use of ENO resources due to the limited safety benefit gained in the interim until PNP has ceased power operations.
The revised scheduled completion date for the commitment, and the previously revised commitment to modify tank T-81, will not negatively impact the ability of affected systems, structures, or components (SSCs) to perform their specified safety function or negatively impact the ability of plant personnel to ensure the SSC is capable of performing its specified safety function. Moreover, the revised commitments will not involve a significant increase in the probability or consequences of an accident previously evaluated, will not create the possibility of a new or different kind of accident from any previously evaluated, and will not involve a significant reduction in a margin of safety.
Nuclear power plants are designed using conservative practices, such that the plants have significant margin to safely withstand large earthquake ground motions. These conservative design practices result in margins such that SSCs will continue to fulfill their functions at ground motions well beyond design-basis earthquakes. This margin has been borne out for plants that have experienced significant earthquakes in recent years.
Therefore, rescheduling the scheduled completion date for the commitment to perform seismic walkdowns, generate HCLPF calculations, and design and implement any necessary modifications for inaccessible items will not negatively impact the ability of the 2 of 3 Discussion of Regulatory Commitment Change affected SSCs to perform safety functions or negatively impact the ability of plant personnel to ensure that SSCs are capable of performing their safety functions.
References
- 1.
NRC letter, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident,"
dated March 12, 2012 (ADAMS Package Accession Number ML12056A046)
- 2.
ENO letter, PNP 2014-108, "Palisades Nuclear Plant Expedited Seismic Evaluation Process Report (CEUS Sites), Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated December 18, 2014 (ADAMS Accession Number ML14357A165)
- 3.
NRC letter, "Electric Power Research Institute Final Draft Report XXXXXX, Seismic Evaluation Guidance: Augmented Approach for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic, as an Acceptable Alternative to the March 12,2012, Information Request for Seismic Reevaluations," dated May 7,2013 (ADAMS Accession Number ML13106A331)
- 4.
ENO letter, PNP 2016-022, "Commitment Changes Concerning Palisades Nuclear Plant Modifications for Expedited Seismic Evaluation Process Report," dated April 18,2016 (ADAMS Accession Number ML161118168)
- 5.
ENO letter, PNP 2017-001, "Certification of Permanent Cessation of Power Operations," dated January 4, 2017 (ADAMS Accession Number ML17004A062) 30f 3
PNP 2017-003 Revised Regulatory Commitment 1 page follows
Revised Regulatory Commitment The following table identifies a revised action which Entergy Nuclear Operations, Inc. (ENO) commits to perform, as discussed in this document.
Original Original Source of Original Revised Commitment Completion Date Commitment Completion Date ENO will perform seismic No later than the end ENO letter, PNP 2014-108, September 30, walkdowns, generate of the second "Palisades Nuclear Plant 2019 High Confidence of a planned refueling Expedited Seismic Low Probability of Failure outage after Evaluation Process Report calculations, and design December 31,2014.
(CEUS Sites), Response to and implement any NRC Request for necessary modifications Information Pursuant to 10 for inaccessible items CFR 50.54(f) Regarding listed in Section 7.1 of Recommendation 2.1 of the the Expedited Seismic Near-Term Task Force Evaluation Process Review of InSights from the (ESEP) Report for Fukushima Dai-ichi Palisades Nuclear Plant.
Accident," dated December 18, 2014 (ADAMS Accession No. ML14357A165).
1 of 1