PNP 2017-060, Report of Changes, Tests and Experiments and Summary of Commitment Changes
| ML17285A014 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/12/2017 |
| From: | Hardy J Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PNP 2017-060 | |
| Download: ML17285A014 (19) | |
Text
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043*9530 Tel 269 7642000 Jeffery A. Hardy Regulatory Assurance Manager PNP 2017-060 October 12,2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Palisades Nuclear Plant Report of Changes, Tests and Experiments and Summary of Commitment Changes Palisades Nuclear Plant Docket No. 50-255 Renewed Facility Operating License No. DPR-20
Dear Sir or Madam:
Entergy Nuclear Operations, Inc. (ENO) is submitting the Palisades Nuclear Plant (PNP)
Report of Facility Changes, Tests, and Experiments for the time period of September 30,2015 through September 30,2017. This report is submitted in accordance with the requirements of 10 CFR 50.59( d)(2) and 10 CFR 72.48( d)(2). During this period, there were three changes to the facility, but no tests or experiments, made pursuant to 10 CFR 50.59, and one change, but no tests or experiments, made pursuant to 10 CFR 72.48.
The report in Attachment 1 contains descriptions of the changes to the facility, and summaries of the evaluations performed for the changes, in accordance with 10 CFR 50.59 and 10 CFR 72.48. contains a summary report of regulatory commitment changes requiring NRC notification that were made from September 30, 2015, through September 30, 2017. The report includes a justification for each change per Nuclear Energy Institute (NEI) Guideline NEI 99-04, "Guidelines for Managing NRC Commitment Changes," and NRC Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff."
This letter contains no new commitments and no revised commitments.
PNP 2017-060 Page 2 of 2 Sincerely, 94~
JAH/jse Attachment(s): 1. Palisades Nuclear Plant Report of Changes, Tests, and Experiments
- 2. Palisades Nuclear Plant Commitment Change Summary Report cc: Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC
ATTACHMENT 1 PALISADES NUCLEAR PLANT REPORT OF CHANGES, TESTS, AND EXPERIMENTS 10 CFR 50.59n2.49 Evaluation Log Number Document Number and Title 16-0110 Engineering Assistance Request (EAR) EAR 1999-0081, "Chemical and Volume Control Declassification" 16-0141 Engineering Change 63472, "Revise NAI-1149-024, Determination of Direct Shine Doses for a Design Basis LOCA for Palisades, to Accommodate Track Alley West Wall Modification for DFS" 16-0171 Engineering Change 66959, "Issue 72.212 Report and Revised Calculations" 17-0030 Engineering Analysis EA-WJB-00-01, "Spent Fuel Pool Dilution Analysis," Revision 2 Six pages follow
ATTACHMENT 1 PALISADES NUCLEAR PLANT REPORT OF CHANGES, TESTS, AND EXPERIMENTS 10 CFR 50.59 Evaluation Log Number: 16-0110 Document Number and
Title:
Engineering Assistance Request (EAR) EAR 1999-0081, "Chemical and Volume Control Declassification" Description of Change:
EAR 1999-0081 reclassified portions of the chemical and volume control system (CVCS) piping and components from safety related to non-safety related, and from Consumers Design Class 1 to Consumers Design Class 3.
The portions of the CVCS that were reclassified were piping and components located outside of containment, beyond the containment isolation valves.
The portions of the CVCS inside containment, and extending up to, and including, the containment isolation valves, were not reclassified, and remain classified as safety related and as Consumers Design Class 1. This includes the portions of the system that provide the containment isolation boundaries and the primary coolant system boundaries.
Summary of 50.59 Evaluation The reclassification of portions of the CVCS does not impact the frequency of occurrence of any Updated Final Safety Analysis Report (UFSAR) accidents. The probability of occurrence of any UFSAR-described design basis accidents, such as loss of coolant and main steam line break accidents, or events, such as floods, fires, earthquakes, anticipated transients without scram, and station blackout, is not affected by the reclassification.
The reclassification of portions of the CVCS does not result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component (SSC) important to safety previously evaluated in the UFSAR. The CVCS continues to be capable of performing its required primary coolant system (PCS) makeup function following a seismic event and continues to comply with General Design Criteria (GDC) 1 and 2. The CVCS remains seismically robust: it met the seismic capability review requirements of Unresolved Safety Issue A-46, and is maintained capable of performing a PCS makeup function following a seismic event.
GDC 1 requires that SSCs important to safety be subject to the quality assurance program. Per Palisades' licensing basis, SSCs subject to GDC 1 are only those SSCs that are credited in a loss of coolant accident (LOCA) scenario. The only portions of the CVCS that are credited in a LOCA scenario are those that support the containment isolation and the primary coolant system isolation functions. These portions of the CVCS are not being reclassified, and remain classified as Consumers Design Class 1.
1 of 6
ATTACHMENT 1 PALISADES NUCLEAR PLANT REPORT OF CHANGES, TESTS, AND EXPERIMENTS GDC 2 requires that SSCs important to safety be designed to withstand the effects of extraordinary phenomena. Following reclassification, the CVCS continues to comply with GDC 2. The CVCS capability to makeup to the PCS following a seismic event is not affected. The seismic capability of the system is not directly affected by the reclassification of portions of the system. Further, as noted in the Unresolved Safety Issue A-46 documentation, successful completion of A-46 for systems, such as the CVCS, constitutes compliance with GDC 2.
The reclassification of CVCS does not result in more than a minimal increase in the consequences of an accident previously evaluated in the UFSAR and does not result in more than a minimal increase in the consequences of a malfunction of a SSC important to safety previously evaluated in the UFSAR. No radiological barriers are affected by the reclassification of portions of the CVCS. Portions of the CVCS maintain the containment and the PCS pressure boundaries, and these functions are not affected by the reclassification.
Therefore, none of the criteria in 10 CFR SO.S9(c)(2) are met, and prior NRC approval is not required.
10 CFR 50.59 Evaluation Log Number: 16-0141 Document Number and
Title:
Engineering Change 63472, "Revise NAI-1149-024, Determination of Direct Shine Doses for a Design Basis LOCA for Palisades, to Accommodate Track Alley West Wall Modification for DFS" Description of Change:
Part of the site transition to the Holtec dry fuel storage (DFS) system included removing a portion of the west wall in the track alley area of the Auxiliary Building. The west wall of track alley is a shared wall with the Technical Support Center, which is part of the Control Room Envelope (CRE) boundary. The west wall formerly contained 27" of concrete, but was reduced to 9" of concrete in an approximately 108"x46" area, with the 18" removed being replaced by a moveable missile shield, which provides equivalent thickness of steel to provide tornado and radiation protection to the CRE.
To address the configuration of the CRE boundary with the track alley missile shield raised out of position, such that the missile shield does not provide radiological shielding for the CRE boundary, EC63472 revised the control room occupant accident dose evaluations to demonstrate that the missile shield is not required to maintain control room dose limits within the acceptance criterion in the event of a postulated radiological accident.
2 of 6
ATTACHMENT 1 PALISADES NUCLEAR PLANT REPORT OF CHANGES, TESTS, AND EXPERIMENTS Summary of 50.59 Evaluation Of the accidents described in the FSAR, the maximum hypothetical accident (MHA) is the accident most affected by removal of the barrier with respect to reduction in dose margin with respect to 10 CFR 50.67 limits. One of the inputs to the MHA calculation is the effective thickness of the wall of the CRE. This revision to the calculation removes the 108"x46"x18" concrete cut-out that was replaced by the missile shield, and demonstrates that the total effective dose equivalent (TEDE) of control room occupants remains within the limits of 10 CFR 50.67.
The revised calculation changes the TEDE of control room occupants from 3.97 rem to 4.00 rem resultant from the MHA.
Per Section 4.3.3 of the NRC-endorsed NEI 96-07, "Guidelines for 10 CFR 50.59 Implementation," Revision 1, a minimal increase in the consequences of an accident is associated with up to 10% of the margin remaining. If a change results in more than a 10% decrease in the margin available, the change is considered to be more than minimal and requires prior NRC approval. With a regulatory limit of 5.00 rem for control room dose and a previously evaluated TEDE of 3.97 rem, the margin available is 1.03 rem. The change results in an increase of 0.03 rem , which is less than ten percent of the margin available (0.10 rem). Therefore, the increase in the consequences of a MHA is not more than a minimal increase, none of the criteria in 10 CFR 50.59(c)(2) are met, and prior NRC approval is not required.
10 CFR 72.48 Evaluation Log Number: 16-0171 Document Number and
Title:
Engineering Change 66959, "Issue 72.212 Report and Revised Calculations" Description of Change:
Palisades transitioned to the Holtec international HI-STORM FW dry fuel storage (DFS) system, under a general license in accordance with Subpart K of 10 CFR 72. The general license issued under 10 CFR 72.210 allows nuclear power plants licensed in accordance with 10 CFR 50 to store spent fuel onsite in a storage system pre-approved by the NRC, provided that the licensee complies with 10 CFR 72.212, "Conditions of General License issued Under Part 72.210."
One of the requirements of 10 CFR 72.212 requires licensees to determine whether or not site-specific environmental parameters (seismic, tornado winds and missiles, ambient temperatures, etc.) are enveloped by the cask design bases, which is documented in a 72.212 report. During preparation of the 72.212 report for the HI-STORM FW DFS system, three items requiring evaluation under 10 CFR 72.48 were 3 of 6
ATTACHMENT 1 PALISADES NUCLEAR PLANT REPORT OF CHANGES, TESTS, AND EXPERIMENTS identified: tornado-generated missile requirements, a cask tip-over accident, and a fire accident.
Summary of 72.48 Evaluation Regarding tornado-generated missiles, the design basis requirements for the HI-STORM FW DFS system are satisfied when subjected to impact from the site-specific missiles described in the Palisades UFSAR Section 5.5. The calculations show that a postulated missile strike would not cause the cask to overturn or excessively slide on the ISFSI pad, and that the damage to the cask overpack would not be significant.
In addition, since the missiles described in the Palisades UFSAR are not bounded by the missiles described in the DFS Safety Analysis Report (SAR), the evaluation of the DFS system with respect to the missiles postulated in the FSAR may be considered a change in an element of methodology, as described in NEI96-07, Appendix B, Section B3.8.
The DFS SAR missiles are based on recommended missiles found in NUREG-0800, "Standard Review Plan," Section 3.5.1.4, and the missiles assumed in the UFSAR were based on industry standards when the site was designed and licensed, so the missiles in both cases may be considered to be an element of a methodology. Per NEI 96-07 Appendix B, Section B4.3.8.1, the definition of "departure" allows licensees to make changes under 10 CFR 72.48 to methods of evaluation whose results are "conservative."
Analytical results obtained by changing any element of a method are "conservative" relative to the previous results if they are closer to design basis or safety analysis limits.
Use of Palisades' tornado-generated missiles caused a decrease in safety factors for the DFS SAR-specified tornado missile design requirements; that is, the results are closer to the design basis limits and, therefore, conservative. Therefore, the change in the elements of the evaluation methodology used to evaluate site-specific tornado wind does not result in a departure from a method of evaluation described in the DFS SAR.
Regarding the postulated tip-over accident, the site-specific tip-over evaluation does not result in more than a minimal increase in the consequences of an accident previously evaluated in the DFS SAR. The acceptance criteria for the non-mechanistic tip-over accident evaluated in Section 12.2.3 of the DFS SAR are: the lid must not dislodge and the overpack cannot suffer a significant loss of shielding, the MPC must remain in the overpack and the overpack cannot suffer deformation to preclude removal of the MPC, the confinement boundary must not be breached, and the maximum plastic deformation sustained by the panels in the fuel basket must be limited to the DFS SAR requirements given in Table 2.2.11. The evaluation demonstrates that these DFS SAR requirements are met.
Regarding the postulated fire accident, the acceptance criteria provided in the DFS SAR with regard to maximum peak cladding temperature, peak concrete temperature, and overpack structural steel temperature, for the fire accident are all met for the site-specific analysis. There is no increase in the consequences of the accident.
4 of 6
ATTACHMENT 1 PALISADES NUCLEAR PLANT REPORT OF CHANGES, TESTS, AND EXPERIMENTS Therefore, none of the criteria in 10 CFR 72.48(c)(2) are met and prior NRC approval is not required.
10 CFR 50.59n2.48 Evaluation Log Number: 17-0030 Document Number and
Title:
Engineering Analysis EA-WJ8-00-01, "Spent Fuel Pool Dilution Analysis," Revision 2 Description of Change:
Engineering Analysis EA-WJ8-00-01 demonstrated that a dilution accident will result in the spent fuel pool (SFP) boron concentration remaining above that assumed in the criticality analysis for long enough to credit operator action to terminate the dilution event.
Revision 2 of the analysis removed credit taken for operator rounds to locally monitor spent fuel pool level on an 8-hour frequency, and instead credits various control room indications to prompt Operator action for mitigation of a dilution event. The change could be considered to be a change from a design function that is manually controlled to one that is automatically controlled. NEI 96-07 states that changes that convert a design function from manual to automatic is an adverse change that requires review in a 50.59 Evaluation.
Summary of 50.59 Evaluation Removing credit for shiftly operator rounds to detect a SEP dilution event does not result in more than a minimal increase in the likelihood of occurrence of a SEP dilution event as there are diverse control room indications that would prompt the control room operations staff to take action prior to the fuel pool boron concentration reaching the design basis limit of 850 ppm. As described in the revised EA-WJ8-00-01, there is a SFP high level control room alarm set at elevation 647'-10". In addition, there are two high and low temperature alarms, in the SFP, both of which transmit to the plant process computer.
Diluting the SFP to 1569 ppm would result in a water level in excess of the high alarm setpoint and would fill the pool to the top; any further water addition would cause overflow. Reducing the pool's boron concentration to 850 ppm would require an additional 107,000 gallons of 0 ppm water, all of which will displace an equivalent volume that would propagate into the auxiliary building open areas, resulting in various sump alarms and other obvious indications. Flooding of this magnitude would be quickly detected at the onset by operations staff. With respect to time and credibility, the bounding case evaluated in EA-WJ8-00-01 is dilution from the fire protection system via 1-1/2" hose station at elevation 649'. Given the flow rate from this hose station, this 5 of 6
ATTACHMENT 1 PALISADES NUCLEAR PLANT REPORT OF CHANGES, TESTS, AND EXPERIMENTS scenario would require 9.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to lower the SEP boron concentration to 850 ppm.
Operations staff would have to ignore the high SEP level alarm, a fire protection system pump start, and other flooding indications for more than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in order for the boron concentration to reach 850 ppm.
Not crediting shiftly operator rounds to detect a SEP dilution event does not result in more than a minimal increase in the consequences of an accident or malfunction of an SSC previously evaluated in the UFSAR. The bounding fuel handling radiological consequences analysis described in UFSAR Section 14.19.3.1 assumes that a fuel bundle is dropped during handling, causing a number of fuel rods to fail, which bounds the consequences of a potential dilution event. Per UFSAR Section 5.1.7.3, the SFP storage racks have a geometrically safe configuration that provides spacing and pOison sufficient to maintain keff less than 1.0 even when flooded with unborated water.
Therefore, a SFP dilution event will not result in criticality by itself even when flooded with unborated water.
Therefore, none of the criteria in 10 CFR 50.59(c)(2) are met, and prior NRC approval is not required.
6 of 6
ATTACHMENT 2 PALISADES NUCLEAR PLANT COMMITMENT CHANGE
SUMMARY
REPORT Nine pages follow
ATTACHMENT 2 PALISADES NUCLEAR PLANT COMMITMENT CHANGE
SUMMARY
REPORT Date of Commitment Letter Title and Date of Commitment Number Original Commitment Description Change 2000077 GL 89-13, "Service Water 01/19/2016 Original Commitment: Inspect service water pump intake bay by divers for I
System Problems Affecting biofouling species each refueling outage. I Safety-Related Equipment 04/01/1990 Revised Commitment: Inspect service water pump intake bay by divers for biofouling species every other refueling outage.
Justification: Previous four refueling outage inspections have shown the service water bay is clean and no cleaning was required. Decrease in frequency of inspection will reduce outage impact and risk by minimizing service water unavailability due to tagging required and the risks associated with diving activities.
2000078 GL 89-13, "Service Water 01/19/2016 Original Commitment: Periodically submit sample of service water pump System Problems Affecting intake bay sediment to a laboratory for detailed analysis.
Safety-Related Equipment 04/01/1990 Revised Commitment: Submit sample of service water pump intake bay sediment to a laboratory for detailed analysis every other refueling outage.
Justification: Previous four refueling outage inspections have shown the service water bay is clean and no cleaning was required. Decrease in frequency of inspection will reduce outage impact and risk by minimizing service water unavailability due to tagging required and the risks associated with diving activities.
Page 1 of 9
ATTACHMENT 2 PALISADES NUCLEAR PLANT COMMITMENT CHANGE
SUMMARY
REPORT Date of Commitment Letter Title and Date of Commitment Number Original Commitment Description Change 2001899 Confirmatory Action Letter 04/20/2016 Original Commitment: Recommended periodic testing - Emergency Core and Information Request Cooling System - A) Motor Operated Valves. 1) Cycle with differential Pursuant to 10 CFR pressure. Surveillance. A) High Pressure Safety Injection (HPSI) Sub-cooled 50.54(f) Suction Valves MO-3070 and MO-3071, performed by PPAC X-OPS345. 8) 05/21/1986 Charging to HPSI MO-3072, performed by 00-88 and 00-8C. 2) Loop check instrumentation. Pre-refueling. A) High Pressure Interlock MO-3015 and MO-3016, performed by surveillance procedure RI-59. 8) Alternate Shutdown Panel (C-33) Cooling Controls for CV-3006, CV-3003, and CV-3055, performed by PPAC X-OPS279.
Revised Commitment: HPSI sub-cooled suction testing via MO-3070 and MO-3071 is no longer necessary. Note: The subcooling valves are actually CV-3070 and CV-3071, not "MO-3070 and MO-3071" as indicated above.
Justification: The air operated valve (AOV) program (procedure EN-DC-140) requires periodic diagnostic testing for these program AOVs.
There are no specific requirements to stroke the valves against differential pressure (DP). It is unclear from the original commitment and related documentation whether this requirement should have ever been applied to CV-3070 and CV-3071 based on them being AOVs, whereas the commitment appears to have been intended for motor operated valves. In either case, the diagnostic testing performed on these valves per the requirements of procedure EN-DC-196 is sufficient to demonstrate that the valves will perform, even under desi!:m basis DP conditions.
2001980 GL 91-15, "Operating 08/17/2016 Original Commitment: The Generic Letter did not require a response. The Experience Feedback information was reviewed for applicability to Palisades. The review Report, Solenoid-Operated determined that solenoid operated valve stroke should be locally observed.
Valve Problems at U.S. This action was entered as a commitment.
Reactors" 09/23/1991 Revised Commitment: This commitment is being canceled.
Justification: The commitment to locally observe the solenoid operated valve's stroke is not a recommendation of Generic Letter 91-15 or NUREG 1275, "Operating Experience Feedback Reports," or the valve manufacturer.
Page 2 of 9
ATTACHMENT 2 PALISADES NUCLEAR PLANT COMMITMENT CHANGE
SUMMARY
REPORT Date of Commitment Letter Title and Date of Commitment Number Original Commitment Description Change 2011144 IEB 80-10, "Response- 10/20/2015 Original Commitment: Lake water inlet and discharge are composite Contamination of Non- sampled daily and analyzed monthly for gross beta activity, gross alpha, and Radioactive System and tritium.
Resulting Potential for Release of Radioactivity to Revised Commitment: This commitment is being canceled.
Environment" 05/06/1980 Justification: Lake discharge sampling for activity is no longer required, as the current sampling program analyzes all inputs to lake discharge individually.
2011602 Generic Safety Issue-191 03/08/2017 Original Commitments: T he commitments below were made in Entergy 2011603 Closure Option Nuclear Operations (ENO) letter, PNP 2013-041 , "Generic Safety Issue-191 2011604 05/15/2013 Closure Option," dated May 15,2013.
- ENO will complete any necessary insulation replacements or remediation, or other identified plant changes.
- ENO will submit a final updated supplemental response to support closure of GL 2004-02 for PNP.
- If it is determined during the risk-informed process that this option is not viable, ENO will complete a deterministic resolution path that is acceptable to the NRC.
Revised Commitment: T he three commitments are being cancelled.
Justification: On February 22, 2017, the NRC issued a letter to ENO stating that no additional action is requested for PNP for NRC Generic Letter (GL) 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation during Design Basis Accidents at Pressurized-Water Reactors," dated September 13, 2004. This letter followed an ENO letter to the NRC dated January 4, 2017, that certified that it plans to permanently cease power operations for PNP on October 1, 2018. - - -- - -
Page 3 of 9
ATTACHMENT 2 PALISADES NUCLEAR PLANT COMMITMENT CHANGE
SUMMARY
REPORT Date of Commitment Letter Title and Date of Commitment Number Original Commitment Description Change 1013087 Update to 1986-1987 12/01/2016 Original Commitment: Station power system: 4, 160V system - Auto transfer Maintenance Outage Action of the buses from normal power source to standby power source is initiated Items by turbine trip or generator trip. Function will be periodically verified in the 10/30/1987 future.
Revised Commitment: Commitment is being canceled.
Justification: The plant was shut down in 1986-1987 due to poor maintenance practices. Every action taken during that time in response I became a commitment. Based on changes and the evolution of engineering processes and maintenance practices over the past 30 years, many of the actions to which the site committed now add more shutdown safety risk than the benefit gained from performing these tasks. In some cases, the commitments are no longer prudent or logical. This commitment falls into one of those categories and is therefore being canceled. Current processes will determine appropriate surveillance/testing practices and intervals.
1013088 Update to 1986-1987 12/01/2016 Original Commitment: Station power system: No testing Maintenance Outage Action performed to verify auto transfer block feature on low volt manually Items operated lockout relays. Although calibrated, they are not covered by 10/30/1987 periodic testing. Periodically test in the future.
Revised Commitment: Commitment is being canceled.
Justification: The plant was shut down in 1986-1987 due to poor maintenance practices. Every action taken during that time in response became a commitment. Based on changes and the evolution of engineering processes and maintenance practices over the past 30 years, many of the actions to which the site committed now add more shutdown safety risk than the benefit gained from performing these tasks. In some cases, the commitments are no longer prudent or logical. This commitment falls into one of those categories and is therefore being canceled. Current processes will determine appropriate surveillance/testing practices and intervals.
Page 4 of 9
ATTACHMENT 2 PALISADES NUCLEAR PLANT COMMITMENT CHANGE
SUMMARY
REPORT Date of Commitment Letter Title and Date of Commitment Number Original Commitment Description Change 1013090 Update to 1986-1987 12/01/2016 Original Commitment: Station power system: No testing is performed to Maintenance Outage Action verify auto transfer block feature on low voltag~. Manually operated lockout Items relays are calibrated, but not covered by periodic testing. Periodically test in 10/30/1987 the future.
Revised Commitment: Commitment is being canceled.
Justification: The plant was shut down in 1986-1987 due to poor maintenance practices. Every action taken during that time in response became a commitment. Based on changes and the evolution of engineering processes and maintenance practices over the past 30 years, many of the actions to which the site committed now add more shutdown safety risk than the benefit gained from performing these tasks. In some cases, the commitments are no longer prudent or logical. This commitment falls into one of those categories and is therefore being canceled. Current processes will determine appropriate surveillance/testing practices and intervals. I 1014017 Update to 1986-1987 12/01/2016 Original Commitment: All alarms, interlocks and trips on page 8.4.4 of FSAR I Maintenance Outage Action to be tested periodically.
Items 10/30/1987 Revised Commitment: Commitment is being canceled.
Justification: The plant was shut down in 1986-1987 due to poor maintenance practices. Every action taken during that time in response became a commitment. Based on changes and the evolution of engineering processes and maintenance practices over the past 30 years, many of the actions to which the site committed now add more shutdown safety risk than the benefit gained from performing these tasks. In some cases, the commitments are no longer prudent or logical. This commitment falls into one of those categories and is therefore being canceled. Current processes will determine appropriate surveillance/testing practices and intervals.
Page 5 of 9
ATTACHMENT 2 PALISADES NUCLEAR PLANT COMMITMENT CHANGE
SUMMARY
REPORT Date of Commitment Letter Title and Date of Commitment Number Original Commitment Description Change 1014018 Update to 1986-1987 12/01/2016 Original Commitment: Diesel will be auto-tripped on generator differential Maintenance Outage Action over-current relay action, engine overspeed/underspeed, over-crank or lube Items oil pressure.
10/30/1987 Revised Commitment: Commitment is being canceled.
Justification: The plant was shut down in 1986-1987 due to poor maintenance practices. Every action taken during that time in response became a commitment. Based on changes and the evolution of engineering processes and maintenance practices over the past 30 years, many of the actions to which the site committed now add more shutdown safety risk than the benefit gained from performing these tasks. In some cases, the commitments are no longer prudent or logical. This commitment falls into one of those categories and is therefore being canceled. Current processes will determine appropriate surveillance/testing practices and intervals.
1014023 Update to 1986-1987 12/01/2016 Original Commitment: Station loads, including safety loads, are normally Maintenance Outage Action supplied from main generator through station power transformer. Test fast Items transfer periodically in the future.
10/30/1987 Revised Commitment: Commitment is being canceled.
Justification: T he plant was shut down in 1986-1987 due to poor maintenance practices. Every action taken during that time in response became a commitment. Based on changes and the evolution of engineering processes and maintenance practices over the past 30 years, many of the actions to which the site committed now add more shutdown safety risk than the benefit gained from performing these tasks. In some cases, the commitments are no longer prudent or logical. This commitment falls into one of those categories and is therefore being canceled. Current processes will determine appropriate surveillance/testing practices and intervals.
Page 6 of 9
ATTACHMENT 2 PALISADES NUCLEAR PLANT COMMITMENT CHANGE
SUMMARY
REPORT Date of Commitment Letter Title and Date of Commitment Number Original Commitment Description Change 1014024 Update to 1986-1987 12/01/2016 Original Commitment: Following turbine or reactor trip, 4160V buses 1A and Maintenance Outage Action 1B auto transfer to standby source and all auxiliaries continue to run. If Items determined to operate on station power, fast transfer function will be 10/30/1987 periodically performed.
Revised Commitment: Commitment is being canceled.
Justification: The plant was shut down in 1986-1987 due to poor maintenance practices. Every action taken during that time in response became a commitment. Based on changes and the evolution of engineering processes and maintenance practices over the past 30 years, many of the actions to which the site committed now add more shutdown safety risk than the benefit gained from performing these tasks. In some cases, the commitments are no longer prudent or logical. This commitment falls into one of those categories and is therefore being canceled. Current processes will determine appropriate surveillance/testing practices and intervals.
1014026 Update to 1986-1987 12/01/2016 Original Commitment: If trip accompanied by failure in standby source, Maintenance Outage Action turbine will supply power to primary coolant pumps for a limited time while Items coasting down to 80% speed. Periodic testing will be performed if 10/30/1987 determined necessary.
Revised Commitment: Commitment is being canceled .
Justification: The plant was shut down in 1986-1987 due to poor maintenance practices. Every action taken during that time in response became a commitment. Based on changes and the evolution of engineering processes and maintenance practices over the past 30 years, many of the actions to which the site committed now add more shutdown safety risk than the benefit gained from performing these tasks. In some cases, the commitments are no longer prudent or logical. This commitment falls into one of those categories and is therefore being canceled. Current processes will determine appropriate surveillance/testing practices and intervals.
Page 7 of 9
ATTACHMENT 2 PALISADES NUCLEAR PLANT COMMITMENT CHANGE
SUMMARY
REPORT Date of Commitment Letter Title and Date of Commitment Number Original Commitment Description Change 1014028 Update to 1986-1987 12101/2016 Original Commitment: Periodically test to verify remote/local operation of Maintenance Outage Action Appendix A isolation switches for 2400V breaker.
Items I
10/30/1987 Justification: The plant was shut down in 1986-1987 due to poor I I
maintenance practices. Every action taken during that time in response became a commitment. Based on changes and the evolution of engineering processes and maintenance practices over the past 30 years, many of the actions to which the site committed now add more shutdown safety risk than the benefit gained from performing these tasks. In some cases, the commitments are no longer prudent or logical. This commitment falls into one of those categories and is therefore being canceled. Current processes will determine C!QproJ!riate surveillance/testing practices and intervals.
1014029 Update to 1986-1987 12/01/2016 Original Commitment: All 2400 breakers on buses 1C and 1D are also Maintenance Outage Action capable of being controlled from the switchgear. Breakers will be operated Items locally. Verify control of buses 1C and 1D from switchgear periodically.
10/30/1987 Revised Commitment: Commitment is being canceled.
Justification: T he plant was shut down in 1986-1987 due to poor maintenance practices. Every action taken during that time in response became a commitment. Based on changes and the evolution of engineering processes and maintenance practices over the past 30 years, many of the actions to which the site committed now add more shutdown safety risk than the benefit gained from performing these tasks. In some cases, the commitments are no longer prudent or logical. This commitment falls into one of those categories and is therefore being canceled. Current processes will determine appro~iate surveillance/testing Qractices and intervals.
Page 8 of 9
ATTACHMENT 2 PALISADES NUCLEAR PLANT COMMITMENT CHANGE
SUMMARY
REPORT Date of Commitment Letter Title and Date of !
Commitment Original Commitment Description I
Number Change 1014031 Update to 1986-1987 12/01/2016 Original Commitment: Critical breaker and motor overload trips are Maintenance Outage Action annunciated in control room. Annunciation of critical breaker trips and motor Items overload trip will be verified periodically in the future, to the extent practical.
10/30/1987 Revised Commitment: Commitment is being canceled.
Justification: The plant was shut down in 1986-1987 due to poor maintenance practices. Every action taken during that time in response became a commitment. Based on changes and the evolution of engineering processes and maintenance practices over the past 30 years, many of the actions to which the site committed now add more shutdown safety risk than the benefit gained from performing these tasks. In some cases, the commitments are no longer prudent or logical. This commitment falls into one of those categories and is therefore being canceled. Current processes will determine appropriate surveillance/testing practices and intervals.
1014124 Update to 1986-1987 12101/2016 Original Commitment: Station loads, including safety loads, normally Maintenance Outage Action supplied main generator through station power transformer. On loss of main Items generator loads are auto transferred from normal source to immediately 10/30/1987 access offsite power circuit. Test during plant operations and verify periodically.
Revised Commitment: Commitment is being canceled.
Justification: The plant was shut down in 1986-1987 due to poor maintenance practices. Every action taken during that time in response became a commitment. Based on changes and the evolution of engineering processes and maintenance practices over the past 30 years, many of the actions to which the site committed now add more shutdown safety risk than the benefit gained from performing these tasks. In some cases, the commitments are no longer prudent or logical. This commitment falls into one of those categories and is therefore being canceled. Current processes will determine appropriate surveillance/testing practices and intervals.
Page 9 of 9