ML18305B321
| ML18305B321 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/01/2018 |
| From: | Halter M Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18305B320 | List: |
| References | |
| PNP 2018-040 | |
| Download: ML18305B321 (4) | |
Text
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 269-764-2000 Mandy K. Halter Director, Nuclear Licensing Attachments 3 & 4 contain Security-Related Information to be withheld from Public Disclosure in accordance with 10 CFR 2.390.
Upon removal of Attachments 3 & 4, this letter is uncontrolled.
PNP 2018-040 November 1, 2018 U. S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
License Amendment Request to Revise Existing Facility Operating License Conditions Regarding NFPA 805 Modifications Palisades Nuclear Plant Docket 50-255 Renewed Facility Operating License No. DPR-20
REFERENCE:
- 1.
END letter, PNP 2012-106, "License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors," dated December 12, 2012 (ADAMS Accession Number ML12348A455)
- 2. END letter, PNP 2014-080, "Response to Request for Additional Information - License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors," dated August 14, 2014 (ADAMS Accession Number ML14226A498)
- 3. END letter, PNP 2014-097, "Response to Request for Additional Information - License Amendment Request to Adopt NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactors," dated November 4, 2014 (ADAMS Accession Number ML14308A228)
- 4. NRC letter, "Palisades Nuclear Plant - Issuance of Amendment Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance with 10 CFR 50.48(c)," dated February 27,2015 (ADAMS Accession Number ML15007A191)
PNP 2018-040 Page 2 of 4
- 5. ENO letter, PNP 2017-066, "License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications," dated November 1, 2017 (ADAMS Accession Number ML17306A086)
- 6. NRC letter, "Palisades Nuclear Plant -Issuance of Amendment RE: License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications," dated February 27, 2018 (ADAMS Accession Number ML18039A244)
- 7. NRC letter to NEI, "Recommended Content for License Amendment Requests that Seek Changes to License Conditions that were Established in Amendments to Adopt National Fire Protection Association Standard 805 But Have Yet to be Fully Implemented," dated March 2, 2016 (ADAMS Accession Number ML16015A416)
Dear Sir or Madam:
Pursuant to Title 10 of the Code of Federal Regulations, Part 50, Section 90 (10 CFR 50.90), Entergy Nuclear Operations, Inc. (ENO) requests Nuclear Regulatory Commission (NRC) review and approval of a proposed license amendment for the Palisades Nuclear Plant (PNP).
In Reference 1, ENO submitted a license amendment request (LAR) to adopt the National Fire Protection Association (NFPA) 805 performance-based standard for fire protection for light water reactors. In Reference 2, ENO submitted a response to a request for additional information (RAI) which included submittal of an updated Attachment S, "Plant Modifications and Items to be Completed During Implementation," and an updated Attachment W, Table W-1, "Fire Initiating Events Contributing >1% to the Calculated Fire Risk," and Table W-2, "PNP Fire Area Risk Summary." During the NRC review of Reference 2, another RAI was issued by the NRC. This additional RAI required a revision to the PRA model to address the impact of the treatment of the potential for fire damage external to well-sealed cabinets. ENO provided a response to this additional RAI in Reference 3. Reference 3 did not include updated Attachment W tables, but it did provide revised risk results for core damage frequency (CDF) and large early release frequency (LERF). In Reference 4, the NRC issued the safety evaluation (SE) for Reference 1, which approved the addition of the NFPA 805 license condition to the PNP renewed facility operating license (RFOL).
The PRA model of record used to support Reference 3 is the same PRA model used to evaluate the cancellation of the six modifications proposed in this
PNP 2018-040 Page 3 of 4 request. This PRA model of record uses the accepted fire PRA methods and approaches as summarized in the NRC NFPA 805 SE (Reference 4).
In Reference 5, ENO submitted a LAR to change the full compliance implementation date for the fire protection program transition license condition for required modifications. In Reference 6, the NRC issued the SE for Reference
- 5. The issuance of this LAR revised the NFPA 805 license condition to the PNP renewed facility operating license (RFOL).
ENO is requesting review and approval of a proposed amendment to the RFOL to clarify ten modifications and cancel six modifications in Attachment S, Table S-2, which is referenced in the NFPA 805 transition license condition, 2.C(3)(c)2.
The guidance provided in Reference 7 was followed to develop this LAR. This LAR utilizes Option A, described in Reference 7, because the plant modifications being cancelled have been evaluated using the accepted fire PRA methods and approaches as summarized in Reference 4. to this letter provides the basis for the proposed change and the significant hazards consideration. Attachment 2 to this letter provides the proposed RFOL changes (markup & clean). These RFOL pages meet the intent of an updated Attachment M, "License Condition Changes." Attachment 3 to this letter provides the updated Attachment S, Table S-2, "Plant Modifications Committed." Attachment 4 to this letter provides the updated Attachment W, Table W-1, "Fire Initiating Events Contributing >1% to the Calculated Fire Risk,"
and Table W-2, "PNP Fire Area Risk Summary." Attachments 3 and 4 contain security related information and should be withheld from public disclosure under 1 0 CFR 2.390.
The proposed changes have been evaluated in accordance with 10 CFR 50.91 (a)(1) using the standards in 10 CFR 50.92(c), and it has been determined that the changes involve no significant hazards consideration. The bases for this determination are included in Attachment 1, which also includes a description of the proposed changes, a technical analysis, a regulatory safety analysis, and an environmental consideration.
ENO requests approval of the proposed license amendment within 6 months of the submittal date to support outage planning milestones, with the amendment being implemented within 60 days.
In accordance with 10 CFR 50.91 (b), a copy of this application, with attachments, is being provided to the designated State of Michigan official.
This submittal contains no proprietary information.
This letter identifies no new regulatory commitments.
PNP 2018-040 Page 4 of 4 I declare under penalty of perjury that the foregoing is true and accurate. Executed on November 1, 2018.
Sincerely, MKH\\ach Attachments:
- 1.
Description and Evaluation of Proposed Operating License Change
- 2.
Updated Attachment M, "License Condition Changes" - Proposed RFOL page changes (markup & clean)
- 3.
Updated Attachment S, Table S-2, "Plant Modifications Committed" (Security-related information, withhold under 10 CFR 2.390)
- 4.
Updated Attachment W, Table W-1," Fire Initiating Events Contributing >1% to the Calculated Fire Risk," and Table W-2,"
PNP Fire Area Risk Summary" (Security-related information, withhold under 10 CFR 2.390) cc Administrator, Region III, USNRC Project Manager, Palisades, USN RC Resident Inspector, Palisades USNRC State of Michigan