ML21124A006

Pre-Application PDTS Meeting Slides (L-2021-LRM-xxxx)

ML21124A006
Person / Time
Site:	Palisades
Issue date:	05/12/2021
From:	Entergy Nuclear Operations
To:	Scott Wall Plant Licensing Branch III
Wall S
References
Download: ML21124A006 (20)

Text

Palisades Nuclear Plant Pre-Application Meeting May 12, 2021

Topic License Amendment Request (LAR)

Permanently Defueled Technical Specifications (PDTS) 1 1

Agenda

• Purpose

• Content

• Design Basis Accidents

• PDTS Proposed Changes

- Renewed Facility Operating License Changes

- Technical Specifications

- Environmental Protection Plan

• Regulatory Basis

• Industry Precedent

• Schedule

• Questions 1

2

Purpose

• Present proposed changes to the Palisades Nuclear Plant (PNP) operating license:

- Renewed Facility Operating License (RFOL)

- Technical Specifications (TS)

- Environmental Protection Plan (EPP)

• Solicit NRC Staff Questions and Comments 1

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Content

• Applicability of Updated Final Safety Analysis Report (UFSAR)

Design Basis Accidents (DBAs) after Permanent Shutdown

• Description of Each Change with Basis

• Applicable Regulatory Requirements

• No Significant Hazards Consideration

• Precedent

• Mark-ups and Clean RFOL, TS, and EPP Pages

• Mark-ups of the TS Bases (for information only) 1 4

Design Basis Accidents

• Postulated Cask Drop Accidents No Additional Analysis Ventilation Filtration Requirements for Fuel Decayed < 90 Days Proposed License Condition to Support Ventilation TS Removal

• Fuel Handling Incident (FHA)

Additional Analysis for Spent Fuel Pool (SFP) Cases Ventilation Filtration Requirements for Fuel Decayed < 17 Days Proposed Effective Date of Amendment > 17 Days

• Liquid Waste Incident No Additional Analysis No PDTS Limiting Condition for Operation (LCOs) Required to Mitigate Consequences

• Waste Gas Incident No Additional Analysis Dose Limits Met with Fuel Decay of 17 Days 1

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Design Basis Accidents

• Fuel Handling Incident (FHA)

Additional analysis cases for FHA in SFP Used methods/assumption consistent with those in the alternative source term calculations of record Results show ventilation filtration to mitigate offsite and control room dose consequences not required for FHA occurring > 17 days after shutdown LAR proposes that the license amendment will not become effective until > 17 days after permanent shutdown Supports proposed removal of:

o TS 3.7.10, Control Room Ventilation CRV Filtration o TS 3.7.11, Control Room Ventilation (CRV) Cooling o TS 3.7.12, Fuel Handling Area Ventilation System 1

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PDTS Proposed Changes Renewed Facility Operating License (RFOL)

• Add Operating License condition 2.C.(5)

- Movement of a fuel cask in or over the spent fuel pool is prohibited when irradiated fuel assemblies decayed less than 90 days are in the spent fuel pool

• Remove NFPA-805 Transition License Condition 2.C.(3)

- License Condition requires compliance with 10 CFR 50.48(a) and 10 CFR 50.48(c)

- PNP will comply with a 10 CFR 50.48(f) Fire Protection Program once the reactor is permanently defueled 1

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PDTS Proposed Changes Renewed Facility Operating License (RFOL):

• Administrative Changes:

- Remove term Operating to reflect PNP as a Permanently Defueled Reactor

- Remove historical license conditions

- Remove license conditions applicable to operating plants 1

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PDTS Proposed Changes TS Section 1.0, Use and Application:

• TS 1.1 Definitions deleted except for:

ACTIONS CERTIFIED FUEL HANDLER NON-CERTIFIED OPERATOR

• TS 1.2 Logical Connectors Revised to reflect remaining TS

• TS 1.3 Completion Times Revised to reflect remaining TS

• TS 1.4 Frequency Revised to reflect remaining TS 1

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PDTS Proposed Changes TS Section 3.0, LCO Applicability

• TS 3.0 Limiting Condition for Operation (LCO) Applicability LCO 3.0.1 and LCO 3.0.2 revised to reflect remaining TS TS LCO 3.0.3 through LCO 3.0.9 deleted TS SR 3.0.1 through SR 3.0.4 revised to reflect remaining TS 1

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PDTS Proposed Changes TS Section 3.0, LCO Applicability

• TS 3.1 through TS 3.9 Deleted except for:

TS 3.7.14, Spent Fuel Pool (SFP) Water Level TS 3.7.15, Spent Fuel Pool (SFP) Boron Concentration TS 3.7.16, Spent Fuel Pool Storage

• TSs 3.7.14 and 3.7.15 FREQUENCY Changed back to original 7 days Surveillance Frequency Control Program Removed

• TSs TS 3.7.10, TS 3.7.11, TS 3.7.12 Removal Requirements Postulated Cask Drop Accidents - License Condition 2.C.(5)

Spent Fuel 90 days decay requirement FHA - PDTS Amendment Effective Date after 17 days Spent Fuel Decay 1

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PDTS Proposed Changes TS Section 4.0, Design Features

• TS 4.1 Site Location No Change

• TS 4.2 Reactor Core Deleted

• TS 4.3 Fuel Storage Revised to Remove Sections Applicable to Receipt of New Fuel 1

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PDTS Proposed Changes TS Section 5.0, Administrative Controls

• Deleted Sections:

TS 5.5.2, Primary Coolant Sources Outside Containment TS 5.5.5, Containment Structural Integrity Surveillance Program TS 5.5.6, Primary Coolant Pump Flywheel Surveillance Program TS 5.5.8, Steam Generator (SG) Program TS 5.5.9, Secondary Water Chemistry Program TS 5.5.10, Ventilation Filter Testing Program TS 5.5.11, Fuel Oil Testing Program TS 5.5.13, Safety Functions Determination Program (SFDP)

TS 5.5.14, Containment Leak Rate Testing Program TS 5.5.16, Control Room Envelope Habitability Program TS 5.5.17, Surveillance Frequency Control Program 1

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PDTS Proposed Changes TS Changes Section 5.0, Administrative Controls

• Deleted Sections:

TS 5.6.5, Core Operating Limits Report (COLR)

TS 5.6.6, Post Accident Monitoring Report TS 5.6.7, Containment Structural Integrity Surveillance Report TS 5.6.8, Steam Generator Tube Inspection Report 1

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PDTS Proposed Changes Environmental Protection Plan (EPP) changes:

• Administrative Changes:

- Replaced terms related to Construction or Operation with terms to reflect the handling and storage of spent fuel and maintenance of the facility where appropriate

- Replaced terms related to Plant or Station with Facility

- Removed terms related to power level 1

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Regulatory Basis PDTS Applicable Regulations:

• 10 CFR 50.82, Termination of License

• 10 CFR 50.36, Technical Specifications

• 10 CFR 50.48(f) [fire protection program requirements after termination of license under 10 CFR 50.82]

• 10 CFR 50.51, Continuation of license

• 10 CFR 50, Appendix A, General Design Criteria for Nuclear Power Plants 1

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Industry Precedent

• San Onofre Nuclear Generating Station, Units 2 and 3, Amendments 230 and 223, respectively, July 17, 2015

• Crystal River Nuclear Plant, Unit 3, Amendment 247, September 4, 2015

• Fort Calhoun Station, Amendment 297, March 6, 2018

• Oyster Creek Nuclear Generating Station, Amendment 295, October 26, 2018

• Pilgrim Nuclear Power Station, Amendment 250, October 28, 2019

• Indian Point Nuclear Generating Plant, Unit 2, Amendment 294, April 28, 2020 1

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Schedule

• Plan to submit by June 1, 2021

• Request NRC approval by May 31, 2022

• Request the Amendment Effective after:

• Irradiated Fuel in the SFP has Decayed 17 Days or More.

• Certifications of Permanent Cessation of Operations and Permanent Removal of Fuel from the Reactor Docketed in accordance with 10 CFR 50.82(a)(1)

• Requesting a 60-day implementation period after amendment becomes effective 1

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