PNP 2024-049, Response to Request for Additional Information Regarding the License Amendment Request to Reinstate the Operating Technical Specifications

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Response to Request for Additional Information Regarding the License Amendment Request to Reinstate the Operating Technical Specifications
ML24354A111
Person / Time
Site: Palisades Entergy icon.png
Issue date: 12/19/2024
From: Fleming J
Holtec, Holtec Palisades
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
HDI PNP 2024-049
Download: ML24354A111 (1)
v • d • e


Text

27780 Blue Star Highway, Covert, MI 49043 HDI PNP 2024-049 10 CFR 50.90 December 19, 2024 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Palisades Nuclear Plant Renewed Facility Operating License No. DPR-20 NRC Docket No. 50-255

Subject:

Response to Request for Additional Information Regarding the License Amendment Request to Reinstate the Operating Technical Specifications

References:

1)

Holtec Decommissioning International, LLC (HDI) letter to U.S. Nuclear Regulatory Commission (NRC), License Amendment Request to Revise Renewed Facility Operating License and Permanently Defueled Technical Specifications to Support Resumption of Power Operations, dated December 14, 2023 (ADAMS Accession No. ML23348A148)

2)

HDI letter to NRC, Supplement to License Amendment Request to Revise Renewed Facility Operating License and Permanently Defueled Technical Specifications to Support Resumption of Power Operations, dated July 9, 2024 (ADAMS Accession No. ML24191A422)

3)

NRC email to James Miksa (HDI), RE: DRAFT Request for Additional Information: Palisades Operating Final Safety Analysis Report, dated November 22, 2024 By letter dated December 14, 2023, Holtec Decommissioning International, LLC (HDI), on behalf of Holtec Palisades LLC, requested U.S. Nuclear Regulatory Commission (NRC) review and approval of a license amendment request (LAR) to revise the Palisades Nuclear Plant (PNP) Renewed Facility Operating License (RFOL) DPR-20 (Reference 1). The LAR proposed to revise the RFOL, Appendix A Permanently Defueled Technical Specifications (PDTS), and the Appendix B Environmental Protection Plan (EPP) to reflect the resumption of power operations at PNP.

Following submittal of the LAR, the NRC informed HDI of several items that potentially could require clarification or administrative corrections. HDI reviewed the NRC identified items and submitted supplemental information in a letter, dated July 9, 2024 (Reference 2), which provided further clarity and administrative corrections to the LAR.

On November 22, 2024, the NRC issued a request for additional information (RAI) (Reference

3) regarding PNP's planned transition from the Defueled Safety Analysis Report (DSAR) to the power operating licensing basis (POLB) Updated Final Safety Analysis Report (UFSAR) under the 10 CFR 50.59, Changes, tests and experiments, process in support of the proposed changes to the RFOL and PDTS contained in the LAR, as supplemented.

HDI PNP 2024-049 Page 2 of 3 The Enclosure to this letter provides the HDI response to the NRC RAI. As documented in the Enclosure, minor editorial errors that were introduced in the Technical Specification (TS) pages provided in the LAR supplement (Reference 2) have been corrected, and the corrected retyped TS pages are provided in Attachment 4 to the Enclosure.

Neither the RAI responses or the editorial corrections to the TS pages alter the no significant hazards consideration or environmental evaluation contained in the original LAR (Reference 1).

In accordance with 10 CFR 50.91(b), State consultation, HDI is notifying the State of Michigan of this LAR supplement by transmitting a copy of this letter, with its enclosure, to the designated State of Michigan official.

This letter contains no new regulatory commitments and no revisions to existing regulatory commitments.

If you have any questions regarding this submittal, please contact Jim Miksa, Manager, Regulatory Assurance, Palisades, at (269) 764-2945.

I declare under penalty of perjury that the foregoing is true and correct. Executed on December 19, 2024.

Respectfully, Jean A. Fleming Vice President, of Licensing and Regulatory Affairs Holtec International

Enclosure:

Response to Request for Additional Information Related to the License Amendment Request to Reinstate the Operating Technical Specifications Enclosure Attachments:

1. Changes to the Pre-Shutdown Updated Final Safety Analysis Report to Support the Transition to Power Operations
2. Changes to the Defueled Safety Analysis Report to Support the Transition to Power Operations
3. Changes to the Facility that are Anticipated to Support the Transition to Power Operations
4. Corrected Retyped Technical Specification Pages Digitally signed by Jean A. Fleming DN: cn=Jean A. Fleming, c=US, o=Holtec Decommissioning International, LLC, ou=Regulatory and Environmental Affairs, email=J.Fleming@Holtec.com Date: 2024.12.19 08:02:43 -05'00' Jean A.

Fleming

HDI PNP 2024-049 Page 3 of 3 cc:

NRC Region III Regional Administrator NRC Senior Resident Inspector - Palisades Nuclear Plant NRC Project Manager - Palisades Nuclear Plant Designated Michigan State Official

HDI PNP 2024-049 Enclosure Response to Request for Additional Information Related to the License Amendment Request to Reinstate the Operating Technical Specifications

HDI PNP 2024-049 Enclosure Page 1 of 4 Introduction By application dated December 14, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23348A148, Holtec Decommissioning International, LLC (HDI), on behalf of Holtec Palisades, LLC, requested changes to Renewed Facility Operating License (RFOL) No. DPR-20 for the Palisades Nuclear Plant (PNP). Specifically, HDI requested U.S. Nuclear Regulatory Commission (NRC, the Commission) approval of a license amendment request (LAR) to revise selected sections of the RFOL, the Permanently Defueled Technical Specifications (PDTS), and the Environmental Protection Plan to reflect the proposed resumption of power operations at PNP.

The LAR proposes changes to selected sections of the technical specifications (TS) listed in paragraph (c) of section 50.36, "Technical specifications," of Title 10 of the Code of Federal Regulations (10 CFR) related to TS requirements that are necessary to support power operations. In the LAR, HDI states that the proposed changes are consistent with the previously approved PNP power operations technical specifications, which were in effect just prior to permanent shutdown and defueling of the plant in May 2022.

To complete its review of the proposed operating TS changes for PNP, the NRC staff has determined that additional information is needed. The regulatory basis and the requested information are below. Timely and accurate responses to these questions are requested.

Regulatory Bases for Request Section 50.90, "Application for amendment of license, construction permit, or early site permit,"

of 10 CFR requires that whenever a licensee desires to amend the license, an application for an amendment must be filed with the Commission fully describing the changes desired and following, as far as applicable, the form prescribed for original license applications. Under paragraph (a) of 10 CFR 50.92, "Issuance of amendment," the NRC determinations on license amendment requests "will be guided by the considerations which govern the issuance of initial licenses to the extent applicable and appropriate."

The NRC regulatory requirements related to the content of the TS are contained in 10 CFR 50.36. Specifically, 10 CFR 50.36(a)(1) states, in part, that "[e]ach applicant for a license authorizing operation of a production or utilization facility shall include in his application proposed technical specifications in accordance with the requirements of this section." In accordance with this requirement, TS will include items in the following five categories (as pertinent to operating nuclear power reactors): (1) safety limits and limiting safety system settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SRs);

(4) design features; and (5) administrative controls.

Paragraph (b) of 10 CFR 50.34, "Contents of applications; technical information," states, in part, that each operating license shall include a final safety analysis report (FSAR). The final safety analysis report must include information that describes the facility, presents the design bases and the limits on its operation, and presents a safety analysis of the structures, systems, and components and of the facility as a whole. Furthermore, 10 CFR 54.37, "Additional records and recordkeeping requirements," addresses the recordkeeping requirements related to the FSAR as it pertains to the extended period of operation.

HDI PNP 2024-049 Enclosure Page 2 of 4 Requests for Additional Information NRC Request

1. In Section 2.2, "Description of Proposed Change," of the Enclosure to the LAR, the licensee explains that the Updated Final Safety Analysis Report (UFSAR), currently titled the Defueled Safety Analysis Report (DSAR), will be updated via the 10 CFR 50.59, "Changes, tests and experiments," process "to reflect the docketed version that was in effective prior to the 10 CFR 50.82(a)(1) certifications, PNP UFSAR Revision 35," which is available at ADAMS Accession No. ML21125A344. Section 2.2 further states:

Any DSAR retained changes to UFSAR Revision 35 have been or will be evaluated via the 10 CFR 50.59 process against UFSAR Revision 35 to determine if NRC approval is required prior to exiting the period of decommissioning. This will include reinstatement of accident analyses and the safety classification of systems, structures, and components (SSCs), required to support the PNP power operations licensing basis (POLB). Changes made to the UFSAR after Revision 35 will be evaluated for retention, to the extent appropriate for an operating plant. The DSAR change back to the PNP POLB UFSAR will be accomplished under the 10 CFR 50.59 process and be implemented coincident with the associated license amendments.

In addition to this general statement regarding restoration of the UFSAR to the previous Revision 35, the application cites the content of UFSAR Revision 35 in support of numerous proposed changes to the license and technical specifications.

The content of the UFSAR is important for the NRC staffs review because an acceptable UFSAR is necessary for authorized reactor operation under an NRC license and the licensee is relying on the proposed UFSAR content to support specific proposed changes to the license. As stated above, HDI plans to make or retain other UFSAR changes in addition to restoring the UFSAR to Revision 35, but the application does not specifically describe these changes or explain why they are acceptable. Under 10 CFR 50.90, an application for an amendment must "fully describ[e]" the changes.

Accordingly, please (1) specifically describe any planned differences from the content of UFSAR Revision 35 (including the planned retention of DSAR changes to UFSAR Revision 35) and (2) explain why these differences from Revision 35 are acceptable and satisfy the standards in 10 CFR 50.92(a) for license amendments.

HDI Response The planned differences from the content of PNP UFSAR Revision 35 (pre-shutdown UFSAR),

submitted to the NRC on April 14, 2021 (Reference 1), and the POLB UFSAR are presented in Attachments 1, 2, and 3 to this Enclosure. Attachment 1 identifies and describes the changes to the pre-shutdown UFSAR that will be retained and included in the POLB UFSAR. Attachment 2 identifies changes to UFSAR Revision 36, which is the DSAR submitted to the NRC on March 31, 2023 (Reference 2), and describes the changes to the DSAR that will be retained and included in the POLB UFSAR. Attachment 3 identifies and describes ongoing, planned, and pending activities that are anticipated to result in updates to the pre-shutdown UFSAR. These ongoing, planned, and pending activities will be evaluated under 10 CFR 50.59, Changes, tests and experiments, and incorporated into the POLB UFSAR at implementation of the PNP power

HDI PNP 2024-049 Enclosure Page 3 of 4 operations technical specifications (POTS) following NRC approval of the LAR (Reference 3).

The updated POLB UFSAR will be submitted to the NRC in accordance with 10 CFR 50.71, Maintenance of records, making of reports, paragraph (e). The changes to the pre-shutdown UFSAR and DSAR will provide assurance that the POLB UFSAR remains consistent with the plant design and analyses to support the previously submitted POTS LAR which revise selected sections of the RFOL, the PDTS, and the Environmental Protection Plan to reflect the proposed resumption of power operations at PNP. Furthermore, HDI has processes in place in compliance with 10 CFR 50.59 and/or 10 CFR 50.54, Conditions of licenses, to determine whether changes to plant equipment and required programs would result in changes to the pre-shutdown UFSAR and DSAR and if the changes require NRC approval prior to implementation.

If prior NRC approval is required, HDI will follow appropriate regulatory processes to request and obtain approval of the license amendment pursuant to 10 CFR 50.90, Applications for amendment of license, construction permit, or early site permit, and 10 CFR 50.92, Issuance of amendment, paragraph (a).

NRC Request

2. The operating TS LAR was supplemented on July 9, 2024 (ML24191A422), to correct several editorial errors. However, three additional minor errors were introduced by these changes and should be addressed in the final version of the operating TS for PNP.

Specifically, Attachment 2, "Updated Retyped Pages for the Palisades Plant," of Enclosure 2 (begins on page 23 of 111 of the supplemental information) contains the following errors:

Item TS Page Number in Enclosure 2 Error 1

3.4.15-2, Attachment 2 is missing replacement page 3.4.15-2.

Replacement page instructions (enclosure page 12 of 14) identified that page 3.4.15-2 was to be updated, which the NRC staff verified is correct. However, page 3.4.15-2 was not included in Enclosure 2, Attachment 2.

2 3.4.16-1, Attachment 2 should not have included replacement page 3.4.16-1.

Replacement page instructions (enclosure page 12 of 14) did not include replacing page 3.4.16-1, which the NRC staff verified is correct. However, page 3.4.16-1 was included in, Attachment 2 and introduced an editorial error.

Specifically, this page was not missing the expression

"(continued)" after ACTIONS but "(continued)" was added in the supplemental information. This is an error because it is the beginning of the Actions Table, not a continuation (see page 55 of 111 of the supplemental information).

3 3.8.1-7 The font color for the whole page appears to be a light gray rather than black, and should be corrected in the final version of the operating TS.

HDI PNP 2024-049 Enclosure Page 4 of 4 HDI Response The references to Enclosure 2, Attachment 2, "Updated Retyped Pages for the Palisades Plant" (beginning on page 23 of 111), in the above NRC Request 2 table are taken to mean Enclosure, which is the actual title of the part of the July 9, 2024 operating TS LAR supplement (ML24191A422) providing the updated retyped TS pages and containing the identified errors.

Item 1 The replacement TS page 3.4.15-2 has been updated to include the "(continued)"

parenthetical after the word "ACTIONS" in the heading at the top of the page to indicate that the ACTIONS are continued from the previous page. The corrected page is provided in Attachment 4 to this Enclosure. Please insert the corrected replacement TS page in Enclosure Attachment 2 of the July 9, 2024 operating TS LAR supplement. The addition of TS page 3.4.15-2 to Enclosure Attachment 2 of the TS LAR supplement will correct the identified error to be consistent with the page change instructions on Page 12 of 14 of the supplement Enclosure.

Item 2 Attachment 4 to this Enclosure provides TS pages 3.4.16-2 and 3.4.16-3 (absent TS page 3.4.16-1). Please replace the TS pages 3.4.16-1, 3.4.16-2, and 3.4.16-3 (3 pages) previously included in Enclosure Attachment 2 of the July 9, 2024 operating TS LAR supplement with the TS pages 3.4.16-2 and 3.4.16-3 (2 pages) provided in. The replacement of these TS pages will correct the identified error in Enclosure Attachment 2 of the TS LAR supplement to be consistent with the page change instructions on Page 12 of 14 of the supplement Enclosure.

Item 3 Attachment 4 to this Enclosure provides a clean retyped TS page 3.8.1-7. Please replace the TS page 3.8.1-7 previously included in Enclosure Attachment 2 of the July 9, 2024 operating TS LAR supplement with the replacement TS page 3.8.1-7 provided in. The replacement of this TS page will correct the font color mismatch on the page while maintaining Enclosure Attachment 2 of the TS LAR supplement consistent with the page change instructions on Page 12 of 14 of the supplement Enclosure.

References:

1.

Entergy Nuclear Operations, Inc letter to U.S. Nuclear Regulatory Commission (NRC),

Final Safety Analysis Report Update - Revision 35, dated April 14, 2021 (ADAMS Accession No. ML21125A285)

2.

Holtec Decommissioning International, LLC (HDI) letter to NRC, Final Safety Analysis Report Update Revision 36, dated March 31, 2023 (ADAMS Accession No. ML23107A064)

3.

HDI letter to NRC, License Amendment Request to Revise Renewed Facility Operating License and Permanently Defueled Technical Specifications to Support Resumption of Power Operations, dated December 14, 2023 (ADAMS Accession No. ML23348A148)

HDI PNP 2024-049 Enclosure Attachment 1 Changes to the Pre-Shutdown Updated Final Safety Analysis Report to Support the Transition to Power Operations

HDI PNP 2024-049 Enclosure Attachment 1 Page 1 of 2 Changes to the Pre-Shutdown Updated Final Safety Analysis Report to Support the Transition to Power Operations*

UFSAR Section Section Title Description / Bases 1.1.2 Licensing History Retain description of NRC approved transfer of ownership of Palisades from Entergy Nuclear Palisades, LLC, to Holtec Palisades, LLC (Holtec Palisades) and the transfer of operating authority of Palisades to Holtec Decommissioning International, LLC (HDI). This transfer of ownership was approved by the NRC on December 13, 2021. The replacement of the word "plant" with the word "facility" is not retained.

Table 1-1 Chronological Licensing Events Retain chronological additions to Table 1-1 dated December 13, 2021, May 13, 2022, June 13, 2022, and June 28, 2022.

These additions to the UFSAR provide historical information in chronological order describing: (1) the NRC approved transfer of Palisades ownership, (2) NRC approval of License Amendment 272 to reflect the permanent cessation of operations and permanent removal of fuel from the reactor vessel, (3) Palisades submittal of the certifications of permanent cessation of operations and permanent removal of fuel from the reactor vessel, and (4) NRC approval of License Amendment 273 to reflect transfer of ownership/operation to Holtec Palisades and HDI.

4.2 Design Basis Retain references to Table 4-1, "Primary Coolant System Parameters," and Table 4-2, "Primary Coolant System Code Requirements," in UFSAR Section 4.2. These Tables apply to UFSAR Section 4.2, "Primary Coolant System," to support power operations and are retained. The changes which delete Table 4-1, retitle Table 4-2 as "Historic Primary Coolant System Codes (e)," and add Note (e) stating that the design requirements no longer apply are not retained.

8.1.2 Description and Operation Retain editorial change that corrected the number of transmission circuits connecting the site switchyard to the power system grid from "six" to "seven." This change is consistent with the pre-existing switchyard to grid system line (aka outgoing line) connection descriptions in UFSAR Sections 8.2.2 and 8.2.3. The change to delete the GDC 17 requirements is not retained.

8.2.4 Transmission System Ownership Retain the paragraph: "Palisades does not own the transmission system to which it is connected. Contractual agreements have been executed to assure that transmission system operation, maintenance, and modifications activities are appropriately controlled, and that adequacy, availability and reliability of offsite power will continue to satisfy Palisades design and licensing basis." This paragraph replaces the previous Transmission System Ownership information, which is no longer accurate.

9.11.5 Spent Fuel Storage at an Independent Spent Fuel Storage Installation Retain editorial correction of the Reference numbers for the HI-STORM FW MPC Storage System Final Safety Analysis Report and Certificate of Compliance No. 1032. The correct Reference numbers for the HI-STORM FW MPC Storage System Final Safety Analysis Report is Reference 79 and

HDI PNP 2024-049 Enclosure Attachment 1 Page 2 of 2

  • The changes to the pre-shutdown UFSAR identified for retention in the POLB UFSAR are based on a review of the list of changes provided in Enclosure 1 Attachment 2 of the 10 CFR 50.71(e) UFSAR update submittal, dated March 31, 2023 (Reference 2 of the Enclosure to this letter).

UFSAR Section Section Title Description / Bases Reference 80 for Certificate of Compliance No. 1032. These References are listed at the end of Chapter 9.

11.1 Source Terms Retain editorial correction of the Reference to Table 11-10 as presenting the recalculated and expanded source term for 1%

failed fuel for AST analyses. The correct Reference is Table 11-17, "Primary Coolant Fission and Corrosion Product Activities for AST Dose Analyses." The change to eliminate discussions of coolant activity during plant operation is not retained.

11.6.6.10 External Radiation Dose Determination Retain the change to the reference to "primary thermoluminescent dosimeters" to just "primary dosimeters."

This change more accurately describes radiation protection practices, in that other than thermoluminescent dosimeters can be used as primary dosimeters.

11.6.7.4 Personal Monitoring Instrumentation Retain the change to the reference to "Thermoluminescent dosimeters" to "Thermoluminescent or optically stimulated luminescent dosimeters." This change more accurately describes radiation protection practices, in that other than thermoluminescent dosimeters can be used for personal monitoring.

11.6.8.4 Radiation Protection Instrumentation Retain the change to the reference to "Thermoluminescent dosimeters (TLDs)" to "Thermoluminescent dosimeters (TLDs) and/or optically stimulated luminescent dosimeters (OSLs)."

This change more accurately describes radiation protection practices, in that other than thermoluminescent dosimeters are provided for dose recording and measurement and are tested and calibrated periodically.

12.3.1 Procedure Control Requirements Retain the descriptions of the Procedure Control Requirements except for the references to the "Entergy Quality Assurance Program Manual (QAPM)." The POLB UFSAR should reference the Palisades Energy, LLC Quality Assurance Program Manual (QAPM), which was submitted to the NRC on August 2, 2024 as part of the Palisades Transition Quality Assurance Plan (TQAP) in accordance with 10 CFR 71.106(b).

Figure 12-1 Palisades Nuclear Plant Organization Retain the Figure 12-1 title "Palisades Nuclear Plant Organization" in the Table of Contents. However, the changes to Figure 12-1 are not retained. The pre-shutdown UFSAR version of Figure 12-1 should be modified to replace the title "Director, Regulatory and Performance Improvement" with "Director, Regulatory and Site Strategies" and "Regulatory Assurance" should be added as reporting to this position.

14.21.1.3.1 Analysis Method Retain the editorial change of the described event from "waste gas accident" to "waste gas incident." The use of the term "Waste Gas Incident" existed previously as the title of UFSAR Section 14.21, is the title listed in the Table of Contents for Section 14.21, and is referenced in Section 14.24.3.1.3.

HDI PNP 2024-049 Enclosure Attachment 2 Changes to the Defueled Safety Analysis Report to Support the Transition to Power Operations

HDI PNP 2024-049 Enclosure Attachment 2 Page 1 of 1 Changes to the Defueled Safety Analysis Report to Support the Transition to Power Operations Description / Bases Anticipated POLB UFSAR Section(s) Affected

1.

Update to reflect Dry Fuel Storage (DFS) campaign changes to HI-STORM FW 72.212 Report, NUHOMS 72.212 Report, and VSC-24 72.212 Report. This change currently only applies to the DSAR but the DFS project is expected to revise the documentation to include an update to the POLB UFSAR following Palisades transition to power operations.

1.5-3, 9-5, 9.11-25, 9.11-27, 9.11-28, 14.11-3, 14.11-4, 14.11-6

2.

Update to reflect installation of a new Northeast Yard Power Panel. This new outdoor electrical distribution panel and cable routing are permanent installations for miscellaneous electrical power needs in the vicinity of the old construction building.

Figure 8.5, Sheet 2

HDI PNP 2024-049 Enclosure Attachment 3 Changes to the Facility That Are Anticipated to Support the Transition to Power Operations

HDI PNP 2024-049 Enclosure Attachment 3 Page 1 of 4 Changes to the Facility that are Anticipated to Support the Transition to Power Operations Each activity listed in the Table below will be reviewed for applicability to 10 CFR 50.59 and 10 CFR 72.48, Changes, tests, and experiments, in accordance with HDI processes and procedures. If necessary, a 10 CFR 50.59 and/or 10 CFR 72.48 screening and evaluation will be performed.

Any activity which screens in as adversely affecting the design function of a structure, system, or component (SSC) as described in the UFSAR or the Spent Fuel Storage Cask Final Safety Analysis Report (CFSAR), a method of performing or controlling a design function of an SSC as described in the UFSAR/CFSAR, a method of evaluation that demonstrates intended design function(s) of an SSC will be accomplished as described in the UFSAR/CFSAR, or involves a test or experiment not described in the UFSAR/CFSAR will be evaluated to determine if NRC approval is required prior to implementation. If prior NRC approval is required, HDI will follow appropriate regulatory processes to request and obtain approval of the license amendment pursuant to 10 CFR 50.90 and 10 CFR 50.92(a).

Title Description / Bases Anticipated POLB UFSAR Section(s)

Affected

1.

NFPA 805 Penetration Conduit Seals Install new 3-hour rated penetration /

conduit seals at penetration locations to meet NFPA 805 requirements 1.4.10, 1.9.1.10, 5.1.2.3, 8.5, 9.6

2.

NFPA 805 Remove Ventilation Damper Replace non-fire rated damper between Emergency Diesel Generators with 3-hour fire barrier 1.4.10, 1.9.1.10, 5.1.2.3, 8.5, 9.6

3.

NFPA 805 Fire Detection Upgrade Replace obsolete incipient fire detection equipment 1.4.10, 1.9.1.10, 5.1.2.3, 8.5, 9.6 and Table 9-10, 9-11

4.

NFPA 805 Fire Extinguishers Increase the number of fire extinguishers in fire areas for NFPA 10 Code compliance 8.7

5.

NFPA 805 Boric Acid Storage Tank Level Control Circuit Install separate fuses between NFPA 805 Safe Shutdown Equipment and non-Safe Shutdown Equipment to protect Boric Acid Storage Tank level control circuit from spurious fault in Boric Acid Batch Tank temperature control circuit 9.10

6.

NFPA-805 Atmospheric Dump Valve Control Alternative Install alternative methods to control Atmospheric Dump Valves (ADVs) locally, and provide manual bypass of ADV air supply solenoid valve for fire related failures 9.5.3.1, 9.7

HDI PNP 2024-049 Enclosure Attachment 3 Page 2 of 4

7.

NFPA-805 Component Cooling Water Temperature Control Modify Component Cooling Water (CCW) temperature control valves to open on Recirculation Actuation Signal (RAS) and fail open on loss of air, to prevent spurious closure and loss of heat removal to Engineering Safeguards System (ESS)

Pumps and Primary Coolant Pump (PCP)

Seals 9.6

8.

NFPA 805 Power Relief Valve Control Modify Power Relief Valve control circuitry and replace cables to prevent spurious energization of Power Operated Relief Valves (PORV) and loss of Primary Coolant System (PCS) inventory Chapter 9

9.

NFPA 805 Auxiliary Shutdown Panel Alternate Power Source Install alternate DC power capability to Auxiliary Hot Shutdown Panels 7.4, 7.7.4

10. NFPA 805 - 480VAC Electrical Coordination Replace 480VAC circuit breaker for the Turbine Room Crane and circuit breaker for the Main Feedwater Main Feed Lube Oil Purification Pump and 480VAC Weld Outlets to resolve electrical coordination issues Chapter 8
11. NFPA 805 - 2400VAC Electrical Coordination Adjust circuit breaker / relay settings to Station Power Transformer Feeder Breakers to resolve 2400VAC electrical coordination issues 8.4
12. NFPA 805 - 125VDC Overcurrent Protection Replace or supplement the overcurrent protection in 125VDC Distribution Panels to assure coordination at higher fault currents (125VDC Left Train)

Chapter 8

13. NFPA 805 Feedwater Purity Building and Turbine Building Fire Barrier Install new 3-hour rated fire barrier Wall and fire rated Door to the Cable and Pipe Gallery between the Feedwater Purity and Turbine Buildings 8.5
14. NFPA 805 Auxiliary Building Fire Doors Install new fire rated doors, to restore degraded fire barriers in the Auxiliary Building 8.5, 9.6
15. NFPA 805 Turbine Building Fire Doors Install new fire rated doors, to restore degraded fire barriers in the Turbine Building 8.5, 9.6
16. NFPA 805 Turbine Building Fire Dampers Upgrade existing Turbine Building Lube Oil Room dampers with fire rated dampers 8.5, 8.7
17. NFPA 805 Containment and Auxiliary Building Fire Barriers Update obsolete silicone fire barrier sealant and fill seismic gaps between Containment and the Auxiliary Buildings to meet fire rating requirements 8.5, 9.6

HDI PNP 2024-049 Enclosure Attachment 3 Page 3 of 4

18. Heater Drain Tank Level and Flow Control Upgrade Extraction Steam, Heaters, Vent and Drain (HED), replaces Feedwater Reheater Drain Tank analog level and flow controls, and air operated control valves with digital upgrades to increase accuracy and reliability 10.2
19. Containment Crane Replacements Replace Containment Boom and Jib Cranes to reduce maintenance burden 1.9.1.15
20. Auxiliary Feedwater Control Upgrade the Auxiliary Feedwater Control (AFW) System with analog to digital and digital to digital design changes to improve function and reliability 7.4.3, 9.7
21. Main Feedwater Pump Refurbish and upgrade the Main Feedwater Pump Turbine 7.5
22. Nuclear Instrumentation Power Range Drawers Replace analog Nuclear Instrumentation (NI) Power Range Monitor (PRM) drawers with digital upgrades in the Reactor Protective System (RPS) cabinets 7.2, 7.3, 7.4, 7.6
23. Main Feedwater Pump Turbine Supervisory Instrumentation Upgrade Main Feedwater Pump Turbine Supervisory Instrumentation and Independent Overspeed Protection Systems to improve function and reliability 7.5, 9.7, and 10.2.3.3
24. Main Turbine Supervisory Instrumentation Upgrade Main Turbine Supervisory Instrumentation (TSI) to improve function and reliability 7.5, 10.2
25. Main Turbine Electrohydraulic Control Upgrade obsolete Main Turbine Digital Electrohydraulic Control System to improve function and reliability 7.5
26. Alloy 600 Repair Alloy 600 Primary Water Stress Corrosion Cracking (PWSCC) mitigation activities for Primary Coolant System & Pressurizer nozzles 1.9, 4.3, and Table 1-9
27. ISFSI Cask Movement Relocate Standard Hi-Storm Flood Wind (FW) Casks on East Independent Spent Fuel Storage Installation (ISFSI) Pad 1.5, 9.11
28. Alloy 600 Repair Alloy 600 PWSCC Mitigation activities for Reactor Vessel Head (RVH) removal and replacement of tube support plate and nozzle extensions.

Industry OE has shown Alloy 600 materials to be susceptible to cracking due to Primary Water Stress Corrosion Cracking (PWSCC). Repair/replace the nozzles and weldments containing Alloy 600 material in accordance with industry regulations 1.9, 3.3, 4.3, and Table 1-9

HDI PNP 2024-049 Enclosure Attachment 3 Page 4 of 4

29. Steam Generator Tube Repair Repair Steam Generator tube leaks. Repair and/or plugging of steam generator internals in accordance with in-service inspection program 1.9.1.18, 1.9.1.21, 4.3.4, and Table 1-5
30. Incore Instrumentation Patch Panel & Cables Upgrade Incore Instrumentation Patch Panel and replace Cables 3.3, 7.4, 7.6
31. Containment Spray Modify Containment Spray Riser Supports Chapter 6
32. Building Renovation Feedwater Purity Building repurpose to support plant needs, such as office space 1.5, 9.5, 9.8, 11.6,
33. Main Turbine Upgrades Main Turbine Generator include upgrades to components such as blade shroud, air operated pilot valves, main stop valves, reheat stop valves, main governor valves, main governor valve gasket, gland seal casing, new bearings with improved babbitt, and replacement of obsolete Fiber Vibration Monitor System.

7.5.3.6, 10.1, 10.2

34. Plant Process Computer System Upgrade The upgrade to the Plant Process Computer System will replace the current process computer in (phased approach) to improve reliability and ability to service the system.

7.2, Table 5.2-5, and Figure 7-61

35. Control Room Heating, Ventilation and Air Conditioning System Replace the Control Room Heating, Ventilation, and Air Conditioning (HVAC) system Refrigerant Condensing Unit Heat Exchangers and Ventilation Main Supply Fans, i.e. Chillers and Air Handlers 9.8
36. Spent Fuel Pool Cooling Provide Alternate Cooling Taps to Spent Fuel Pool (SFP) Heat Exchanger 9.4
37.

Spent Fuel Pool Cooling Provide temporary cooling to the Spent Fuel Pool, to allow for Component Cooling Water (CCW) heat exchanger modifications 9.4

38.

Component Cooling Water System Upgrade Replace both Component Cooling Water (CCW) heat exchangers with modular design, upgrade, for system reliability 9.3

39. Instrument Air System Replace Instrument Air Compressors and Dryer 9.5.1
40. Engineered Safeguards Replace Safeguards Rooms watertight barriers 5.4.2, 5.6.7.3, 6.1.4
41.

Building Consolidation Upgrade South Rad Waste Storage Building to replace East Radwaste Storage Building 5.1.7.5, 11.6.5.2, and Table 11-16

42. Reactor Vessel Internals Reactor Vessel Internals / Baffle Bolts /

Core Barrel / Leak Before Break Analysis 1.9.1.17 and Table 1-9

43.

Repair Thermal Sleeve Repair dislodged and rotated High Pressure Safety Injection to Primary Coolant System Cold Leg Thermal Sleeve 4.3.6

HDI PNP 2024-049 Enclosure Attachment 4 Corrected Retyped Technical Specification Pages 4 pages follow

PCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued)

Palisades Nuclear Plant 3.4.15-2 Amendment No. XXX CONDITION REQUIRED ACTION COMPLETION TIME C.

All required channels inoperable.

C.1 Enter LCO 3.0.3.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 Perform CHANNEL CHECK of the required containment sump level indicator.

In accordance with the Surveillance Frequency Control Program SR 3.4.15.2 Perform CHANNEL CHECK of the required containment atmosphere gaseous activity monitor.

In accordance with the Surveillance Frequency Control Program SR 3.4.15.3 Perform CHANNEL CHECK of the required containment atmosphere humidity monitor.

In accordance with the Surveillance Frequency Control Program SR 3.4.15.4 Perform CHANNEL FUNCTIONAL TEST of the required containment air cooler condensate level switch.

In accordance with the Surveillance Frequency Control Program SR 3.4.15.5 Perform CHANNEL CALIBRATION of the required containment sump level indicator.

In accordance with the Surveillance Frequency Control Program

PCS Specific Activity 3.4.16 ACTIONS (continued)

Palisades Nuclear Plant 3.4.16-2 Amendment No. XXX CONDITION REQUIRED ACTION COMPLETION TIME B.

Required Action and associated Completion Time of Condition A not met.

OR DOSE EQUIVALENT I-131 40 µCi/gm.

OR Gross specific activity of the primary coolant not within limit.

B.1 Be in MODE 3 with Tave < 500F.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.16.1 Verify primary coolant gross specific activity 100/ µCi/gm.

In accordance with the Surveillance Frequency Control Program

PCS Specific Activity 3.4.16 SURVEILLANCE REQUIREMENTS (continued)

Palisades Nuclear Plant 3.4.16-3 Amendment No. XXX SURVEILLANCE FREQUENCY SR 3.4.16.2

NOTE---------------------------

Only required to be performed in MODE 1.

Verify primary coolant DOSE EQUIVALENT I-131 specific activity 1.0 µCi/gm.

In accordance with the Surveillance Frequency Control Program AND Once between 2 and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after THERMAL POWER change of 15% RTP within a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period SR 3.4.16.3

NOTE---------------------------

Not required to be performed until 31 days after a minimum of 2 EFPD and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

Determine from a sample taken in MODE 1 after a minimum of 2 EFPD and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

In accordance with the Surveillance Frequency Control Program

AC Sources - Operating 3.8.1 Palisades Nuclear Plant 3.8.1-7 Amendment No. XXX SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.8

NOTE-----------------------------

Momentary transients outside the load and power factor ranges do not invalidate this test.

Verify each DG, operating at a power factor 0.9, operates for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:

a.

For 100 minutes loaded its peak accident loading; and

b.

For the remaining hours of the test loaded 2300 kW and 2500 kW.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.9

NOTE-----------------------------

This Surveillance shall not be performed in MODE 1, 2, 3, or 4.

Verify each DG:

a.

Synchronizes with offsite power source while supplying its associated 2400 V bus upon a simulated restoration of offsite power;

b.

Transfers loads to offsite power source; and

c.

Returns to ready-to-load operation.

In accordance with the Surveillance Frequency Control Program

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