PNP 2025-033, Response to Request for Additional Information Regarding License Amendment Request to Revise Selected Permanently Defueled Technical Specifications to Support Repairing of Steam Generator Tubes by Sleeving
| ML25149A013 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/29/2025 |
| From: | Fleming J Holtec Palisades |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| PNP 2025-033 | |
| Download: ML25149A013 (1) | |
Text
27780 Blue Star Highway, Covert, MI 49043 1 Holtec Palisades, LLC ("Holtec Palisades") is the licensed owner of PNP. Holtec Decommissioning International, LLC ("HDI") is the licensed operator of PNP while the facility is in decommissioning. Pursuant to the license transfer application submitted in connection with the PNP restart (Reference 2), licensed authority will transfer from HDI to Palisades Energy, LLC ("Palisades Energy") upon NRC's approval of the transition from decommissioning back to power operations. Holtec Palisades will remain the licensed owner of PNP.
PNP 2025-033 10 CFR 50.90 May 29, 2025 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Palisades Nuclear Plant NRC Docket No. 50-255 Renewed Facility Operating License No. DPR-20
Subject:
Response to Request for Additional Information Regarding License Amendment Request to Revise Selected Permanently Defueled Technical Specifications to Support Repairing of Steam Generator Tubes by Sleeving By letter dated February 11, 2025 (Reference 1), Holtec1 requested U.S. Nuclear Regulatory Commission (NRC) review and approval of a license amendment request (LAR) to revise the Palisades Nuclear Plant (PNP) Permanently Defueled Technical Specifications (PDTS) to allow use of Framatome Alloy 690 sleeves to repair defective steam generator (SG) tubes as an alternative to removing the tubes from service by plugging. The approval of this LAR is contingent upon prior approval of the LAR dated December 14, 2023 (Reference 3) that proposes changes to the Technical Specifications (TSs) to support the resumption of power operations at PNP and that is currently under NRC review.
By electronic mail (email) received on April 14, 2025, the NRC forwarded a draft request for additional information (RAI) regarding the LAR. A clarification call with the NRC reviewers was held on April 29, 2025 to discuss the LAR, and the NRC provided the final RAI in an email dated May 7, 2025 (Reference 4).
to this letter provides the responses to the RAI questions. Enclosures 2 and 3 provide revised TS markup pages and retyped pages, respectively, that address the RAI questions. Enclosure 4 provides a conforming change to a TS Bases page in markup form for information only. The TS and TS Bases pages provided in Enclosures 2, 3, and 4 supersede and replace the corresponding pages provided in Enclosures 2, 3, and 4 of the Reference 1 LAR.
The revised TS pages do not alter the no significant hazards consideration contained in the Reference LAR.
In accordance with 10 CFR 50.91(b), State consultation, Holtec is notifying the State of Michigan of these RAI responses by transmitting a copy of this letter, with Enclosures, to the designated State of Michigan official.
HOLTEC PALISADES
PNP 2025-033 Page 2 of 3 If you have any questions regarding this submittal, please contact Frank Sienczak, Regulatory Assurance Manager, at (269) 764-2520.
This letter contains no new regulatory commitments and no revisions to existing regulatory commitments.
I declare under penalty of perjury that the foregoing is true and correct. Executed on May 29, 2025.
Respectfully, Jean A. Fleming Vice President, Licensing and Regulatory Assurance Holtec International
References:
- 1.
Holtec Palisades, LLC (Holtec) letter to U.S. Nuclear Regulatory Commission (NRC), License Amendment Request to Revise Selected Permanently Defueled Technical Specifications to Support Repairing of Steam Generator Tubes by Sleeving, dated February 11, 2025 (ADAMS Accession Nos. ML25042A692 and ML25043A348)
- 2.
Holtec Decommissioning International, LLC (HDI) letter to NRC, Application for Order Consenting to Transfer of Control of License and Approving Conforming License Amendments, dated December 6, 2023 (ADAMS Accession No. ML23340A161)
- 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)
- 4.
NRC letter to Holtec, Request for Additional Information RE: Steam Generator Tube Sleeving Amendment (L-2025-LLA-0036), dated May 7, 2025 (ADAMS Accession No. ML25128A171) : Response to Request for Additional Information - License Amendment Request to Revise Selected Permanently Defueled Technical Specifications to Support Repairing of Steam Generator Tubes by Sleeving : Technical Specification Page Markups : Retyped Technical Specification Pages : Technical Specifications Bases Page Markups (For information only)
Digitally signed by Jean A. Fleming DN: cn=Jean A. Fleming, o=Holtec Decommissioning International, LLC, ou=Regulatory and Environmental Affairs, email=J.Fleming@Holtec.com Date: 2025.05.29 06:34:06 -04'00' Jean A.
Fleming
PNP 2025-033 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
PNP 2025-033 Page 1 of 7 PNP 2025-033 Response to Request for Additional Information License Amendment Request to Revise Selected Permanently Defueled Technical Specifications to Support Repairing of Steam Generator Tubes by Sleeving
PNP 2025-033 Page 2 of 7 Response to Request for Additional Information
=
Background===
By letter dated February 11, 2025 (Agencywide Documents Access and Management System Accession No. ML25042A692), 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) technical specifications to allow the use of Framatome Alloy 690 sleeves to repair defective steam generator (SG) tubes as an alternative to removing the tubes from service by plugging. The approval of this LAR is contingent upon the prior approval of the LAR, dated December 14, 2023 (ML23348A148), that supports resumption of power operations at PNP (e.g., restores power operation technical specifications) and is currently under NRC review.
The LAR to permit SG sleeve installation proposed changes to the following PNP technical specifications. Note, these proposed changes modify the PNP power operation technical specifications that are currently under NRC review in the December 14, 2023, LAR.
Surveillance Requirement (SR) 3.4.1.3, Verify PCS [primary coolant system] total flow rate within the limit specified in the COLR [core operating limits report],
Technical Specification (TS) 3.4.17, "Steam Generator (SG) Tube Integrity,"
TS 5.5.8, "Steam Generator (SG) Program," and TS 5.6.8, "Steam Generator Tube Inspection Report."
Regulatory Basis Section 182(a) of the Atomic Energy Act requires nuclear power plant operating licenses to include TS. In 10 CFR 50.36, "Technical specifications," NRC regulatory requirements related to the content of the TS are established. The TS for all current pressurized water reactor (PWR) licenses require that an SG Program be established and implemented to ensure that SG tube integrity is maintained. Programs established by the licensee, including the SG Program, are listed in the administrative controls section of the TS and contain the necessary requirements to operate the facility in a safe manner.
SG tube integrity is maintained by meeting the performance criteria specified in the TS for structural and leakage integrity, consistent with the plant design and licensing basis. The TS require that a condition monitoring assessment be performed during each outage in which the SG tubes are inspected, to confirm that the performance criteria are being met. The TS include provisions regarding the scope, frequency, and methods of SG tube inspections. These provisions require that the inspections be performed with the objective of detecting flaws of any type that may be present along the length of a tube and that may satisfy the applicable tube plugging criteria.
The applicable tube plugging criteria, specified in the TS, are that tubes found during in service inspection to contain flaws with a depth equal to or exceeding 40 percent of the nominal wall thickness shall be plugged, unless the tubes are permitted to remain in service through application of alternate repair criteria provided in the TS. The TS also include a limit on operational primary-to-secondary leakage, beyond which the plant must be promptly shut down. Should an existing flaw that exceeds the tube integrity repair limit not be detected during the periodic tube surveillance required by the plant TS, the operational leakage limit provides
PNP 2025-033 Page 3 of 7 added assurance of timely plant shutdown before tube structural and leakage integrity are impaired, consistent with the design and licensing bases.
The general design criteria (GDC) in Appendix A to Part 50 of Title 10 of the Code of Federal Regulations (10 CFR) provide regulatory requirements that state the reactor coolant pressure boundary (RCPB) shall have "an extremely low probability of abnormal leakage and of gross rupture" (GDC 14), "shall be designed with sufficient margin" (GDCs 15 and 31), shall be of "the highest quality standards practical" (GDC 30), and shall be designed to permit "periodic inspection and testingto assess structural and leak tight integrity" (GDC 32).
Question 1 LAR Section 3.5.1.c, "Sleeve Plugging Criteria," states, "[t]he PNP TS tube plugging limit of >40 percent through wall (TW) is also applicable to the TSP [tube support plate] sleeve."
The power operation PNP TS 5.5.8 item c, contains provisions for SG tube repair criteria. It currently states:
Tubes found by inservice inspection to contain flaws with a depth equal to or exceeding 40% [percent] of the nominal tube wall thickness shall be plugged (emphasis added).
The proposed change in the LAR to support SG tube repair by installing sleeves states:
Tubes found by inservice inspection to contain a flaw in a non-sleeved region flaws with a depth equal to or exceeding 40% [percent] of the nominal tube wall thickness shall be plugged or repaired (emphasis added).
The proposed change to TS 5.5.8 does not appear to address tubes found by inservice inspection to contain flaws in the sleeve (e.g., a requirement to plug tubes found by inservice inspection that contain a flaw in a sleeve with a depth equal to or exceeding 40 percent of the nominal sleeve wall thickness). Given the discussion above, the NRC staff requests the licensee explain how this LAR Section 3.5.1.c plugging requirement is addressed in the proposed technical specifications or justify any alternative approach.
Holtec Response to Question 1 The proposed PNP TS 5.5.8 item c wording was based on the wording approved by the NRC in the Watts Bar 2 August 10, 2020 License Amendment (ADAMS Accession No. ML20156A018):
- c.
Provisions for SG tube plugging or repair criteria. Tubes found by inservice inspection to contain a flaw in a non-sleeved region with a depth equal to or exceeding 40% of the nominal tube wall thickness shall be plugged or repaired.
The NRC reviewers commented during the clarification call held on April 29, 2025 that the Watts Bar 2 amendment was approved by the NRC when a replacement SG was onsite and that this was a consideration. The NRC reviewers suggested that Holtec consider reviewing PNP TS 5.5.8 item c against the related NRC approved Beaver Valley 2 TSs in order to address Question 1. A Framatome Engineer then presented a description of the Regulatory Guide 1.121, Bases for Plugging Degraded PWR Steam Generator Tubes, analysis performed to support the proposed plugging criteria for a flaw in a sleeve. Following Framatome's
PNP 2025-033 Page 4 of 7 presentation, the NRC reviewers restated their suggestion to consider reviewing the Beaver Valley 2 TSs related to tube plugging criteria. Beaver Valley 2 TS 5.5.5.2 item c.2 (ADAMS Accession No. ML092590189) has the following requirement:
- 2.
Tubes found by inservice inspection to contain a flaw in a sleeve with a depth equal to or exceeding the following percentages of the nominal sleeve wall thickness shall be plugged:
Westinghouse leak limiting Alloy 800 sleeves Any flaw Holtec was aware that Watts Bar 2 had an imposed limit on the service life of their leak limiting Alloy 800 sleeves of five refueling cycles of operation but elected to replace the SGs in 2022 at one refueling cycle following amendment approval. Holtec had no knowledge of any other circumstances or conditions that would result in restrictions on the SG tube repair provisions of PNP TS 5.5.8 item c beyond those imposed on Watts Bar 2. Nevertheless, to address this question, and in view of the NRC's comments, Holtec proposes to revise the PNP TS 5.5.8 item c wording to align with Beaver Valley 2 TS 5.5.5.2 item c.2. This change is acceptable to Holtec because the Framatome Alloy 690 sleeves are not expected to develop significant numbers of crack-like indications or other flaws during their service life. The revised TS wording is presented in the response to Question 2.
Question 2 LAR Section 3.5.1.c, "Sleeve Plugging Criteria," states, "[t]he PNP SG Program currently requires plugging of crack-like indications on detection in the parent tubing, except in areas within the tubesheet covered by the existing alternate repair criteria. This same plug-on-detection criteria applies to the parent tubing portion of the pressure boundary in the sleeve joint regions."
The proposed change to TS 5.5.8 does not appear to address "plug-on-detection" criteria for the parent tubing portion of the pressure boundary in the sleeve joint regions (e.g., a requirement to plug tubes with a flaw in a sleeve to tube joint). Given the discussion above, the NRC staff requests the licensee explain how this LAR Section 3.5.1.c plugging requirement is addressed in the proposed technical specifications or justify any alternative approach.
Holtec Response to Question 2 As described in the response to Question 1, Holtec proposes to revise PNP TS 5.5.8 item c to align with the related Beaver Valley 2 TSs regarding the plugging criteria for a flaw in a sleeve.
Aligning with the Beaver Valley TSs will also address this question by providing a requirement to plug tubes with a flaw detected in a sleeve to tube joint. Beaver Valley 2 TS 5.5.5.2 item c.3 has the following requirement for a flaw detected in the sleeve joint region:
- 3.
Tubes with a flaw in a sleeve to tube joint shall be plugged.
In addition, an NRC reviewer commented that Holtec should consider changing the word "shall" to "may" in PNP TS 5.5.8 item c because applying the SG alternate repair criteria as an alternate to the 40 percent depth based criteria is not a requirement, but an option, given that the tube could be plugged. The proposed change from "shall" to "may" in the last sentence of
PNP 2025-033 Page 5 of 7 PNP TS 5.5.8 item c is consistent with TS 5.5.8 item c of the Standard Technical Specifications for Combustion Engineering Plants, Revision 5.0 (NUREG-1432 Volume 1).
Based on the foregoing information as presented in the responses to Question 1 and this question, Holtec Palisades proposes to modify TS 5.5.8 item c as shown below in red text:
- c.
Provisions for SG tube plugging or tube repair criteria. Tubes found by inservice inspection to contain a flaw in a non-sleeved region with a depth equal to or exceeding 40% of the nominal tube wall thickness shall be plugged or repaired.
Sleeved tubes found by inservice inspection to contain a flaw in a sleeve or a flaw in the sleeve to tube joint shall be plugged. The following SG alternate repair criteria may be applied as an alternate to the 40% depth based criteria:
Question 3 SR 3.4.1.3 requires the licensee to "verify PCS total flow rate within the limit specified in the COLR," with (in part) an event based Frequency based on plugging SG tubes that currently states:
After each plugging of 10 or more steam generator tubes LAR Section 2.2, "Description of Proposed Change," explains that the event based Frequency will add repairing SG tubes by sleeving because sleeves can impact PCS total flow rate. The proposed change (shown below with underline and italics) to SR 3.4.1.3 event based Frequency states:
After each plugging or repairing of the number of steam generator tubes which results in the same primary flow reduction as plugging 10 or more steam generator tubes There is some ambiguity in the expression " plugging or repairing" (emphasis added). The use of "or" could mean that plugging or repairing would be considered individually. Based on the LAR, it appears that plugging or repairing or any combination of both should be compared against the event based Frequency criterion (e.g., results in the same primary flow reduction as plugging 10 or more steam generator tubes). The expression "and/or" means it could be one of these (plugging or repairing) or both of these (plugging and repairing) and may remove ambiguity. However, TSTF-GG-05-01, Revision 1, "Writers Guide for Plant-Specific Improved Technical Specifications" (ML12046A089), indicates the term "and/or" is to be avoided. Given the discussion above, the NRC staff requests the licensee explain how it plans to address the apparent ambiguity. In the response, the NRC staff requests the licensee evaluate the merits of modifying the expression in part to state, "After each plugging or repairing (or both) " as a means to address any ambiguity.
Holtec Response to Question 3 Holtec Palisades agrees with the NRC's suggestion to modify the SR 3.4.1.3 Frequency statement by adding the parenthetical "(or both)" after the word "repairing" to eliminate any ambiguity. This proposed change does not alter the original intent of the SR 3.4.1.3 Frequency statement, in that the flow resistance resulting from SG tube plugging or repairing or any combination of both should be used to determine if there is any significant impact on PCS flow resistance. The proposed change serves only to clarify the Frequency statement. The revised wording is shown below in red text:
PNP 2025-033 Page 6 of 7 After each plugging or repairing (or both) of the number of steam generator tubes which results in the same primary flow reduction as plugging 10 or more steam generator tubes A similar change will also be made to the TS Bases for SR 3.4.1.3 as shown below in red text:
PCS flow rate must also be verified after plugging or repairing (or both) the number of steam generator tubes which results in the same primary flow reduction as plugging 10 tubes since plugging 10 or more tubes could result in an increase in PCS flow resistance.
NRC Question 4 The power operation PNP TS 5.5.8 provisions for items c.1 and c.2 provide tube repair criteria as an alternate to the tube plugging (40 percent depth) criteria. TS 5.5.8 provisions for item c.1 are associated with the SG hot-leg tubesheet region. TS 5.5.8 provisions for item c.2 are associated with the SG cold-leg tubesheet region.
- a.
The LAR for SG tube repair by sleeving does not appear to directly impact or require changes to the TS 5.5.8 provisions for items c.1 and c.2. However, the LAR proposed changes to these provisions without a justification. Therefore, the NRC staff requests the licensee to provide a justification for updating the TS 5.5.8 provisions for items c.1 and c.2.
- b.
Aside from differences between c.1 and c.2 such as "hot-leg" and "cold-leg" and dimensional differences "12.5 inches" versus "13.67 inches," respectively, it appears that the proposed wording for c.1 and c.2 should have a parallel structure when compared to each other (note, the current specifications contain a parallel structure). However, the LAR proposed changes that structures c.1 and c.2 differently, which could introduce an unintended technical change. For example, "flaws located XX inches below " versus "flaws located below XX inches " convey different meanings. Therefore, the NRC staff requests the licensee provide a justification for the structural differences between the provisions for items c.1 and c.2 and address the potential introduction of an unintended technical change.
Holtec Response to Question 4.a The LAR proposed changes to the TS 5.5.8 provisions for items c.1 and c.2 to clarify potentially confusing wording in the current specifications to address internal licensee comments requesting the clarification. The current specifications use the term "within" with only one defined boundary. For this application, the word "within" should define a range inside two boundaries, but in this case only one boundary was defined, leaving the specifications incomplete and unclear. The proposed wording is not intended to change the locations where service induced flaws in the SG hot-leg and cold-leg tubesheet regions require plugging or may remain in service. The proposed changes serve only to clarify the locations. Therefore, the wording for the TS 5.5.8 provisions for items c.1 and c.2 is proposed to be revised as indicated in the response to RAI Question 4.b (below) to provide clarity and ensure proper application of specifications.
Holtec Response to Question 4.b The proposed changes in the LAR contained incorrect wording in TS 5.5.8 item c.2. The non-parallel structure was created unintentionally by the differences in wording between TS 5.5.8
PNP 2025-033 Page 7 of 7 items c.1 and c.2. The word "below" should have been added between the words "located" and "13.67" in the last sentence of TS 5.5.8 item c.2. The originally intended parallel structure and wording for the TS 5.5.8 provisions for items c.1 and c.2 are shown below with the change shown in red text:
c.1 Tubes found by inservice inspection to contain service-induced flaws between the bottom of the hot-leg expansion transition or top of the hot-leg tubesheet, whichever is lower, and 12.5 inches below the bottom of the hot-leg expansion transition or top of the hot-leg tubesheet, whichever is lower, shall be plugged. Flaws located below 12.5 inches below the bottom of the hot-leg expansion transition or top of the hot-leg tubesheet, whichever is lower, may remain in service.
c.2 Tubes found by inservice inspection to contain service-induced flaws between the bottom of the cold-leg expansion transition or top of the cold-leg tubesheet, whichever is lower, and 13.67 inches below the bottom of the cold-leg expansion transition or top of the cold-leg tubesheet, whichever is lower, shall be plugged. Flaws located below 13.67 inches below the bottom of the cold-leg expansion transition or top of the cold-leg tubesheet, whichever is lower, may remain in service.
Page Replacement Instructions Replace the TS markup pages 3.4.1-2 and 5.0-11 provided in Enclosure 2 of the February 11, 2025 LAR with the corresponding TS markup pages 3.4.1-2 and 5.0-11 provided in Enclosure 2 of this letter. The replaced TS pages supersede the corresponding pages in the LAR.
Replace the retyped TS pages 3.4.1-2 and 5.0-11 provided in Enclosure 3 of the February 11, 2025 LAR with the corresponding retyped TS pages provided in of this letter. The replaced TS pages supersede the corresponding pages in the LAR.
Replace the TS Bases markup page B 3.4.1-3 provided in Enclosure 4 of the February 11, 2025 LAR with the corresponding TS Bases markup page provided in of this letter. The replaced TS Bases page supersedes the corresponding page in the LAR.
The replacement of these TS and TS Bases pages will supplement the LAR by providing the modifications and corrections to the TSs and TS Bases described in the responses to the RAI questions.
PNP 2025-033 Technical Specification Page Markups (2 pages follow)
PCS Pressure, Temperature, and Flow DNB Limits 3.4.1 Palisades Nuclear Plant 3.4.1-2 Amendment No. XXX SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.1.1 Verify pressurizer pressure within the limits specified in the COLR.
In accordance with the Surveillance Frequency Control Program SR 3.4.1.2 Verify PCS cold leg temperature within the limit specified in the COLR.
In accordance with the Surveillance Frequency Control Program SR 3.4.1.3
NOTE----------------------------
Not required to be performed until 31 EFPD after THERMAL POWER is 90% RTP.
Verify PCS total flow rate within the limit specified in the COLR.
In accordance with the Surveillance Frequency Control Program AND After each plugging or repairing (or both) of the number of steam generator tubes which results in the same primary flow reduction as plugging 10 or more steam generator tubes
Programs and Manuals 5.5 5.5 Programs and Manuals Palisades Nuclear Plant 5.0-11 Amendment No. XXX 5.5.8 Steam Generator (SG) Program (Continued)
- b.
Performance criteria for SG tube integrity. (continued)
- 2.
Accident induced leakage performance criterion: The primary to secondary accident induced leakage rate for any design basis accident, other than a SG tube rupture, shall not exceed the leakage rate assumed in the accident analysis in terms of total leakage rate for all SGs and leakage rate for an individual SG.
Leakage is not to exceed 0.3 gpm.
- 3.
The operational LEAKAGE performance criterion is specified in LCO 3.4.13, PCS Operational LEAKAGE.
- c.
Provisions for SG tube plugging or tube repair criteria. Tubes found by inservice inspection to contain a flaw in a non-sleeved region flaws with a depth equal to or exceeding 40% of the nominal tube wall thickness shall be plugged or repaired. The following SG alternate alternative repair criteria may shall be applied as an alternate to the 40% depth based criteria:
- 1.
Tubes found by inservice inspection to contain service induced flaws within 12.5 inches below the bottom of the hot-leg expansion transition or top of the hot-leg tubesheet, whichever is lower, shall be plugged. Flaws located below this elevation may remain in service.
- 2.
Tubes found by inservice inspection to contain service induced flaws within 13.67 inches below the bottom of the cold-leg expansion transition or top of the cold-leg tubesheet, whichever is lower, shall be plugged. Flaws located below this elevation may remain in service.
- d.
Provisions for SG tube inspections. Periodic SG tube inspections shall be performed. The number and portions of the tubes inspected and methods of inspection shall be performed with the objective of detecting flaws of any type (e.g., volumetric flaws, axial and circumferential cracks) that may be present along the length of the tube, from 12.5 inches below the bottom of the hot-leg expansion transition or top of the hot-leg tubesheet, whichever is lower, to 13.67 inches below the bottom of the cold-leg expansion transition or top of the cold-leg tubesheet, whichever is lower, and that may satisfy the applicable tube plugging or tube repair criteria.
The tube to tubesheet weld is not part of the tube. In addition to meeting the requirements of d.1, d.2, d.3, and d.4 below, the inspection scope, inspection methods, and inspection intervals shall be such as to ensure that SG tube integrity is maintained until the next SG inspection. An assessment of degradation shall be performed to determine the type and between the bottom of the hot-leg expansion transition or top of the hot-leg tubesheet, whichever is lower, and 12.5 inches below the bottom of the hot-leg expansion transition or top of the hot-leg tubesheet, whichever is lower, between the bottom of the cold-leg expansion transition or top of the cold-leg tubesheet, whichever is lower, and 13.67 inches below the bottom of the cold-leg expansion transition or top of the cold-leg tubesheet, whichever is lower, Sleeved tubes found by inservice inspection to contain a flaw in a sleeve or a flaw in the sleeve to tube joint shall be plugged.
PNP 2025-033 Retyped Technical Specification Pages (2 pages follow)
PCS Pressure, Temperature, and Flow DNB Limits 3.4.1 Palisades Nuclear Plant 3.4.1-2 Amendment No. XXX SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.1.1 Verify pressurizer pressure within the limits specified in the COLR.
In accordance with the Surveillance Frequency Control Program SR 3.4.1.2 Verify PCS cold leg temperature within the limit specified in the COLR.
In accordance with the Surveillance Frequency Control Program SR 3.4.1.3
NOTE----------------------------
Not required to be performed until 31 EFPD after THERMAL POWER is 90% RTP.
Verify PCS total flow rate within the limit specified in the COLR.
In accordance with the Surveillance Frequency Control Program AND After each plugging or repairing (or both) of the number of steam generator tubes which results in the same primary flow reduction as plugging 10 or more steam generator tubes
Programs and Manuals 5.5 5.5 Programs and Manuals Palisades Nuclear Plant 5.0-11 Amendment No. XXX 5.5.8 Steam Generator (SG) Program (Continued)
- b.
Performance criteria for SG tube integrity. (continued)
- 2.
Accident induced leakage performance criterion: The primary to secondary accident induced leakage rate for any design basis accident, other than a SG tube rupture, shall not exceed the leakage rate assumed in the accident analysis in terms of total leakage rate for all SGs and leakage rate for an individual SG.
Leakage is not to exceed 0.3 gpm.
- 3.
The operational LEAKAGE performance criterion is specified in LCO 3.4.13, PCS Operational LEAKAGE.
- c.
Provisions for SG tube plugging or tube repair criteria. Tubes found by inservice inspection to contain a flaw in a non-sleeved region with a depth equal to or exceeding 40% of the nominal tube wall thickness shall be plugged or repaired. Sleeved tubes found by inservice inspection to contain a flaw in a sleeve or a flaw in the sleeve to tube joint shall be plugged. The following SG alternate repair criteria may be applied as an alternate to the 40% depth based criteria:
- 1.
Tubes found by inservice inspection to contain service induced flaws between the bottom of the hot-leg expansion transition or top of the hot-leg tubesheet, whichever is lower, and 12.5 inches below the bottom of the hot-leg expansion transition or top of the hot-leg tubesheet, whichever is lower, shall be plugged. Flaws located below 12.5 inches below the bottom of the hot-leg expansion transition or top of the hot-leg tubesheet, whichever is lower, may remain in service.
- 2.
Tubes found by inservice inspection to contain service induced flaws between the bottom of the cold-leg expansion transition or top of the cold-leg tubesheet, whichever is lower, and 13.67 inches below the bottom of the cold-leg expansion transition or top of the cold-leg tubesheet, whichever is lower, shall be plugged.
Flaws located below 13.67 inches below the bottom of the cold-leg expansion transition or top of the cold-leg tubesheet, whichever is lower, may remain in service.
- d.
Provisions for SG tube inspections. Periodic SG tube inspections shall be performed. The number and portions of the tubes inspected and methods of inspection shall be performed with the objective of detecting flaws of any type (e.g., volumetric flaws, axial and circumferential cracks) that may be present along the length of the tube, from 12.5 inches below the
PNP 2025-033 Technical Specifications Bases Page Markups (For information only)
(1 page follows)
PCS Pressure, Temperature, and Flow DNB Limits B 3.4.1 BASES Palisades Nuclear Plant B 3.4.1-3 Amendment No. XXX Revised XX/XX/20XX ACTIONS A.1 Pressurizer pressure and cold leg temperature are controllable and measurable parameters. PCS flow rate is not a controllable parameter and is not expected to vary during steady state operation. With any of these parameters not within the LCO limits, action must be taken to restore the parameter.
The 2-hour Completion Time for restoration of the parameters provides sufficient time to adjust plant parameters, to determine the cause of the off normal condition, and to restore the readings within limits.
The Completion Time is based on plant operating experience.
B.1 If Required Action A.1 is not met within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. In MODE 2, the reduced power condition eliminates the potential for violation of the accident analysis bounds.
Six hours is a reasonable time that permits the plant power to be reduced at an orderly rate without challenging plant systems.
SURVEILLANCE SR 3.4.1.1 and SR 3.4.1.2 REQUIREMENTS The Surveillance for monitoring pressurizer pressure and PCS cold leg temperature is performed using installed instrumentation. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.4.1.3 Measurement of PCS total flow rate verifies that the actual PCS flow rate is within the bounds of the analyses. This verification may be performed by a calorimetric heat balance or other method.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. PCS flow rate must also be verified after plugging or repairing (or both) the number of each 10 or more steam generator tubes which results in the same primary flow reduction as plugging 10 tubes since plugging 10 or more tubes could result in an increase in PCS flow resistance. Plugging or repairing less than the equivalent of 10 steam generator tubes will not have a significant impact on PCS flow resistance and, as such, does not require a verification of PCS flow rate.