PNP 2017-003, Notification of Changes to Regulatory Commitments Concerning NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding the Flooding Aspects of Recommendation 2.1 of the Near-Term Task Force..
| ML17066A255 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/07/2017 |
| From: | Arnone C Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PNP 2017-003 | |
| Download: ML17066A255 (9) | |
Text
~Entergy Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043*9530 Tel 269 764 2000 Charles F. Arnone PNP 2017-003 Site Vice President March 7, 2017 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852
SUBJECT:
Notification of Changes to Regulatory Commitments Concerning NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding the Flooding Aspects of Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident Palisades Nuclear Plant Docket No. 50-255 Renewed Facility Operating License No. DPR-20
REFERENCES:
- 1. NRC letter, "Request for information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated March 12, 2012 (ADAMS Package Accession Number ML12056A046)
- 2. Entergy Nuclear Operations, Inc. letter, PNP 2012-049, "Response to NRC Request for Information (RFI) Pursuant to 10 CFR 50.54(f)
Regarding the Flooding Aspects of Recommendations 2.1 and 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated June 8, 2012 (ADAMS Accession Number ML12163A533)
- 3. Entergy Nuclear Operations, Inc. letter, PNP 2013-002, "Response to March 12, 2012, Request for Information Enclosure 2, Recommendation 2.1, Flooding, Required Response 1, Integrated Assessment Approach," dated January 29, 2013 (ADAMS Accession Number ML13029A669)
- 4. NRC Memorandum, "Staff Requirements - COMSECY-15-0019-Closure Plan for the Reevaluation of Flooding Hazards for Operating Nuclear Power Plants," dated July 28, 2015 (ADAMS Accession Number ML15209A682)
PNP 2017-003 Page 2 of 2
Dear Sir or Madam:
On March 12, 2012, the NRC issued "Request for information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident" to all NRC power reactor licensees and holders of construction permits in active or deferred status (Reference 1).
In response to Enclosure 2, "Recommendation 2.1: Flooding," of Reference 1, Entergy Nuclear Operations, Inc. (ENO) made commitments in References 2 and 3 concerning submittal of an integrated assessment for flooding for the Palisades Nuclear Plant (PNP).
With NRC approval of an action plan for closure of the flooding aspects of Recommendation 2.1 in Reference 4, a new commitment has been established to submit an integrated assessment for PNP in accordance with the approved closure plan. This new commitment replaces the commitments made in References 2 and 3, which have been cancelled. contains a discussion of the commitment changes. Attachment 2 contains a list of new commitments. Attachment 3 contains a list of cancelled commitments.
I declare under penalty of perjury that the foregoing is true and correct. Executed on March 7, 2017.
Sincerely,
~....---~
CFA/jse Attachments: 1. Discussion of Regulatory Commitment Changes
- 2. List of New Regulatory Commitments
- 3. List of Cancelled Regulatory Commitments cc: Director of Office of Nuclear Regulation Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC
PNP 2017-003 Attachment 1 Discussion of Regulatory Commitment Changes
Attachment 1 Discussion of Regulatory Commitment Changes Dn March 12, 2012, the NRC issued "Request for information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near Term Task Force Review of Insights from the Fukushima Dai-ichi Accident" to all NRC power reactor licensees and holders of construction permits in active or deferred status (Reference 1).
Within this request for information, Enclosure 2, titled "Recommendation 2.1: Flooding,"
requested licensees to provide an integrated assessment report for flooding. In response to this request, END made the following commitment for PNP in Reference 2:
- An Integrated Assessment report for PNP, if it is necessary, will be submitted two years after the flood evaluation is completed.
Scheduled Completion Date: March 12, 2017 (if necessary)
In Reference 3, END made two additional commitments:
- END commits to use Interim Staff Guidance JLD-ISG-2012-05, "Guidance for Performing the Integrated Assessment for External Flooding," Revision 0 guidance as the approach for developing the NTTF 2.1 flooding Integrated Assessment Report for Palisades Nuclear Plant if the reevaluated flooding hazard is not bounded by the current design basis flooding evaluation.
Scheduled Completion Date: March 12, 2017 (Upon submittal of the Integrated Assessment Report, if required, which is two years following submittal of the site's Hazard Reevaluation Report)
- END commits to use the guidance provided in NRC letter, D.L. Skeen (NRC) to J.E.
Pollock (NEI), "Trigger Conditions for Performing an Integrated Assessment and Due Date for Response," regarding the trigger conditions and scope of any required Integrated Assessment.
Scheduled Completion Date: March 12, 2017 (Upon submittal of the Integrated Assessment Report, if required, which is two years following submittal of the site's Hazard Reevaluation Report)
Subsequent to the above commitments made in References 2 and 3, the NRC approved in Reference 4 an action plan for closure of the reevaluation of flooding hazards in Recommendation 2.1. The action plan included a completion date of December 2018 for licensees submitting an integrated assessment (Reference 5).
Therefore, in order to comply with the NRC action plan, END has cancelled the commitments made in References 2 and 3, as described in Attachment 3, and plans to follow Path 4 as described in NEI 16-05, Revision 1, "External Flooding Assessment 1 of 2
Attachment 1 Discussion of Regulatory Commitment Changes Guidelines," (Reference 6) for closure of the reevaluation flooding hazards in Recommendation 2.1 at PNP. Accordingly, ENO has established a new commitment to submit an integrated assessment for PNP by December 31, 2018, as described in .
References
- 1. NRC letter, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident,"
dated March 12, 2012 (ADAMS Package Accession Number ML12056A046)
- 2. ENO letter, PNP 2012-049, "Response to NRC Request for Information (RFI)
Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendations 2.1 and 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated June 8, 2012 (ADAMS Accession Number ML12163A533)
- 3. ENO letter, PNP 2013-002, "Response to March 12, 2012, Request for Information Enclosure 2, Recommendation 2.1, Flooding, Required Response 1, Integrated Assessment Approach," dated January 29, 2013 (ADAMS Accession Number ML13029A669)
- 4. NRC Memorandum, "Staff Requirements - COMSECY-15-0019 - Closure Plan for the Reevaluation of Flooding Hazards for Operating Nuclear Power Plants," dated July 28, 2015 (ADAMS Accession Number ML15209A682)
- 5. NRC COMSECY-15-0019, "Closure Plan for the Reevaluation of Flooding Hazards for Operating Nuclear Power Plants, " June 30, 2015 (ADAMS Package Accession Number ML15153A104)
- 6. NEI 16-05, "External Flooding Assessment Guidelines," Revision 1, dated June 2016 (ADAMS Accession Number ML16165A178) 2 of 2
PNP 2017-003 Attachment 2 List of New Regulatory Commitments
Attachment 2 List of New Regulatory Commitments The following table identifies actions committed to by Entergy Nuclear Operations, Inc.
(ENO), as discussed in this document.
TYPE SCHEDULED (Check One) COMPLETION COMMITMENT ONE-TIME CONTINUING DATE ACTION COMPLIANCE (If Required)
ENO commits to submit an integrated assessment for Palisades X December 31, 2018 Nuclear Plant, prepared in accordance with NEI 16-05, Revision 1, "External Flooding Assessment Guidelines."
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PNP 2017-003 Attachment 3 List of Cancelled Regulatory Commitments
Attachment 3 List of Cancelled Regulatory Commitments The following table identifies actions cancelled by Entergy Nuclear Operations, Inc. (ENO),
as discussed in this document.
ORIGINAL ORIGINAL SOURCE OF ORIGINAL COMMITMENT COMPLETION DATE COMMITMENT An Integrated Assessment March 12, 2017 (if ENO letter, PNP 2012-049, report for PNP, if it is necessary, necessary) "Response to NRC Request for will be submitted two years after Information (RFI) Pursuant to 10 the flood evaluation is CFR 50.54(f) Regarding the completed. Flooding Aspects of Recommendations 2.1 and 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated June 8, 2012 (ADAMS Accession Number ML12163A533)
ENO commits to use Interim March 12,2017 (Upon ENO letter, PNP 2013-002, Staff Guidance JLD-ISG-2012- submittal of the Integrated "Response to March 12, 2012, 05, "Guidance for Performing Assessment Report, if Request for Information Enclosure the Integrated Assessment for required, which is two 2, Recommendation 2.1, Flooding, External Flooding," Revision 0 years following submittal Required Response 1, Integrated guidance as the approach for of the site's Hazard Assessment Approach," dated developing the NTTF 2.1 Reevaluation Report) January 29,2013 (ADAMS flooding Integrated Assessment Accession Number ML13029A669)
Report for Palisades Nuclear Plant if the reevaluated flooding hazard is not bounded by the current design basis flooding evaluation.
ENO commits to use the March 12, 2017 (Upon ENO letter, PNP 2013-002, guidance provided in NRC letter, submittal of the Integrated "Response to March 12, 2012, D.L. Skeen (NRC) to J.E. Assessment Report, if Request for Information Enclosure Pollock (NEI), Trigger required, which is two 2, Recommendation 2.1, Flooding, Conditions for Performing an years following submittal Required Response 1, Integrated Integrated Assessment and Due of the site's Hazard Assessment Approach," dated Date for Response," regarding Reevaluation Report) January 29, 2013 (ADAMS the trigger conditions and scope Accession Number ML13029A669) of any required Integrated Assessment.
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