PNP 2019-002, Status of Remaining Actions for Generic Safety Issue - 191 Resolution

Status of Remaining Actions for Generic Safety Issue - 191 Resolution

ML19064A089
Person / Time
Site:	Palisades
Issue date:	03/05/2019
From:	Hardy J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PNP 2019-002
Download: ML19064A089 (3)

Text

Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 Tel 269-764-2000 Jeffery A. Hardy Regulatory Assurance Manager PNP 2019-002 March 05, 2019 ATIN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Status of Remaining Actions for Generic Safety Issue - 191 Resolution Palisades Nuclear Plant Docket 50-255 Renewed Facility Operating License No. DPR-20

REFERENCES:

1. Entergy Nuclear Operations, Inc. letter, PNP 2017-065, Supplement to Certification of Permanent Cessation of Power Operations, dated October 19, 2017 (ADAMS Accession Number ML17292A032)

2. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2018-017, Milestone Schedule for Generic Safety Issue - 191 Resolution, dated March 29, 2018 (ADAMS Accession Number ML18088A139)

3. NRC letter, Staff Re-evaluation of Closure Path for Generic Safety Issue 191 and Generic Letter 2004-02, dated November 30,2018 (ADAMS Accession Number ML18311A297)

4. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2013-041, Generic Safety Issue-191 Closure Option, dated May 15, 2013 (ADAMS Accession Number ML13136A006)

Dear Sir or Madam:

In Reference 1, Entergy Nuclear Operations, Inc. (ENO) certified that, in accordance with 10 CFR 50.82(a)(1)(i) and 10 CFR 50.4(b)(8), it plans to permanently cease power operations at the Palisades Nuclear Plant (PNP) no later than May 31,2022.

In Reference 2, ENO submitted a revised milestone schedule for resolution of Generic Safety Issue (GSI)-191. This milestone schedule reflected ENO's plans to operate PNP until May 31 ,

2022.

In Reference 3, the NRC issued a letter stating that the GSI-191 closure path is being re-evaluated. Based on this and the continued uncertainties in the issuance of technical support documents for GSI-191 closure, such as WCAP-17788, "Comprehensive Analysis and Test Program for GSI-191 Closure," the PNP milestone schedule is being impacted. Additional changes to the milestone schedule would also occur if the WCAP-17788 methodology option is determined to not be appropriate for GSI-191 resolution at PNP and ENO needs to pursue another option for GSI-191 closure.

PNP 2019-002 Page 2 of 2 END will likely need to submit a license amendment request for the closure option chosen, which will require NRC review and approval. Any additional required plant modifications identified during the closure efforts would need to be implemented during a refueling outage, and PNP has only one refueling outage scheduled prior to the planned PNP permanent shutdown date.

While ENO has not completed the remaining actions to close GSI-191, END has completed extensive analyses, testing, and modifications to substantially improve sump performance during a postulated design basis loss of coolant accident (LDCA) at PNP, as described in Reference 4. The modifications include installation of passive containment sump strainer assemblies for segregating post-LOCA generated debris from the containment sump envelope, and installation of passive debris screens on containment sump downcomers, containment floor drains, and containment sump vent lines to mitigate post-LOCA generated debris entry into the containment sump envelope. Procedural controls, specification requirements, and containment and equipment inspections have been implemented to limit and mitigate debris generation and chemical effects that may impact sump strainer performance following a LDCA. In addition, during the 2018 refueling outage, ENO modified the containment sump vents to enhance sump performance.

Considering the schedule uncertainties that exist for resolution of GSI-191, the remaining work to complete analyses, testing, license amendment submittal, license amendment issuance, and modifications, and the END plans to permanently cease power operations at PNP, there is not sufficient time available for the remaining GSI-191 closure efforts to result in an appreciable safety benefit for PNP before the permanent shutdown date. Therefore, this letter provides notification that ENO does not plan to take additional actions for GSI-191 closure at PNP.

This letter also provides notification of the cancellation of regulatory commitments associated with GSI-191 that were established in Reference 4. The cancelled commitments are identified in the attachment.

Should you have any questions concerning this letter, or require additional information, please contact Jeff Erickson at 269-764-2375.

Sincerely, JAH/jse

Attachment:

Cancelled Regulatory Commitments cc: Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC

PNP 2019-002 ATTACHMENT Cancelled Regulatory Commitments The following table identifies Palisades Nuclear Plant regulatory commitments associated with Generic Safety Issue (GSI)-191 that have been cancelled by Entergy Nuclear Operations, Inc.

(ENO), in accordance with NEI 99-04, Guidelines for Managing NRC Commitment Changes.

Original Original Source of Original Commitment Completion Date Commitment ENO will complete any During the refueling outage ENO letter to NRC, PNP necessary insulation that follows issuance of a 2013-041, Generic Safety replacements or remediation, [safety evaluation] SE for the Issue-191 Closure Option, or other identified plant risk-informed resolution dated May 15, 2013 (ADAMS changes. [license amendment request] Accession Number LAR for Palisades Nuclear ML13136A006).

Plant (PNP).

ENO will submit a final Within six months of receipt ENO letter to NRC, PNP updated supplemental of the SE for the 2013-041, Generic Safety response to support closure risk-informed resolution LAR Issue-191 Closure Option, of [Generic Letter] GL for PNP. dated May 15, 2013 (ADAMS 2004-02 for PNP. Accession Number ML13136A006).

If it is determined during the Within two refueling outages ENO letter to NRC, PNP risk-informed process that after the issuance of the SE 2013-041, Generic Safety this option is not viable, ENO for the [South Texas Project] Issue-191 Closure Option, will complete a deterministic STP LAR. dated May 15, 2013 (ADAMS resolution path that is Accession Number acceptable to the NRC. ML13136A006).

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