PNP 2019-007, License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications

License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications

ML19067A004
Person / Time
Site:	Palisades
Issue date:	03/08/2019
From:	Halter M Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PNP 2019-007
Download: ML19067A004 (20)

Text

~Entergr.

Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5573 Mandy K. Halter Director, Nuclear Licensing 10 CFR 50.90 PNP 2019-007 March 8, 2019 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications Palisades Nuclear Plant NRC Docket 50-255 Renewed Facility Operating License No. DPR-20 Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc. (ENO) requests U.S. Nuclear Regulatory Commission (NRC) review and approval of a revision to the Palisades Nuclear Plant (PNP) renewed facility operating license (RFOL) in which the full compliance date for the fire protection program transition license condition is changed in order to allow an extension for the implementation of the remaining modifications necessary to achieve full compliance with 10 CFR 50.48(c). The proposed changes have been evaluated in accordance with 10 CFR 50.91 (a)(1) using criteria in 10 CFR 50.92(c), and ENO has determined that this change involves no significant hazards consideration .

In Reference 1, the NRC issued ENO Amendment No. 254 to the PNP RFOL for transition to a risk-informed, performance-based fire protection program in accordance with 10 CFR 50.48(c).

In Reference 2, ENO certified the plan to permanently cease power operations at PNP no later than May 31,2022. In Reference 3, ENO submitted a license amendment request (LAR) to change the full compliance implementation date for the fire protection program transition license condition for required modifications. In Reference 4, the NRC issued the safety evaluation for Reference 3. Due to the planned permanent cessation of power operations at PNP no later than May 31,2022, ENO is requesting a revision of the full compliance date for the fire protection program transition license condition to allow an extension for the implementation of the remaining modifications necessary to achieve full compliance with 10 CFR 50.48(c).

Approval of the proposed amendment is requested by August 30, 2019, to support refueling outage planning milestones. Once approved, the amendment shall be implemented within 60 days.

This letter identifies no new commitments and no revisions to existing commitments.

PNP 2019-007 Page 2 In accordance with 10 CFR 50.91, ENO is notifying the State of Michigan of this LAR by transmitting a copy of this letter and enclosure to the designated state official.

If there are questions or if additional information is needed, please contact Jeff Hardy at 269-764-2011.

I declare under penalty of perjury that the foregoing is true and correct. Executed on March 8, 2019.

Respectfully, lt27~

MKH/ach

Enclosure:

Evaluation of the Proposed Change Attachments to

Enclosure:

1 . Renewed Facility Operating License Page Markups

2. Operating License Page Change Instructions and Retyped Renewed Operating License Pages

References:

1. NRC letter, "Palisades Nuclear Plant - Issuance of Amendment Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance with 10 CFR 50,48(c)," dated February 27,2015 (ADAMS Accession Number ML15007A191 )

2. ENO letter to NRC, PNP 2017-065, "Supplement to Certification of Permanent Cessation of Power Operations," dated October 19, 2017 (ADAMS Accession Number ML17292A032)

3. ENO letter, PNP 2017-066, "License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications," dated November 1, 2017 (ADAMS Accession Number ML17306A086)

4. NRC letter, "Palisades Nuclear Plant - Issuance of Amendment RE: License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications,"

dated February 27, 2018 (ADAMS Accession Number ML18039A244)

PNP 2019-007 Page 3 cc: NRC Region III Regional Administrator NRC Senior Resident Inspector - Palisades Designated State Official - Michigan NRC Project Manager - Palisades

Enclosure to PNP 2019-007 Evaluation of the Proposed Change 5 pages follow

Enclosure to PNP 2019-007 Page 1 of 5 EVALUATION OF THE PROPOSED CHANGE 1.0

SUMMARY

DESCRIPTION The proposed amendment would modify the Palisades Nuclear Plant (PNP) Renewed Facility Operating License (RFOL) DPR-20 by revising the full compliance date for the fire protection program transition license condition to allow an extension for the implementation of the remaining modifications necessary to achieve full compliance with 10 CFR 50.48(c). The requested change involves no significant hazards consideration.

2.0 DETAILED DESCRIPTION 2.1 Reason for the Proposed Change In Reference 1, the NRC issued ENO Amendment No. 254 to the PNP RFOL for transition to a risk-informed, performance-based fire protection program in accordance with 10 CFR 50.48(c).

In Reference 2, ENO certified the plan to permanently cease power operations at PNP no later than May 31, 2022. In Reference 3, ENO submitted a license amendment request (LAR) to change the full compliance implementation date for the fire protection program transition license condition for required modifications. In Reference 4, the NRC issued the safety evaluation for Reference 3.

During the fall 2018 refueling outage (1 R26), ENO implemented the majority of the planned NFPA 805 modifications characterized as "High" risk rank. This was done in order to maximize the risk benefit over the remaining life of the plant. The implementation of the remaining modifications is currently required upon start up from the planned summer 2020 refueling outage (1 R27). Due to the planned permanent cessation of power operations at PNP no later than May 31,2022, ENO is proposing a revision of the full compliance date for the fire protection program transition license condition to allow an extension for the implementation of the remaining modifications necessary to achieve full compliance with 10 CFR 50.48(c).

2.2 Description of Proposed Change ENO proposes to revise the PNP RFOL fire protection program transition license condition 2.C.(3)(c)2.

Currently, transition license condition 2.C.(3)(c)2 reads as follows:

2. The licensee shall implement the modifications to its facility, as described in Table S-2, "Plant Modifications Committed," of ENO letter PNP 2014-080 dated August 14, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) before the end of the refueling outage following the third full operating cycle after NRC approval. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

The current transition license condition would require ENO to fully implement the NFPA 805 modifications before the end of 1R27. ENO is proposing to revise the transition license condition 2.C.(3)(c)2 as follows:

Enclosure to PNP 2019-007 Page 2 of 5

2. The licensee shall implement the modifications to its facility, as described in Table 8-2, "Plant Modifications Committed," of ENO letter PNP 2014-080 dated August 14, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) before the end of the refueling outage following the fourth full operating cycle after NRC approval. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

The proposed transition license condition would require the NFPA 805 modifications to be fully implemented before the end of the planned summer 2022 outage, which is a defueling outage per Reference 2.

3.0 TECHNICAL EVALUATION

Due to the planned permanent cessation of power operations at PNP no later than May 31, 2022, ENO is proposing a revision of the full compliance date for the fire protection program transition license condition to allow an extension for the implementation of the remaining modifications necessary to achieve full compliance with 10 CFR 50.48(c).

ENO's approach to the implementation of NFPA 805 modifications at PNP has been to install the modifications with the largest risk reduction impact as soon as achievable in order to maximize the risk benefit over the remaining life of the plant. During 1R26, ENO implemented the majority of the planned NFPA 805 modifications characterized as "High" risk rank.

In addition, the proposed change has no impact on the defense-in-depth (DID) echelons, which are: (1) prevent fires from starting, (2) rapidly detect, control, and extinguish promptly those fires that do occur thereby preventing fire damage, and (3) provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed, because changing the full compliance implementation date for fire protection program transition license condition 2.C.(3)(c)2 is not considered a change in methods. The proposed schedule change does not impact the level of fire protection provided so that a fire will not prevent essential safety functions from being performed.

Also, in regard to safety margins, the proposed change continues to maintain adequate safety margins because the change does not impact any codes and standards, or their alternatives accepted for use by the NRC, and because the change does not impact any safety analysis acceptance criteria in the licensing basis.

Therefore, this extension is acceptable given that the majority of the planned modifications characterized as "High" risk have already been installed, and the fire protection transition license conditions that remain in effect during this period, including the continuation of compensatory measures. This proposed change is administrative in nature and has no impact on DID echelons or safety margins. Additionally, the license condition for making risk-informed changes without prior NRC approval is not effective until ENO has implemented the NFPA 805 modifications and PNP is in full compliance with 10 CFR 50.48(c).

Enclosure to PNP 2019-007 Page 3 of S

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria On July 16, 2004, the NRC amended 10 CFR S0.48, "Fire Protection," to add a new subsection, 10 CFR S0.48(c), which establishes alternative fire protection requirements. 10 CFR S0.48 endorses, with exceptions, NFPA 80S, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition (NFPA 80S), as a voluntary alternative for demonstrating compliance with 10 CFR S0.48 Section (b), concerning Appendix R, and Section (f), concerning decommissioning.

The voluntary adoption of 10 CFR S0.48(c) by ENO does not eliminate the need to comply with 10 CFR S0.48(a) and 10 CFR SO, Appendix A, and General DeSign Criteria (GDC) 3, "Fire Protection." The new rule provides actions that may be taken to establish compliance with 10 CFR S0.48(a), which requires each operating nuclear power plant to have a fire protection program plan that satisfies GDC 3, as well as specific requirements in that section. The transition process described in 10 CFR S0.48(c)(3)(ii) provides, in pertinent parts, that a licensee intending to adopt the new rule must, among other things, "modify the fire protection plan required by paragraph (a) of that section to reflect the licensee's decision to comply with NFPA 80S." Therefore, to the extent that the contents of the existing fire protection program plan required by 10 CFR S0.48(a) is inconsistent with NFPA 80S, the fire protection program plan must be modified to achieve compliance with the requirements in NFPA 80S. All other requirements of 10 CFR S0.48(a) and GDC 3 have corresponding requirements in NFPA 80S.

4.2 No Significant Hazards Consideration Analysis Entergy Nuclear Operations, Inc. (ENO) has evaluated the proposed changes to the Renewed Facility Operating License DPR-20 using the criteria in 10 CFR SO.92 and has determined that the proposed changes do not involve a significant hazard consideration.

ENO is requesting an amendment to the Palisades Nuclear Plant (PNP) renewed facility operating license (RFOL) to revise the full compliance date for the fire protection program transition license condition to allow an extension for the implementation of the remaining modifications necessary to achieve full compliance with 10 CFR S0.48(c).

Basis for no significant hazards consideration determination: As required by 10 CFR SO.91 (a),

ENO analysis of the issue of no significant hazards consideration is presented below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change to the PNP RFOL to change the full compliance date for the fire protection program transition license condition to allow additional time for the implementation of the remaining modifications necessary to achieve full compliance with 10 CFR S0.48(c) is administrative in nature. This change does not alter accident analysis assumptions, add any initiators, or affect the function of plant systems or the manner in which systems are operated, maintained, modified, tested, or inspected. The proposed change does not require any plant modifications which affect the performance capability of the structures, systems, and components relied upon to mitigate the

Enclosure to PNP 2019-007 Page 4 of 5 consequences of postulated accidents, and has no impact on the probability or consequences of an accident previously evaluated.

Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change to the PNP RFOL to change the full compliance date for the fire protection program transition license condition to allow additional time for the implementation of the remaining modifications necessary to achieve full compliance with 10 CFR 50.48(c) is administrative in nature. This proposed change does not alter accident analysis assumptions, add any initiators, or affect the function of plant systems or the manner in which systems are operated, maintained, modified, tested, or inspected.

The proposed change does not require any plant modifications which affect the performance capability of the structures, systems, and components relied upon to mitigate the consequences of postulated accidents and does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Therefore, this change does not create the possibility of a new or different kind of accident from an accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change to the PNP RFOL to change the full compliance implementation date for the fire protection program transition license condition to allow additional time for implementation of the remaining modifications necessary to achieve full compliance with 10 CFR 50.48(c) is administrative in nature. Plant safety margins are established through limiting conditions for operation, limiting safety system settings, and safety limits specified in the technical specifications. Because there is no change to established safety margins as a result of this change, the proposed change does not involve a significant reduction in a margin of safety.

Therefore, this change does not involve a significant reduction in a margin of safety.

Based upon the reasoning presented above, ENO concludes that the requested change involves no significant hazards consideration, as set forth in 10 CFR 50.92(c), "Issuance of Amendment."

4.3 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Enclosure to PNP 2019-007 Page 5 of 5

5.0 ENVIRONMENTAL CONSIDERATION

The proposed change revises the PNP RFOL to change the NFPA 805 full compliance implementation date for the fire protection program transition license condition associated with implementation of NFPA 805 modifications. The proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

6.0 REFERENCES

1. NRC letter, "Palisades Nuclear Plant - Issuance of Amendment Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance with 10 CFR 50.48(c)," dated February 27,2015 (ADAMS Accession Number ML15007A191)

2. ENO letter to NRC, PNP 2017-065, "Supplement to Certification of Permanent Cessation of Power Operations," dated October 19, 2017 (ADAMS Accession Number ML17292A032)

3. ENO letter, PNP 2017-066, "License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications," dated November 1, 2017 (ADAMS Accession Number ML17306A086)

4. NRC letter, "Palisades Nuclear Plant - Issuance of Amendment RE: License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications," dated February 27,2018 (ADAMS Accession Number ML18039A244)

ATTACHMENTS

1. Renewed Facility Operating License Page Markups

2. Operating License Page Change Instructions and Retyped Renewed Operating License Pages

Enclosure Attachment 1 to PNP 2019-007 Renewed Facility Operating License Page Markups 4 pages follow

(1) Pursuant to Section 104b of the Act, as amended, and 10 CFR Part 50, "Licensing of Production and Utilization Facilities," (a) ENP to possess and use, and (b) ENO to possess, use and operate, the facility as a utilization facility at the designated location in Van Buren County, Michigan, in accordance with the procedures and limitation set forth in this license; (2) ENO, pursuant to the Act and 10 CFR Parts 40 and 70, to receive, possess, and use source and special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Updated Final Safety Analysis Report, as supplemented and amended; (3) ENO, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use byproduct, source, and special nuclear material as sealed sources for reactor startup, reactor instrumentation, radiation monitoring equipment calibration, and fission detectors in amounts as required; (4) ENO, pursuant to the Act and 10 CFR Parts 30,40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material for sample analysis or instrument calibration, or associated with radioactive apparatus or components; and (5) ENO, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operations of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations in 10 CFR Chapter I and is subject to all applicable provisions of the Act; to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) ENO is authorized to operate the facility at steady-state reactor core power levels not in excess of 2565.4 Megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.

(2) The Technical Specifications contained in Appendix A, as revised through Amendment No. 263, and the Environmental Protection Plan contained in Appendix B are hereby incorporated in the license. ENO shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Fire Protection ENO shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment request dated December 12, 2012, aRG November 1, 2017, and March 8, 2019, as supplemented by letters dated February 21, 2013, September 30, 2013, October 24, 2013, December 2, 2013, Renewed License No. DPR-20 Amendment No. ~, 265

April 2, 2014, May 7,2014, June 17,2014, August 14,2014, November 4,2014, and December 18, 2014, and January 24, 2018, as approved in the safety evaluations dated February 27,2015, aOOFebruary 27,2018, and XXX. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c),

the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

(a) Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

1. Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

2. Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x1 0-7/ year (yr) for CDF and less than 1x1 O-B/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

(b) Other Changes that May Be Made Without Prior NRC Approval

1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 Renewed License No. DPR-20 Amendment No. 2e4, 265

Page included for continuity element is functionally equivalent or adequate for the hazard.

The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is "adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

• "Fire Alarm and Detection Systems" (Section 3.8);

• "Automatic and Manual Water-Based Fire Suppression Systems" (Section 3.9);

• "Gaseous Fire Suppression Systems" (Section 3.10); and

• "Passive Fire Protection Features" (Section 3.11).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2. Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation dated February 27, 2015, to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety Renewed License No. DPR-20 Amendment No. 2a4, 265

-5a-margins are maintained when changes are made to the fire protection program.

(c) Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by 2, below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above.

2. The licensee shall implement the modifications to its facility, as described in Table S-2, "Plant Modifications Committed," of ENO letter PNP 2014-080 dated August 14, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) before the end of the refueling outage following the tffifG fourth full operating cycle after NRC approval. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall implement the items listed in Table S-3, "Implementation Items," of ENO letter PNP 2014-097 dated November 4, 2014, within six months after NRC approval, or six months after a refueling outage if in progress at the time of approval with the exception of Implementation Items 3 and 8 which will be completed once the related modifications are installed and validated in the PRA model.

(4) The following requirements shall apply to control rod drive CRD-13 during cycle 25:

(a) Performance of Technical Specifications Surveillance Requirement SR 3.1.4.3 is not required for CRD-13 until the next entry into Mode 3.

(b) Seal leakage on CRD-13 shall be repaired prior to entering Mode 2, following the next Mode 3 entry.

(c) The reactor shall be shut down if CRD-13 seal leakage exceeds two gallons per minute.

(5) [deleted]

Renewed License No. DPR-20 Amendment No. 2SG, 265

Enclosure Attachment 2 to PNP 2019-007 Operating License Page Change Instructions and Retyped Renewed Facility Operating License Pages 5 pages follow

Page Change Instructions ENCLOSURE ATTACHMENT 2 RENEWED FACILITY OPERATING LICENSE NO. DPR-20 DOCKET NO. 50-255 Remove the following pages of the renewed facility operating license (RFOL) and replace them with the attached revised pages. The revised pages are identified by amendment number and contain a line in the margin indicating the area of change.

RFOL pages:

REMOVE INSERT RFOL pages 3, 4, 5 and 5a RFOL pages 3, 4, 5, and 5a

(1) Pursuant to Section 104b of the Act, as amended, and 10 CFR Part 50, "Licensing of Production and Utilization Facilities," (a) ENP to possess and use, and (b) ENO to possess, use and operate, the facility as a utilization facility at the designated location in Van Buren County, Michigan, in accordance with the procedures and limitation set forth in this license; (2) ENO, pursuant to the Act and 10 CFR Parts 40 and 70, to receive, possess, and use source and special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Updated Final Safety Analysis Report, as supplemented and amended; (3) ENO, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use byproduct, source, and special nuclear material as sealed sources for reactor startup, reactor instrumentation, radiation monitoring equipment calibration, and fission detectors in amounts as required; (4) ENO, pursuant to the Act and 10 CFR Parts 30,40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material for sample analysis or instrument calibration, or associated with radioactive apparatus or components; and (5) ENO, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operations of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations in 10 CFR Chapter I and is subject to all applicable provisions of the Act; to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) ENO is authorized to operate the facility at steady-state reactor core power levels not in excess of 2565.4 Megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.

(2) The Technical Specifications contained in Appendix A, as revised through Amendment No. 263, and the Environmental Protection Plan contained in Appendix B are hereby incorporated in the license. ENO shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Fire Protection ENO shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment request dated December 12, 2012, November 1, 2017, and March 8, 2019, as supplemented by letters dated February 21, 2013, September 30,2013, October 24,2013, December 2,2013, April 2, 2014, Renewed License No. DPR-20 Amendment No. 2ea, XXX

May 7,2014, June 17,2014, August 14, 2014, November 4,2014, and December 18, 2014, and January 24,2018, as approved in the safety evaluations dated February 27,2015, February 27,2018, and XXX. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c),

and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

(a) Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

1. Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain suffiCient safety margins. The change may be implemented following completion of the plant change evaluation.

2. Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x1 0*7/year (yr) for CDF and less than 1x1 0*8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

(b) Other Changes that May Be Made Without Prior NRC Approval

1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 Renewed License No. DPR-20 Amendment No. 26e, XXX

element is functionally equivalent or adequate for the hazard.

The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is "adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

• "Fire Alarm and Detection Systems" (Section 3.8);

• "Automatic and Manual Water-Based Fire Suppression Systems" (Section 3.9);

• "Gaseous Fire Suppression Systems" (Section 3.10); and

• "Passive Fire Protection Features" (Section 3.11).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2. Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation dated February 27, 2015, to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety Renewed License No. DPR-20 Amendment No. 2ea, XXX

-5a-margins are maintained when changes are made to the fire protection program.

(c) Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by 2, below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above.

2. The licensee shall implement the modifications to its facility, as described in Table S-2, "Plant Modifications Committed," of ENO letter PNP 2014-080 dated August 14, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) before the end of the refueling outage following the fourth full operating cycle after NRC approval. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall implement the items listed in Table S-3, "Implementation Items," of ENO letter PNP 2014-097 dated November 4,2014, within six months after NRC approval, or six months after a refueling outage if in progress at the time of approval with the exception of Implementation Items 3 and 8 which will be completed once the related modifications are installed and validated in the PRA model.

(4) The following requirements shall apply to control rod drive CRD-13 during cycle 25:

(a) Performance of Technical Specifications Surveillance Requirement SR 3.1.4.3 is not required for CRD-13 until the next entry into Mode 3.

(b) Seal leakage on CRD-13 shall be repaired prior to entering Mode 2, following the next Mode 3 entry.

(c) The reactor shall be shut down if CRD-13 seal leakage exceeds two gallons per minute.

(5) [deleted]

Renewed License No. DPR-20 Amendment No. 2Sa, XXX