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| | issue date = 04/03/2014 | | | issue date = 04/03/2014 |
| | title = Response to Second Request for Additional Information Reactor Vessel Internals - ME9569 | | | title = Response to Second Request for Additional Information Reactor Vessel Internals - ME9569 |
| | author name = Gustafson O W | | | author name = Gustafson O |
| | author affiliation = Entergy Nuclear Operations, Inc | | | author affiliation = Entergy Nuclear Operations, Inc |
| | addressee name = | | | addressee name = |
Revision as of 15:14, 21 June 2019
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Category:Letter type:PNP
MONTHYEARPNP 2023-030, License Amendment Request to Revise Renewed Facility Operating License and Permanently Defueled Technical Specifications to Support Resumption of Power Operations2023-12-14014 December 2023 License Amendment Request to Revise Renewed Facility Operating License and Permanently Defueled Technical Specifications to Support Resumption of Power Operations PNP 2023-035, Withdrawal of License Amendment Request - Revise License Condition to Eliminate Cyber Security Plan Requirements2023-12-12012 December 2023 Withdrawal of License Amendment Request - Revise License Condition to Eliminate Cyber Security Plan Requirements PNP 2023-028, Application for Order Consenting to Transfer of Control of License and Approving Conforming License Amendments2023-12-0606 December 2023 Application for Order Consenting to Transfer of Control of License and Approving Conforming License Amendments PNP 2023-026, Pre-Submittal Meeting Presentation - Palisades Nuclear Plant License Transfer Application to Support Resumption of Power Operations2023-09-28028 September 2023 Pre-Submittal Meeting Presentation - Palisades Nuclear Plant License Transfer Application to Support Resumption of Power Operations PNP 2023-025, Request for Exemption from Certain Termination of License Requirements of 10 CFR 50.822023-09-28028 September 2023 Request for Exemption from Certain Termination of License Requirements of 10 CFR 50.82 PNP 2023-023, Special Report High Range Noble Gas Monitor Inoperable2023-08-0909 August 2023 Special Report High Range Noble Gas Monitor Inoperable PNP 2023-018, 2022 Annual Non-Radiological Environmental Operating Report2023-04-25025 April 2023 2022 Annual Non-Radiological Environmental Operating Report PNP 2023-007, and Big Rock Point, 2022 Annual Radioactive Effluent Release and Waste Disposal Reports2023-04-19019 April 2023 and Big Rock Point, 2022 Annual Radioactive Effluent Release and Waste Disposal Reports PNP 2023-008, 2022 Radiological Environmental Operating Report2023-04-18018 April 2023 2022 Radiological Environmental Operating Report PNP 2023-002, 6 to Updated Final Safety Analysis Report2023-03-31031 March 2023 6 to Updated Final Safety Analysis Report PNP 2023-006, Report of Changes to Security Plan, Revision 202023-03-29029 March 2023 Report of Changes to Security Plan, Revision 20 PNP 2023-012, Presentation on Regulatory Path to Reauthorize Power Operations2023-03-16016 March 2023 Presentation on Regulatory Path to Reauthorize Power Operations PNP 2023-001, Regulatory Path to Reauthorize Power Operations2023-03-13013 March 2023 Regulatory Path to Reauthorize Power Operations PNP 2023-004, Report of Changes to Palisades Nuclear Plant Technical Specification Bases2023-03-0808 March 2023 Report of Changes to Palisades Nuclear Plant Technical Specification Bases PNP 2023-005, Response to Palisades Nuclear Plant - Request for Additional Information Related to the Post-Shutdown Decommissioning Activities Report2023-03-0101 March 2023 Response to Palisades Nuclear Plant - Request for Additional Information Related to the Post-Shutdown Decommissioning Activities Report PNP 2022-037, Report of Changes to Security Plan, Revision 192022-12-14014 December 2022 Report of Changes to Security Plan, Revision 19 PNP 2022-036, Response to Request for Additional Information Regarding License Amendment Request for Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme2022-11-0808 November 2022 Response to Request for Additional Information Regarding License Amendment Request for Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme PNP 2022-035, International - Notification of Commitment Cancellations for Remaining Activities Related to Beyond-Design-Basis Seismic Hazard Reevaluations2022-11-0202 November 2022 International - Notification of Commitment Cancellations for Remaining Activities Related to Beyond-Design-Basis Seismic Hazard Reevaluations PNP 2022-026, Request for Exemption from 10 CFR 50.54(w)(1) Concerning Onsite Property Damage Insurance2022-10-26026 October 2022 Request for Exemption from 10 CFR 50.54(w)(1) Concerning Onsite Property Damage Insurance PNP 2022-024, Request for Exemption from 10 CFR 140.11(a)(4) Concerning Primary and Secondary Liability Insurance2022-10-26026 October 2022 Request for Exemption from 10 CFR 140.11(a)(4) Concerning Primary and Secondary Liability Insurance PNP 2022-031, License Amendment Request, Revise License Condition to Eliminate Cyber Security Plan Requirements2022-09-14014 September 2022 License Amendment Request, Revise License Condition to Eliminate Cyber Security Plan Requirements PNP 2022-025, Report of Changes to Palisades Nuclear Plant Security Plan, Revision 182022-09-12012 September 2022 Report of Changes to Palisades Nuclear Plant Security Plan, Revision 18 PNP 2022-032, 2022 Evacuation Time Estimate Report2022-09-0707 September 2022 2022 Evacuation Time Estimate Report PNP 2022-023, Report of Changes to Palisades Nuclear Plant Security Plan, Revision 172022-08-15015 August 2022 Report of Changes to Palisades Nuclear Plant Security Plan, Revision 17 PNP 2022-014, Report of Changes to Palisades Nuclear Plant Site Emergency Plan, Revision 342022-07-13013 July 2022 Report of Changes to Palisades Nuclear Plant Site Emergency Plan, Revision 34 PNP 2022-016, License Amendment Request: Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme2022-07-12012 July 2022 License Amendment Request: Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme PNP 2022-017, Request for Exemptions from Certain Emergency Planning Requirements of 10 CFR 50.47(b); 10 CFR 50.47(c)(2); and 10 CFR Part 50, Appendix E2022-07-11011 July 2022 Request for Exemptions from Certain Emergency Planning Requirements of 10 CFR 50.47(b); 10 CFR 50.47(c)(2); and 10 CFR Part 50, Appendix E PNP 2022-019, & Big Rock Point - Notification of Expected Date of Transfer of Ownership of Nuclear Plants to Holtec Palisades, LLC; and Notification of Receipt of All Required Regulatory Approvals2022-06-24024 June 2022 & Big Rock Point - Notification of Expected Date of Transfer of Ownership of Nuclear Plants to Holtec Palisades, LLC; and Notification of Receipt of All Required Regulatory Approvals PNP 2022-011, Termination of the Emergency Response Data System (Eros) Link2022-06-13013 June 2022 Termination of the Emergency Response Data System (Eros) Link PNP 2022-010, Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel2022-06-13013 June 2022 Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel PNP 2022-004, 2021 Radiological Environmental Operating Report2022-05-12012 May 2022 2021 Radiological Environmental Operating Report PNP 2022-003, and Big Pock Point Plant - 2021 Annual Radioactive Effluent Release and Waste Disposal Report2022-04-25025 April 2022 and Big Pock Point Plant - 2021 Annual Radioactive Effluent Release and Waste Disposal Report PNP 2022-007, 2021 Annual Non-Radiological Environmental Operating Report2022-04-21021 April 2022 2021 Annual Non-Radiological Environmental Operating Report PNP 2022-012, Response to Request for Additional Information Regarding License Amendment Request to Revise Facility Operating License and Technical Specifications for a Permanently Defueled Condition2022-04-21021 April 2022 Response to Request for Additional Information Regarding License Amendment Request to Revise Facility Operating License and Technical Specifications for a Permanently Defueled Condition PNP 2022-002, Annual Report of Changes in Emergency Core Cooling System Models2022-03-24024 March 2022 Annual Report of Changes in Emergency Core Cooling System Models PNP 2021-012, Report of Changes, Tests and Experiments, and Summary of Commitment Changes2021-10-0707 October 2021 Report of Changes, Tests and Experiments, and Summary of Commitment Changes PNP 2021-029, Pre-Notice of Disbursement from Decommissioning Trust2021-09-0202 September 2021 Pre-Notice of Disbursement from Decommissioning Trust PNP 2021-013, Request for Rescission of Interim Compensatory Measure from Order EA-02-0262021-07-21021 July 2021 Request for Rescission of Interim Compensatory Measure from Order EA-02-026 PNP 2021-020, Request for Partial Exemption from Record Retention Requirements in 10 CFR 50.122021-06-15015 June 2021 Request for Partial Exemption from Record Retention Requirements in 10 CFR 50.12 PNP 2021-005, License Amendment Request to Revise Renewed Facility Operating License and Technical Specifications for Permanently Defueled Condition2021-06-0101 June 2021 License Amendment Request to Revise Renewed Facility Operating License and Technical Specifications for Permanently Defueled Condition PNP 2021-026, Pre-Notice of Disbursement from Decommissioning Trust2021-05-27027 May 2021 Pre-Notice of Disbursement from Decommissioning Trust PNP 2021-016, 2020 Radiological Environmental Operating Report2021-05-12012 May 2021 2020 Radiological Environmental Operating Report PNP 2021-022, 2020 Annual Non-Radiological Environmental Operating Report2021-04-27027 April 2021 2020 Annual Non-Radiological Environmental Operating Report PNP 2021-015, and Big Rock Point, Submittal of 2020 Annual Radioactive Effluent Release and Waste Disposal Report2021-04-21021 April 2021 and Big Rock Point, Submittal of 2020 Annual Radioactive Effluent Release and Waste Disposal Report PNP 2021-017, Schedule Change to Open Phase Condition Detection Implementation2021-04-0101 April 2021 Schedule Change to Open Phase Condition Detection Implementation PNP 2021-003, 2020 Steam Generator Tube Inspection Report2021-03-25025 March 2021 2020 Steam Generator Tube Inspection Report PNP 2021-010, Annual Report of Changes in Emergency Core Cooling System Models2021-03-19019 March 2021 Annual Report of Changes in Emergency Core Cooling System Models PNP 2021-004, Report - Changes to Palisades Nuclear Plant Technical Specifications Bases2021-03-10010 March 2021 Report - Changes to Palisades Nuclear Plant Technical Specifications Bases PNP 2021-006, Pre-Notice of Disbursement from Decommissioning Trust2021-03-0808 March 2021 Pre-Notice of Disbursement from Decommissioning Trust PNP 2021-001, ASME Section XI 90-Day Owner'S Activity Report2021-01-12012 January 2021 ASME Section XI 90-Day Owner'S Activity Report 2023-09-28
[Table view] |
Text
Entergy Nuclear Operations, Inc. Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 Tel 269 764 2000
________________________
_____________________
__________________
___________ Otto W Gustafson Regulatory Assurance Manager PNP 2014-001
April 3, 2014
U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Response to Second Request for Additional Information - Reactor Vessel Internals - ME9569 Palisades Nuclear Plant Docket 50-255 License No. DPR-20
References:
- 1. Entergy Nuclear Operations, Inc. letter to NRC, "Revised Program Plan for Aging Management of Reactor Vessel Internals," September 13, 2012 (ADAMS Accession Number ML12257A352)
- 2. NRC e-mail, "Palisades - Request for Additional Information - ME9569 - Revised Program Plan for Aging Management of Reactor Vessel Internals,"
March 4, 2013 (ADAMS Accession Number ML13063A318)
- 3. Entergy Nuclear Operations, Inc. letter to NRC, "Response to Request for Additional Information - Revised Program Plan for Aging Management of Reactor Vessel Internals," April 4, 2013 (ADAMS Accession Number ML13094A414)
- 4. NRC e-mail, "Palisades - Request for Additional Information - Reactor Vessel Internals - ME9569 - Email Resend," December 12, 2013 (ADAMS Accession Number ML13346A644)
- 5. Entergy Nuclear Operations, Inc. Letter to NRC, "Summary of January 2, 2014 Teleconference with Nuclear Regulatory Staff on Palisades - Request for Additional Information - Reactor Vessel Internals - ME9569 Response Schedule," January 07, 2014 (ADAMS Accession Number ML14007A151)
Dear Sir or Madam:
In Reference 1, Entergy Nuclear Operations, Inc. (ENO) submitted to the Nuclear Regulatory Commission (NRC) a revised program plan for aging management of reactor vessel internals.
In Reference 2, the NRC issued a request for additional information (RAI). ENO responded to the RAI in Reference 3.
Page 1 of 2 ATTACHMENT Response to Second Request for Additional Information - Reactor Vessel Internals - ME9569 By letter dated September 13, 2012, Entergy Nuclear Operations, Inc. (ENO) submitted to the Nuclear Regulatory Commission (NRC) a revised program plan for aging management of reactor vessel internals. By electronic mail, dated December 12, 2013, the Nuclear Regulatory Commission (NRC) submitted a second request for additional information. The requested information is provided below.
- 1. NRC Information Request - RAI-2.1 As discussed in References 1 and 2, the staff has identified two additional questions that all CE and Westinghouse design plants referencing topical report MRP-227-A must answer to close Applicant/Licensee Action Item 1 related to plant-specific applicability of the topical report. If the answer to either or both questions is yes, then further evaluation will be necessary to demonstrate the applicability of MRP-227-A to Palisades. The staff therefore requests the following information:
- 1. Do the Palisades RVI have non-weld or bolting austenitic stainless steel components with 20% cold work or greater, and if so do the affected components have operating stresses greater than 30 ksi?
- 2. Has Palisades ever utilized atypical design or fuel management that could make the assumptions of MRP-227-A regarding core loading/core design non-representative for that plant, including power changes/uprates?
References
- 1. 2/25/2013 Summary of Telecom with EPRI and Westinghouse Electric Company, March 15, 2013 (ADAMS Accession No. ML13067A262) 2. MRP-227-A Applicability Guidelines for Combustion Engineering and Westinghouse Pressurized Water Reactor Designs, Enclosure to MRP Letter 2013-025, October 14, 2013 ENO Response
- 1. No, Palisades' reactor vessel internals (RVI) do not contain any non-weld or bolting austenitic stainless steel components with 20% cold work or greater.
To support this conclusion, Electric Power Research Institute (EPRI) letter MRP 2013-025, "MRP-227-A Applicability Guidelines for Combustion Engineering and Westinghouse Pressurized Water Reactor Designs," response guidance was used as guidance to fully demonstrate PNP specific applicability by performing a detailed review of all RVI stainless steel component drawings, procurement specifications, and listed material standards. The review included a categorization and reexamination of the screening process that had been used under MRP-191, "Materials Reliability Program: Screening Categorization and Ranking of Reactor Internals Components of Page 2 of 2 Westinghouse and Combustion Engineering PWR Design," and MRP-227-A, "Materials Reliability Program: Pressurized Water Reactors Internals Inspection and Evaluation Guidelines," to determine those components that may be most susceptible due to fabrication or replacement, and whether any additional components or locations may fall outside the criteria that were chosen for generic screening purposes. The review determined that PNP does not have materials with greater than 20% cold working.
- 2. No, Palisades has not utilized atypical design or fuel management, including power changes/uprates, which are non-representative of the assumptions of MRP-227-A.
To support this conclusion, the assumptions of MRP-227-A, along with the additional guidance provided by MRP 2013-025, were evaluated. The assumptions of MRP-227-A were evaluated against fuel design changes, core designs, and plant operation.
Palisades Nuclear Plant (PNP) highest calculated reactor core power density remains below the MRP-191 assumption of 83.0 W/cm
- 3. Additionally, PNP operated 14 years with a high leakage core, followed by 25 plus years of low (or ultra-low) leakage cores, resulting in much less fluence than assumed in MRP-227-A. The MRP 2013-025 screening criteria for Combustion Engineering plants was also met, except for fuel cycles prior to fuel cycle 14. For fuel cycles prior to fuel cycle 14 the distance between the active fuel and the fuel alignment plate was slightly below the assumed 12.4 inches (by a maximum of 0.57" for fuel cycle 1). Since fuel cycle 14, this screening criterion has been met. Even though this screening criteria was not met prior to fuel cycle 14, PNP is still bounded by the MRP 2013-025 analysis because the screening criteria used a fuel power density that was 27% higher than PNP's fuel density during fuel cycle 1 when the maximum deviation from the screening criteria occurred. This 27% margin more than offsets the increased flux due to the active fuel being closer to the alignment plate. Therefore, even with the active fuel slightly closer to the upper alignment plate than
analyzed for MRP 2013-025 for the first 13 fuel cycles, PNP reactor vessel upper internals would have received less fluence than analyzed in MRP 2013-025.