ML100280114

Palisades - License Amendment Request for a Change to License Section 2.E

ML100280114
Person / Time
Site:	Palisades
Issue date:	01/27/2010
From:	Schwarz C J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML100280114 (12)

Text

January 27, 2010 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Nuclear nnc,?",tinnQ Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Tel 269 7642000 Christopher J. Schwarz Site Vice President

SUBJECT:

License Amendment Request for a Change to License Section 2.E. Palisades Nuclear Plant Docket 50-255 License No. DPR-20

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc. (ENO) requests that Section 2.E. of the Palisades Nuclear Plant (PNP) Renewed Facility Operating License be amended. The change would remove the name of the former operator of the plant in the title of the PNP physical security plan and replace it with Entergy Nuclear. The change would also remove the security plan revision number and the date the plan was submitted to the NRC. The changes have been discussed with the NRC Palisades Project Manager. The proposed change has been evaluated in accordance with 10 CFR 50.91 (a)(1) using criteria in 10 CFR 50.92(c) and it has been determined that the change involves no significant hazards consideration.

The bases for these determinations are included in Attachment 1 along with a detailed description of the proposed change, background and technical evaluation, and an environmental review consideration.

Attachment 2 provides the revised License page reflecting the proposed change. Attachment 3 provides the annotated License page showing the proposed change. ENO requests approval of the proposed amendment by January 31,2011. Once approved, the amendment shall be implemented within 60 days. A copy of this request has been provided to the designated representative of the State of Michigan.

The proposed change does not include any new or revised commitments.

Document Control Desk Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on January 27, 2010. Sincerely, 0NL cjs/jlk Attachments:

1. Evaluation of the Proposed Change 2. Revised License Pages 3. Mark-Up of License Pages cc: Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC ATTACHMENT 1 EVALUATION OF PROPOSED CHANGE LICENSE AMENDMENT REQUEST FOR A CHANGE TO LICENSE SECTION 2.E.

1.0 DESCRIPTION

Entergy Nuclear Operations, Inc. (ENO) requests to amend the Renewed Facility Operating License number DPR-20 for the Palisades Nuclear Plant (PNP) to revise the title of the PNP physical security plan and remove the plan revision number and submittal date.

2.0 PROPOSED CHANGE

ENO proposes to revise the last sentence in Section 2.E. of the Renewed Facility Operating License DPR-20 as follows: 1\1 Remove the words "Nuclear Management Company" and replace them with "Entergy Nuclear." 1\1 End the last sentence after "Palisades Nuclear Plant Physical Security Plan" by removing the following:

", Revision 2," submitted by letter dated May 1 0, 2006."

3.0 BACKGROUND

By letter dated February 15, 2007, the NRC issued a conforming administrative change to the Renewed Facility Operating License number DPR-20 that added the title, revision and submittal letter date of the PNP physical security plan. Subsequently, the NRC issued a correction letter on April 2, 2007, to revise the revision number and submittal date of the security plan. On April 11 ,2007, the purchase of PNP was completed by Entergy Nuclear Palisades, LLC (ENP) and ENO became the plant operator.

Thereafter, "Nuclear Management Company" was removed from the title of the physical security plan and replaced with "Entergy Nuclear." Subsequent revisions to the PNP physical security plan were submitted to the NRC beginning on May 24,2007, when ENO submitted revision three to the plan. The latest revision submittal was revision nine that was sent to the NRC by letter dated September 23,2009. ENO documented in each of the revision submittals that the changes did not decrease the safeguards effectiveness of the PNP physical security plan. All of the revisions were submitted as safeguards information to be withheld from public disclosure in accordance with 10 CFR 73.22. The submittal letter dates for PNP physical security plan revisions three through nine are as follows: Page 1 of 4 III Revision 3 submitted May 24, 2007 III Revision 4 submitted February 8, 2008 III Revision 5 submitted August 26, 2008 III Revision 6 submitted January 7,2009 III Revision 7 submitted March 25, 2009 III Revision 8 submitted August 13, 2009 III Revision 9 submitted September 23, 2009 The change to the name of the PNP physical security plan and submittal of the subsequent plan revisions were not recognized, until recently, as having affected section 2.E. of the Renewed Facility Operating License. This condition has been documented in the corrective action system. The proposed changes have been discussed with the NRC Palisades Project Manager. As a result of the discussion, the proposed license revision is being submitted to correct the title of the PNP physical security plan and to remove the revision number and the date of the plan revision submittal to the NRC. 4.0 TECHNICAL EVALUATION The title, revision number and submittal date of the PNP physical security plan as referenced in Section 2.E. of the Renewed Facility Operating License are not current. Based on discussions with the NRC Palisades Project Manager, ENO proposes to remove the former plant operator from the title of the PNP physical security plan and replace it with "Energy Nuclear." Additionally, as also discussed, the plan revision number and date of submittal of the plan revision to the NRC are proposed to be deleted from Section 2.E. of the license. Removing the physical security plan revision number and date of the submittal, of the plan revision, to the NRC would also remove an unnecessary administrative burden for ENO and the NRC. This is demonstrated by the four revisions to the plan that were submitted in 2009. The proposed changes will align the Renewed Facility Operating License with the current PNP physical security plan.

5.0 REGULATORY EVALUATION

5.1 Applicable

Regulatory Requirements and Criteria Applicable regulations and requirements continue to be met with the proposed change. The proposed change does not require relief from other regulatory requirements and does not affect conformance with the General Design Criteria as described in the Final Safety Analysis Report. Page 2 of 4 In conclusion, based on the considerations described 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. 5.2 No Significant Hazards Consideration Entergy Nuclear Operations, Inc. (ENO) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as described below: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response:

No. The proposed license amendment corrects the out-ot-date title, removes the revision number, and removes the submittal date of the Palisades Nuclear Plant (PNP) physical security plan in section 2.E. of the Renewed Facility Operating License. The proposed amendment does not involve operation of plant structures, systems, or components (SSC) in a manner or configuration different from those previously recognized or evaluated.

The proposed change in section 2.E. of the Renewed Facility Operating License is administrative and has no impact on plant operation or equipment.

Therefore, operation of the facility in accordance with the proposed amendment would 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 license amendment does not involve a physical alteration of any SSC or change the way any SSC is operated.

The proposed license amendment does not involve operation of any SSC in a manner or configuration different from those previously recognized or evaluated.

The proposed change in section 2.E. of the Renewed Facility Operating License is administrative and has no impact on plant operation or equipment.

Page 3 of 4 Therefore, the proposed Renewed Facility Operating License change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

No. The proposed modification of section 2.E. of the Renewed Facility Operating License is administrative and has no impact on plant operation or equipment or on any margins of safety. Therefore, the proposed TS change does not involve a significant reduction in a margin of safety. Conclusion Based on the above, ENO concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

6.0 ENVIRONMENTAL

CONSIDERATION The proposed amendment affecting section 2.E. of the Renewed Facility Operating License is administrative.

The proposed amendment corrects the title of the physical security plan and removes the plan revision number and the date the plan was submitted to the NRC. The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment 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 amendment.

Page 4 of 4 2 . REVISED LICENSE PAGES LICENSE AMENDMENT REQUEST FOR A CHANGE TO LICENSE SECTION 2.E. Renewed Facility Operating License Page Change Instructions and Revised License Page 6 Two pages follow ATTACHMENT TO LICENSE AMENDMENT NO. RENEWED FACILITY OPERATING LICENSE NO. DPR-20 DOCKET NO. 50-255 Remove the following page of the Renewed Facility Operating License and replace with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change. REMOVE INSERT Page 6 Page 6 D. The facility has been granted certain exemptions from the requirements of Section III, G of Appendix R to 10 CFR Part 50, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979." This section relates to fire protection features for ensuring the systems and associated circuits used to achieve and maintain safe shutdown are free of fire damage. These exemptions were granted in letters dated February 8, 1983, July 12, 1985, and July 23, 1985. In addition, the facility has been granted certain exemptions from Appendix J to 10 CFR Part 50, "Primary Reactor Containment Leakage Testing for Water Cooled Power Reactors." This section contains leakage test requirements, schedules and acceptance criteria for tests of the leak-tight integrity of the primary reactor containment and systems and components which penetrate the containment.

These exemptions were granted in a letter dated December 6, 1989. These exemptions granted pursuant to 10 CFR 50.12, are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security.

With these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

E. ENO shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Entergy Nuclear Palisades Nuclear Plant Physical Security Plan." F. [deleted]

G. ENP and ENO shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims. Renewed License No. DPR-20 Amendment No. 224, 2xx 3 MARK-UP OF LICENSE PAGES LICENSE AMENDMENT REQUEST FOR A CHANGE TO LICENSE SECTION 2.E. Page 6 (the addition is highlighted and the removed words are lined out) One page follows D. The facility has been granted certain exemptions from the requirements of Section III, G of Appendix R to 10 CFR Part 50, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979." This section relates to fire protection features for ensuring the systems and associated circuits used to achieve and maintain safe shutdown are free of fire damage. These exemptions were granted in letters dated February 8, 1983, July 12, 1985, and July 23, 1985. In addition, the facility has been granted certain exemptions from Appendix J to 10 CFR Part 50, "Primary Reactor Containment Leakage Testing for Water Cooled Power Reactors." This section contains leakage test requirements, schedules and acceptance criteria for tests of the leak-tight integrity of the primary reactor containment and systems and components which penetrate the containment.

These exemptions were granted in a letter dated December 6, 1989. These exemptions granted pursuant to 10 CFR 50.12, are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security.

With these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

E. ENO shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

The combined set of plans, whichcontains Safeguards Information protected under 10 CFR 73.21, is entitled:

Nuclear Management Company Palisades Nuclear Plant Physical Security Plan, Revision 2," submitted by letter dated May 10, 2006." F. [deleted]

G. ENP and ENO shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims. Renewed License No. DPR-20 Amendment No. 224