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Category:Letter
MONTHYEARML24022A1172024-01-23023 January 2024 Acceptance of Requested Licensing Action Amendment Request to Revise Renewed Facility Operating License and Permanently Defueled Technical Specifications to Support Resumption of Power Operations ML24012A2422024-01-16016 January 2024 Acceptance of Requested Licensing Action License Transfer Request ML23236A0042023-12-27027 December 2023 Issuance of Amendment 274 Re Changes to Perm Defueled Emergency Plan and Perm Defueled Emergency Action Level Scheme ML23355A1242023-12-26026 December 2023 Withdrawal of an Amendment Request Re License Amendment Request to Revise License Condition to Eliminate Cyber Security Plan Requirements ML23192A0772023-12-26026 December 2023 Letter Exemption from the Requirements of 10 CFR 140.11(a)(4) Concerning Offsite Primary and Secondary Liability Insurance ML23191A5222023-12-22022 December 2023 Exemption Letter from the Requirements of 10 CFR 50.54(W)(1) Concerning Onsite Property Damage Insurance (EPID - L-2022-LLE-0032) ML23263A9772023-12-22022 December 2023 Exemption from Certain Emergency Planning Requirements and Related Safety Evaluation ML23354A2602023-12-21021 December 2023 Reference Simulator Inspection Request for Information L-23-019, Proof of Financial Protection 10 CFR 140.152023-12-18018 December 2023 Proof of Financial Protection 10 CFR 140.15 PNP 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 L-23-012, Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point2023-11-13013 November 2023 Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point ML23291A4402023-11-0303 November 2023 Acceptance of Requested Licensing Action Request for Exemption from 10 CFR 50.82(a)(2) to Support Reauthorization of Power Operations IR 05000255/20230032023-10-0404 October 2023 NRC Inspection Report No. 05000255/2023003(DRSS)-Holtec Decommissioning International, LLC, Palisades Nuclear Plant ML23275A0012023-10-0202 October 2023 Request for Withholding Information from Public Disclosure for Palisades Nuclear Plant 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 2023-026, 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 2023-023, Special Report High Range Noble Gas Monitor Inoperable2023-08-0909 August 2023 Special Report High Range Noble Gas Monitor Inoperable ML23215A2302023-08-0303 August 2023 Notice of Organization Change - Chief Nuclear Officer IR 05000255/20230022023-07-19019 July 2023 NRC Inspection Report 05000255/2023002 DRSS-Holtec Decommissioning International, LLC, Palisades Nuclear Plant ML23087A0362023-05-0202 May 2023 PSDAR Review Letter ML23117A2172023-05-0101 May 2023 Safety Evaluation for Quality Assurance Program Manual Reduction in Commitment PNP 2023-018, 2022 Annual Non-Radiological Environmental Operating Report2023-04-25025 April 2023 2022 Annual Non-Radiological Environmental Operating Report L-23-004, HDI Annual Occupational Radiation Exposure Data Reports - 20222023-04-24024 April 2023 HDI Annual Occupational Radiation Exposure Data Reports - 2022 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 L-23-003, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2023-03-31031 March 2023 Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations PNP 2023-002, 6 to Updated Final Safety Analysis Report2023-03-31031 March 2023 6 to Updated Final Safety Analysis Report ML23088A0382023-03-29029 March 2023 Stations 1, 2, & 3, Palisades Nuclear Plant, and Big Rock Point - Nuclear Onsite Property Damage Insurance 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 ML23038A0982023-03-15015 March 2023 Request for Withholding Information from Public Disclosure ML23095A0642023-03-14014 March 2023 American Nuclear Insurers, Notice of Cancellation Rescinded 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 ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities ML23052A1092023-02-17017 February 2023 FEMA Letter to NRC, Proposed Commission Paper Language for Palisades Nuclear Plant Emergency Plan Decommissioning Exemption Request ML23032A3992023-02-0101 February 2023 Regulatory Path to Reauthorize Power Operations IR 05000255/20220032022-12-28028 December 2022 NRC Inspection Report No. 05000255/2022003(DRSS); 07200007/2022001 (Drss) Holtec Decommissioning International, LLC, Palisades Nuclear Plant L-22-042, Oyster, Pilgrim, Indian Point, Palisades and Big Rock Point - Proof of Financial Protection 10 CFR 140.152022-12-14014 December 2022 Oyster, Pilgrim, Indian Point, Palisades and Big Rock Point - Proof of Financial Protection 10 CFR 140.15 PNP 2022-037, Report of Changes to Security Plan, Revision 192022-12-14014 December 2022 Report of Changes to Security Plan, Revision 19 ML22321A2852022-11-17017 November 2022 LLC Master Decommissioning Trust Agreement for Palisades Nuclear Plant IR 05000255/20224012022-11-0909 November 2022 Decommissioning Palisades Nuclear Plant - Decommissioning Security Inspection Report 05000255/2022401 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 2022-024, 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 2022-026, 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 ML22292A2572022-10-25025 October 2022 Permanently Defueled Emergency Plan License Amendment RAI Letter 2024-01-23
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a Entergy Entergy Nuclear Operations, Inc.Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 Tel 269 764 2000 Anthony J. Vitale Site Vice President PNP 2014-008 January 30, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852
SUBJECT:
Update to Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding -Review of Available Physical Margin Assessments Palisades Nuclear Plant Docket 50-255 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-lchi Accident," dated March 12, 2012 (ADAMS Accession Number ML1 2056A046).
- 2. NRC letter to Nuclear Energy Institute, "Endorsement of Nuclear Energy Institute (NEI) 12-07, 'Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features,"'
dated May 31, 2012 (ADAMS Accession Number ML12144A142).
- 3. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2012-101,"Flooding Walkdown Report -Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated November 27, 2012 (ADAMS Accession Number ML12332A377).
- 4. NRC letter, "Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Flooding Walkdowns," dated December 23, 2013 (ADAMS Accession Number ML13325A891)
/p t Pfi PNP 2014-008 Page 2
Dear Sir or Madam:
On March 12, 2012, the NRC staff issued Reference 1, which requested information pursuant to Title 10 of the Code of Federal Regulations 50.54(f).
Enclosure 4 of that letter contains specific requested information associated with Near-Term Task Force Recommendation 2.3 for Flooding.
Per Reference 2, the NRC endorsed Nuclear Energy Institute (NEI) 12-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features." In Reference 3, Entergy Nuclear Operations, Inc.(ENO) submitted the final report in response to the request for information.
One of the requirements of NEI 12-07 is to identify the available physical margin (APM)associated with each flood protection feature, determine if the margin provided is small, and evaluate any small margins that have potentially significant consequences through the corrective action process. The results of this effort were to be maintained on site for future NRC audits.Following the NRC staff's initial review of the walkdown reports, regulatory site audits were conducted at a sampling of plants. Based on the walkdown report reviews and site audits, the Staff identified additional information necessary to allow them to complete its assessments.
Accordingly, by Reference 4, the NRC staff has issued a request for additional information (RAI). The RAI questions and the ENO responses for the Palisades Nuclear Plant (PNP) are provided below.RAI Number 1: Confirmation that the process for evaluating APM was reviewed.ENO Response:
ENO has completed a review of the process used at PNP to evaluate available APMs.RAI Number 2: Confirmation that the APM process is now or was always consistent with the guidance in NEI 12-07 and discussed in this RAI.ENO Response:
The original walkdown effort followed the guidance provided in NEI 12-07, including the definition for a small margin. Additional actions have been taken to make the process consistent with the information provided in this RAI.RAI Number 3: If changes are necessary, a general description of any process changes to establish this consistency.
ENO Response:
As stated above, the original walkdown effort followed the guidance provided in NEI 12-07, including a definition for a small margin. However, a specific APM had not been assigned to the seals associated with flood protection features.
PNP 2014-008 Page 3 These items have now been addressed in accordance with the guidance provided in this RAI.RAI Number 4: As a result of the audits and subsequent interactions with industry during public meetings, NRC staff recognized that evaluation of APM for seals (e.g., flood doors, penetrations, flood gates, etc.) was challenging for some licensees.
Generally, licensees were expected to use either Approach A or Approach B (described below) to determine the APM for seals: a) If seal pressure ratings were known, the seal ratings were used to determine APM (similar to example 2 in Section 3.13 of NEI 12-07). A numerical value for APM was documented.
No further action was performed if the APM value was greater than the pre-established small-margin threshold value. If the APM value was small, an assessment of"significant consequences" was performed and the guidance in NEI 12-07 Section 5.8 was followed.b) If the seal pressure rating was not known, the APM for seals in a flood barrier is assumed to be greater than the pre-established small-margin threshold value if the following conditions were met: (1) the APM for the barrier in which the seal is located is greater than the small-margin threshold value and there is evidence that the seals were designed/procured, installed, and controlled as flooding seals in accordance with the flooding licensing basis. Note that in order to determine that the seal has been controlled as a flooding seal, it was only necessary to determine that the seal configuration has been governed by the plant's design control process since installation.
In this case, the APM for the seal could have been documented as "not small".As part of the RAI response, state if either Approach A or Approach B was used as part of the initial walkdowns or as part of actions taken in response to this RAI. No additional actions are necessary if either Approach A or B was used.If neither Approach A or B was used to determine the APM values for seals (either as part of the walkdowns or as part of actions taken in response to this RAI), then perform the following two actions: Enter the condition into the CAP (note: it is acceptable to utilize a single CAP entry to capture this issue for multiple seals). CAP disposition of "undetermined" APM values for seals should consider the guidance provided in NEI 12-07, Section 5.8. The CAP disposition should confirm all seals can perform their intended safety function against floods up to the current licensing basis flood height. Disposition may occuras part of the Integrated Assessment.
If an Integrated Assessment is not performed, determine whether there are significant consequences associated with exceeding the capacity of the seals and take PNP 2014-008 Page 4 interim action(s), if necessary, via the CAP processes.
These actions do not need to be complete prior to the RAI response.Report the APM as "undetermined" and provide the CAP reference in the RAI response.ENO Response:
Approach B, described above, was used to determine the APM values for seals. When the seal pressure rating was not known, the APM for these seals is assumed to be greater than the pre-established small-margin threshold value.The conditions described above were met, as the APM for the barrier in which the seal is located is greater than the small-margin threshold value and there is evidence that the seals were designed/procured, installed, and controlled as flooding seals in accordance with the PNP flooding licensing basis. All of the seals were inspected as part of the original walkdowns for signs of degradation, and corrective actions were taken, when required.This letter contains no new or revised commitments.
I declare under penalty of perjury that the foregoing is true and correct. Executed on January 30, 2014.Sincerely,/ajv/jse cc: Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC