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MONTHYEARML0524205032005-08-18018 August 2005 Comment (5) of Wayne Rendell Regarding the Scope of the Environmental Review for the Palisades Nuclear Plant Located in Covert Township Project stage: Request ML0534704282005-10-18018 October 2005 Response to Supplemental Questions Concerning Radioactive Solid Waste Management Project stage: Request ML0534704262005-11-18018 November 2005 Supplement to Response to NRC Request for Additional Information Dated August 24, 2005, Dated October 21, 2005, and Telecon on November 10, 2005 for Palisades. Project stage: Supplement ML0604004302006-02-28028 February 2006 NUREG-1437 S27 Dfc Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Regarding Palisades Nuclear Plant. Draft Report for Comment Project stage: Draft Other ML0626402682006-09-13013 September 2006 G20060792 - John T. Larkins Ltr. Re Questions Raised by Members of the Public During the ACRS Subcommittee Meeting on Palisades Nuclear Plant License Renewal Application Project stage: Meeting ML0626405882006-10-16016 October 2006 G20060792 - John T. Larkins Ltr. Re Questions Raised by Members of the Public During the ACRS Subcommittee Meeting on Palisades Nuclear Plant License Renewal Application Project stage: Meeting 2005-08-18
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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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N Palisades Nuclear Plant Commifted to NuaExceence Operated by Nuclear Management Company, LLC November 18, 2005 Ms. Leslie Fields Project Manager U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Mail Stop 0-11 F1 Washington, DC 20555
SUBJECT:
Supplement to "Response to NRC Request for Additional Information Dated August 24, 2005 relating to License Renewal for the Palisades Nuclear Plantr, dated October 21, 2005, (Accession Number ML052990316) and telecon on November 10, 2005.
Dear Ms. Fields,
Enclosed, please find information addressing your inquiries to Palisades Nuclear Plant responses to NRC RAls submitted on October 21, 2005 (Accession Number ML05299036) and telecon on November 10, 2005 concerning the Severe Accident Mitigation Alternatives reviewed in the Environmental Report.
If you have any questions or concerns, please contact me at 715-377-3380.
Sincerely, James Holthaus Environmental Project Manager Palisades Nuclear Plant Nuclear Management Company, LLC 27780 Blue Star Highway
Enclosure I NRC E-Mail: 3.c.1 - NMC response is that the importance list did not disclose any instances where the level of redundancy for actuation logic was an issue. Why was this the case? Did the NMC model evaluate this redundancy and determine it wasn't important or does the NMC model not evaluate this redundancy?
NMC Response to 3.c.i Why certain events at other units have importance measures that meet the criteria they have established for screening and do not meet the criteria for another plant, would require an In depth evaluation of the design of their systems and their interactions to understand the differences. The PRA model includes the redundancy in the logic as it exists for Palisades. Events that result in failure of the logic did not meet the criteria (RRW > 1.01) established for screening in the Palisades SAMA analysis. AFAS Logic is modeled however, it screens out.
NRC E-Mail: 3.c.iii - NMC response is that at time of CST depletion it is possible to align the power to this equipment to a safety related power supply that would be supplied by a diesel generator. This response suggests that this SAMA is applicable to Palisades. Does this mean that NMC will investigate the benefits of developing a procedure to do this and, if beneficial, add it to the Palisades Severe Accident Management Guidelines?
NMC Response to 3.c.iii Current Palisades design does include automatic makeup from the demineralized water tank (T-939) to the condensate storage tank (CST) (T-2). The alignment of power exists in procedure guidance. The required actions are included in Off-Normal procedure 2.1, Revision 12, "Loss of AC Power," Attachment 2 'Restoring P-936 To Service During Loss Of Offisite Power." Pump P-936 is the pump that provides the makeup function to Condensate Storage Tank (T-2).
NRC E-Mail: 7.d - NMC response provided an estimate of the cost of a new dedicated cooling loop to serve as the primary source of EDG cooling. The response is confusing because SAMA 18 already evaluated the cost of a dedicated pump and line for EDG cooling. How is the RAI response cost estimate different than the SAMA 18 estimate? Is the RAI response cost estimate for a permanent or temporary line? It is still not clear whether it is feasible to install an additional line or temporary connection directly from the FPS (by-passing the SW lines).
NMC Response to 7.d Palisades will conduct an evaluation to identify a lower cost alternative to the proposed permanent diesel generator cooling line discussed in SAMA 18. An action to document the evaluation has been entered into the corrective action system. If an appropriate cost-benefit as defined in the Environmental Report is calculated this SAMA would be evaluated according to the plant's design processes.
NRC E-Mail: 7.e-iii and 7.e-viii - Clarify what is meant in the last sentence of the responses to these RAls (i.e., that the respective failures did not meet the criteria for SAMA consideration).
NMC Resoonse to 7.e-iii Palisades' PRA model was reviewed to identify plant specific components that were the same or performed the same function for the referenced plant. The importance of Palisades' plant specific events for equivalent equipment (basket strainers) or conditions (thermally induced failure of steam generator tubes) did not meet the criteria (RRW > 1.01) for consideration of SAMA for Palisades.
Thermally induced failure of steam generator tubes did not meet the criteria for consideration of SAMA for Palisades. This event screened out.
NMC Response to 7.e-viii Page 2 of 4
Enclosure I The Palisades PRA model was reviewed to identify plant specific components that were the same or performed the same function for the referenced plant. The importance of Palisades' plant specific events for equivalent equipment (basket strainers) or conditions (thermally induced failure of steam generator tubes) did not meet the criteria (RRW > 1.01) for consideration of SAMA for Palisades.
The Palisades modeled basket strainers screened out. Therefore any back flush device would also screen out.
NRC E-Mail: 7.e-iv - Is it accurate to characterize NMC's response as a commitment to further evaluate the SAMA (flashing the EDG field) as an additional, potentially-cost-beneficial SAMA?
NMC Response to 7.e-lv NMC agreed to review this SAMA. This SAMA has been entered into the Palisades corrective action system for further review.
NRC E-Mail: 7.e-ix - NMC response provided a cost estimate to replace one of the containment sump AOVs with an MOV. This response suggests that the SAMA is applicable to Palisades. Based on the cost estimate, is the SAMA cost beneficial? (This can't be determined from the response because a risk reduction and benefit estimate was not provided.)
NMC Resoonse to 7.e-ix Palisades will conduct an evaluation to determine the potential risk reduction and cost benefit of the installation of a diverse valve operator to one of the containment sump valves. An action to document the evaluation has been entered into the corrective action system. If an appropriate cost-benefit as defined in the Environmental Report is calculated this SAMA would be evaluated according to the plant's design processes.
During the telecon with the NRC on 11/10/2005, the issue of a lower cost alternative to the installation of a new diesel generator discussed In SAMA 1 was raised for further consideration. The plant's position is that a lower cost alternative (SAMA 10) has already been identified. While SAMA I was intended to address the broad class of Loss of Offsite Power (LOOP) events that contribute to the Palisades core damage frequency, approximately eighty-seven percent of the core damage frequency from LOOP events is associated with the dominant station blackout scenario. For this scenario the turbine-driven pump is operating, offsite power is not recovered within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and battery depletion occurs at fours. Under these conditions core damage is assumed to occur due to the potential to overfill a steam generator and fail the turbine-driven pump. SAMA 10 was developed as a mitigating strategy to deal specificallywith this station blackout scenario. Therefore, SAMA 10 is a lower cost alternative that will provide a significant percentage of the expected benefit of SAMA 1.
In addition, the following information was obtained regarding the installation of non-safety commercially procured diesel generators at the DC Cook (COOK) plant. Two non-safety grade diesel generators will be installed with connections to an existing non-safety off-site bus. Both diesels are required to support one division of power (each diesel is rated at about 2450 KW). The original intent of the modification was to provide an alternate power source to provide cooling to the COOK reactor coolant pump seals (which is not a significant issue with Combustion Engineering (CE) seals). However, the modification evolved to supporting eight different LOOP configurations as well as extending different system Tech Spec AOTs.
The cost of the diesel units is currently in the range of 5 to 7 million dollars (unofficial and not final).
It is considered that a single diesel may be sufficient for Palisades. However, engineering would be required to support the Palisades EDG 1-1 and EDG 1-2 initial loading requirements of about 2529 KW and 2630 KW, respectively (note that according to COOK personnel an upgrade of the 2450 KW design to a higher rated value was a significant cost increase).
Assuming a single diesel would be sufficient, an equivalent cost to Palisades would be on the order of 2.5 to 3.5 million for a single unit plus an undefined cost of a connection capability from a non-safety to a safety system. Additionally the connection would have to be capable of supplying either of the safety buses depending on which diesel generator failed or was unavailable. It is expected that the cost of the Page 3 of 4
£ wEnclosure I Connection will significantly increase the total cost of the installation of a non-safety diesel generator.
Moreover, the engineering costs justifying a single diesel would contribute to the overall expense as well.
As noted above, implementation of SAMA 10 would offset a portion of the benefit related to SAMA 1.
Palisades will conduct an evaluation to determine the potential risk reduction and cost benefit of the installation of a non-safety diesel generator as a lower cost alternative to SAMA I subsequent to the evaluation of SAMA 10. An action to document the evaluation has been entered into the corrective action system. If an appropriate cost-benefit as defined in the Environmental Report is calculated, this SAMA would be evaluated in accordance with Palisades Plant design processes.
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