ML21152A110

Evaluation of the Proposed Changes

ML21152A110
Person / Time
Site:	Palisades
Issue date:	06/01/2021
From:	Entergy Nuclear Operations
To:	Office of Nuclear Reactor Regulation
Shared Package
ML21152A108	List: ML21152A110 ML21152A111 ML21152A112 ML21152A113 PNP 2021-005, License Amendment Request to Revise Renewed Facility Operating License and Technical Specifications for Permanently Defueled Condition
References
PNP 2021-005
Download: ML21152A110 (107)

Text

Enclosure PNP 2021-005 Evaluation of the Proposed Changes

PNP 2021-005 Enclosure Page 1 of 106 TABLE OF CONTENTS 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

3.1 General Analysis Applicable to Proposed Change 3.2 Postulated Cask Drop Accidents 3.3 Fuel Handling Accident Analysis 3.4 Waste Gas Incident 3.5 Liquid Waste Incident

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination 4.4 Conclusion 5.0 ENVIRONMENTAL EVALUATION

6.0 REFERENCES

7.0 ATTACHMENTS

Enclosure to PNP 2021-005 Page 2 of 106 EVALUATION OF THE PROPOSED CHANGES 1.0

SUMMARY

DESCRIPTION As required by Title 10 of the Code of Federal Regulations, Part 50, Section 90 (10 CFR 50.90), Application for amendment of license, construction permit, or early site permit, Entergy Nuclear Operations, Inc. (Entergy) hereby r-equests U.S. Nuclear Regulatory Commission (NRC) review and approval of a proposed amendment to revise the Palisades Nuclear Plant (PNP) Renewed Facility Operating License (RFOL) DPR-20. The proposed license amendment would revise the RFOL, the Appendix A Technical Specifications (TS), and the Appendix B Environmental Protection Plan (EPP). The proposed changes are consistent with the permanent cessation of operations and permanent removal of fuel from the reactor vessel. The requested changes involve no significant hazards consideration .

2.0 DETAILED DESCRIPTION Reason for Proposed Change In the Reference 1 letter, Entergy notified the NRC that it has decided to permanently cease operations at PNP no later than May 31, 2022. Once certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel are submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) , respectively, and they are docketed, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel in accordance with 10 CFR 50.82(a)(2).

The approved license amendment will become effective once the certifications required by 10 CFR 50.82(a)(1) have been docketed, and the irradiated fuel assembly decay time requirement of 17 days, established in the analysis of the fuel handling accident in the fuel handling building, has been met. Once effective, Entergy requests a 60-day implementation period.

Description of Proposed Change This license amendment request will revise the PNP Renewed Facility Operating License (RFOL), revise the TS in Appendix A to Permanently Defueled Technical Specifications (POTS),

and revise the Environmental Protection Plan (EPP) in Appendix B. The proposed changes are consistent with the permanent cessation of operations and permanent removal of fuel from the reactor vessel. The proposed changes would revise certain requirements contained within the PNP RFOL and TS and remove the requirements that would no longer be applicable after PNP is permanently shut down and defueled. The proposed changes to the PNP RFOL and TS are in accordance with 10 CFR 50.36(c)(1) through 10 CFR 50.36(c)(6). The proposed changes to the PNP EPP are in accordance with 10 CFR 50.36b(b).

The proposed changes also include a renumbering of pages in the RFOL and the Appendix A TSs, where appropriate, to condense and reduce the number of pages without affecting the technical content. The Appendix A TSs Table of Contents is also accordingly revised.

Currently, there is one PNP docketed license application that is under NRC review. In the Reference 2 letter, Entergy requested that the NRC consent to the indirect transfer of control of several licenses, including the RFOL No. DPR-20 for PNP, to Holtec International. If approved,

Enclosure to PNP 2021-005 Page 3 of 106 the transfers will occur after the docketing of Entergy's certifications of permanent cessation of operations and permanent removal of fuel from the PNP reactor vessel. As shown in Attachment A to Enclosure 1 of the Reference 2 letter, the request proposes changes to the PNP RFOL and PNP TS Section 4.1, Site Location. The Reference 2 license transfer request RFOL and TS changes are independent of the changes proposed in this enclosure and as such, the changes proposed by the license transfer request are not reflected in the RFOL and TS markups of this license amendment request.

3.0 TECHNICAL EVALUATION

This license amendment request proposes modifications to the PNP RFOL, the Appendix A TS, and the Appendix B EPP to comport with a permanently shut down and defueled reactor.

3.1 General Analysis Applicable to Proposed Change The regulatory requirements related to the content of TS are promulgated in 10 CFR 50.36, Technical Specifications. As detailed in a subsequent section of this proposed amendment, this regulation lists four criteria to define the scope of items that must be included in TS. In a permanently defueled condition, the scope of equipment and parameters that must be included in the PNP TS is limited to those needed to address the postulated design basis accidents (DBAs) that will remain applicable to PNP in the permanently shut down and defueled condition, so that the consequences of the accidents are maintained within acceptable limits. Chapter 14 of the PNP Updated Final Safety Analysis Report (UFSAR) describes safety analyses for postulated DBAs and transient scenarios under which the PNP is licensed.

Chapter 14 of the PNP UFSAR describes the OBA and transient scenarios applicable to PNP during plant operations. During normal power operations, the forced inlet flow of water through the primary coolant system (PCS) removes the heat from the reactor by generating steam. The PCS, operating at high temperatures and pressures, transfers this heat through the steam generator tubes to the secondary system. The most severe postulated accidents for nuclear power plants involve damage to the nuclear reactor core and the release of large quantities of fission products to the PCS. Many of the accident scenarios postulated in the UFSAR involve failures or malfunctions of systems which could affect the reactor core. Once the reactor is permanently defueled, the consequences from these UFSAR events are no longer applicable.

After the certifications are submitted for permanent cessation of operations and fuel has been removed from the PNP reactor vessel in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and docketed in accordance with 10 CFR 50.82(a)(2), the majority of OBA and transient scenarios postulated for an operating plant, and addressed in the PNP UFSAR, will no longer be applicable. The remaining scenarios are applicable to the storage and handling of irradiated fuel in the spent fuel pool (SFP) which is located outside containment. In the decommissioning phase, spent fuel will be stored in the SFP and the independent spent fuel storage installation (ISFSI) until it is shipped off site in accordance with the Post Shut Down Decommissioning Activities Report and irradiated fuel management plan schedule.

Chapter 14 of the PNP UFSAR describes the safety analysis aspects of the plant that were evaluated to demonstrate that the plant could be operated safely and that radiological consequences from postulated DBAs and transients do not exceed the applicable limits. Safety analyses are evaluated against regulatory acceptance criteria and are integral to the plant's design and licensing basis. The safety analyses demonstrate the integrity of the fission product barriers, the capability to shut down the reactor and maintain it in a safe shutdown condition,

Enclosure to PNP 2021-005 Page 4 of 106 and the capability to prevent or mitigate the consequences of DBAs and transients. Certain systems, structures, and components (SSCs) are credited in the safety analyses for the purpose of mitigating the DBAs or transients. These aspects of the safety analysis were considered when determining the defueled applicability of the PNP UFSAR DBAs and transients.

A list of the PNP UFSAR Chapter 14 safety analysis DBAs and transients, and a determination regarding whether the accident or transient applies to a permanently defueled reactor vessel is provided in Table 3-1.

Table 3 PNP DBAs and Transients UFSAR DBA or Transient Def ueled Applicability Section 14.2 Uncontrolled Control Rod Withdrawal Not Applicable 14.3 Boron Dilution Not Applicable 14.4 Control Rod Drop Not Applicable 14.5 Core Barrel Failure Not Applicable 14.6 Control Rod Mis-operation Not Applicable 14.7 Decreased Reactor Coolant Flow Not Applicable 14.8 Start-up of an Inactive [Primary Coolant Pump] Loop Not Applicable 14.9 Excessive Feedwater Incident Not Applicable 14.10 Increase in Steam Flow (Excess Load) Not Applicable 14.11 Postulated Cask Drop Accidents Applicable 14.12 Loss of External Load Not Applicable 14.13 Loss of Normal Feedwater Not Applicable 14.14 Steam Line Rupture Incident Not Applicable Steam Generator Tube Rupture with a Loss of Offsite 14.15 Not Applicable Power 14.16 Control Rod Ejection Not Applicable 14.17 Loss of Coolant Accident Not Applicable 14.18 Containment Pressure and Temperature Analysis Not Applicable 14.19 Fuel Handling Incident Applicable 14.20 Liquid Waste Incident Applicable 14.21 Waste Gas Incident Applicable 14.22 Maximum Hypothetical Accident Not Applicable Radiological Consequences of Failure of Small Lines 14.23 Not Applicable Carrying Primarv Coolant Outside Containment 14.24 Control Room Radiological Habitability Not Applicable The analyzed accidents that remain applicable to PNP in the permanently shut down and defueled condition are the Postulated Cask Drop Accidents, the Fuel Handling Incident (referred to as Fuel Handling Accident (FHA) hereafter), the Liquid Waste Incident, and the Waste Gas Incident. Each event is discussed in detail below.

Enclosure to PNP 2021-005 Page 5 of 106 3.2 Postulated Cask Drop Accidents In 2003, the main hoist of the SFP crane was modified to increase its capacity to 110-tons, and to meet single failure criteria in accordance with NUREG-0612, Control of Heavy Loads at Nuclear Power Plants, and NUREG-0554, Single-Failure-Proof Cranes for Nuclear Power Plants. On June 16, 2004, the NRG issued Amendment 215 (Reference 3) to the Palisades Operating License No. DPR-20 to approve the use of the SFP crane main hoist as a single

-failure-proof crane for loads up to 11 O tons. In Amendment 215, the NRG staff found that the proposed upgrade of the existing SFP crane to a single-failure-proof design was in accordance with NUREG-0612 and satisfied the intent of NUREG-0554. The staff found that the use of the SFP crane main hoist, with special lifting devices and slings meeting the specified design criteria, would enable PNP to handle heavy loads with little risk to irradiated fuel stored in the SFP. The amendment stated that, in accordance with the guidance in NUREG-0612, if a crane meets the criteria of NUREG-0544, a load drop is not considered to be a credible event.

Although the main hoist of the spent fuel crane is designed and operated in accordance with single-failure-proof criteria for cask handling activities, there may be situations in which lifting devices used with the main hook do not meet these requirements or single-failure-proof features of the main hoist may be disabled. In these situations, the crane would no longer meet single failure proof requirements, and therefore, load drops are postulated as discussed below.

Offsite and onsite radiological consequences were updated, in support of Amendment 226 (Reference 4), to incorporate the alternative source term (AST) methodology of Regulatory Guide 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors. RG 1.183 provides the methodology for analyzing the radiological consequences of several DBAs to show compliance with 10 CFR 50.67, Accident source term.

RG 1.183 provides guidance to licensees on acceptable content of AST submittals, including acceptable radiological analysis assumptions for use in conjunction with the accepted AST.

This analysis, discussed in UFSAR Section 14.11.3.1.1, assumes a cask drop onto fuel that has decayed for 90 days with no filtering of control room intake air via the control room heating, ventilation, and air conditioning (HVAC) system, or pre-filtering of stack exhaust via the fuel handling area ventilation system. UFSAR Table 14.1-6, Summary of Radiological Consequences of the Chapter 14 Events, provides offsite and control room dose consequences as shown in Table 3-2 below:

Table 3 Cask Drop After 90 Days (all values in rem TEDE}

Scenario Description Offsite Calculated Dose Control Calculated Dose Room Control Limits< 1l Dose Room Limits<2> Dose Cask drop in the Exclusion Area Low spent fuel pool onto Boundary (0-2 Population fuel with 90 days of hours) Zone decay. No charcoal filtering is assumed. 6.3 0.08 0.01 5 1.67 (1) Per RG 1.183 (2) Per 10 CFR 50.67

Enclosure to PNP 2021-005 Page 6 of 106 As shown above, there are no SSCs that are required to mitigate the consequences of a cask drop occurring 90 days or more after shutdown. Specifically, the RG 1.183 offsite dose limits and RG 10 CFR 50.67 control room dose limits are met without requiring fuel handling charcoal filtration SSCs or control room unfiltered leak path isolation SSCs to function to mitigate the consequences of a cask drop occurring 90 days or more after shutdown. To ensure PNP POTS support this accident scenario analysis, a new License Condition 2.C.(5) is proposed to prohibit fuel cask movement in or over the spent fuel pool when irradiated fuel assemblies with less than 90 days decay time are in the spent fuel pool.

TS 3.7.10, "Control Room Ventilation CRV Filtration," and TS 3.7.11, "Control Room Ventilation (CRV) Cooling," and TS 3.7.12, "Fuel Handling Area Ventilation System," are currently applicable during movement of a fuel cask in or over the spent fuel pool. TS 3. 7 .10 and TS 3.7.11 contain operability requirements for control room filtration and cooling, respectively, which provide control room unfiltered leak path isolation following a cask drop accident. TS 3.7.12, "Fuel Handling Area Ventilation System," is also applicable during movement of a fuel cask in or over the SFP when irradiated fuel assemblies with < 90 days decay time are in the fuel handling building. TS 3.7.12 contains operability requirements for the fuel handling area ventilation system, which provides filtration of air exhausted via the stack following a cask drop accident. The proposed new License Condition 2.C.(5), which prohibits cask movement over the spent fuel pool when it contains fuel decayed less than 90 days, ensures the UFSAR Section 14.11.3.1.1 analysis remains bounding without crediting the operability of these mitigating SSCs. Therefore, TS 3. 7 .10, TS 3. 7 .11, and TS 3. 7 .12 are no longer required to be retained in the POTS to mitigate the consequences of a fuel cask drop.

3.3 Fuel Handling Accident Analysis In 2005, PNP reanalyzed the FHA, utilizing the AST methodology described in RG 1.183, to support implementation of a full-scope AST in accordance with 10 CFR 50.67. This reanalysis is the current licensing basis analysis for an FHA (hereafter CLB-FHA), the results of which are presented in UFSAR Section 14.19 and UFSAR Table 14.1-6.

License Amendment 226 (Reference 4) implemented the TS changes and evaluations of the radiological consequences of DBAs for implementation of a full-scope AST in accordance with 10 CFR 50.67 and in accordance with methodology of RG 1.183. The CLB-FHA was reviewed by the NRC, as documented in the amendment safety evaluation.

As described in UFSAR Section 14.19, the CLB-FHA assumes that the FHA occurred in containment two days after reactor shutdown from full power operations and initiation of control room emergency HVAC 20 minutes into the event. The analysis describes two possible activity release paths: a filtered release via the fuel handling building ventilation system which exhausts via the plant stack, and the bounding case of an unfiltered release from containment.

Once the plant is permanently shut down and the reactor is defueled, an FHA in containment is no longer applicable because all irradiated spent fuel will either be stored in the SFP or the ISFSI. Therefore, since an FHA can only occur during movement of spent fuel in the SFP, the FHA event will be limited to the SFP.

With the reduction in scope of the FHA to the movement of spent fuel only in the SFP, Entergy proposes to delete the APPLICABILITY statement, "during movement of irradiated fuel assemblies," from TS 3.7.10, TS 3.7.11, and TS 3.7.12, which supports removal of these TS in the PNP POTS. To support these changes, Entergy has revised the FHA analysis to include a calculation of dose consequences from an FHA in the SFP. This calculation,

Enclosure to PNP 2021-005 Page 7 of 106 EA-EC89582-01, Revision O (Reference 5), concludes that the dose consequences of the FHA will remain within the licensing basis dose limits without crediting control room ventilation filtration, ventilation cooling, and fuel handling area ventilation filtration, after 17 days of irradiated fuel decay following shutdown. Therefore, TS 3.7.10, "Control Room Ventilation CRV Filtration," and TS 3.7.11, "Control Room Ventilation (CRV) Cooling," and TS 3.7.12, "Fuel Handling Area Ventilation System," which are currently applicable during movement of irradiated fuel assemblies, will no longer be required to mitigate the consequences of an FHA.

FHA Analysis Assumptions The revised FHA analysis assumptions and methodologies are consistent with those in the CLB-FHA analysis described in UFSAR Section 4.19, and approved in Amendment 226, which used the methodologies described in RG 1.183. The NRC safety evaluation (SE) for Amendment 226 states, in part, that the NRC staffs review found those assumptions and methodologies to be consistent with the applicable regulatory guidance identified in Section 2.0 of the SE.

RADTRAD Version 3.03 was used to estimate the dose consequences of an FHA in the SFP.

The control room and EAB doses, in terms of Total Effective Dose Equivalent (TEDE) were calculated for the FHA in the SFP.

As previously discussed, the revised FHA analysis takes no credit for control room ventilation filtration or pre-filtration of the stack exhaust via the fuel handling area ventilation system.

Instead, unfiltered air is assumed to enter through the normal control room ventilation and fuel handling area ventilation system alignments, and unfiltered air is assumed to exhaust through the stack from the SFP ventilation for the entirety of the event. A control room volume of 35,923 ft3 and unfiltered normal makeup flow rate to the control room of 660.0 cfm (ft3/minute) throughout the event are assumed. A volume of 10,000 ft3 is assumed for the space above the SFP. Note that crediting normal control room and fuel handling area ventilation is more conservative than assuming no ventilation because the normal ventilation provides a driving force for radionuclide entry into the control room or release via the stack.

Activity released from the SFP is based on the following fission product gap release fractions, per RG 1.183, and are consistent with the CLB-FHA.

Table 3 Release Fractions Group Fractions 1-131 0.08 Kr-85 0.10 Other Noble Gases 0.05 Other Haloaens 0.05 Alkali Metals 0.12 The iodine released from the assembly gap is assumed to be 99.85% elemental and 0.15%

organic, in accordance with RG 1.183. The CLB-FHA assumed 22.5 feet of water above the stored fuel which resulted in an effective decontamination factor of 183.07 and an overall decontamination factor for elemental iodine of 252. There is a minimum of 22.6 feet of water above the top of the fuel rack in the SFP. Therefore, an effective decontamination factor of 183.07 and an overall decontamination factor for elemental iodine of 252 are used in the revised FHA analysis.

Enclosure to PNP 2021-005 Page 8 of 106 Table 3-4 lists the nuclide inventories used in the revised FHA analysis. These values are consistent with the source term of the CLB-FHA, except where noted, and assume a design basis power level of 2703 MWt and an initial 48-hour decay period.

Table 3 Post-Permanent Shutdown AST FHA Source Term Nuclide Curies (Ci) 1-130 0.2546E+04 1-131* 0.1028E+07 1-132 0.7060E+06 1-133 0.3019E+06 1-135 0.8949E+04 Xe-131m 0.8276E+04 Xe-133 0.1298E+07 Xe-133m 0.3403E+05 Xe-135 0.8201E+05 Xe-135m 0.1434E+04 Kr-83m 0.3727E+00 Kr-85,. 0.2104E+05 Kr-85m 0.1174E+03 Kr-88 0.4302E+01 Br-82 0.2060E+04 Br-83 0.8833E-01 Te-131m 0.3690E+05 Te-131 0.8307E+04 Te-132 0.6852E+06

• These values are taken from the CLB-FHA after being adjusted for the higher individual isotope release fraction as specified in Table 3-3 above.

The atmospheric dispersion factors (X/0) associated with the transport of released radioactivity are consistent with the CLB-FHA and are shown in Table 3-5 below. Given the release is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in duration per RG 1.183, only the 0-2 hour timestep is applicable.

Table 3 Atmospheric Dispersion Factors 0-2 Hours Atmospheric Dispersion Factor (X'Q)

Location (seconds/meter)

Plant Stack to CR Normal Intake 'B' 5.29x10-3 s/m 3 EAB 5.39x10"" s/m 3 LPZ 6.66x10-5 s/m 3 FHA Analysis Results RG 1.183 dose acceptance criteria for the FHA are a Total Effective Dose Equivalent (TEDE) of 6.3 rem at the Exclusion Area Boundary (EAB) and at the outer boundary of the Low Population Zone (LPZ), assuming a 2-hour release duration. As discussed in RG 1.183, the 10 CFR 50.67 limit of 5 rem TEDE in the control room, for the duration of the accident, applies to all accidents.

As shown below, for an FHA in the SFP occurring after an irradiated fuel decay time of at least

Enclosure to PNP 2021-005 Page 9 of 106 17 days, the calculated TEDE values to the control room and EAB are less than the limits set forth in 10 CFR 50.67 and Regulatory Guide 1.183, respectively. For an FHA in the SFP where the radioactivity is released in the first two hours, the ratio of the dispersion factors is such that the dose at the LPZ will be much lower than the calculated dose at the EAB. Therefore, the EAB dose shown in Table 3-6 below, bounds the dose at the LPZ.

Table 3-6-FHA Results With 17 Days Total Decay Location TEDE Dose Regulatory Limit (TEDE)

Control Room 4.71 rem 5.0 rem Exclusion Area Boundary 0.52 rem 6.3 rem 3.4 Waste Gas Incident Section 14.21 of the PNP UFSAR evaluates the accidental release of waste gas. Two scenarios are analyzed, a gas decay tank rupture (GDTR) and a volume control tank rupture.

Both scenarios assume an uncontrolled release of tank contents to the atmosphere.

Gas Decay Tank Rupture As discussed in UFSAR Section 14.21, "Waste Gas Incident," PNP has six gas decay tanks which contain compressed radioactive gases from the waste gas surge tank which collects gases vented from the primary coolant system, the volume control tank and the liquid waste system. Administrative procedures require that the tanks be normally isolated from each other.

The gas decay tanks are designed for service at 135 psia and 550°F for expected operation at 115 psi a and 90°F. Because components of the waste gas system are not subjected to high temperatures or high stresses, a GDTR is unlikely.

The activity released from a gas decay tank is assumed to be the maximum amount that would accumulate from operation with 1% failed fuel rods in the primary coolant system. This activity is obtained from the noble gases krypton and xenon by assuming no gas release from the gas decay tank between plant refueling outages with an equilibrium core. The inventory of one gas decay tank is released to the auxiliary building. Partial decay is assumed corresponding to the time required, approximately 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />, to fill one waste gas decay tank. The release then travels unfiltered to the ventilation stack and then to the atmosphere over a period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

Control room emergency HVAC is initiated 20 minutes into the event. UFSAR Table 14.1-6 indicates offsite and control room dose consequences from the GDTR are within the requirements of 10 CFR 100.

Control room emergency HVAC is supported by TS 3.7.10, "Control Room Ventilation CRV Filtration," and 3.7.11, "Control Room Ventilation (CRV) Cooling." Entergy proposes deletion of TS 3. 7 .1 O and 3. 7 .11 from the POTS. Deletion of these TS is supported by demonstrating that the GDTR accident dose consequences are bounded by those of the revised FHA in the spent fuel pool (Reference 5). Specifically, this is accomplished by comparing two inputs to the dose consequence analysis in the revised FHA analysis to the same inputs in the GDTR analysis.

The first is the atmospheric dispersion coefficients; the second is the source term. If both GDTR inputs are bounded by those in the revised FHA analysis, then the revised FHA is the bounding scenario (i.e., the FHA dose consequences would be more severe) and the GDTR does not require any additional decay time beyond what is calculated for the FHA.

Enclosure to PNP 2021-005 Page 10 of 106 The atmospheric dispersion coefficients for the revised FHA are taken from the Reference 5 calculation and are consistent with those used in the CLB-FHA analysis performed for Amendment 226. The atmospheric dispersion coefficients for the GDTR are taken from the design basis calculation for control room habitability following accidents with radiological consequences presented in UFSAR Section 14.21. The atmospheric dispersion coefficients in the control room, site boundary, and the low population zone (LPZ) were compared. All atmospheric dispersion coefficients for the revised FHA bound (i.e., result in more severe dose consequences) the atmospheric dispersion coefficients for a GDTR.

A comparison of the source term for the revised FHA and the GDTR is also made. The source term for the revised FHA is taken from the Reference 5 calculation and is consistent with that used in the CLB-FHA analysis performed for Amendment 226. The current licensing basis source term for the GDTR is taken from the design basis calculation for control room habitability following accidents with radiological consequences presented in UFSAR Section 14.21. When compared, the FHA source term identified in the Reference 5 calculation bounds the current licensing basis GDTR source term on a dose equivalent basis.

Since the atmospheric dispersion coefficients and the source term for the revised FHA bound those of the design basis GDTR, it is therefore concluded that the dose consequences calculated for the FHA at an irradiated fuel decay time of 17 days, with no credit for control room ventilation filtration and cooling, bound the dose consequences of a GDTR with the same decay period and no credit for these mitigating systems. With the 17-day irradiated fuel decay time, the GDTR dose consequences remain within requirements of 10 CFR 100. No further analysis is required.

Volume Control Tank Rupture The volume control tank (VCT) rupture incident is no longer applicable. The VCT is part of the chemical and volume control system which supports the primary coolant system. During operations, the VCT contains primary letdown coolant with its associated fission product concentrations. The volatile fission products collect in the VCT vapor space and are vented by the operator to the waste gas system. In the permanently shut down and defueled condition, primary coolant letdown, and the chemical and volume control system will no longer be required to support primary coolant system operation, and the conditions assumed in the VCT rupture event, such as tank radionuclide inventory due to failed fuel, letdown flow rate, and primary coolant dose equivalent iodine 1-131 concentration, will no longer be applicable. Therefore, this incident is no longer applicable.

3.5 Liquid Waste Incident Section 14.20 of the PNP UFSAR addresses the accidents that may result in a release of waste liquid. Activity released from the liquid waste system to the environs can occur via (1) rupture of the volume control tank; (2) accidental discharge to the circulating water discharge canal; or (3) failure of the primary system makeup storage tank (T-90) or the utility water storage tank (T-91 ).

As discussed above, rupture of the VCT with the ensuing gaseous release is no longer applicable. Accidental discharge of radioactive liquid, in excess of the limits in 10 CFR 20, Standards for Protection Against Radiation, to the circulating water canal is prevented by administrative process, system design, and system monitoring. Liquid storage tanks T-90 and T-91 have administrative controls that maintain tank activity concentration such that 10 CFR 20 dose limits would not be exceeded in the event of a tank failure. The analyses for these events

Enclosure to PNP 2021-005 Page 11 of 106 are not impacted by the proposed removal of any LCOs and SRs from the POTS.

4.0 REGULATORY EVALUATION

Entergy proposes to modify the PNP RFOL, TS, and EPP as listed in the following tables. The tables identify each section that is proposed to be changed, the proposed changes, and the basis for each change. Changes to the RFOL are listed first followed by changes to the TS and EPP. Proposed deletions are shown with strikethrough and additions are shown in bold italics. to this enclosure contains a mark-up of the current RFOL, TS, and EPP pages.

The proposed changes to the Appendix A TS are considered a major rewrite. Thus, the Appendix A TS that are deleted in their entirety are identified as such, but the associated deleted pages are not included in Attachment 1 to this enclosure. In addition, the following administrative changes are not shown in the marked-up RFOL, Appendix A TS, and Appendix A TS Bases pages in Attachment 1, because they do not affect the technical content of the RFOL or the Appendix A TS:

• Reformatting (margins, font, tabs, line spacing, etc.) content to create a continuous electronic file,

• Renumbering of pages, where appropriate, to condense and reduce the number of pages.and

• The TS Table of Contents is also revised accordingly. of this enclosure provides the re-typed PNP Renewed Facility License, POTS, and EPP in their entirety.

Amendment 266 (Reference 6) was issued June 4, 2018. This amendment revised certain staffing and training requirements, reports, and programs, and made editorial changes in TS Sections 1.0, "Use and Application," and 5.0, "Administrative Controls," to support the permanently shut down and defueled condition. Amendment 266 will be implemented coincident with the changes proposed in this license amendment request. Since the Amendment 266 changes have been approved by the NRC, where affected, those changes are included in the markups in Attachments 1 and 3, and in the clean typed pages in Attachment 2, for clarity.

The markups of the TS Bases, provided in Attachment 3, are provided for information only. TS Bases sections that will be deleted in their entirety are not included in Attachment 3. Upon approval of this amendment, changes to the TS Bases will be incorporated in accordance with TS 5.5.12, "Technical Specifications (TS) Bases Control Program."

Enclosure to PNP 2021-005 Page 12 of 106 Proposed Changes to the PNP Renewed Facility Operating License License Title Current Title Proposed Title Renewed Facility Operating License Renewed Facility G19eFatiAg License Basis The license title is modified to eliminate the reference to "Operating." After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

License Condition 1.A Current License Condition 1.A Proposed License Condition 1.A The application for Renewed Operating License The application for Renewed G19emting No. DRP-20 complies with the standards and License No. DRP-20 complies with the requirements of the Atomic Energy Act of 1954, standards and requirements of the Atomic as amended (the Act), Energy Act of 1954, as amended (the Act),

and the Commission's rules and regulations set and the Commission's rules and regulations forth in 10 CFR Chapter I, and all required set forth in 10 CFR Chapter I, and all notifications to other agencies or bodies have required notifications to other agencies or been duly made; bodies have been duly made; Basis This license is modified to eliminate the reference to "Operating." After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

License Condition 1.B Current License Condition 1.8 Proposed License Condition 1. B Construction of the Palisades Plant (the facility) [deleted];

has been substantially completed in conformity with Provisional Construction Permit No.

CPPR-25, and the application, as amended, the provisions of the Act and regulations of the Commission, and has been operating under facility operating license since February 21, 1991; Basis This license condition is proposed for deletion in its entirety. Decommissioning of PNP is not dependent on the regulations that governed construction of the facility.

Enclosure to PNP 2021-005 Page 13 of 106 License Condition 1.D Current License Condition 1.D Pro~osed License Condition 1.D The facility will operate in conformity with the The facility will operate be maintained in application, the provisions of the Act, and the conformity with the application, the regulations of the Commission; provisions of the Act, and the regulations of the Commission; Basis This license condition is revised to reflect a more accurate description of the future requirements. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, replacing the verb "operate" with the verb "be maintained" will provide accuracy regarding the possession-only 10 CFR Part 50 license.

License Condition 1.E Current License Condition 1.E Pro~osed License Condition 1.E There is reasonable assurance (i) that the There is reasonable assurance (i) that the activities authorized by this renewed operating activities authorized by this renewed license can be conducted without endangering operating license can be conducted without the health and safety of the public, and (ii) that endangering the health and safety of the such activities will be conducted in compliance public, and (ii) that such activities will be with the Commission's regulations set forth in conducted in compliance with the 10 CFR Chapter I; Commission's regulations set forth in 10 CFR Chapter I; Basis This license condition is revised to reflect that after the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

License Condition 1.F Current License Condition 1.F Pro~osed License Condition 1. F Entergy Nuclear Palisades, LLC (ENP) is Entergy Nuclear Palisades, LLC (ENP) is financially qualified and Entergy Nuclear financially qualified and Entergy Nuclear Operations, Inc. (ENO) is financially and Operations, Inc. (ENO) is financially and technically qualified to engage in the activities technically qualified to engage in the authorized by this renewed operating license activities authorized by this renewed in accordance with the Commission's operating license in accordance with the regulations set forth in 10 CFR Chapter I; Commission's regulations set forth in 10 CFR Chapter I;

Enclosure to PNP 2021-005 Page 14 of 106 Basis This license condition is revised to reflect that after the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

License Condition 1.H Current License Condition 1.H Pro1;2osed License Condition 1. H The issuance of this renewed operating The issuance of this renewed opmatiAg license will not be inimical to the common license will not be inimical to the common defense and security or to the health and defense and security or to the health and safety of the public; safety of the public; Basis This license condition is revised to reflect that after the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

License Condition 1.1 Current License Condition 1.1 Pro1;2osed License Condition 1.1 After weighing the environmental, economic, After weighing the environmental, technical, and other benefits of the facility economic, technical, and other benefits of against environmental and other costs and the facility against environmental and other considering available alternatives, the costs and considering available alternatives, issuance of this renewed Facility Operating the issuance of this renewed Facility License No. DPR- 20, subject to the OperatiAg License No. DPR- 20, subject to conditions for the protection of the the conditions for the protection of the environment set forth herein, is in accordance environment set forth herein, is in with 10 CFR Part 51 (formerly Appendix D to accordance with 10 CFR Part 51 (formerly Part 50), of the Commission's regulations and Appendix D to Part 50), of the all applicable requirements have been Commission's regulations and all applicable satisfied; and requirements have been satisfied; and Basis This license condition is revised to reflect that after the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Enclosure to PNP 2021-005 Page 15 of 106 License Condition 1.J Current License Condition 1.J ProQosed License Condition 1.J The receipt, possession, and use of source, The receipt, possession, and use of source, byproduct, and special nuclear material as byproduct, and special nuclear material as authorized by this renewed operating license authorized by this renewed opOFating will be in accordance with 10 CFR Parts 30, license will be in accordance with 40, and 70. 10 CFR Parts 30, 40, and 70.

Basis This license condition is revised to reflect that after the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

License Condition 2 Current License Condition 2 ProQosed License Condition 2 Operating License No. DPR-20, dated GpeFating bisense No. QPR 2Q, ElateEl February 21, 1991, as amended, was i;:e1:m1ai:y 2~, QQ~, as amenEleEl, 1,Yas superseded in its entirety by Renewed Facility supeFseEleEl in its entiFety by Renewed Operating License No. DPR-20 (previously Facility GpeFating License No. DPR-20 issued to Consumers Energy Company), is (pFeviously issueEl to ConsumeFs EneFgy hereby issued to ENP and ENO as follows: Company), is hereby issued to ENP and ENO as follows:

Basis This license condition is revised to reflect that after the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

License Condition 2.8.(1)

Current License Condition 2.8.(1) ProQosed License Condition 2.8.(1)

Pursuant to Section 104b of the Act, as Pursuant to Section 104b of the Act, as amended, and 10 CFR Part 50, "Licensing of amended, and 10 CFR Part 50, "Licensing of Production and Utilization Facilities", (a) ENP to Production and Utilization Facilities", (a) ENP possess and use, and (b) ENO to possess, use to possess and use, and (b) ENO to possess, and operate, the facility as a utilization facility at and use anEl epeFate, the facility as-a-the designated location in Van Buren County, utilization fasility at the designated location in Michigan, in accordance with the procedures Van Buren County, Michigan, in accordance and limitation set forth in this license; with the procedures and limitation set forth in this license; Basis This license condition is revised to reflect that after the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Enclosure to PNP 2021-005 Page 16 of 106 License Condition 2.B.(2)

Current License Condition 2.8.{2) Pro12osed License Condition 2.8.{2)

ENO, pursuant to the Act and 10 CFR Parts ENO, pursuant to the Act and 10 CFR Parts 40 and 70, to receive, possess, and use 40 and 70, to reoei\*e, possess, and 1:1se source and special nuclear material as reactor source and special nuclear material that fuel, in accordance with the limitations for was used as reactor fuel, in accordance storage and amounts required for reactor with the limitations for storage and ame1:1nts operation, as described in the Updated Final req1:1ired fer reaoter eperatien, as described Safety Analysis Report, as supplemented and in the Updated Final Safety Analysis Report, amended; as supplemented and amended; Basis This license condition is revised to remove the authorization for receipt and use of special nuclear material (SNM) as reactor fuel, eliminate the reference to use of the SNM for reactor operations, and limit the possession of SNM to SNM "that was used" as reactor fuel at PNP.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As such, PNP has no need to receive SNM in the form of reactor fuel and cannot use SNM as reactor fuel for reactor operations. The continued authorization to possess SNM "that was used" as reactor fuel is necessary as PNP currently possesses the reactor fuel that was used for the past operations of the reactor.

License Condition 2.B.(3)

Current License Condition 2.8{3) Pro12osed License Condition 2.8.(3}

ENO pursuant to the Act and 10 CFR Parts 30, ENO pursuant to the Act and 10 CFR Parts 40 and 70, to receive, possess, and use 30, 40 and 70, to receive, possess, and use byproduct, source, and special nuclear material byproduct, source, and special nuclear as sealed sources for reactor startup, reactor material as sealed sources that were used instrumentation, radiation monitoring for reactor startup, sealed sources that equipment calibration, and fission detectors in were used for reactor instrumentation, and amounts as required; are used in the calibration of radiation monitoring equipment oalibratien, and that were used as fission detectors in amounts as required;

Enclosure to PNP 2021-005 Page 17 of 106 Basis This license condition is revised to remove the authorization for receipt and use of byproduct, source, and SNM as sealed neutron sources for reactor startup, reactor instrumentation, and fission detectors. This deletion is consistent with the fact that PNP will no longer be authorized to operate.

The authorization to possess such sources previously used for reactor startup, reactor instrumentation and fission detectors is retained and is consistent with the safe storage of byproduct, source, and SNM. The use of sources for radiation monitoring will continue to be required.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel, in accordance with 10 CFR 50.82(a)(2). These changes are consistent with the permanently defueled condition.

License Condition 2.B.(5)

Current License Condition 2.8(5) Pro12osed License Condition 2.B.(5)

ENO pursuant to the Act and 10 CFR Parts ENO pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials such byproduct and special nuclear as may be produced by the operations of the materials as may be-that were produced by facility. the operations of the facility.

Basis This license condition is revised to reflect that after the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

License Condition 2.C Current License Condition 2.C Pro12osed License Condition 2.C This renewed operating license shall be This renewed operating license shall be deemed to contain and is subject to the deemed to contain and is subject to the conditions specified in the Commission's conditions specified in the Commission's regulations of 10 CFR Chapter I and is subject regulations of 10 CFR Chapter I and is to all applicable provisions of the Act; to the subject to all applicable provisions of the Act; rules, regulations, and orders of the to the rules, regulations, and orders of the Commission now or hereafter in effect; and is Commission now or hereafter in effect; and is subject to the additional conditions specified subject to the additional conditions specified or incorporated below: or incorporated below:

Basis This license condition is revised to reflect that after the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Enclosure to PNP 2021-005 Page 18 of 106 License Condition 2.C.(1)

Current License Condition 2.C.{1} Pro12osed License Condition 2.C.{1}

ENO is authorized to operate the facility at [deleted]

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.

Basis This license condition is deleted in its entirety to reflect the permanently defueled condition of the facility. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

License Condition 2.C.(2)

Current License Condition 2.C.{2} Pro12osed License Condition 2.C.{2}

The Technical Specifications contained in The Technical Specifications contained in Appendix A, as revised through Amendment Appendix A, as revised through Amendment No. 271, and the Environmental Protection No. a74XXX, and the Environmental Plan contained in Appendix B are hereby Protection Plan contained in Appendix B are incorporated in the license. ENO shall operate hereby incorporated in the license. ENO shall the facility in accordance with the Technical eperate maintain the facility in accordance Specifications and the Environmental with the Technical Specifications and the Protection Plan. Environmental Protection Plan.

Basis This license condition is revised to replace the verb "shall operate" with the verb "shall maintain" to better describe the permanently defueled condition. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). The current amendment number, 271, is deleted and replaced with "XXX" which acts as a placeholder for the new amendment number associated with the approval of this LAR.

Enclosure to PNP 2021-005 Page 19 of 106 License Condition 2.C.(3), Fire Protection Current License Condition 2.C.(3) Proposed License Condition 2.C.(3)

ENO shall implement and maintain in effect all [deleted]

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 requests dated December 12, 2012, November 1, 2017, November 1, 2018, and March 8, 2019, as supplemented by letters dated February 21, 2013, September 30, 2013, October 24, 2013, December 2, 2013, April 2, 2014, May 7, 2014, June 17, 2014, August 14, 2014, November 4, 2014, December 18, 2014, January 24, 2018, and May 28, 2019, as approved in the safety evaluations dated February 27, 2015, February 27, 2018, and August 20, 2019.

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 ... .[for entirety of text proposed for deletion, see Attachment 1] ... will be completed once the related modifications are installed and validated in the PRA model.

Enclosure to PNP 2021-005 Page 20 of 106 Basis This license condition provides extensive guidance for implementation of a fire protection program that complies with 10 CFR 50.48(a) and 10 CFR 50.48(c), including requirements for risk informed changes that may be made without prior NRC approval, other changes that may be made without prior NRC approval, and transition license conditions. See Appendix A for the complete license condition. 10 CFR 50.48(a) and 10 CFR 50.48(c) apply to holders of operating licenses issued under Part 50. The conditions specified in 2.C.(3) include consideration of risk metrics for core damage frequency and large early release frequency, which are associated with power operation. This license condition, which is based on maintaining an operational fire protection program in accordance with 10 CFR 50.48, with the ability to achieve and maintain safe shut down of the reactor in the event of a fire, will no longer be applicable at PNP since, after the certifications required by 10 CFR 50.82(a)(1) are docketed, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Therefore, License Condition 2.C.(3) is deleted to reflect the permanently defueled condition of the facility.

Licensees that have submitted the certifications required under 10 CFR 50.82(a)(1) shall maintain a fire protection program to address the potential for fires that could cause the release or spread of radioactive materials (i.e., that could result in a radiological hazard). This regulation is applicable regardless of whether a requirement for a fire protection program is included in the facility license. Consequently, the PNP fire protection program will be revised in accordance with 10 CFR 50.48(f) to reflect decommissioning facility conditions and activities. The fire protection program revision will include many of the elements that are applicable for the operating plant fire protection program, and will continue to utilize the defense-in-depth concept, placing special emphasis on detection and suppression in order to minimize radiological releases to the environment.

License Condition 2.C.(4)

Current License Condition 2.C.(4} Proi2osed License Condition 2.C.(4}

The following requirements shall apply to [deleted]

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 until the next entry into Mode 3.

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

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

Enclosure to PNP 2021-005 Page 21 of 106 Basis This license condition is deleted in its entirety. The license condition was applicable in PNP cycle 25, which was completed on May 17, 2017 and is, therefore, historical. Additionally, after the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2), thus eliminating the need for control rod drives in the reactor.

License Condition 2.C.(5)

Current License Condition 2.C.(5} Pro12osed License Condition 2.C.(5}

[deleted] Movement of a fuel cask in or over the spent fuel pool is prohibited when irradiated fuel assemblies decayed less than 90 days are in the spent fuel pool.

Basis A new license condition is added to prohibit movement of a fuel cask in or over the spent fuel pool when irradiated fuel assemblies with less than 90 days decay time are in the spent fuel pool. TS 3.7.10, "Control Room Ventilation (CRV) Filtration," and TS 3.7.11, "Control Room Ventilation (CRV) Cooling," are required during movement of a fuel cask in or over the SFP; TS 3.7.12, "Fuel Handling Area Ventilation System," is required during movement of a fuel cask in or over the SFP when fuel assemblies with less than 90 days decay time are in the fuel handling building.

UFSAR Table 14.1-6 contains the radiological consequences of the UFSAR Chapter 14 events.

The table shows that for a postulated cask drop in the SFP, following a 90-day spent fuel decay time, offsite and control room radiological doses are maintained within regulatory limits without the use of CRV filtration, CRV cooling, or fuel handling area ventilation and its associated filtration.

TS 3.7.10, TS 3.7.11, and TS 3.7.12 are proposed for deletion. New License Condition 2.C.(5) is added to ensure the 90-day spent fuel assembly decay time requirement is maintained and the associated analyses presented in UFSAR Table 14.1-6 remains bounding.

Enclosure to PNP 2021-005 Page 22 of 106 License Condition 2.C.(7), CONTROL ROOM ENVELOPE HABITABILITY Current License Condition 2.C.(7) Proposed License Condition 2.C.(7)

Upon implementation of Amendment 230 adopting [deleted]

TSTF-448, revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.10.4, in accordance with TS 5.5.16.c.(i), the assessment of CRE habitability as required by Specification 5.5.16.c.(ii), and the measurement of CRE pressure as required by TS 5.5.16.d, shall be considered met. Following implementation:

(a) The first performance of SR 3. 7 .10.4, in accordance with TS 5.5.16.c.(i), shall be within the specified Frequency of six years, plus the 18-month allowance of SR 3.0.2, as measured from June 26, 2007, the date of the most recent successful tracer gas test, as stated in the August 16, 2007, letter response to Generic Letter 2003-01.

(b) The first performance of the periodic assessment of CRE habitability, Specification 5.5.16.c.(ii), shall be within three years, plus the nine-month allowance of SR 3.0.2, as measured from June 26, 2007, the date of the most recent successful tracer gas test, as stated in the August 16, 2007, letter response to Generic Letter 2003-01.

(c) The first performance of the periodic measurement of CRE pressure, Specification 5.5.16.d, shall be within 18 months, plus the 138 days allowed by SR 3.0.2, as measured from July 16, 2007, the date of the most recent successful pressure measurement test.

Basis This license condition is deleted in its entirety. The license condition contains schedular requirements for the first performance of CRE unfiltered air inleakage testing, assessment of CRE habitability, and measurement of CRE pressure. This is a historical license condition, because the test, assessment, and measurement were completed in accordance with the schedule specified in the license condition.

Enclosure to PNP 2021-005 Page 23 of 106 License Condition 2.C.(8)

Current License Condition 2.C.(8} Proposed License Condition 2.C.(8}

Amendment 257 authorizes the [deleted]

implementation of 10 CFR 50.61a in lieu of 10 CFR 50.61.

Basis This license condition is deleted in its entirety to reflect the permanently shut down and defueled condition of the facility. 10 CFR 50.61a, Fracture toughness requirements for protection against pressurized thermal shock events, does not apply to facilities for which the certifications required under 10 CFR 50.82(a)(1) have been submitted.

License Condition 2.D Current License Condition 2.D Proposed License Condition 2.D The facility has been granted certain [deleted]

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, scheduled 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.

Basis

• This license condition is deleted in its entirety to reflect the permanently shut down and defueled condition of the facility. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, the containment will not play a role in mitigating the consequences of the remaining DBAs discussed in Section 3.0 of this Enclosure.

Enclosure to PNP 2021-005 Page 24 of 106 License Condition 2.H Current License Condition 2.H Pro~osed License Condition 2.H (a) The Updated Safety Analysis Report [deleted]

supplement, as revised, submitted pursuant to 10 CFR 54.21(d), shall be included in the next scheduled update to the Updated Safety Analysis Report required by 10 CFR 50.71(e)(4) following issuance of this renewed operating license. Until that update is complete, ENO may make changes to the programs and activities described in the supplement without prior Commission approval, provided that ENO evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements of that section.

Basis This license condition is historical and will be deleted in its entirety. The license condition became effective with the issuance of the RFOL on January 17, 2007 and required that the UFSAR be supplemented per 10 CFR 50.21(d) to incorporate descriptions of programs and activities credited for managing the effects of aging, and of the evaluation of the time-limited aging analysis. This information has been added to the UFSAR as requested. The actions required by this license condition have been completed and the license condition can, therefore, be deleted.

License Condition 2.1 Current License Condition 2.1 Pro~osed License Condition 2.1 The Updated Safety Analysis Report [deleted]

supplement, as revised, describes certain future activities to be completed prior to the period of extended operation. ENO shall complete these activities no later than March 24, 2011, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

Basis This license condition is historical and will be deleted in its entirety. The license condition required certain actions be completed prior to the period of extended operation. Entergy confirmed completion of actions to support entry into the period of extended operation in a letter to NRC dated March 23, 2011 (Reference 7). Therefore, the actions required by this license condition have been completed and the license condition can be deleted.

Enclosure to PNP 2021-005 Page 25 of 106 License Condition 2.J Current License Condition 2.J Pro12osed License Condition 2.J All capsules in the reactor vessel that are [deleted]

removed and tested must meet the test procedures and reporting requirements of American Society for Testing and Materials (ASTM) E 185-82 to the extent practicable for the configuration of the specimens in the capsule. Any changes to the capsule withdrawal scheduled, including spare capsules, must be approved by the NRC prior to implementation. All capsules placed in storage must be maintained for future insertion. Any changes to storage requirements must be approved by the NRC, as required by 10 CFR Part 50, Appendix H.

Enclosure to PNP 2021-005 Page 26 of 106 Basis 10 CFR 50 Appendix H requires that the design of the reactor vessel surveillance capsule program and withdrawal schedule must meet the requirements in the version of ASTM Standard Practice E 185 that is current on the issue date of the American Society of Mechanical Engineers (ASME) Code to which the reactor pressure vessel (RPV) was purchased. The rule also requires the licensee to perform capsule testing and to report the test results in accordance with the requirements in ASTM Standard Practice E 185-82 to the extent practicable for the configuration of the test specimens in the RPV surveillance capsules.

The requirements in Appendix H are only applicable to nuclear plants that are performing power operations in the reactor critical operating mode because: (a) this is the plant operating mode that produces high energy neutrons as a result of the reactor's nuclear fission process; and (b) the requirements are set in place to provide assurance that the RPV will maintain adequate levels of fracture toughness throughout the operating life of the reactor.

Continued implementation of the applicable surveillance capsule testing and reporting requirements are no longer necessary for PNP because: (a) Entergy has decided to cease power operations of PNP; and (b) from a fracture toughness perspective, the PNP RPV will cease to be exposed to further irradiation by high energy neutrons or subjected to any high thermal stress environments, as induced by operating the reactor coolant system at an elevated temperature.

The physical and radiological control of the remaining surveillance capsules that are located in the RPV will be managed in accordance with the applicable radiological control requirements of 10 CFR Part 20 and with any applicable security or physical protection requirements for components in either 10 CFR Part 37, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material, or 10 CFR Part 73, Physical Protection of Plants and Materials. Therefore, the removal, testing, reporting, and storage requirements for reactor vessel surveillance capsules and their test specimens do not need to be implemented further after PNP permanently ceases power operations because there will no longer be any need to remove the remaining surveillance capsules from the RPV or perform material testing of the test specimens in those capsules. As such, deletion of this license condition is appropriate. Any corresponding commitments in the PNP UFSAR will also be deleted under the provisions of 10 CFR 50.59 upon NRG approval of this change.

License Condition 2.K Current License Condition 2.K Proi;2osed License Condition 2.K This license is effective as of the date of This license is effective as of the date of issuance and shall expire at midnight March issuance and shall expiFe at midnight March 24, 2031. 24, 2031.until the Commission notifies the licensee in writing that the license is terminated.

Enclosure to PNP 2021-005 Page 27 of 106 Basis After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, this license condition is revised to conform with 10 CFR 50.51, Continuation of license, in that the license authorizes ownership and possession by Entergy until the Commission notifies the licensee in writing that the license is terminated.

ATTACHMENTS AND DATE OF ISSUANCE Current Attachments and Date of Issuance Proposed Attachments and Date of Issuance Appendix A - Technical Specifications ... Appendix A - Permanently Defueled Technical Specifications ...

Date of Issuance: January 17, 2007 Date of Issuance: January 17, 2007 XXX XX, 20XX Basis The title of Appendix A is updated to reflect that the Technical Specifications will be retitled as the Permanently Defueled Technical Specifications. The date of issuance is modified to reflect the date that the NRC issues the amendment associated with this LAR, which is yet to be determined. These are administrative changes.

APPENDIX A TITLE PAGE Current Title Proposed Title PALISADES PLANT PALISADES PLANT RENEWED FACILITY OPERATING LICENSE RENEWED FACILITY GPe~+ING LICENSE DPR-20 DPR-20 APPENDIX A APPENDIX A TECHNICAL SPECIFICATIONS PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS Basis The title is modified to remove "Operating" and to add "Permanently Defueled" before "Technical Specifications" to reflect that PNP will be permanently shut down and defueled.

After the certifications required by 10 CFR 50.82(a)(1) are docketed, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with to 10 CFR 50.82(a)(2).

Enclosure to PNP 2021-005 Page 28 of 106 TS SECTION 1.1, DEFINITIONS TS 1.1, Definitions, provides defined terms that are applicable throughout the TS and TS Bases.

The following Definitions are proposed to be deleted because they have no relevance to, and no longer apply to, the permanently defueled facility status.

Definition Basis for Change AVERAGE DISINTEGRATION This definition is proposed for deletion because the ENERGY-I= term is not used in any POTS specification. This term is no longer applicable since fuel will be permanently removed from the reactor core.

AXIAL OFFSET (AO) This definition is proposed for deletion because the term is not used in any POTS specification. This term is no longer applicable since fuel will be permanently removed from the reactor core.

AXIAL SHAPE INDEX (ASI) This definition is proposed for deletion because the term is not used in any POTS specification. This term is no longer applicable since fuel will be permanently removed from the reactor core.

CHANNEL CALIBRATION This definition is proposed for deletion because the term is not used in any POTS specification. There is no instrumentation credited in the analysis of the accidents that remain in the permanently defueled condition.

CHANNEL CHECK This definition is proposed for deletion because the term is not used in any POTS specification. There is no instrumentation credited in the analysis of the accidents that remain in the permanently defueled condition.

CHANNEL FUNCTIONAL TEST This definition is proposed for deletion because the term is not used in any POTS specification. There is no instrumentation credited in the analysis of the accidents that remain in the permanently defueled condition.

CORE ALTERATION This definition is proposed for deletion because the term is not used in any POTS specification. This term is no longer applicable since fuel will be permanently removed from the reactor core.

CORE OPERATING LIMITS REPORT This definition is proposed for deletion This term (COLR) is no longer applicable since fuel will be permanently removed from the reactor core.

TS 5.6.5, which requires the COLR, is also proposed for elimination.

Enclosure to PNP 2021-005 Page 29 of 106 DOSE EQUIVALENT 1-131 This definition is proposed for deletion because the term is not used in any POTS specification. This term is used in current TS 3.7.17 to express the specific activity limit from a mixture of iodine isotopes contained in reactor coolant and secondary coolant.

TS 3.7.17 is proposed for deletion in the POTS. The specific activity limit is used as the basis in accident analysis involving coolant releases. Since accident conditions associated with the PCS and secondary coolant system will no longer apply to the permanently shut down and defueled facility, the definition is no longer applicable.

INSERVICE TESTING PROGRAM This definition is proposed for deletion because the term is not used in any POTS specification.

lnservice testing in accordance with 10 CFR 50.55a will no longer be required once the reactor is permanently shut down and defueled.

LEAKAGE This definition is proposed for deletion because the term is not used in any POTS specification. Refer to the discussions for the proposed deletion of TS 3.4.13 and TS 5.5.8.

MODE This definition, including Table 1.1-1, is proposed for deletion because operational MODES are not used in any POTS specification. MODES as defined in Table 1.1-1 are applicable to operating or refueling conditions. This term does not apply to a facility in the permanently defueled condition.

OPERABLE-OPERABILITY This definition is proposed for deletion because the term is not used in any POTS specification. There are no systems or components required to be operable in the POTS because there are no active systems, structures or components required to perform specified safety functions to mitigate any of the remaining DBAs.

PHYSICS TESTS This definition is proposed for deletion because the term is not used in any POTS specification. This definition only applies to an operating reactor core.

QUADRANT POWER TILT RATIO (Tq) This definition is proposed for deletion because the term is not used in any POTS specification. This definition only applies to an operating reactor core.

RATED THERMAL POWER (RTP) This definition is proposed for deletion because the term is not used in any POTS specification. This term is meaningful only to a reactor authorized to contain fuel and operate at power. It does not apply to a facility in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 30 of 106 REFUELING BORON This definition is proposed for deletion because the CONCENTRATION term is not used in any POTS specification. This term is meaningful only to a reactor authorized to contain fuel and operate at power. It does not apply to a facility in the permanently defueled condition.

SHUTDOWN MARGIN (SOM) This definition is proposed for deletion because the term is not used in any POTS specification . This term is applicable only to a reactor authorized to contain fuel and operate at power. It does not apply to a facility in the permanently defueled condition.

STAGGERED TEST BASIS This definition is proposed for deletion because the term is not used in any POTS specification. This definition applies to the performance of surveillance tests on systems with multiple subsystems or channels. There are no surveillance requirements in the POTS for SSCs with multiple subsystems or channels.

THERMAL POWER This definition is proposed for deletion because the term is not used in any POTS specification. This term is applicable only to a reactor authorized to contain fuel and operate at power. It does not apply to a facility in the permanently defueled condition.

TOTAL RADIAL PEAKING This definition is proposed for deletion because the FACTOR (FRT) term is not used in any POTS specification. This definition is proposed for deletion because the term is not used in any POTS specification. This term is applicable only to a reactor authorized to contain fuel and operate at power. It does not apply to a facility in the permanently defueled condition.

TS SECTION 1.2, LOGICAL CONNECTORS TS 1.2, Logical Connectors, explains how the arrangement of these connectors constitutes logical conventions with specific meanings. The proposed modifications reflect the logical connectors that will remain in the POTS.

Current PURPOSE Proposed PURPOSE Logical connectors are used in Technical Logical connectors are used in Technical Specifications (TS) to discriminate between, Specifications (TS) to discriminate between, and yet connect, discrete Conditions, and yet connect, discrete Conditions, Required Actions, Completion Times, Required Actions, Completion Times, Surveillances, and Frequencies. The only Surveillances, and Frequencies. The only logical connectors that appear in TS are AND logical connectors that appears in TS are is and OR. The physical arrangement of these AND and OR. The physical arrangement of connectors constitutes logical conventions tAese this connectors constitutes logical with specific meanings. conventions with specific meanings.

Enclosure to PNP 2021-005 Page 31 of 106 Current BACKGROUND Proposed BACKGROUND Several levels of logic may be used to state Se1.i0Fal I01.iels Levels of logic may be used to Required Actions. These levels are identified by state Required Actions. These levels are the placement ( or nesting) of the logical identified by the placement ( or nesting) of the connectors and by the number assigned to logical connectors and by the number each Required Action. The first level of logic is assigned to each Required Action. The first identified by the first digit of the number level of logic is identified by the first digit of the assigned to a Required Action and the number assigned to a Required Action and the placement of the logical connector in the first placement of the logical connector in the first level of nesting (i.e., left justified with the level of nesting (i.e., left justified with the number of the Required Action). The number of the Required Action). +Re-successive levels of logic are identified by s1:1ssessi¥e le¥els ef legis aFe iEleAti:fieEI ey additional digits of the Required Action number aEIElitieAal Eligits ef tl=te Req1:1iFOEI iA,stieA and by successive indentions of the logical Al:lmeeF aAEI ey 61:166essi1.ie iAEIOAtieAS ef tl=te connectors. legisal 68AA06t8F6.

When logical connectors are used to state a Wl=teA legisal seAAesteFs aFe 1:1seEI te state a Condition, Completion Time, Surveillance, or GeAElitieA, Gem~letieA +ime, S1:1FYeillaAse, eF Frequency, only the first level of logic is used, i;:Feq1:1eAsy, eAly tl=te :fiFSt le¥el ef legis is 1:1s0EI, and the logical connector is left justified with the aAEI tl=te legisal seAAesteF is left j1:1sti:fieEI 14'.iitl=t statement of the Condition, Completion Time, tl=te statemeAt ef tl=te GeAElitieA, Gem~letieA Surveillance, or FreQuencv. T:- ,_

C' ,_ -:~1---- _ _. C'.-.--

~.

Current EXAMPLES Proposed EXAMPLES The following examples illustrate the use of The following examples illustrates the use logical connectors ... of logical connectors ...

EXAMPLE 1.2-1 REQUIRED ACTION EXAMPLE 1.2-1 REQUIRED ACTION A.1 Verify ... A.1 Vefify-Suspend ...

AND AND A.2 Restore ... A.2 ResteFO Initiate ...

EXAMPLE 1.2-2 ... EXAMPLE 1.2-2 is proposed for deletion.

Basis This section is modified to reflect the logical connectors utilized in TS 3.7.14, TS 3.7.15, and TS 3.7.16. These are the only TS that utilize logical connectors in the POTS. The Required Actions of Example 1.2-1 are changed to "Suspend" and "Initiate" to more closely align with TS remaining in the POTS. Example 1.2-2 is deleted since it pertains to logical connectors that are no lonoer used in the PDTS. These chanoes are administrative chanoes.

TS SECTION 1.3, COMPLETION TIMES TS 1.3, Completion Times, establishes the Completion Time convention and provides guidance for its use. It is modified to reflect the permanently shut down and defueled condition and the Completion Times that remain in the POTS.

Enclosure to PNP 2021-005 Page 32 of 106 Current BACKGROUND Proposed BACKGROUND Limiting Conditions for Operation (LCOs) Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring specify minimum requirements for ensuring safe operation of the plant. safe operation of the plant storage and handling of spent nuclear fuel.

The Background section of TS 1.3 is modified to reflect that PNP will be permanently shut down and defueled. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, the primary mission will change from the safe operation of the unit to the safe handling and storage of spent nuclear fuel.

Current DESCRIPTION Proposed DESCRIPTION The Completion Time is the amount of time The Completion Time is the amount of time allowed for completing a Required Action. It is allowed for completing a Required Action. It referenced to the discovery of a situation (e.g., is referenced to the discovery of a situation inoperable equipment or variable not within (e.g., inoperable equipment or variable not limits) that requires entering an ACTIONS within limits) that requires entering an Condition unless otherwise specified, providing ACTIONS Condition unless otherwise the plant is in a MODE or specified condition specified, providing the plamfacility is in a stated in the Applicability of the LCO. MODE or specified condition stated in the Applicability of the LCO.

Unless otherwise specified, the Completion time Unless otherwise specified, the The begins when a senior licensed operator on the Completion time begins when a senior operating shift crew with responsibility for plant licensed operator Certified Fuel Handler operations makes the determination that an LCO (CFHJ on the operating shift crew with is not met and an ACTIONS Condition is responsibility for f3laAt facility operations entered. The "otherwise specified ... .[for entirety makes the determination that an LCO is not of text, see Attachment 1] ... are satisfied. met and an ACTIONS Condition is entered.

The "otherwise specified ... .[for entirety of text proposed for deletion, see Attachment 1] ... are satisfied.

Required Actions must be completed prior to Required Actions must be completed prior to the expiration of the specified Completion the expiration of the specified Completion Time. An ACTIONS Condition remains in Time. An ACTIONS Condition remains in effect and the Required Actions apply until effect and the Required Actions apply until the Condition no longer exists or the plant is the Condition no longer exists or the plaRt-not within the LCO Applicability. facility is not within the LCO Applicability.

If situations are discovered ... [for entirety of text, If situations are disco*,ered.[for entirety of see Attachment 1] ... Example 1.3-3 may not be text proposed for deletion, see Attachment extended. 1]. .. Example 1.3 3 may not be extended.

Enclosure to PNP 2021-005 Page 33 of 106 Basis The Description section of TS 1.3 is modified to reflect that PNP will be permanently shut down and defueled. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

As a result, the PDTS will contain no operability requirements for any equipment and Completion Time rules are simplified to reflect the remaining TS LCOs. In addition, the term "facility" better represents PNP in the permanently shut down and defueled condition. "Senior licensed operator" and "operating shift crew" are replaced with "Certified Fuel Handler (CFH)"

and "shift crew," respectively, to ali~:m with terminoloav used in Amendment 266. (Reference 6)

Current EXAMPLES Proposed EXAMPLE The following examples illustrate the use of The following examples illustrates the use Completion Times with different types of of Completion Times with different types of Conditions and changing Conditions. Conditions and changing Conditions Required Actions.

EXAMPLE 1.3-1 ... [for entirety of text for EXAMPLE 1.3-1 is modified to address examples 1.3-1 through 1.3-7, see Attachment Completion Times as utilized by TS

1) ... 3.7.14, TS 3.7.15, and TS 3.7.16. See Attachment 1 for proposed changes.

EXAMPLE 1.3-2 .. . EXAMPLE 1.3-2 is proposed for deletion.

EXAMPLE 1.3-3 .. . EXAMPLE 1.3-3 is proposed for deletion.

EXAMPLE 1.3-4 .. . EXAMPLE 1.3-4 is proposed for deletion.

EXAMPLE 1.3-5 .. . EXAMPLE 1.3-5 is proposed for deletion.

EXAMPLE 1.3-6 .. . EXAMPLE 1.3-6 is proposed for deletion.

EXAMPLE 1.3-7 .. . EXAMPLE 1.3-7 is proposed for deletion.

This section is modified to reflect the use of Completion Times that are utilized in TS 3.7.14, TS 3.7.15, and TS 3.7.16. These are the only TS that have Completion Times in the PDTS.

These changes to the Examples section of TS 1.3 are administrative changes.

Enclosure to PNP 2021-005 Page 34 of 106 TS SECTION 1.4, FREQUENCY TS 1.4, Frequency, defines the proper use and application of Frequency requirements. It is modified to reflect the permanently shut down and defueled condition and the Frequencies that remain in the POTS.

Current DESCRIPTION Proposed DESCRIPTION

... The "specified Frequency" is referred to ... The "specified Frequency" is referred to throughout this section and each of the throughout this section and each of the Specifications of Section 3.0, Surveillance Specifications of Section 3.0, Surveillance Requirement (SR) Applicability. The "specified Requirement (SR) Applicability. The "specified Frequency" consists of the requirements of the Frequency" consists of the requirements of the Frequency column of each SR, as well as Frequency column of each SR, as well as certain Notes in the Surveillance column that seFtaiR Netes iR tl=te S1.1F¥eillaRse sel1.1FRR tl=tat modify performance requirements. medify perfermaRse req1.1iremeRts.

Sometimes special situations dictate when the Semetimes spesial sit1.1atieRs distate wl=teR tl=te requirements of a Surveillance are to be met. req1.1iremeRts ef a S1.1F¥eillaRse are ta Be met.

They are "otherwise stated" conditions allowed +l=tey are "etl=terwise stated" seRditieRs allewed by SR 3.0.1. They may be stated as clarifying By SR :HU. +l=tey may Be stated as slari~tiRg Notes in the Surveillance, as part of the Netes iR tl=te S1.1F¥eillaRse, as paFt ef tl=te Surveillances, or both. S1.1F¥eillaRses, er Betl=t.

Situations where a Surveillance could be Sit1.1atieRs wl=tere a S1.1F\teillaRse se1.1ld Be required (i.e., its Frequency could expire), but req1.1ired (i.e., its r;:req1.1eRsy se1.1ld e*pire), Bl.It where it is not possible or not desired that it be wl=tere it is Rat f:)essiBle er Rat desired tl=tat it Be performed until sometime after the associated f:)erfermed 1.1Rtil semetime after tl=te assesiated LCO is within its Applicability, represent bGG is 1*1.<itl=tiR its Apf:)lisaBili~t, represeRt potential SR 3.0.4 conflicts. To avoid these peteRtial SR a.Q.4 seRflists. +a a1.<eid tl=tese conflicts, the SR (i.e., the Surveillance or the seRflists, tl=te SR (i.e., tl=te S1.1F¥eillaRse er tl=te Frequency) is stated such that it is only r;:req1.1eRsy) is stated s1.1sl=t tl=tat it is eRly "required" when it can be and should be "req1.1ired" 11,tl=teR it saR Be aRd sl=te1.1ld Be performed. With an SR satisfied, SR 3.0.4 perfermed. ),OJitl=t aR SR satisfied, SR imposes no restriction. 3:G:4- imf:)eses Re restristieR .

... Some Surveillances contain notes that ... Same S1.1F¥eillaRses seRtaiR Rates tl=tat modify the Frequency of performance or the medify tl=te J;:req1.1eRsy ef perfermaRse er tRe conditions during which the acceptance seRditieRs d1.1riRg wRisR tRe assef:)taRse criteria must be satisfied. For these sriteria m1.1st se satisfied. J;:er tRese Surveillances, the MODE-entry restrictions S1.1ri.<eillaRses, tRe MG9e: eRtry restristieRs of SR 3.0.4 may not apply. Such a ef SR a.Q.4 may Ret apply. S1.1sR a Surveillance is not required to be S1.1ri.<eillaRse is Ret req1.1ireel te se performed prior to entering a MODE or perfermed 13rier te eRteriRg a MG9e: er other specified condition in the Applicability etRer spesified seRditieR iR tRe Applisasility of the associated LCO is any of the ef tRe assesiated bGG is aRy ef tRe following three conditions are satisfied: fellewiRg tRree seRditieRs are satisfied:

a. The Surveillance is not required to be a. +Re S1.1F¥eillaRse is Ret req1.1ired te se met in the MODE or other specified met iR tRe MG9e: er etRer spesified condition to be entered; or seRditieR te se eAtered; er

b. The Surveillance is required to be met 13. +Re S1.1F¥eillaRse is req1.1ired te se met in the MODE or other specified iR tRe MG9e: er etRer spesified condition to be entered, but has been seRaitieR te ee eRtereel, e1.1t Ras seeR

Enclosure to PNP 2021-005 Page 35 of 106 performed within the specified performed within the specified Frequency (i.e., it is current) and is F'.requenoy (i.e., it is current) and is known not to be failed; or knoi.*.in not to be failed; or

c. The Surveillance is required to be met, c. The SuF\<eillance is required to be met, but not performed, in the MODE or but not performed, in the MODE or other specified condition to be entered, other specified condition to be entered, and is not known to be failed. and is not kno'l.in to be failed.

Examples 1.4-3, 1.4-4, 1.4-5, and 1.4-6 E*amples 1.4 3, 1.4 4, 1.4 5, and 1.4 6 discuss these special situations. discuss those special situations.

Current EXAMPLES Proposed EXAMPLE The following examples illustrate the various The following examples illustrate the various ways that Frequencies are specified. In these ways that F'.requensios are specified. In examples, the Applicability of the LCO (LCO these e:>Eamples, the Applicability of the LCO not shown) is MODES 1, 2, and 3. {bGG net shewn) is MODES 1, 2, and 3 illustrate the type of Frequency statement that appears in the Technical Specifications (TS).

Example 1.4-1 ... [for entirety of text for Example 1.4-1 is modified to address examples 1.4-1 through 1.4-6, see Frequencies as utilized by TS 3.7.14, and Attachment 1) ... TS 3.7.15. See Attachment 1 for proposed changes.

Example 1.4-2 ... Example 1.4-2 is modified to address Frequencies as utilized by TS 3.7.16. See Attachment 1 for proposed changes Example 1.4-3 .. . Example 1.4-3 is proposed for deletion.

Example 1.4-4 .. . Example 1.4-4 is proposed for deletion.

Example 1.4-5 .. . Example 1.4-5 is proposed for deletion.

Example 1.4-6 .. . Example 1.4-6 is proposed for deletion.

The Description section of TS 1.4 is modified to reflect that PNP will be permanently shut down and defueled. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

As a result, the number and types of Surveillance Requirements that remain in the POTS are limited to those in TS 3. 7 .14, TS 3. 7 .15, and TS 3. 7 .16. This section is modified to provide the rules of usage and examples that continue to be applicable for those TS.

Enclosure to PNP 2021-005 Page 36 of 106 TS SECTION 2.0, SAFETY LIMITS (SLS)

TS Section 2.0 contains safety limits that are necessary to reasonably protect the integrity of certain physical barriers that guard against the uncontrolled release of radioactivity from the reactor core and the primary coolant system (PCS) in accordance with 10 CFR 50.36(c)(1).

TS Section 2.0 is proposed for deletion in its entirety, since the safety limits do not apply to a reactor that is in a permanently defueled condition.

The TS will not be renumbered, therefore, a mark-up is provided to identify the section as deleted.

Current TS 2.0 Proposed TS 2.0 TS 2.0 SAFETY LIMITS (SLs) TS 2.0 SAFETY LIMITS (Sbs) (Deleted)

TS 2.0 is proposed for deletion in its entirety.

The restrictions of TS 2.1.1, "Reactor Core SLs," prevent overheating of the fuel and possible cladding perforation which would result in the release of fission products to the reactor coolant.

It is applicable in MODES 1 and 2. Since TS 2.1.1 applies to an operating reactor, its restrictions have no function in the permanently defueled condition.

The restriction of TS 2.1.2, "Primary Cooling System (PCS) Pressure SL," protects the PCS from over-pressurization and thereby prevents the release of radionuclides contained in the reactor coolant from reaching the containment atmosphere. It is applicable in MODES 1 through 6. Since TS 2.1.2 applies to maintaining the PCS pressure, its restriction has no function in the permanently defueled condition.

In 2.2, "SL Violations," TS 2.2.1 defines the action to take if SL 2.1.1 is not met. It requires the unit to be placed in MODE 3. TS 2.2.2 defines the action to take if SL 2.1 .2 is not met. If the unit is in MODE 1 or 2, it requires the unit to be placed in MODE 3. If the unit is MODE 3, 4, 5, or 6, it requires compliance to be restored within five minutes.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). The safety limits and safety limit violations TS apply to an operating reactor and the PCS, they have no function in the permanently defueled condition. These specifications do not apply to the safe storage and handling of spent fuel in the SFP.

Enclosure to PNP 2021-005 Page 37 of 106 TS SECTION 3.0, LIMITING CONDITIONS FOR OPERATION (LCO)

TS Section 3.0 contains the general requirements applicable to all Limiting Conditions for Operation (LCOs) and applies at all times unless otherwise stated in a TS. Proposed revisions to the PNP TS (including those proposed for deletion) are described below. The corresponding TS Bases are also being revised to reflect these changes.

A mark-up of this section is provided in Attachment 1.

Current LCO 3.0.1 Proposed LCO 3.0.1 LCOs shall be met during the MODES or other LCOs shall be met during the MODES er ether specified conditions in the Applicability, except specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9. 3.0.8, aREI LCO 3.0.Q.

Basis MODES as defined in Table 1.1-1 apply to operating or refueling conditions. This term does not apply to a facility in the permanently shut down and defueled condition. MODES are not used in any POTS specification. Thus, the reference to MODES is deleted.

In addition, the references to LCOs 3.0.7, LCO 3.0.8, and 3.0.9 are deleted to reflect the proposed deletion of those LCOs as discussed below.

Current LCO 3.0.2 Proposed LCO 3.0.2 Upon discovery of a failure to meet an LCO, Upon discovery of a failure to meet an LCO, the Required Actions of the associated the Required Actions of the associated Conditions shall be met, except as provided in Conditions shall be met, e:,mept as pre 1,iEleEI iR LCO 3.0.5 and LCO 3.0.6. LCO 3.0.5 aREI LCO 3.0.e.

Basis LCO 3.0.2 is modified by eliminating the references to LCOs 3.0.5 and 3.0.6. This change reflects the proposed deletion of those LCOs as discussed below.

Current LCO 3.0.3 Proposed LCO 3.0.3 When an LCO is not. .. [for entirety of text, see This LCO is proposed for deletion.

Attachment 1J Basis LCO 3.0.3 provides the actions that must be implemented when an LCO is not met. It is only applicable in MODES 1 through 4. In accordance with 10 CFR 50.82(a)(2), the facility license for PNP will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor. References to operating MODES will no longer be relevant. Thus, LCO 3.0.3 is no longer applicable in the permanently defueled condition.

Current LCO 3.0.4 Proposed LCO 3.0.4 When an LCO is not. .. [for entirety of text, see This LCO is proposed for deletion.

Attachment 1J

Enclosure to PNP 2021-005 Page 38 of 106 Basis LCO 3.0.4 provides limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. In accordance with 10 CFR 50.82(a)(2), the facility license for PNP will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor. References to operating MODES are no longer relevant. Thus, LCO 3.0.4 is no longer applicable in the permanently defueled condition.

Current LCO 3.0.5 Proposed LCO 3.0.5 Equipment removed from service ... [forentirety This LCO is proposed for deletion.

of text, see Attachment 1J Basis LCO 3.0.5 provides the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The allowance of LCO 3.0.5 to not comply with the requirements of LCO 3.0.2 (i.e.,

to not comply with the Required Actions) to allow the performance of SRs on equipment declared inoperable or removed from service is no longer required. The remaining permanently defueled TS ACTIONS do not include requirements to declare equipment inoperable or to remove it from service. Thus, LCO 3.0.5 is no longer applicable in the permanently defueled condition.

Current LCO 3.0.6 Proposed LCO 3.0.6 When a support system LCO is not met. .. [for This LCO is proposed for deletion.

entiretv of text, see Attachment 1J Basis LCO 3.0.6 addresses the actions required for a supported system when the support system LCO is not met. It is proposed for deletion since there are no supported system LCOs in the POTS.

Thus, LCO 3.0.6 is no longer applicable in the permanently defueled condition.

Current LCO 3.0.7 Proposed LCO 3.0.7 Special Test Exception (STE) LCOs ... [for This LCO is proposed for deletion.

entirety of text, see Attachment 11 Basis LCO 3.0.7 allows certain LCO exceptions when special tests are required to be performed at various times over the life of the unit. It is proposed for deletion since there are no special test exceptions required in the POTS. Thus, LCO 3.0.7 is no longer applicable in the permanently defueled condition .

Current LCO 3.0.8 Proposed LCO 3.0.8 When one or more required snubbers ... [for This LCO is proposed for deletion.

entirety of text, see Attachment 1J Basis LCO 3.0.8 addresses the actions required when one or more required snubbers are unable to perform their associated support function(s). It is proposed for deletion because, in the permanently defueled facility, snubbers will no longer be required to perform their associated support functions. Thus, LCO 3.0.8 is no longer applicable in the permanently defueled condition.

Current LCO 3.0.9 Proposed LCO 3.0.9 When one or more required barriers ... [for This LCO is proposed for deletion.

entirety of text, see Attachment 1)

Enclosure to PNP 2021-005 Page 39 of 106 Basis LCO 3.0.9 addresses the actions required when one or more required barriers are unable to perform their related support function(s). It is proposed for deletion, because there are no LCOs for equipment to be operable or in operation in the POTS. Thus, barriers are not required to support any TS function.

TS SECTION 3.0, SURVEILLANCE REQUIREMENT (SR)

APPLICABILITY TS Section 3.0 contains the general requirements applicable to all SRs and applies at all times unless otherwise stated in a TS. Proposed revisions to these TS are described below. The corresponding TS Bases are also being revised to reflect these changes.

A mark-up of this section is provided.

Current SR 3.0.1 Proposed SR 3.0.1 SRs shall be met during the MODES or other SRs shall be met during the MODES or other specified conditions in the Applicability for specified conditions in the Applicability for individual LCOs, unless otherwise stated in individual LCOs, unless otherwise stated in the SR ... [for entirety of text, see the SR. .. [for entirety of text, see Attachment 1]. ..Surveillances do not have to Attachment 1]. ..Surveillances do not have to be performed on inoperable equipment or be performed on inoperaele eq1::1ipment or variables outside specified limits. variables outside specified limits.

SR 3.0.1 is modified by deleting the reference to MODES. In accordance with 10 CFR 50.82(a)(2), the facility license for PNP will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor.

MODES are not used in any POTS specification . MODES as defined in Table 1.1-1 are for operating or refueling conditions. This term does not apply to a facility in the permanently defueled condition.

In addition, SR 3.0.1 is modified by eliminating the discussion regarding inoperable equipment.

The remaining LCOs do not include any equipment operability requirements.

Enclosure to PNP 2021-005 Page 40 of 106 Current SR 3.0.2 Proposed SR 3.0.2 The specified Frequency for each SR is met if The specified Frequency for each SR is met if the Surveillance is performed within 1.25 the Surveillance is performed within 1.25 times the interval specified in the Frequency, times the interval specified in the Frequency, as measured from the previous performance as measured from the previous performance or as measured from the time a specified or as meas1::1red fr:om the time a specified condition of the Frequency is met. condition of the Freq1::1ency is met.

For Frequencies specified as "once," the For Freq1::1encies specif.ieEI as "once," the above interval extension does not apply. ab8¥e interval e~ension Eloes not apply.

If a Completion Time requires periodic If a Gompletion +ime req1::1ires perioElic performance on a "once per ... " basis, the perfermance on a "once per . .. " easis, the above Frequency extension applies to each ab8¥e Freq1::1ensy e~ension applies to each performance after the initial performance. perfermance after the initial perfermance.

Exceptions to this Specification are stated in e*ceptions to this Specification are stateEI in the individual Specifications. the inEli1,1iEl1::1al Specifications.

Basis SR 3.0.2 provides an allowance for extending the frequency for performance of a SR to 1.25 times the interval specified in the frequency to facilitate scheduling or unforeseen problems that may prevent performance during normal intervals. It is proposed to remove the discussion of frequency requirements that will no longer exist in POTS LCOs.

Current SR 3.0.4 Proposed SR 3.0.4 Entry into a MODE or other specified condition Entry into a MODe or other specified condition in the Applicability of an LCO shall only be in the Applicability of an LCO shall only be made when the LCO's Surveillances have made when the LCO's Surveillances have been met within their specified Frequency, been met within their specified Frequency, except as provided by SR 3.0.3. When an except as provided by SR 3.0.3. ).IVhen an bGO LCO is not met due to Surveillances not is not met E11::1e to S1::1rveillances not ha1*1in9 having been met, entry into a MODE or other eeen met, entl\1 into a MODe or other specifieEI specified condition in the Applicability shall conElition in the Applicaeility shall only ee maEle only be made in accordance with LCO 3.0.4. in accorElance with bGO 3.0.4.

This provision shall not prevent entry into +his pro1, 1ision shall not pre1;.1ent entry into MODES or other specified conditions in the MODeS or other specifieEI conElitions in the Applicability that are required to comply with Applicaeility that are req1::1ireEI to comply with ACTIONS or that are part of a shutdown of AG+IONS or that are part of a sh1::1tE101,*.in of the the plant. plaAt,.

Enclosure to PNP 2021-005 Page 41 of 106 SR 3.0.4 is modified by deleting the reference to MODES. In accordance with 10 CFR 50.82(a)(2), the facility license for PNP will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor.

MODES are not used in any POTS specification. MODES as defined in Table 1.1-1 are for operating or refueling conditions. This term does not apply to a facility in the permanently defueled condition.

In addition, SR 3.0.4 is modified by eliminating the provision that states that it shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. TS 3. 7 .14, TS 3. 7 .15, and TS 3. 7 .16 are the only remaining TS with Required Actions, and they do not contain any Required Actions that would require an entry into another specified condition defined in the Applicability of a TS.

In addition, in accordance with 10 CFR 50.82(a)(2), the facility license for PNP will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor. Thus, there will be no ACTIONS that require the shutdown of a unit.

TS SECTION 3.1, REACTIVITY CONTROL SYSTEMS TS Section 3.1 contains requirements to assure and verify operability of reactivity control systems to ensure the reactor remains within the bounds of the PNP accident analyses.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, reactivity control systems will not be required and the requirements in TS Section 3.1 will not apply in the permanently defueled condition.

TS Section 3.1 is proposed for deletion in its entirety. Thus, a mark-up of this TS section is not provided .

Current PNP TS Basis for Change TS 3.1.1, SHUTDOWN MARGIN (SOM) TS 3.1.1 is proposed for deletion.

TS 3.1.1 ensures the SOM is maintained within the limits specified in the COLR. TS 3.1.1 is applicable in MODES 3 through 5. The TS will not be required after the certifications required under 10 CFR 50.82(a)(1) have been docketed for PNP. At that time, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel. Thus, operation in the applicable MODES will no longer occur. As a result, TS 3.1.1 will not apply in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 42 of 106 TS 3.1.2, Reactivity Balance TS 3.1.2 is proposed for deletion.

TS 3.1.2 ensures that core reactivity balance remains within +/- 1% of predicted values. TS 3.1.2 is applicable in MODE 1. The TS will not be required after the certifications required under 10 CFR 50.82(a)(1) have been docketed for PNP. At that time, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel. Thus, operation in MODE 1 will no longer occur. As a result, TS 3.1.2 will not apply in the permanently defueled condition.

TS 3.1.3, Moderator Temperature TS 3.1.3 is proposed for deletion.

Coefficient (MTC)

TS 3.1.3 establishes MTC limits during plant operation to ensure stable plant operation. TS 3.1 .3 is applicable in MODES 1 and 2. It will not be required after the certifications required under 10 CFR 50.82(a)(1) have been docketed for PNP. At that time, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel. Thus, operation in the applicable will no longer occur. As a result, this TS will not apply in the permanently defueled condition.

TS 3.1.4, Control Rod Alignment TS 3.1.4 is proposed for deletion.

TS 3.1.4 establishes limits on control rod alignment and OPERABILITY to ensure that the power distribution and reactivity limits defined by the design power peaking and SOM limits are preserved. TS 3.1.4 is applicable in MODES 1 and 2. It will not be required after the certifications required under 10 CFR 50.82(a)(1) have been docketed for PNP. At that time, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel. Thus, operation in MODES 1 and 2 will no longer occur.

As a result, this TS will not apply in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 43 of 106 TS 3.1.5, Shutdown and Part-Length Control TS 3.1 .5 is proposed for deletion.

Rod Group Insertion Limits TS 3.1.5 establishes limits on insertion of PNP's shutdown control rods and four part-length control rods to ensure that reactivity limits, ejected rod worth, and SOM limits are preserved. TS 3.1.5 also places insertion limits on PNP's four part-length control rods. This TS is applicable in MODE 1 and MODE 2 with any regulating rod withdrawn above 5 inches. It will not be required after the certifications required under 10 CFR 50.82(a)(1) have been docketed for PNP.

At that time, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel. Thus, operation in MODES 1 and 2 will no longer occur. As a result, this TS will not apply in the permanently defueled condition.

TS 3.1.6, Regulating Rod Group Position TS 3.1.6 is proposed for deletion.

Limits TS 3.1.6 ensures regulating rod groups are limited to the withdrawal sequence, overlap, and insertion limits specified in the COLR. TS 3.1.6 is applicable in MODES 1 and 2. It will not be required after the certifications required under 10 CFR 50.82(a)(1) have been docketed for PNP. At that time, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel. Thus, operation in the applicable MODES will no longer occur. As a result, this TS will not apply in the permanently defueled condition.

TS 3.1.7, Special Test Exceptions (STE) TS 3.1. 7 is proposed for deletion.

TS 3.1. 7 permits suspension of existing LCOs to allow the performance of certain PHYSICS TESTS in MODE 2. The TS 3.1. 7 suspensions will not be required after the certifications required under 10 CFR 50.82(a)(1) have been docketed for PNP. At that time, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel. Thus, operation in the applicable MODE and specified condition will no longer occur. As a result, this TS will not apply in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 44 of 106 TS SECTION 3.2, POWER DISTRIBUTION LIMITS TS Section 3.2 contains power distribution limits that provide assurance that fuel design criteria are not exceeded and the accident analysis assumptions remain valid.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, the accidents discussed above are no longer credible. Therefore, the requirements in TS Section 3.2 will not apply in the permanently defueled condition.

TS Section 3.2 is proposed for deletion in its entirety. Thus, a mark-up of this TS section is not provided.

Current PNP TS Basis for Change TS 3.2.1, Linear Heat Rate (LHR) TS 3.2.1 is proposed for deletion.

TS 3.2.1 ensures the LHR remains within the limits specified by the COLR.

TS 3.2.1 is applicable in MODE 1 with THERMAL POWER> 25% RTP. It will not be required after the certifications required under 10 CFR 50.82(a)(1) have been docketed for PNP. At that time, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel. Thus, operation in MODE 1 will no longer occur. As a result, this TS will not apply in the permanently defueled condition.

TS 3.2.2, Total Radial Peaking TS 3.2.2 is proposed for deletion.

Factor (FRT)

TS 3.2.2 ensures the FR T remains within the limits specified in the COLR.

TS 3.2.2 is applicable in MODE 1 with THERMAL POWER> 25% RTP. It will not be required after the certifications required under 10 CFR 50.82(a)(1) have been docketed for PNP. At that time, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel. Thus, operation in MODE 1 will no longer occur. As a result, this TS will not apply in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 45 of 106 TS 3.2.3, Quadrant Power Tilt (Tq} TS 3.2.3 is proposed for deletion.

The limitations on Tq, specified in TS 3.2.3, ensure that assumptions used in the analysis for establishing LHR limits and DNB margin remain valid during operation.

TS 3.2.3 is applicable in MODE 1 with THERMAL POWER> 25% RTP. It will not be required after the certifications required under 10 CFR 50.82(a)(1) have been docketed for PNP. At that time, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel. Thus, operation in the applicable MODE and specified condition will no longer occur. As a result, this TS will not apply in the permanently defueled condition.

TS 3.2.4, Axial Shape Index (ASI) TS 3.2.4 is proposed for deletion.

TS 3.2.4 ensures the ASI remains within the limits specified in the COLR.

TS 3.2.4 is applicable in MODE 1 with THERMAL POWER> 25% RTP. It will not be required after the certifications required under 10 CFR 50.82(a)(1) have been docketed for PNP. At that time, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel. Thus, operation in the applicable MODE and specified condition will no longer occur. As a result, this TS will not apply in the permanently defueled condition.

TS SECTION 3.3, INSTRUMENTATION TS Section 3.3 contains operability requirements for sensing and control instrumentation required for safe operation of the facility.

After the certifications required under 10 CFR 50.82(a)(1) have been docketed for PNP, the 10 CFR Part 50 license will no longer authorize emplacement or retention of fuel in the reactor vessel. The TS that do not apply in the permanently defueled condition, which includes TS for structures, systems, or components that are not needed for accident mitigation in the defueled condition, are being proposed for deletion.

TS Section 3.3 is proposed for deletion in its entirety. Thus, a mark-up of this TS section is not provided.

Enclosure to PNP 2021-005 Page 46 of 106 Current PNP TS Basis for Change TS 3.3.1, Reactor Protection System (RPS) TS 3.3.1, including Tables 3.3.1-1 and 3.3.1-2, Instrumentation is proposed for deletion.

The RPS initiates a reactor shutdown as required to mitigate design basis accidents and transients.

TS 3.3.1 is applicable in various portions of MODES 1 through 5 and other specified conditions as defined in Table 3.3.1-1. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Thus, operation in the applicable MODES and specified conditions will no longer occur. Thus, the RPS instrumentation will not be required in the permanently defueled condition.

TS 3.3.2, Reactor Protective System (RPS) TS 3.3.2 is proposed for deletion.

Logic and Trip Initiation The RPS initiates a reactor shutdown as required to mitigate design basis accidents and transients.

TS 3.3.2 is applicable in MODES 1, and 2, and in MODES 3 through 5 under specified conditions.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in applicable MODES and specified conditions will not occur. As a result, the RPS Logic and trip initiation instrumentation will not be required in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 47 of 106 TS 3.3.3, Engineered Safety Features TS 3.3.3, including Table 3.3.3-1, is proposed (ESF) Instrumentation for deletion.

The ESF instrumentation initiates necessary safety systems to mitigate design basis accidents and transients.

TS 3.3.3 is applicable in various portions of MODES 1 through 4 and other specified conditions as defined in Table 3.3.3-1. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Thus, operation in the applicable MODES and specified conditions will no longer occur. As a result, the ESF instrumentation will not be required in the permanently defueled condition.

TS 3.3.4, Engineered Safety Features TS 3.3.4, including Table 3.3.4-1, is proposed for (ESF) Logic and Manual Initiation deletion.

The ESF logic initiates necessary safety systems when monitored variables indicate protective action is required. ESF manual initiation permits the operator to manually actuate an ESF system when necessary.

TS 3.3.4 is applicable in various portions of MODES 1 through 4 and other specified conditions as defined in Table 3.3.4-1. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Thus, operation in the applicable MODES and specified conditions will no longer occur. As a result, the ESF logic and manual initiation instrumentation will not be required in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 48 of 106 T 3.3.5, Diesel Generator (DG) - TS 3.3.5 is proposed for deletion.

Undervoltage Start (UV Start)

Instrumentation The DGs provide a source of emergency power to allow safe operation of the plant.

Undervoltage protection instrumentation will generate a DG start in the event a loss of voltage or degraded voltage condition occurs.

TS 3.3.5 is applicable when required to support the associated DG operability per LCO 3.8.2, AC Sources - Shutdown. TS 3.8.2 is also proposed for deletion as discussed in the table for Section 3.8 as the DGs are no longer required to be operable in a permanently defueled condition. Therefore, the DG UV start instrumentation will no longer be required, and TS 3.3.5 is no longer applicable.

TS 3.3.6, Refueling Containment High TS 3.3.6 is proposed for deletion.

Radiation (CHR) Instrumentation CHR Instrumentation provides automatic containment isolation during refueling operations.

TS 3.3.6 is applicable during CORE ALTERATIONS and during movement of irradiated fuel assemblies within containment.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, CORE ALTERATIONS will no longer occur.

Additionally, all spent fuel within the reactor vessel will be moved to the spent fuel pool, therefore, movement of irradiated fuel within the containment will no longer occur. Therefore, this TS is no longer applicable to a permanently defueled facility.

Enclosure to PNP 2021-005 Page 49 of 106 TS 3.3.7, Post Accident Monitoring (PAM) TS 3.3.7, including Table 3.3.7-1, is proposed for Instrumentation deletion.

The PAM instrumentation displays plant variables that provide information required by the operators during accident situations.

TS 3.3.3 is applicable in MODES 1, 2, and 3.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 3 will no longer occur. As a result, the PAM instrumentation will not be required in the permanently defueled condition.

TS 3.3.8, Alternate Shutdown System TS 3.3.8, including Table 3.3.8-1, is proposed for deletion.

The Alternate Shutdown System provides the control room operator with sufficient instrumentation and controls to maintain the plant in a safe shutdown condition from a location other than the control room.

TS 3.3.8 is applicable in MODES 1, 2, and 3.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 3 will no longer occur. As a result, the remote shutdown system will not be required in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 50 of 106 TS 3.3.9, Neutron Flux Monitoring Channels TS 3.3.9 is proposed for deletion.

The neutron flux monitoring channels are necessary to monitor core reactivity changes.

TS 3.3.9 is applicable in MODES 3, 4, and 5.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 3 through 5 will no longer occur. As a result, the neutron flux monitoring channels will not be required in the permanently defueled condition.

TS 3.3.10 Engineered Safeguards Room TS 3.3.1 O is proposed for deletion.

Ventilation (ESRV) Instrumentation The ESRV instrumentation provides isolation of the engineered safeguards pump rooms in the event of high radiation in the pump rooms.

TS 3.3.10 is applicable in MODES 1 through 4.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 4 will no longer occur. As a result, the ESRV instrumentation will not be required in the permanently defueled condition.

TS SECTION 3.4, PRIMARY COOLANT SYSTEM (PCS)

TS Section 3.4 contains requirements that provide for appropriate control of process variables, design requirements, or operating restrictions needed for appropriate functional capability of PCS equipment required for safe operation of the facility.

After the certifications required under 10 CFR 50.82(a)(1) have been docketed for PNP, 10 CFR Part 50 license will no longer authorize emplacement or retention of fuel in the reactor vessel. The TS that do not apply in a defueled condition, which includes TS for structures, systems, or components that are not needed for accident mitigation in the defueled condition, are being proposed for deletion.

TS Section 3.4 is proposed for deletion in its entirety. Thus, a mark-up of this TS section is not provided.

Enclosure to PNP 2021-005 Page 51 of 106 Current PNP TS Basis for Change TS 3.4.1, PCS Pressure, Temperature, and TS 3.4.1 is proposed for deletion.

Flow Departure from Nucleate Boiling (DNB)

Limits The requirements of TS 3.4.1 ensure that PCS pressure, temperature and flow rate remain within the limits specified in the COLR.

TS 3.4.1 is applicable in MODE 1. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Thus, operation in MODE 1 will no longer occur.

As a result, the PCS pressure, temperature, and PCS total flow rate limits are no longer applicable in the permanently defueled condition.

TS 3.4.2, PCS Minimum Temperature for TS 3.4.2 is proposed for deletion.

Criticality TS 3.4.2 ensures the PCS temperature remains above the minimum temperature for reactor criticality to prevent operation in an unanalyzed condition.

TS 3.4.2 is applicable in MODE 1, and in MODE 2 with keff.:: 1.0. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in the applicable MODES and specified condition will no longer occur. As a result, the PCS minimum temperature for criticality limit is no longer applicable in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 52 of 106 TS 3.4.3, PCS Pressure and Temperature TS 3.4.3, including Figures 3.4.3-1 and 3.4.3-2, (PIT) Limits is proposed for deletion.

TS 3.4.3 limits pressure and temperature changes during PCS heatup and cooldown to within specified limits.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). With no fuel allowed in the reactor, there is no heat source capable of producing rapid temperature changes or nonductile failure of the PCS components. Therefore, the PCS PIT limits are no longer applicable in the permanently defueled condition.

TS 3.4.4, PCS Loops - MODES 1 and 2 TS 3.4.4 is proposed for deletion.

TS 3.4.4 ensures adequate PCS heat transfer capability during power operation.

TS 3.4.4 is applicable in MODES 1 and 2. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Thus, operation in MODES 1 and 2 will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS 3.4.5, PCS Loops - MODE 3 TS 3.4.5 is proposed for deletion.

TS 3.4.5 ensures adequate PCS heat transfer capability during hot standby.

TS 3.4.5 is applicable in MODE 3. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Thus, operation in MODE 3 will no longer occur.

As a result, this TS will not be applicable in a permanently defueled condition.

Enclosure to PNP 2021-005 Page 53 of 106 TS 3.4.6, PCS Loops - MODE 4 TS 3.4.6 is proposed for deletion.

TS 3.4.6 ensures adequate PCS heat transfer capability during hot shutdown.

TS 3.4.6 is applicable in MODE 4. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Thus, operation in MODE 4 will no longer occur.

As a result, this TS will not be applicable in a permanently defueled condition.

TS 3.4.7, PCS Loops- MODE 5, Loops TS 3.4.7 is proposed for deletion.

Filled TS 3.4. 7 ensures adequate PCS heat transfer capability during cold shutdown with the PCS piping filled.

TS 3.4. 7 is applicable in MODE 5 with the PCS loops filled. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODE 5 with the PCS loops filled will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS 3.4.8, PCS Loops - MODE 5, Loops TS 3.4.8 is proposed for deletion.

Not Filled TS 3.4.8 ensures adequate PCS heat transfer capability during cold shutdown with the PCS piping not filled.

TS 3.4.8 is applicable in MODE 5 with the PCS loops not filled. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Thus, operation in MODE 5 with the PCS loops not filled will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 54 of 106 TS 3.4.9, Pressurizer TS 3.4.9 is proposed for deletion.

TS 3.4.9 provides requirements for pressurizer water level, required pressurizer heater capacity, and heater power supply to ensure proper operation of the pressurizer.

TS 3.4.9 is applicable in MODES 1, 2, and 3. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Thus, operation in MODES 1 through 3 will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS 3.4.10, Pressurizer Safety Valves TS 3.4.10, including Table 3.4.10-1, is proposed for deletion.

TS 3.4.1 O ensures the pressurizer safety valves are capable of providing PCS overpressure protection.

TS 3.4.10 is applicable in MODES 1 and 2, and in MODE 3 with all PCS cold leg temperatures

430°F. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1, 2, and 3 with the specified condition will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 55 of 106 TS 3.4.11, Pressurizer Power Operated TS 3.4.11 is proposed for deletion.

Relief Valves (PORVs)

TS 3.4.11 ensures the PORVs are capable of providing PCS overpressure protection.

TS 3.4.11 is applicable in MODES 1 and 2, and MODE 3 with all PCS cold leg temperatures .!:

430°F. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1, 2, and 3 with the specified condition will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS 3.4.12, Low Temperature Overpressure TS 3.4.12, including Figure 3.4.12-1, is proposed Protection (LTOP) System for deletion.

TS 3.4.12 ensures the integrity of the primary coolant pressure boundary by maintaining the PCS pressure within allowable values at low temperatures.

TS 3.4.12 is applicable in MODE 3 when any PCS cold leg temperature is< 430°F, in MODES 4 and 5, and in MODE 6 when the reactor vessel head is on. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in the applicable MODES and specified conditions will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 56 of 106 TS 3.4.13, PCS Operational LEAKAGE TS 3.4.13 is proposed for deletion.

TS 3.4.13 limits operation when PCS leakage is present.

TS 3.4.13 is applicable in MODES 1 through 4.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 4 will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS 3.4.14, PCS Pressure Isolation Valve TS 3.4.14 is proposed for deletion.

(PIV) Leakage TS 3.4.14 ensures that PIV leakage or inadvertent valve positioning does not result in overpressure of low pressure piping and components.

TS 3.4.14 is applicable in MODES 1 through 3, and MODE 4 except during the SOC mode of operation, or transition to or from, the shutdown cooling mode of operation. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Thus, operation in MODES 1 through 3, and in MODE 4 with the specified condition, will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS 3.4.15, PCS Leakage Detection TS 3.4.15 is proposed for deletion.

Instrumentation TS 3.4.15 ensures instrumentation is provided to detect and identify PCS leakage.

TS 3.4.15 is applicable in MODES 1 through 4.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 4 will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 57 of 106 TS 3.4.16, PCS Specific Activity TS 3.4.16 is proposed for deletion.

TS 3.4.16 limits the allowable concentration level of radionuclides in the primary coolant to minimize the offsite dose consequences in the event of a steam generator tube rupture or other accident.

TS 3.4.16 is applicable in MODES 1 and 2, and in MODE 3 with PCS average temperature~

500°F. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1, 2, and 3 with the specified condition will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS 3.4.17, Steam Generator (SG) Tube TS 3.4.17 is proposed for deletion.

Integrity TS 3.4.17 ensures the primary containment pressure boundary function of the SG.

TS 3.4.17 is applicable in MODES 1 through 4.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 4 will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS SECTION 3.5, EMERGENCY CORE COOLING SYSTEMS (ECCS)

TS Section 3.5 contains requirements that provide for appropriate functional capability of ECCS equipment required for mitigation of DBAs or transients to protect the integrity of a fission product barrier.

After the certifications required under 10 CFR 50.82(a)(1) have been docketed for PNP, the 10 CFR Part 50 license will no longer authorize emplacement or retention of fuel in the reactor vessel. The TS that do not apply in a defueled condition, which includes TS for structures, systems, or components that are not needed for accident mitigation in the defueled condition, are being proposed for deletion.

TS Section 3.5 is proposed for deletion in its entirety. Thus, a mark-up of this TS section is not provided.

Enclosure to PNP 2021-005 Page 58 of 106 Current PNP TS Basis for Change TS 3.5.1, Safety Injection Tanks (SITs) TS 3.5.1 is proposed for deletion.

TS 3.5.1 ensures the SITs are capable of supplying water to the reactor vessel throughout a Loss of Coolant Accident (LOCA) event and subsequent recovery from the event.

TS 3.5.1 is applicable in MODES 1 and 2. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Thus, operation in MODES 1 and 2 will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS 3.5.2, ECCS - Operating TS 3.5.2 is proposed for deletion.

TS 3.5.2 ensures the ECCS can provide core cooling and negative reactivity to protect the reactor core during accidents involving inventory loss.

TS 3.5.2 is applicable in MODES 1 and 2, and in MODE 3 with PCS temperature.!: 325°F. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Thus, operation in MODES 1 and 2, and in MODE 3 with the specified condition will no longer occur.

As a result, this TS will not be applicable in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 59 of 106 TS 3.5.3, ECCS - Shutdown TS 3.5.3 is proposed for deletion.

TS 3.5.3 ensures the ECCS can provide core cooling and negative reactivity to protect the reactor core during accidents involving inventory loss while in the hot shutdown condition.

TS 3.5.3 is applicable in MODE 3 with PCS temperature < 325°F and in MODE 4. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Thus, operation in MODE 3 with the specified condition and in MODE 4 will no longer occur.

As a result, this TS will not be applicable in the permanently defueled condition.

TS 3.5.4, Safety Injection Refueling TS 3.5.4 is proposed for deletion.

Water Tank (SIRWT)

TS 3.5.4 ensures a source of borated water is available for engineered safeguards pump operation.

TS 3.5.4 is applicable in MODES 1 through 4.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 4 will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS 3.5.5, Containment Sump Buffering TS 3.5.5 is proposed for deletion.

Agent and Weight Requirements TS 3.5.5 ensures the buffering agent, i.e., sodium tetraborate, results in a post-LOCA sump water pH value consistent with accident analyses.

TS 3.5.5 is applicable in MODES 1, 2, and 3.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 3 will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 60 of 106 TS SECTION 3.6, CONTAINMENT SYSTEMS TS Section 3.6 contains requirements that assure the integrity of the containment, depressurization and cooling systems, and containment isolation valves.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). The TS that do not apply in a defueled condition, which includes TS for structures, systems, or components that are not needed for accident mitigation in the defueled condition, are being proposed for deletion.

TS Section 3.6 is proposed for deletion in its entirety. Thus, a mark-up of this TS section is not provided.

Current PNP TS Basis for Change TS 3.6.1, Containment TS 3.6.1 is proposed for deletion.

TS 3.6.1 ensures a containment configuration that is consistent with the safety analyses.

TS 3.6.1 is applicable in MODES 1 through 4.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 4 will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS 3.6.2, Containment Air Locks TS 3.6.2 is proposed for deletion.

TS 3.6.2 ensures the containment air locks perform their design function as part of the containment pressure boundary.

TS 3.6.2 is applicable in MODES 1 through 4.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 4 will no longer occur. As a result, the containment airlocks will not be applicable in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 61 of 106 TS 3.6.3, Containment Isolation Valves TS 3.6.3 is proposed for deletion.

TS 3.6.3 ensures the containment isolation valves and devices are capable of providing containment isolation within the time limits assumed in the safety analyses.

TS 3.6.3 is applicable in MODES 1 through 4.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 4 will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS 3.6.4, Containment Pressure TS 3.6.4 is proposed for deletion.

TS 3.6.4 ensures containment pressure is limited during normal operation to preserve the initial conditions assumed in accident analyses.

TS 3.6.4 is applicable in MODES 1 through 4.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 4 will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS 3.6.5, Containment Air Temperature TS 3.6.5 is proposed for deletion.

TS 3.6.5 ensures containment air temperature is limited during normal operation to preserve the initial conditions assumed in accident analyses.

TS 3.6.5 is applicable in MODES 1 through 4.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 4 will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 62 of 106 TS 3.6.6, Containment Cooling Systems TS 3.6.6 is proposed for deletion.

TS 3.6.6 ensures containment atmosphere cooling is capable of maintaining post-accident containment design values.

TS 3.6.6 is applicable in MODES 1 through 3.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 3 will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS SECTION 3. 7, PLANT SYSTEMS TS Section 3. 7 provides requirements for the appropriate functional capability of plant equipment required for safe operation of the facility, including requirements that apply when the facility is in a defueled condition.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). The TS that do not apply in a defueled condition, which includes TS for structures, systems, or components that are not needed for accident mitigation in the defueled condition, are being proposed for deletion.

TS 3. 7 is retitled to reflect that the remaining TS address non-operational facility requirements.

TS 3.7.1 through TS 3.7.13, and TS 3.7.17 are proposed for deletion in their entirety. Mark-ups of these TS are not provided.

TS 3. 7 .14 provides the limit regarding the SFP water level. It will be retained in the POTS and modified to eliminate the reference to LCO 3.0.3.

TS 3. 7 .15 provides requirements regarding the SFP boron concentration. It will be retained in the POTS and modified to eliminate the reference to LCO 3.0.3.

TS 3. 7 .16 provides the limits for storing fuel assemblies in the SFP. It will be retained in the POTS and modified to eliminate the reference to LCO 3.0.3.

Mark-ups of TS 3.7.14, TS 3.7.15, and TS 3.7.16 are provided in Attachment 1 in this enclosure.

Enclosure to PNP 2021-005 Page 63 of 106 Current PNP TS Basis for Change TS 3.7, PLANT SYSTEMS Proposed TS 3.7, PLANT FAC/L/TYSYSTEMS The TS section is proposed to be retitled to reflect that the remaining TS in this section deal with facility requirements in a permanently shut down and defueled facility. This is an administrative change.

TS 3. 7 .1, Main Steam Safety Valves TS 3.7.1, including Table 3.7.1-1, is proposed (MSSVs) for deletion.

TS 3.7.1 ensures the MSSVs are capable of providing protection against over-pressurization of the secondary system and the primary coolant system.

TS 3.7.1 is applicable in MODES 1 through 3.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 3 with the specified condition will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS 3.7.2, Main Steam Isolation Valves TS 3.7.2 is proposed for deletion.

(MSIVs)

TS 3.7.2 ensures the MSIVs are capable of isolating steam flow in the event of a high energy line break event.

TS 3.7.2 is applicable in MODE 1, and in MODES 2 and 3, except when all MSIVs are closed and deactivated. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1, and in MODES 2 and 3, with the specified condition, will no longer occur.

As a result, this TS will not be applicable in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 64 of 106 TS 3.7.3, Main Feedwater Regulating Valves TS 3.7.3 is proposed for deletion.

(MFRVs) and MFRV Bypass Valves TS 3.7.3 ensures the MFRVs and MFRV bypass valves provide steam generator level control during normal plant operation and provide isolation in the event of a high energy line break.

TS 3.7.3 is applicable in MODES 1 and 2, and in MODE 3 except when both MFRVs and both MFRV bypass valves are either closed and de-activated, or isolated by closed manually actuated valves. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Thus, operation in MODES 1 through 3 with the specified condition will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS 3.7.4, Atmospheric Dump Valves TS 3.7.4 is proposed for deletion.

(ADVs)

TS 3.7.4 ensures the ADVs are capable of removing decay heat should the preferred heat sink not be available.

TS 3.7.4 is applicable in MODES 1 through 3 and in MODE 4 when the SG is relied upon for heat removal. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 3, and in MODE 4 with the specified condition, will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 65 of 106 TS 3. 7 .5, Auxiliary Feedwater (AFW) TS 3.7.5 is proposed for deletion.

System TS 3.7.5 ensures a supply of feedwater to the steam generators upon a loss of the normal feedwater supply.

TS 3.7.5 is applicable in MODES 1 through 3 and in MODE 4 when the SG is relied upon for heat removal. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 3, and in MODE 4 with the specified condition, will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS 3.7.6, Condensate Storage and Supply TS 3.7.6 is proposed for deletion.

TS 3.7 .6 ensures a supply of safety-grade source of water to the steam generators for removing decay and sensible heat.

TS 3.7.6 is applicable in MODES 1 through 3 and in MODE 4 when the SG is relied upon for heat removal. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 3, and in MODE 4 with the specified condition will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 66 of 106 TS 3.7.7, Component Cooling Water (CCW) TS 3.7.7 is proposed for deletion.

System TS 3.7.7 ensures a heat sink for the removal of process and operating heat from safety related components during a OBA or transient.

TS 3.7.7 is applicable in MODES 1 through 4.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 4 will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS 3.7.8, Service Water System (SWS) TS 3.7.8 is proposed for deletion.

TS 3.7.8 ensures a heat sink for the removal of process and operating heat from safety related components during a OBA or transient.

TS 3.7.8 is applicable in MODES 1 through 4.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 4 will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS 3.7.9, Ultimate Heat Sink (UHS) TS 3.7.9 is proposed for deletion.

TS 3. 7 .9 ensures a heat sink for the removal of process and operating heat from safety related components during a OBA or transient.

TS 3.7.9 is applicable in MODES 1 through 4.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 4 will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 67 of 106 TS 3.7.10, Control Room Ventilation TS 3.7.10 is proposed for deletion.

(CRV) Filtration TS 3.7.10 is applicable in MODES 1 through 4, during CORE AL TERA TIONS, during movement of irradiated fuel assemblies, or during movement of a fuel cask in or over the SFP.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 4 and CORE ALTERATIONS will no longer occur.

As discussed in Section 3.0 of this Enclosure, the revised FHA analysis (Reference 5) concludes that the dose consequences of the FHA will remain within the licensing basis dose limits without crediting CRV filtration assuming 17 days of irradiated fuel decay time following shut down.

Consequently, the POTS will not be effective until after that time period.

As discussed in Section 3.0 of this Enclosure, the UFSAR Chapter 14 cask drop analysis concludes that the dose consequences of a cask drop will remain within the licensing basis dose limits without crediting CRV filtration assuming 90 days of irradiated fuel decay time following shut down.

There are no SSCs required to mitigate the consequences of a cask drop occurring 90 days after shutdown. A new License Condition 2.C.(5) is proposed to prohibit cask movement in or over the SFP when irradiated fuel assemblies with less than 90 days decay time are in the SFP.

Therefore, since operation in MODES 1 through 4 will no longer occur, the reactor will be permanently defueled, the POTS will not become effective before 17 days of irradiated fuel decay time, and new License Condition 2.C.(5) will prohibit cask movement over irradiated fuel assemblies decayed less than 90 days, this TS will not be applicable and can be removed from the POTS.

Enclosure to PNP 2021-005 Page 68 of 106

3. 7 .11, Control Room Ventilation TS 3. 7 .11 is proposed for deletion.

(CRV) Cooling TS 3.7.11 is applicable in MODES 1 through 4, during CORE ALTERATIONS, during movement of irradiated fuel assemblies, and during movement of a fuel cask in or over the SFP.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 4 and CORE AL TERATIONS will no longer occur.

As discussed in Section 3.0 of this Enclosure, the revised FHA analysis (Reference 5) concludes that the dose consequences of the FHA will remain within the licensing basis dose limits without crediting CRV cooling assuming 17 days of irradiated fuel decay time following shut down.

Consequently, the POTS will not be effective until after that time period.

As discussed in Section 3.0 of this Enclosure, the UFSAR Chapter 14 cask drop analysis concludes that the dose consequences of a cask drop will remain within the licensing basis dose limits without crediting CRV filtration assuming 90 days of irradiated fuel decay time following shut down.

There are no SSCs required to mitigate the consequences of a cask drop occurring 90 days after shutdown. A new License Condition 2.C.(5) is proposed to prohibit cask movement in or over the SFP when irradiated fuel assemblies with less than 90 days decay time are in the SFP.

Therefore, since operation in MODES 1 through 4 will no longer occur, the reactor will be permanently defueled, the POTS will not become effective before 17 days of irradiated fuel decay time, and new license condition 2.C.(5) will prohibit cask movement over irradiated fuel assemblies decayed less than 90 days, this TS will not be applicable and can be removed in the POTS.

Enclosure to PNP 2021-005 Page 69 of 106 3.7.12, Fuel Handling Area TS 3.7.12 is proposed for deletion.

Ventilation System TS 3.7.12 is applicable: 1) during movement of irradiated fuel assemblies in the fuel handling building when irradiated fuel assemblies with

< 30 days decay time are in the fuel handling building, 2) during movement of a fuel cask in or over the SFP when irradiated fuel assemblies with < 90 days decay time are in the fuel handling building, 3) during CORE ALTERATIONS when irradiated fuel assemblies with < 30 days decay time are in the containment with the equipment hatch open, and 4) during movement of irradiated fuel assemblies in the containment when irradiated fuel assemblies with < 30 days decay time are in the containment with the equipment hatch open.

Each of the specified applicability conditions are addressed as follows.

1) As discussed in Section 3.0 of this Enclosure, the revised FHA analysis (Reference 5) concludes that the dose consequences of the FHA will remain within the licensing basis dose limits without crediting the fuel handling ventilation system assuming 17 days of irradiated fuel decay time for fuel assemblies in the SFP. Consequently, the POTS will not be effective until after that time period and applicability condition 1 is no longer necessary.

2) There are no SSCs required to mitigate the consequences of a cask drop occurring 90 days after shutdown. A new License Condition 2.C.(5) is proposed to prohibit cask movement in or over the spent fuel pool when irradiated fuel assemblies with less than 90 days decay time are in the spent fuel pool.

Thus, applicability condition 2 is no longer necessary.

3) After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, CORE ALTERATIONS will no longer occur and applicability condition 3 is no longer necessary.

4) After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR

Enclosure to PNP 2021-005 Page 70 of 106 Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). All spent fuel within the reactor vessel will be located in the spent fuel pool and movement of irradiated fuel assemblies in the containment will no longer occur and applicability condition 4 is no longer necessary.

Therefore, since the reactor will be permanently defueled, the POTS will not become effective before 17 days of irradiated fuel decay time, and new License Condition 2.C.(5) will prohibit cask movement over irradiated fuel assemblies decayed less than 90 days, this TS will not be applicable and can be removed in the POTS.

TS 3.7 .13, Engineered Safeguards TS 3.7.13 is proposed for deletion.

Room Ventilation (ESRV) Dampers TS 3. 7 .13 ensures the ESRV dampers provide isolation of the engineered safeguards room in the event of a high radiation alarm.

TS 3.7.13 is applicable in MODES 1 through 4 .

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2) . Thus, operation in MODES 1 through 4 will no longer occur.

As a result, this TS will not be applicable in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 71 of 106 TS 3.7.14, Spent Fuel Pool (SFP) Water TS 3.7.14 is retained in the POTS.

Level TS 3.7.14 ensures the initial SFP water level assumed in the fuel handling accident analysis is maintained.

The TS section title is administratively changed from "Plant Systems" to "Facility Systems" to reflect that this TS section addresses non-operational facility requirements. In addition, the NOTE in ACTIONS ("LCO 3.0.3 is not applicable") is proposed to be deleted to conform to the deletion of TS LCO 3.0.3 as previously proposed.

PNP will not maintain the Surveillance Frequency Control Program (SFCP), implemented as Amendment 271 (Reference 8), in the POTS.

Therefore, the FREQUENCY of SR 3.7.14.1 will revert to the frequency that was relocated to the SFCP as approved by Amendment 271.

Consequently, SR 3.7.14.1 FREQUENCY is changed from "In accordance with the Surveillance Frequency Control Program" to "7 days."

TS 3.7.15, Spent Fuel Pool (SFP) Boron TS 3.7.15 is retained in the POTS.

Concentration TS 3.7.15 ensures the initial SFP boron concentration assumed in the fuel handling accident analysis in maintained.

The TS section title is administratively changed from "Plant Systems" to "Facility Systems" to reflect that this TS section addresses non-operational facility requirements. In addition, the NOTE in ACTIONS ("LCO 3.0.3 is not applicable") is proposed to be deleted to conform to the deletion of TS LCO 3.0.3 as previously proposed.

PNP will not maintain the SFCP, implemented as Amendment 271 (Reference 8), in the POTS.

Therefore, the FREQUENCY of SR 3.7.15.1 will revert to the frequency that was relocated to the SFCP as approved by Amendment 271.

Consequently, SR 3.7.15.1 FREQUENCY is changed from "In accordance with the Surveillance Frequency Control Program" to "7 davs."

Enclosure to PNP 2021-005 Page 72 of 106 TS 3.7.16, Spent Fuel Pool Storage TS 3.7.16, including Tables 3.7.16-1 through 3.7.16-5, is retained in the POTS.

The TS section title is administratively changed from "Plant Systems" to "Facility Systems" to reflect that this TS section addresses non-operational facility requirements. In addition, the NOTE in ACTIONS ("LCO 3.0.3 is not applicable") is proposed to be deleted to conform to the deletion of TS LCO 3.0.3 as previously proposed.

TS 3. 7.17, Secondary Specific Activity TS 3.7.17 is proposed for deletion.

TS 3.7.17 ensures steam generator tube out-leakage is identified.

TS 3.7.17 is applicable in MODES 1 through 4.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 4 will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS SECTION 3.8, ELECTRICAL POWER SYSTEMS TS Section 3.8 contains operability requirements that provide for appropriate functional capability of plant electrical equipment required for safe operation of the facility.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

TS Section 3.8 is proposed for deletion in its entirety. Thus, a mark-up of this TS section is not provided.

Enclosure to PNP 2021-005 Page 73 of 106 Current PNP TS Basis for Change TS 3.8.1, AC Sources - Operating TS 3.8.1 is proposed for deletion.

TS 3.8.1 ensures an independent and redundant source of power to the ESF systems.

TS 3.8.1 is applicable in MODES 1 through 4.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2) . Thus, operation in MODES 1 through 4 will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS 3.8.2, AC Sources - Shutdown TS 3.8.2 is proposed for deletion.

TS 3.8.2 ensures an independent and redundant source of power to the ESF systems.

TS 3.8.2 is applicable in MODES 5 and 6, and during movement of irradiated fuel assemblies.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 5 and 6 will no longer occur.

TS 3.8.2 is applicable during movement of irradiated fuel assemblies. As discussed in Section 3.0 of this Enclosure, the revised FHA analysis (Reference 5) concludes that the dose consequences of the FHA will remain within the licensing basis dose limits without crediting electrical power sources for accident mitigation.

Specifically, dose consequences are acceptable without relying on any electrically powered SSCs to remain functional during and following the event and there are no active systems credited as part of the initial conditions of an analysis or as part of the primary success path for mitigation of these events. Since the proposed amendment will not be effective until irradiated fuel has decayed for at least 17 days, AC sources are not required to support accident mitigation and, as a result, this TS will not be included in the POTS.

Enclosure to PNP 2021-005 Page 74 of 106 TS 3.8.3, Diesel Fuel, Lube Oil, and Starting TS 3.8.3 is proposed for deletion.

Air TS 3.8.3 ensures the DGs are capable of performing their design function.

TS 3.8.3 is applicable when the associated diesel generator (DG) is required to be OPERABLE. TS 3.8.1 and TS 3.8.2 provide the OPERABILITY requirements for the DGs. As previously discussed, these TS are proposed for deletion. Thus, TS 3.8.3 is not included in the POTS because the TS that it supports are no longer required after PNP is permanently shut down and defueled.

TS 3.8.4, DC Sources - Operating TS 3.8.4 is proposed for deletion.

TS 3.8.4 ensures the DC electrical system supports the AC power system and selected safety related equipment.

TS 3.8.4 is applicable in MODES 1 through 4.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 4 will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 75 of 106 TS 3.8.5, DC Sources - Shutdown TS 3.8.5 is proposed for deletion.

TS 3.8.5 ensures the DC electrical system supports the AC power system and selected safety related equipment.

TS 3.8.5 is applicable in MODES 5 and 6, and during movement of irradiated fuel assemblies.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 5 and 6 will no longer occur.

TS 3.8.5 is applicable during movement of irradiated fuel assemblies. As discussed in Section 3.0 of this Enclosure, the revised FHA analysis (Reference 5) concludes that the dose consequences of the FHA will remain within the licensing basis dose limits without crediting electrical power sources for accident mitigation.

Specifically, dose consequences are acceptable without relying on any electrically powered SSCs to remain functional during and following the event and there are no active systems credited as part of the initial conditions of an analysis or as part of the primary success path for mitigation of these events. Since the proposed amendment will not be effective until irradiated fuel has decayed for at least 17 days, DC sources are not required to support accident mitigation and, as a result, this TS will not be included in the POTS.

Enclosure to PNP 2021-005 Page 76 of 106 TS 3.8.6, Battery Cell Parameters TS 3.8.6, including Table 3.8.6-1, is proposed for deletion.

TS 3.8.6 maintains battery cell parameters remain within acceptable limits to ensure availability of the required DC power.

TS 3.8.6 is applicable when the associated DC electrical power source(s) are required to be OPERABLE.

TS 3.8.4 and TS 3.8.5 provide the OPERABILITY requirements regarding the DC sources. As previously discussed, these TS are proposed for deletion. Thus, TS 3.8.6 is not included in the POTS because the TS that it supports are no longer required after PNP is permanently shut down and defueled.

TS 3.8.7, Inverters-Operating TS 3.8.7 is proposed for deletion.

TS 3.8. 7 ensures the inverters are capable of providing continuous AC power to the preferred AC buses.

TS 3.8. 7 is applicable in MODES 1 through 4.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 4 will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 77 of 106 TS 3.8.8, Inverters - Shutdown TS 3.8.8 is proposed for deletion.

TS 3.8.8 ensures the inverters are capable of providing continuous AC power to the preferred AC buses.

TS 3.8.8 is applicable in MODES 5 and 6, and during movement of irradiated fuel assemblies:

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 5 and 6 will no longer occur.

TS 3.8.8 is applicable during movement of irradiated fuel assemblies. As discussed in Section 3.0 of this Enclosure, the revised FHA analysis (Reference 5) concludes that the dose consequences of the FHA will remain within the licensing basis dose limits without crediting electrical power sources for accident mitigation.

Specifically, dose consequences are acceptable without relying on any electrically powered SSCs to remain functional during and following the event and there are no active systems credited as part of the initial conditions of an analysis or as part of the primary success path for mitigation of these events. Since the proposed amendment will not be effective until irradiated fuel has decayed for at least 17 days, inverters are not required to support accident mitigation and, as a result, this TS will not be included in the POTS.

TS 3.8.9, Distribution Systems - Operating TS 3.8.9 is proposed for deletion.

TS 3.8.9 ensures an independent and redundant source of power to the ESF systems.

TS 3.8.9 is applicable in MODES 1 through 4.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 1 through 4 will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 78 of 106 TS 3.8.10, Distribution Systems TS 3.8.1 O is proposed for deletion.

-Shutdown TS 3.8.1 O ensures an independent and redundant source of power to the ESF systems.

TS 3.8.10 is applicable in MODES 5 and 6, and during movement of irradiated fuel assemblies.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, operation in MODES 5 and 6 will no longer occur.

TS 3.8.1 O is applicable during movement of irradiated fuel assemblies. As discussed in Section 3.0 of this Enclosure, the revised FHA analysis (Reference 5) concludes that the dose consequences of the FHA will remain within the licensing basis dose limits without crediting electrical power sources for accident mitigation.

Hence distribution systems for these electrical power sources will no longer be required.

Specifically, dose consequences are acceptable without relying on any electrically powered SSCs to remain functional during and following the event and there are no active systems credited as part of the initial conditions of an analysis or as part of the primary success path for mitigation of these events. Since the proposed amendment will not be effective until irradiated fuel has decayed for at least 17 days, distribution systems are not required to support accident mitigation and, as a result, this TS will not be included in the POTS.

TS SECTION 3.9, REFUELING OPERATIONS TS Section 3.9 contains requirements that provide for appropriate functional capability of parameters and equipment that are required for mitigation of DBAs during refueling operations (moving irradiated fuel to or from the reactor core).

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

TS Section 3.9 is proposed for deletion in its entirety. Thus, a mark-up of this TS section is not provided.

Enclosure to PNP 2021-005 Page 79 of 106 Current PNP TS Basis for Change TS 3.9.1, Boron Concentration TS 3.9.1 is proposed for deletion.

TS 3.9.1 maintains boron concentration of the PCS and the refueling cavity during refueling activities.

TS 3.9.1 is applicable in MODE 6. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Thus, operation in MODE 6 will no longer occur.

As a result, this TS will not be applicable in a permanently defueled condition.

TS 3.9.2, Nuclear Instrumentation TS 3.9.2 is proposed for deletion.

TS 3.9.2 ensures instrumentation is available to monitor the core reactivity condition during refueling activities.

TS 3.9.2 is applicable in MODE 6. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Thus, operation in MODE 6 will no longer occur.

As a result, this TS will not be applicable in a permanently defueled condition.

Enclosure to PNP 2021-005 Page 80 of 106 TS 3.9.3, Containment Penetrations TS 3.9.3 is proposed for deletion.

TS 3.9.3 ensures that a release of fission product radioactivity from a fuel handling accident in containment will be mitigated.

TS 3.9.3 is applicable during CORE ALTERATIONS and during movement of irradiated fuel assemblies within containment.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, CORE ALTERATIONS will no longer occur.

Additionally, all spent fuel within the reactor vessel will be moved to the spent fuel pool, therefore, movement of irradiated fuel within the containment will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS 3.9.4, Shutdown Cooling (SOC) and TS 3.9.4 is proposed for deletion.

Coolant Circulation - High Water Level TS 3.9.4 ensures the removal of decay and sensible heat and the mixing of borated coolant during refueling activities.

TS 3.9.4 is applicable in MODE 6 with the water level~ 647 ft elevation. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Thus, operation in MODE 6 with the specified condition will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 81 of 106 TS 3.9.5, Shutdown Cooling (SOC) and TS 3.9.5 is proposed for deletion.

Coolant Circulation - Low Water Level TS 3.9.5 ensures the removal of decay and sensible heat and the mixing of borated coolant during refueling activities.

TS 3.9.5 is applicable in MODE 6 with the water level< 647 ft elevation. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Thus, operation in MODE 6 with the specified condition will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

TS 3.9.6, Refueling Cavity Water Level TS 3.9.6 is proposed for deletion.

TS 3.9.6 ensures sufficient water level in the refueling cavity and spent fuel pool during refueling activities.

TS 3.9.6 is applicable during CORE ALTERATIONS and during movement of irradiated fuel assemblies within containment.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, CORE ALTERATIONS will no longer occur.

Additionally, all spent fuel within the reactor vessel will be moved to the spent fuel pool, therefore, movement of irradiated fuel within the containment will no longer occur. As a result, this TS will not be applicable in the permanently defueled condition.

Enclosure to PNP 2021-005 Page 82 of 106 TS Section 4.0, DESIGN FEATURES Currently, TS Section 4.0, Design Features, provides information and design requirements associated with plant systems.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). The TS that do not apply in a defueled condition, which includes TS for structures, systems, or components that are not needed for accident mitigation in the defueled condition, are being proposed for deletion.

TS 4.2 and TS 4.3.1.4 are proposed for deletion.

Current PNP TS Basis for Change TS 4.2, Reactor Core TS 4.2 is proposed for deletion.

4.2.1 Fuel Assemblies TS 4.2 provides requirements for reactor The reactor core shall contain 204 fuel fuel assemblies and control rods in the assemblies. Each assembly shall consist of a reactor core. After the certifications matrix ... [for entirety of text proposed for required by 10 CFR 50.82(a)(1) are deletion, see Attachment 1]. docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation 4.2.2 Control Rod Assemblies of the reactor or emplacement or retention The reactor core shall contain 45 control rods. of fuel in the reactor vessel in accordance Four of these control rods may consist of with 10 CFR 50.82(a)(2). In the part-length absorbers. The control material shall permanently shut down and defueled be silver-indium-cadmium, as approved by the condition, fuel assemblies and control rod NRC. requirements for the core will not be necessary. Therefore, this TS will be deleted.

4.3.1 Criticality These TS sections are proposed to be revised to remove references to new fuel TS Sections 4.3.1.1, 4.3.1.2, and 4.3.1.3 provide storage. 4.3.1.1.a, 4.3.1.2.e, and 4.3.1.3.e requirements to ensure the new and irradiated fuel will be revised as follows:

stored in racks in Regions I and II of the spent fuel New or irradiated Irradiated fuel pool remains subcritical. Specifically, assemblies ...

4.3.1.1.a New or irradiated fuel assemblies .. .

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, 4.3.1.2.e New or irradiated fuel assemblies .. .

the 10 CFR Part 50 license will no longer authorize operation of the reactor or 4.3.1 .3.e New or irradiated fuel assemblies .. .

emplacement or retention of fuel in the

[For entirety of TS 4.3. 1 text, see Attachment 1] reactor vessel in accordance with 10 CFR 50.82(a)(2). Consequently, PNP will no longer be licensed to acquire new fuel assemblies. As a result, references to new fuel storaQe are deleted.

Enclosure to PNP 2021-005 Page 83 of 106 TS 4.3.1.4 TS 4.3.1.4, including Figure 4.3-1, is proposed for deletion.

The new fuel storage racks are designed and shall be maintained with ... [for entirety of text TS 4.3.1.4 provides requirements for the proposed for deletion, see Attachment 1]. fuel racks for new fuel assemblies. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Consequently, PNP will no longer be licensed to acquire new fuel and the requirements for storing new fuel will no longer be applicable. Thus, this TS is not included in the POTS.

Enclosure to PNP 2021-005 Page 84 of 106 TS Section 5.0, Administrative Controls TS Section 5.0 establishes the requirements associated with site personnel responsibilities, the site organization, staffing, training, procedures, programs, reporting requirements, and high radiation areas. This section is proposed to be revised to include only those administrative requirements needed for safe handling and storage of spent fuel and maintenance of the facility.

Current PNP TS Basis for Change TS 5.5.2, Primary Coolant Sources Outside TS 5.5.2 is deleted.

Containment This program provides controls to minimize primary coolant leakage to the engineered safeguards rooms from portions of systems outside containment during mitigation of a OBA occurring in containment. Those systems include the containment spray system, the safety injection system, the shutdown cooling system, and the containment sump suction piping.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Therefore, primary coolant leakage can no longer occur. The systems included in this program have been removed from the TS and are not required for the safe storage of spent fuel.

Additionally, as discussed in Section 3.0, the UFSAR Chapter 14 accidents and transients inside containment are no longer applicable and therefore, recirculation of post-accident highly radioactive primary coolant outside containment will no longer occur. Therefore, this program will not be included in the POTS.

TS 5.5.3, Post Accident Sampling Program The post accident sampling program TS was deleted by Amendment 193 (Reference 9). At that time, the title of TS 5.5.3 was retained. As an administrative change, the title is proposed to be removed and replaced with "(Deleted)" for consistency and to avoid the need to renumber the TS.

Enclosure to PNP 2021-005 Page 85 of 106 TS 5.5.5, Containment Structural TS 5.5.5 is proposed for deletion. This program lntegritv Surveillance Program controls monitoring of several containment attributes to ensure containment structural integrity.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Once PNP is permanently shut down and defueled, the containment is no longer credited as part of the initial conditions of the remaining applicable accident analyses or as part of the primary success path for mitigation of these events with the PNP permanently shut down and defueled.

Therefore, this program is no longer required.

TS 5.5.6, Primaey Coolant Pum12 Fl~heel TS 5.5.6 is proposed for deletion.

Surveillance Program After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, the primary coolant pumps will no longer perform a function in the permanently shut down and defueled facility. Therefore, this program is no longer required.

TS 5.5.7, lnservice Testing Program TS 5.5.7 was deleted by Amendment 262 (Reference 10). At that time, the title of TS 5.5. 7 was retained. As an administrative change, the title is proposed to be removed and replaced with "(Deleted)" for consistency and to avoid the need to renumber the TS.

Enclosure to PNP 2021-005 Page 86 of 106 TS 5.5.8, Steam Generator (SG) Program TS 5.5.8 is proposed for deletion.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, the SG will no longer perform a function in the permanently shut down and defueled facility.

Additionally, TS 3.4.17 provides the requirements to ensure SG tube integrity in MODES 1 through 4, and is proposed for deletion. Therefore, this program is no longer required.

TS 5.5.9, Seconda!Y Water Chemist!Y TS 5.5.9 is proposed for deletion.

Program The purpose of the secondary water chemistry program is to maintain water chemistry to inhibit steam generator tube degradation.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, the SG will no longer perform a function in the permanently shut down and defueled facility. Therefore, this program is no longer required.

TS 5.5.10, Ventilation Filter Testing TS 5.5.10 is proposed for deletion. This program Program implements the required testing of control room ventilation and fuel handling area ventilation systems.

As previously discussed, TS 3.7.10, "Control Room Ventilation (CRV) Filtration," and TS

3. 7 .12, "Fuel Handling Area Ventilation" are proposed for deletion. Therefore, this program is no longer required.

Enclosure to PNP 2021-005 Page 87 of 106 TS 5.5.11, Fuel Oil Testing Program TS 5.5.11 is proposed for deletion. This program implements required testing of both new fuel oil and stored fuel oil to ensure compliance with manufacturer's specifications and applicable ASTM Standards.

As previously discussed, the DGs are no longer included in the POTS. Therefore, this program is no longer required.

TS 5.5.13, Safety Functions TS 5.5.13 is proposed for deletion.

Determination Program (SFDP}

This program was established to ensure loss of safety function is detected and appropriate actions taken when a supported system LCO is not met solely due to a support system LCO not being met. The LCOs remaining in the POTS do not rely on the operability of any active support equipment or systems to satisfy the LCO.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2) and there is no longer a need for redundant systems to mitigate the UFSAR Chapter 14 accidents an transients. Therefore, the requirements of the SFDP, which directs cross train checks of multiple and redundant safety systems, no longer apply. Additionally, the SFDP is invoked in LCO 3.0.6, which is being deleted in its entirety as previously discussed. Therefore, this program is no longer reauired.

TS 5.5.14, Containment Leak Rate TS 5.5.14 is proposed for deletion.

Testing Program After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Containment integrity is not credited in the analysis of the accidents that remain credible in the permanently defueled condition. In addition, TS 3.6.1 through TS 3.6.6 regarding the containment systems are proposed for deletion.

Therefore, this program is no longer required.

Enclosure to PNP 2021-005 Page 88 of 106 TS 5.5.16, Control Room Envelope TS 5.5.16 is proposed for deletion.

Habitability Program After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, an FHA over the reactor core will no longer occur and only an FHA in the SFP is applicable.

As discussed in Section 3.0 of this Enclosure, the revised FHA analysis (Reference 5) concludes that the dose consequences of the FHA will remain within the licensing basis dose limits without crediting CRV filtration assuming 17 days of irradiated fuel decay time following shut down. Consequently, the POTS will not be effective until after that time period.

As discussed in Section 3.0 of this Enclosure, the UFSAR Chapter 14 cask drop analysis concludes that the dose consequences of a cask drop will remain within the licensing basis dose limits without crediting CRV filtration assuming 90 days of irradiated fuel decay time following shut down. There are no SSCs required to mitigate the consequences of a cask drop occurring 90 days after shutdown. A new License Condition 2.C.(5) is proposed to prohibit cask movement in or over the SFP when irradiated fuel assemblies with less than 90 days decay time are in the SFP.

Since the reactor will be permanently defueled, the POTS will not become effective before 17 days of irradiated fuel decay time, and new license condition 2.C.(5) will prohibit cask movement over irradiated fuel assemblies decayed less than 90 days, CRV filtration is no longer required in the POTS. Therefore, this program is no longer required.

Enclosure to PNP 2021-005 Page 89 of 106 TS. 5.5.17, Surveillance Frequency TS 5.5.17 is proposed for deletion.

Control Program The Surveillance Frequency Control Program (SFCP) at PNP was implemented via Amendment 271. PNP will not maintain the SFCP in the permanently shut down and defueled condition. The FREQUENCY of SRs remaining in the POTS will revert to the frequency that was relocated to the SFCP as approved by Amendment 271. See previous discussion of TS 3.7.14 and TS 3.7.15.

Therefore, this program is no longer required.

TS 5.6.2, Radiological Environmental TS 5.6.2 will be retained but modified by replacing Operating Report the reference to the "plant" with the "facility" to reflect the permanently shut down and defueled condition as follows:

"The Radiological Environmental Operating Report covering the operation of the plaAt facility during .. . [for entirety of 5.6.2 text, see Attachment 1]. *

• II TS 5.6.3, Radioactive Effluent Release TS 5.6.3 will be retained but modified by replacing Report the references to the "plant" with the "facility" to reflect the permanently shut down and defueled condition as follows:

"The Radioactive Effluent Release Report covering operation of the plaAt facility in the previous year. .. waste released from the plaAt facility ... .[for entirety of 5.6.3 text, see Attachment 11. .. "

TS 5.6.5, CORE OPERATING LIMITS TS 5.6.5 is proposed for deletion.

REPORT (COLR)

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, there will no longer be an operating core and consequently, no need to establish core operating limits. Therefore, this report is no lonoer reauired.

Enclosure to PNP 2021-005 Page 90 of 106 TS 5.6.6, Post Accident Monitoring Report TS 5.6.6 is proposed for deletion.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Since TS 3.3. 7 is proposed for deletion in its entirety, the post -accident monitoring instrument reporting requirements from TS 3.3.7, Conditions B and G, will also be deleted including the references to TS 5.6.6. Therefore, this report is no longer required.

TS 5.6.7, Containment Structural Integrity TS 5.6.7 is proposed for deletion.

Surveillance Report TS 5.5.5, "Containment Structural Integrity Surveillance Program," is proposed for deletion in its entirety. Therefore, this report is no longer required.

TS 5.6.8, Steam Generator Tube Inspection TS 5.6.8 is proposed for deletion.

Report TS 5.5.8, "Steam Generator (SG) Program,"

which ensures that SG tube integrity is maintained, is proposed for deletion.

Therefore, this report is no longer required.

Enclosure to PNP 2021-005 Page 91 of 106 APPENDIX B Title Page Current Title Proposed Title PALISADES PLANT PALISADES PLANT FACILITY OPERATING LICENSE DPR-20 RENEWED FACILITY OPERATING LICENSE DPR-20 APPENDIX B APPENDIX B ENVIRONMENTAL PROTECTECTION ENVIRONMENTAL PROTECTECTION PLAN (NON-RADIOLOGICAL) PLAN (NON-RADIOLOGICAL)

Appendix Bis modified by replacing the reference to "Facility Operating License" with a reference to "Renewed Facility License." This administrative change reflects that PNP will be permanently shut down and defueled and ensures the title of the EPP correctly references the License title requested in this LAR. The word "Renewed" is also added, administratively, to be consistent with the title of the PNP License.

All changes to the EPP proposed in this LAR are made solely to more accurately reflect the PNP facility after it is permanently shut down and defueled and to ensure the terminology used in the EPP is consistent with that used in the facility license. The proposed changes do not alter the obligations in the environmental area, including, as appropriate, requirements for reporting and keeping records of environmental data, and any conditions and monitoring requirement for the protection of the nonaquatic environment. As such, the changes to the EPP proposed by this LAR are administrative changes only.

Current Table of Contents Proposed Table of Contents 2.2 Terrestrial Issues ....... .. ... .............. 2-2 2.2 Terrestrial Issues ........................ .. 2-2-1 3.1 Plant Design and Operation 3.1 PlaAt Facility Design and Operation 5.4 Plant Reporting Requirements 5.4 PlaAt Facility Reporting Requirements The Table of Contents (TOC) is modified by updating a page number. This administratively corrects a previously existing error in the TOC.

After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). To reflect PNP as a permanently shut down and defueled facility, the EPP is administratively revised to replace the word "Plant" with "Facility" to be consistent with terminology used in the Operating License and the Appendix A Technical Specifications.

Enclosure to PNP 2021-005 Page 92 of 106 Current Section 1.0 Proposed Section 1.0 1.0 "Objectives of the Environmental 1.0 "Objectives of the Environmental Protection Plan" Protection Plan" The Environmental Protection Plan (EPP) is The Environmental Protection Plan (EPP) is to to provide for protection of environmental provide for protection of environmental values values during construction and operation of during oonstruotion and operationhand/ing and the nuclear facility. The principal objectives storage of spent fuel and maintenance of the of the EPP are as follows: nuclear facility. The principal objectives of the EPP are as follows:

(1) Verify that the plant is operated in an (1) Verify that the plant is operatedfacility is environmentally acceptable manner, as maintained in an environmentally established by the FES and other NRC acceptable manner, as established by the environmental impact assessments. FES and other NRC environmental impact assessments.

(2) Coordinate NRC requirements and (2) Coordinate NRC requirements and maintain consistency with other Federal, maintain consistency with other Federal, State and local requirements for State and local requirements for environmental protection. environmental protection.

(3) Keep NRC informed of the environmental (3) Keep NRC informed of the environmental effects of facility construction and effects of handling and storage of spent operation and of actions taken to control fuel and maintenance of the facility-those effects. oonstruotion and operation and of actions taken to control those effects.

Environmental concerns identified in the FES Environmental concerns identified in the FES which relate to water quality matters are which relate to water quality matters are regulated by way of the licensee's NPDES regulated by way of the licensee's NPDES permit. permit.

The proposed administrative changes to Section 1.0 replace a reference to "construction and operation" with a reference to "handling and storage of spent fuel and maintenance," a reference to "plant is operated" with "facility is maintained," and a reference to "facility construction and operation" with "handling and storage of spent fuel and maintenance of the facility." These proposed administrative changes more accurately reflect the revised purpose of the facility in the permanently shut down and defueled condition.

Enclosure to PNP 2021-005 Page 93 of 106 Current Section 2.1 Proposed Section 2.1 2.1 Aquatic Issues 2.1 Aquatic Issues

... The need for aquatic monitoring programs ... The need for aquatic monitoring programs to to confirm that thermal mixing occurs as confirm that thermal mixing occurs as predicted, that chlorine releases are predicted, that chlorine releases are controlled controlled within those discharge within those discharge concentrations concentrations evaluated, and that effects on evaluated, and that effects on aquatic biota aquatic biota and water quality due to plant and water quality due to plaAt facility operation are no greater than predicted ...

operation are no greater than predicted ...

Basis The proposed change to Section 2.1 replaces "plant" with "facility." This proposed administrative change more accurately reflects the revised purpose of the facility in the permanently shut down and defueled condition.

Current Section 3.1 Proposed Section 3.1 3.1 Plant Design and Operation 3.1 PlaAt Facility Design and Operation The licensee may make changes in station The licensee may make changes in statien design or operation or perform tests or facility design or operation or perform tests or experiments ... Changes in plant design or experiments ... Changes in plam-facility design operation or performance of tests or or operation or performance of tests or experiments ... experiments ...

A proposed change, test, or experiment A proposed change, test, or experiment shall ... (2) a significant change in effluents or shall ... (2) a significant change in effluents ei:-

power level [in accordance with 10 CFR Part pewer le1,el [in accordance with 10 CFR Part 51.5(b)(2)] ... 51.5(b)(2)] ...

The proposed changes to Section 3.1 replace references to "station" and "plant" with references to "facility." These proposed administrative changes more accurately reflect the revised purpose of the facility in the permanently shut down and defueled condition.

The proposed change to Section 3.1 to eliminate the reference to "power level [in accordance with 10 CFR Part 51.5(b)(2)]" reflects the permanently shut down and defueled condition. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As such, power operation of PNP will no longer occur and references to power level changes are no longer applicable. This proposed administrative change more accurately reflect the revised purpose of the facility in the permanently shut down and defueled condition.

Enclosure to PNP 2021-005 Page 94 of 106 Current Section 3.3 Proposed Section 3.3 3.3 Changes Required for Compliance with 3.3 Changes Required for Compliance with Other Environmental Regulations Other Environmental Regulations Changes in plant design or operation and ... Changes in f}Jamfacility design or operation and ...

The proposed change to Section 3.3 replaces the reference to "plant" with a reference to "facility." This proposed administrative change more accurately reflects the revised purpose of the facility in the permanently shut down and defueled condition.

Current Section 4.1 Proposed Section 4.1 4.1 Unusual or Important Environmental 4.1 Unusual or Important Environmental Events Events Any occurrence of an unusual or important Any occurrence of an unusual or important event that indicates or could result in event that indicates or could result in significant significant environmental impact causally environmental impact causally related to plaRt related to plant operation shall be recorded operation the handling and storage of spent and ... fuel and maintenance of the facility shall be recorded and .. .

The proposed change to Section 4.1 replaces the reference to "plant operation" with a reference to "the handling and storage of spent fuel and maintenance of the facility" to more accurately reflect the revised purpose of the facility in the permanently shut down and defueled condition. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As such, power operation of PNP will no longer occur and references to plant operation are no longer applicable. This proposed administrative change more accurately reflect the revised purpose of the facility in the permanently shut down and defueled condition and is consistent with Operatina License and Appendix A TS terminoloav proposed in this LAR.

Enclosure to PNP 2021-005 Page 95 of 106 Current Section 5.2 Proposed Section 5.2 5.2 Records Retention 5.2 Records Retention Records and logs relative to the environmental Records and logs relative to the environmental aspects of plant operation shall be made and aspects of previous plant operation and the retained in a manner convenient for review and handling and storage of spent fuel and inspection. These records and logs shall be maintenance of the facility shall be made and made available to the NRC on request. retained in a manner convenient for review and inspection. These records and logs shall be made available to the NRC on request.

Records of modifications to plant structures, Records of modifications to f)lamfacility systems and components determined to structures, systems and components potentially affect the continued protection of determined to potentially affect the continued the environment shall be retained for the life protection of the environment shall be retained of the plant. All other records, data and logs for the life of the f)lamfacility. All other records, relating to this EPP shall be retained for five data and logs relating to this EPP shall be years or, where applicable, in accordance with retained for five years or, where applicable, in the requirements of other agencies. accordance with the requirements of other agencies.

The proposed changes to Section 5.2 clarify that the reference to "plant operation" refers to plant operations previous to the permanent shutdown and includes a reference to "the handling and storage of spent fuel and maintenance of the facility" to more accurately reflect the revised purpose of the facility in the permanently shut down and defueled condition. After the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As such, power operation of PNP will no longer occur and references to plant operation are no longer applicable. This proposed administrative change more accurately reflect the revised purpose of the facility in the permanently shut down and defueled condition and is consistent with the Operating License and Appendix A TS terminology proposed in this LAR.

In addition, references to "plant" are replaced with "facility." These proposed administrative changes reflect the revised purpose of the facility in the permanently shut down and defueled condition.

Current Section 5.4 Current Section 5.4 5.4 Plant Reporting Requirements 5.4 PlaRt Facility Reporting Requirements The proposed change to the title of Section 5.4 replaces the references to "Plant" with a reference to "Facility." This proposed administrative change more accurately reflects the revised purpose of the facility in the permanently shut down and defueled condition.

Enclosure to PNP 2021-005 Page 96 of 106 Current Section 5.4.1 Proposed Section 5.4.1 5.4.1 Routine Reports 5.4.1 Routine Reports

... and an assessment of the observed impacts ... and an assessment of the observed impacts of the plant operation on the environment. ... of the J}laAt facility operation on the environment. ...

(b) A list of all changes in station design or (b) A list of all changes in statioR facility operation, tests, and experiments ... design or operation, tests, and experiments ...

The proposed change to Section 5.4.1 replaces the references to "plant" and "station" with a reference to "facility." This proposed administrative changes more accurately reflect the revised purpose of the facility in the permanently shut down and defueled condition.

Current Section 5.4.2 Proposed Section 5.4.2 5.4.2 Nonroutine Reports 5.4 .2 Nonroutine Reports

... The report shall (a) describe, analyze, ... The report shall (1) describe, analyze, and and evaluate the event, including extent evaluate the event, including extent and and magnitude of the impact and plant magnitude of the impact and J}laAt facility operating characteristics, (2) ... operating characteristics, (2) ...

The proposed change to Section 5.4.2 replaces "plant" with "facility." This proposed administrative change more accurately reflects the revised purpose of the facility in the permanently shut down and defueled condition.

Proposed Changes to the PNP Technical Specifications Bases The mark-ups of the TS Bases are provided in Attachment 3 for information only. Upon approval of this amendment, changes to the TS Bases will be incorporated in accordance with TS 5.5.12, Technical Specifications (TS) Bases Control Program.

4.1 Applicable Regulatory Requirement/Criteria 10 CFR 50.82, Termination of License The 10 CFR 50.82(a)(1) paragraph requires that when a licensee has determined to permanently cease operations the licensee shall, within 30 days, submit a written certification to the NRC, consistent with the requirements of 10 CFR 50.4(b)(8), and once fuel has been permanently removed from the reactor vessel, the licensee shall submit a written certification to the NRC that meets the requirements of 10 CFR 50.4(b)(9). On October 19, 2017, Entergy notified the NRC that PNP would permanently cease operations no later than May 31, 2022 (Reference 1). Entergy recognizes that approval of the proposed changes in this license amendment request is contingent upon the submittal of the certifications required by 10 CFR 50.82(a)(1 ).

Enclosure to PNP 2021-005 Page 97 of 106 The 10 CFR 50.82(a)(2) paragraph states: "Upon docketing of the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel, or when a final legally effective order to permanently cease operations has come into effect, the 10 CFR Part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel."

10 CFR 50.36, Technical Specifications In 10 CFR 50.36, the Commission established its regulatory requirements related to the content of TS. In doing so, the Commission placed emphasis on those matters related to the prevention of accidents and mitigation of accident consequences; the Commission noted that applicants were expected to incorporate into their TS "those items that are directly related to maintaining the integrity of the physical barriers designed to contain radioactivity." (Statement of Consideration, Technical Specification for Facility Licenses; Safety Analysis Reports, 33 FR 18610 (December 17, 1968))

In accordance with 10 CFR 50.36, TS are required to include items in the following five categories: (1) safety limits, limiting safety system settings, and limiting control settings; (2)

LCOs; (3) SRs; (4) design features; and (5) administrative controls. However, the rule does not specify the particular requirements to be included in a facilities' TS.

These criteria, which were subsequently codified in changes to Section 36 of Part 50 of Title 10 of the Code of Federal Regulations (10 CFR 50.36) (60 FR 36953), also pertain to the TS requirements for safe storage of spent fuel. A general discussion of these considerations is provided below to address the existing TS LCOs.

Criterion 1 of 10 CFR 50.36(c)(2)(ii)(A) states that TS LCOs must be established for "installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary." Since no fuel will be present in the reactor at PNP in the permanently shut down and defueled condition, the reactor coolant pressure boundary will not be required and this criterion is not applicable.

Criterion 2 of 10 CFR 50.36(c)(2)(ii)(B) states that TS LCOs must be established for a "process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier." The purpose of this criterion is to capture those process variables that have initial values assumed in the OBA and transient analyses, and which are monitored and controlled during power operation. While this criterion was developed for operating reactors, there are some DBAs which continue to apply to a facility authorized only to handle, store, and possess nuclear fuel. The scope of DBAs applicable to a facility with a reactor that is permanently shut down and defueled is markedly reduced from those postulated for an operating plant. The applicable DBAs for PNP in the permanently defueled condition are discussed in more detail within this license amendment request.

• Criterion 3 of 10 CFR 50.36(c)(2)(ii)(C) states that TS LCOs must be established for SSCs that are part of the primary success path and which function or actuate to mitigate a OBA or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The intent of this criterion is to capture into the TS only those SSCs that are part of the primary success path of a safety sequence analysis. Also captured by this criterion are those support and actuation systems that are necessary for items in the primary success

Enclosure to PNP 2021-005 Page 98 of 106 path to successfully function. The primary success path of a safety sequence analysis consists of the combination and sequences of equipment needed to operate (including consideration of the single failure criterion), so that the plant response to DBAs and transients limits the consequences of these events to within the appropriate acceptance criteria. While there are no transients that will continue to apply to PNP, there are still DBAs that will continue to apply to a facility authorized only to handle, store, and possess nuclear fuel. The scope of DBAs applicable to a facility with a reactor that is permanently shut down and defueled is markedly reduced from those postulated for an operating plant. The scope of DBAs that will be applicable to PNP is discussed in more detail within this license amendment request.

Criterion 4 of 10 CFR 50.36(c)(2)(ii)(D) states that TS LCOs must be established for SSCs that operating experience or probabilistic risk assessment has shown to be significant to public health and safety. The intent of this criterion is that risk insights and operating experience be factored into the establishment of TS LCOs. All of the accident sequences that previously dominated risk at PNP will no longer be applicable after the reactor is in the permanently shut down and defueled condition.

Addressing administrative controls, 10 CFR 50.36(c)(5) states that they " ... are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner." This license amendment request is proposing changes to the Administrative Controls section, with conforming changes proposed to additional sections, consistent with the pending decommissioning status of the plant. This request applies the principles identified in 10 CFR 50.36(c)(6), Decommissioning, for a facility which has submitted certifications required by 50.82(a)(1) and proposes changes to the Administrative Controls appropriate for the PNP permanently defueled condition. As 10 CFR 50.36(c)(6) states, this type of change should be considered on a case-by-case basis.

The 10 CFR 50.36(c)(6) provisions apply only to nuclear power reactor facilities that have submitted the certifications required by 10 CFR 50.82(a)(1). For such facilities, TS involving safety limits, limiting safety system settings, and limiting control system settings; limiting conditions for operation; surveillance requirements; design features; and administrative controls will be developed on a case-by-case basis.

This proposed amendment deletes the portions of the previous PNP TS that are no longer applicable to a permanently defueled facility while modifying the remaining portions to correspond to the permanently shut down and defueled condition.

10 CFR 50.48{f), Fire Protection During Decommissioning The 10 CFR 50.48(f) paragraph states, in part, that: "Licensees that have submitted the certifications required under 10 CFR 50.82(a)(1) shall maintain a fire protection program to address the potential for fires that could cause the release or spread of radioactive materials (i.e., that could result in a radiological hazard) ...

(1) The objectives of the fire protection program are to-(i) Reasonably prevent these fires from occurring; (ii) Rapidly detect, control, and extinguish those fires that do occur and that could result in a radiological hazard; and

Enclosure to PNP 2021-005 Page 99 of 106 (iii) Ensure that the risk of fire-induced radiological hazards to the public environment and plant personnel is minimized.

(2) The licensee shall assess the fire protection program on a regular basis. The licensee shall revise the plan as appropriate throughout the various stages of facility decommissioning.

(3) The licensee may make changes to the fire protection program without NRC approval if these changes do not reduce the effectiveness of fire protection for facilities, systems, and equipment that could result in a radiological hazard, taking into account the decommissioning plant conditions and activities."

10 CFR 50.51, Continuation of License The 10 CFR 50.51(b) paragraph states: "Each license for a facility that has permanently ceased operations, continues in effect beyond the expiration date to authorize ownership and possession of the production or utilization facility, until the Commission notifies the licensee in writing that the license is terminated. During such period of continued effectiveness the licensee shall:

(1) Take actions necessary to decommission and decontaminate the facility and continue to maintain the facility, including, where applicable, the storage, control and maintenance of the spent fuel, in a safe condition, and (2) Conduct activities in accordance with all other restrictions applicable to the facility in accordance with the NRC regulations and the provisions of the specific 10 CFR part 50 license for the facility."

10 CFR 50, Appendix A. General Design Criteria for Nuclear Power Plants PNP design and licensing basis for fuel storage and handling and radiological controls is detailed in the UFSAR Section 5.1 and other plant-specific licensing basis documents.

10 CFR 50.46, Acceptance Criteria for Emergency Core Cooling Systems for Light-Water Nuclear Power Reactors The 10 CFR 50.46(a)(1 )(i) paragraph states: "This section does not apply to a nuclear power reactor facility for which the certifications required under 10 CFR 50.82(a)(1) have been submitted."

10 CFR 50.62, Requirements for Reduction of Risk from Anticipated Transients Without Scram (ATWS) Events for Light-Water-Cooled Nuclear Power Plants The 10 CFR 50.62(a) paragraph states: "The requirements of this section apply to all commercial light-water-cooled nuclear power plants, other than nuclear power reactor facilities for which the certifications required under 10 CFR 50.82(a)(1) have been submitted."

Design Basis Accidents {DBAs)

Chapter 14 of the PNP UFSAR describes the OBA scenarios that are applicable during plant operations. After certifications for permanent cessation of operations and permanent

Enclosure to PNP 2021-005 Page 100 of 106 removal of fuel from the reactor vessel are submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and they are docketed for PNP, the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel in accordance with 10 CFR 50.82(a)(2). With the reactor in a permanently shut down and defueled condition, the facility purpose changes. The primary purpose becomes the safe storage and handling of irradiated fuel. In this condition, the spectrum of credible accidents is much smaller than for an operational plant. Therefore, most of the accident scenarios postulated in UFSAR Chapter 14 will no longer be applicable after PNP is in the permanently defueled condition. The only remaining DBAs will be the fuel cask drop, the FHA in the fuel handling building, and the accidental release of waste liquid or waste gas. This license amendment request includes additional discussion regarding the analyses of these accidents.

4.2 Precedent The proposed changes to the PNP RFOL, the Appendix A TS, and the Appendix B EPP are consistent with the intent of the license and accompanying PDTS and EPP issued to facilities that have been permanently shut down and defueled:

• Fort Calhoun Station, for which an amendment was issued on March 6, 2018 (Reference 11),

• Oyster Creek Nuclear Generating Station, for which an amendment was issued on October 26, 2018 (Reference 12),

• San Onofre Nuclear Generating Station, Units 2 and 3, for which an amendment was issued on July 17, 2015 (Reference 13),

• Crystal River Nuclear Plant, Unit 3, for which an amendment was issued on September 4, 2015 (Reference 14),

• Pilgrim Nuclear Power Station, for which an amendment was issued on October 28, 2019 (Reference 15), and

• Indian Point Nuclear Generating Plant, Unit 2, for which an amendment was issued on April 28, 2020 (Reference 16).

4.3 No Significant Hazards Consideration Determination In accordance with 10 CFR 50.92, Issuance of amendment, Entergy Nuclear Operations, Inc.

(Entergy) has reviewed the proposed changes and concludes that the changes do not involve a significant hazards consideration since the proposed changes satisfy the criteria in 10 CFR 50.92(c). These criteria require that operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

On October 19, 2017, Entergy notified the U.S. Nuclear Regulatory Commission (NRG) that it would permanently cease power operations at Palisades Nuclear Plant (PNP) no later than May 31, 2022 (Reference 1). After the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel are docketed for PNP, the 10 CFR Part 50 license for PNP will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel, in accordance with 10 CFR 50.82(a)(2).

Enclosure to PNP 2021-005 Page 101 of 106 This proposed license amendment would revise the PNP Renewed Facility Operating License (RFOL), revise the Technical Specifications (TS) in Appendix A to Permanently Defueled Technical Specifications (POTS), and revise the Environmental Protection Plan (EPP) in Appendix B. The proposed changes are consistent with the permanent cessation of operations and permanent removal of fuel from the reactor vessel. The proposed changes would revise certain requirements contained within the PNP RFOL and TS and remove the requirements that would no longer be applicable after PNP is permanently shut down and defueled.

The existing PNP Appendix A TS contain Limiting Conditions for Operation (LCOs) that provide for appropriate functional capability of equipment required for safe operation of the facility, including the plant being in a defueled condition. Since the safety function related to safe storage and management of irradiated fuel at an operating plant is similar to the corresponding function at a permanently defueled facility, the existing Appendix A TS provide an appropriate level of control. However, the majority of the existing TS are only applicable with the reactor in an operational mode. LCOs and associated Surveillance Requirements (SRs) that will not apply in the permanently defueled condition are being proposed for deletion. The remaining portions of the Appendix A TS are being proposed for revision and incorporation as the POTS to provide a continuing acceptable level of safety which addresses the reduced scope of postulated design basis accidents (DBAs) associated with a defueled facility.

The discussion below addresses each 10 CFR 50.92(c) no significant hazards consideration criterion and demonstrates that the proposed amendment does not constitute a significant hazard.

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

Response: No.

The proposed amendment would not take effect until PNP has permanently ceased operation, entered a permanently defueled condition, met the irradiated fuel assembly decay requirement of 17 days, established in the analysis of the fuel handling accident (FHA), implemented NRC approved License Amendments regarding fuel storage requirements and administrative controls for the permanently defueled condition, and received NRC approval of the Certified Fuel Handler Training and Retraining Program. The proposed amendment would modify the PNP RFOL, the Appendix A TS, and the Appendix B EPP by deleting the portions of the RFOL and TS that are no longer applicable to a permanently defueled facility, while modifying other portions of the RFOL and the TS, as well as portions of the EPP, to correspond to the permanently defueled condition. These proposed changes are consistent with the criteria set forth in 10 CFR 50.36, Technical Specifications, for the contents of TS.

Chapter 14 of the PNP Updated Final Safety Analysis Report (UFSAR) describes the OBA and transient scenarios applicable to PNP during plant operations. After the reactor is in a permanently defueled condition, the spent fuel pool (SFP) and its cooling systems will be dedicated only to spent fuel storage. In this condition, the spectrum of credible accidents will be much smaller than for an operational plant.

After the certifications are docketed for PNP in accordance with 10 CFR 50.82(a)(1),

and the consequent removal of authorization to operate the reactor or to place or

Enclosure to PNP 2021-005 Page 102 of 106 retain fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2), the majority of the accident scenarios previously postulated in the UFSAR will no longer be applicable and will be removed from the UFSAR under the provisions of 10 CFR 50.59.

The deletion of TS definitions and rules of usage and application requirements that will not be applicable in a defueled condition has no impact on facility structures, systems, and components (SSCs) or the methods of operation of such SSCs. The deletion of design features and safety limits not applicable to the permanently shut down and defueled status of PNP has no impact on the remaining applicable DBAs.

The removal of LCOs or SRs that are related only to the operation of the nuclear reactor or only to the prevention, diagnosis, or mitigation of reactor-related transients or accidents do not affect the applicable DBAs previously evaluated since these DBAs are no longer applicable in the permanently defueled condition.

The safety functions involving core reactivity control, reactor heat removal, primary coolant system (PCS) inventory control, and containment integrity are no longer applicable at PNP as a permanently shut down and defueled facility. The analyzed accidents involving damage to the PCS, main steam lines, reactor core, and the subsequent release of radioactive material will no longer be applicable to PNP.

After PNP permanently ceases operation, the future generation of fission products will cease and the remaining source term will decay. The radioactive decay of the irradiated fuel following shut down of the reactor will have reduced the consequences of the FHA such that mitigating SSCs are not required to maintain regulatory limits.

The SFP water level, boron concentration, and fuel storage TS are retained to preserve the current requirements for safe storage of irradiated fuel. SFP cooling and make-up related equipment and support equipment (e.g., electrical power systems) are not required to be continuously available since there will be sufficient time to effect repairs, establish alternate sources of make-up flow, or establish alternate sources of cooling in the event of a loss of cooling and make-up flow to the SFP.

The deletion and modification of provisions of the administrative controls of the Appendix A TS and the non-radiological environmental protection requirements in Appendix B do not directly affect the design of SSCs necessary for safe storage of irradiated fuel or the methods used for handling and storage of such fuel in the SFP.

The changes do not affect any accidents applicable to the safe management of irradiated fuel or the permanently shut down and defueled condition of the reactor.

The probability of occurrence of previously evaluated accidents is not increased since extended operation in a defueled condition will be the only operation allowed, and therefore bounded by the existing analyses. Additionally, the occurrence of postulated accidents associated with reactor operation will no longer be credible in a permanently defueled reactor. This significantly reduces the scope of applicable accidents.

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

Enclosure to PNP 2021-005 Page 103 of 106

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

Response: No.

The proposed changes to the PNP RFOL, the Appendix A TS, and the Appendix B EPP have no impact on facility SSCs affecting the safe storage of irradiated fuel, or on the methods of operation of such SSCs, or on the handling and storage of irradiated fuel itself. The removal of TS that are related only to the operation of the nuclear reactor or only to the prevention, diagnosis, or mitigation of reactor-related transients or accidents, cannot result in different or more adverse failure modes or accidents than previously evaluated because the reactor will be permanently shut down and defueled and PNP will no longer be authorized to operate the reactor.

The proposed deletion and modification of requirements of the PNP RFOL and Appendices A and B do not affect systems credited in the accidents that remain applicable at PNP in the permanently defueled condition. The proposed RFOL and TS will continue to require proper control and monitoring of safety significant parameters and activities.

The Appendix A TS regarding SFP water level, boron concentration, and fuel storage are retained to preserve the current requirements for safe storage of irradiated fuel in the SFP. The proposed amendment does not result in any new mechanisms that could initiate damage to the remaining relevant safety barriers for defueled plants (fuel cladding and spent fuel cooling). Since extended operation in a defueled condition will be the only operation allowed, and therefore bounded by the existing analyses, such a condition does not create the possibility of a new or different kind of accident.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any previously evaluated.

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

Response: No.

Because the 10 CFR Part 50 license for PNP will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel after the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP as specified in 10 CFR 50.82(a)(2), the occurrence of postulated accidents associated with reactor operation are no longer credible. The only remaining credible accidents are the fuel cask drop, the FHA, and the accidental release of waste liquids or waste gas. The proposed amendment does not adversely affect the inputs or assumptions of any of the design basis analyses that impact the remaining DBAs.

The proposed amendment would modify the PNP RFOL and Appendices A and B by deleting the portions of the RFOL and TS that are no longer applicable to a permanently defueled facility, while modifying other portions to correspond to the permanently defueled condition. The requirements that are proposed to be deleted from the PNP RFOL and Appendix A TS are not credited in the accident analyses for the remaining DBAs; and as such, do not contribute to the margin of safety

Enclosure to PNP 2021-005 Page 104 of 106 associated with the accident analyses. Postulated DBAs involving the reactors will no longer be applicable because the reactor will be permanently shut down and defueled and PNP will no longer be authorized to operate the reactor.

The Appendix A TS regarding SFP water level, boron concentration, and fuel storage are retained to preserve the current requirements for safe storage of irradiated fuel in the SFP.

Therefore, the proposed amendment does not involve a significant reduction in the margin of safety.

Based on the above, Entergy concludes that the proposed amendment presents no 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.

4.4 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.

5.0 ENVIRONMENTAL EVALUATION This amendment request meets the eligibility criteria for categorical exclusion from environmental review set forth in 10 CFR 51 .22(c)(9) as follows:

(i) The amendment involves no significant hazards consideration.

As described in Section 4.3 of this evaluation, the proposed amendment involves no significant hazards consideration.

(ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

The proposed amendment does not involve any physical alterations to the facility configuration that could lead to a change in the type or amount of effluent release offsite.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed amendment does not involve a significant increase individual or cumulative occupational radiation exposure.

Based on the above, Entergy concludes that the proposed change meets the eligibility criteria for categorical exclusion as set forth in 10 CFR 51.22(c)(9). In accordance with 10 CFR 51.22(b}, no environmental impact statement or environmental assessment need be

Enclosure to PNP 2021-005 Page 105 of 106 prepared in connection with the issuance of this amendment.

6.0 REFERENCES

1. Letter, Entergy Nuclear Operations, Inc., to U.S. Nuclear Regulatory Commission, "Supplement to Certification of Permanent Cessation of Power Operations," (ADAMS Accession No. ML17292A032), dated October 19, 2017

2. Letter, Entergy Nuclear Operations, Inc., to U. S. Nuclear Regulatory Commission, "Application for Order Consenting to Transfers of Control of Licenses and Approving Conforming License Amendments," (ADAMS Accession No. ML20358A075), dated December 23, 2020

3. Letter, U.S. Nuclear Regulatory Commission, to Entergy Nuclear Operations, Inc.,

"Palisades Plant - Issuance of Amendment Re: Palisades Spent Fuel Pool Crane Upgrade," (ADAMS Accession No. ML041600035), dated June 16, 2004

4. Letter, U.S. Nuclear Regulatory Commission, to Entergy Nuclear Operations, Inc.,

"Palisades Plant- Issuance of Amendment Re: Alternative Radiological Source Term,"

(ADAMS Accession No. ML072470676), dated September 28, 2007

5. Calculation No. EA-EC89582-01, Revision 0, "Post-Permanent Shutdown Fuel Handling Accident and Waste Gas Tank Rupture," dated April 26, 2021

6. Letter, U.S. Nuclear Regulatory Commission, to Entergy Nuclear Operations, Inc.,

"Palisades Plant - Issuance of Amendment Regarding Administrative Controls for Permanently Defueled Condition," (ADAMS Accession No. ML18114A410), dated June 4,2018

7. Letter, Entergy Nuclear Operations, Inc., to U.S. Nuclear Regulatory Commission, "Completion of Activities to Support Entry Into the Period of Extended Operation,"

(ADAMS Accession No. ML110830011), dated March 23, 2011

8. Letter, U.S. Nuclear Regulatory Commission, to Entergy Nuclear Operations, Inc.,

"Palisades Plant - Issuance of Amendment No. 271 Regarding Adoption of TSTF-425, Relocate Surveillance Frequencies to License Control - RITSTF Initiative 58," (ADAMS Accession No. ML19317D855), dated December 30, 2019

9. Letter, U.S. Nuclear Regulatory Commission, to Nuclear Management Company, LLC, "Palisades Plant - Issuance of Amendment Re: Elimination of Requirements for Post

-Accident Sampling Systems," (ADAMS Accession No. ML010670348), dated March 7, 2001

10. Letter, U.S. Nuclear Regulatory Commission, to Entergy Nuclear Operations, Inc.,

"Palisades Nuclear Plant- Issuance of Amendment Re: Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, "TS lnservice Testing Program Removal

& Clarify SR Usage Rule Application to Section 5.5 Testing," (ADAMS Accession No. ML17082A465), dated May 30, 2017

Enclosure to PNP 2021-005 Page 106 of 106

11. Letter, U. S. Nuclear Regulatory Commission, to Omaha Public Power District, "Fort Calhoun Station, Unit 1 - Issuance of Amendment Re: Revised Technical Specifications to Align to Those Requirements for Decommissioning (CAC No.

MF9567; EPID L-2017-LLA-0192)," (ADAMS Accession No. ML18010A087),

dated March 6, 2018

12. Letter, U.S. Nuclear Regulatory Commission, to Exelon Nuclear, Oyster Creek "Nuclear Generating Station - Issuance of Amendment Re: License Amendment Request for Proposed Defueled Technical Specifications and Revised License Conditions for Permanently Defueled Condition (EPID L-2017-LLA-0395)," (ADAMS Accession No. ML18227A338), dated October 26, 2018

13. Letter, U.S. Nuclear Regulatory Commission, to Southern California Edison Company, "San Onofre Nuclear Generating Station, Units 2 and 3 - Issuance of Amendment for Permanently Shutdown and Defueled Operating License and Technical Specifications (TAC Nos. MF3774 and MF3775)," (ADAMS Accession No. ML15139A390), dated July 17, 2015

14. Letter, U.S. Nuclear Regulatory Commission, to Crystal River Nuclear Plant, "Crystal River Unit 3 Nuclear Generating Plant- Issuance of Amendment for Permanently Shutdown and Defueled Operating License and Technical Specifications (TAC No.

MF3089)," (ADAMS Accession No. ML15224B286), dated September 4, 2015

15. Letter, U. S. Nuclear Regulatory Commission, to Holtec Decommissioning International, LLC, "Pilgrim Nuclear Power Station - Issuance of Amendment No. 250 Re: Permanently Defueled Technical Specifications (EPID L-2018-LLA-0268),"

(ADAMS Accession No. ML19275E425), dated October 28, 2019

16. Letter, U.S. Nuclear Regulatory Commission, to Entergy Nuclear Operations, Inc.,

"Indian Point Nuclear Generating Unit No. 2 - Issuance of Amendment No. 294 Re:

Permanently Defueled Technical Specifications (EPID L-2019-LLA-0079)," (ADAMS Accession No. ML20081J402), dated April 28, 2020 7.0 ATTACHMENTS

1. Proposed Changes (mark-up) to Palisades Plant Renewed Facility Operating License DPR-20, Appendix A Technical Specifications, and Appendix B Environmental Protection Plan Pages

2. Page Change Instructions and Retyped Pages for the Palisades Plant Renewed Facility License DPR-20, Appendix A Permanently Defueled Technical Specifications, and Appendix B Environmental Protection Plan

3. Proposed Technical Specifications Bases Changes (for information only)