PNP 2023-002, 6 to Updated Final Safety Analysis Report

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6 to Updated Final Safety Analysis Report
ML23107A064
Person / Time
Site: Palisades Entergy icon.png
Issue date: 03/31/2023
From: Fleming J
Holtec Decommissioning International
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML23107A065 List: ... further results
References
HDI PNP 2023-002
Download: ML23107A064 (300)


Text

SECURITY-RELAED INFORMATION H*o*L TEC OECOMMDSSUOINIIINIG I NITfERINIA HO INlA L Withhold Under 10 CFR 2.390 Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856} 797-0900 Fax (856) 797-0909 HDI PNP 2023-002 10 CFR 50.71(e) 10 CFR 50.4(b)(6)

March 31, 2023 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Palisades Nuclear Plant Docket No. 50-255 Renewed Facility Operating License No. DPR-20

Subject:

Final Safety Analysis Report Update Revision 36 In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Sections 50.71, Maintenance ofrecords, making of reports, paragraph (e), 10 CFR 50.71 (e), and 50.4, Written communications, paragraph (b)(6), 10 CFR 50.4(b)(6), Holtec Decommissioning International, LLC (HDI) on behalf of Holtec Palisades, LLC (Holtec Palisades) is providing the Palisades Nuclear Plant (PNP) Final Safety Analysis Report (FSAR) update, Revision 36. Revision 36

-includes changing the FSAR title to Defueled Safety Analysis Report (DSAR) reflecting the transition of PNP to a permanently defueled facility.

Since incorporation of the DSAR changes resulted in a major rewrite of the FSAR, revision bars were not used to denote the changes. All changes, other than those involving typographical corrections, format changes, and removed obsolete information, were made under the provisions of 10 CFR 50 or in accordance with safety evaluations received from the Nuclear Regulatory Commission (NRG). The FSAR update incorporates changes made to the facility or the procedures described in the FSAR, and all other applicable information and analyses submitted to the NRG or prepared pursuant to NRG Requirements, up to October 14, 2022, which is 18 months since the last UFSAR submittal on April 14, 2021.

DSAR Revision 36 is provided, in its entirety, on the CD-ROMs in the enclosures.

Enclosure 1 contains the list of changes included in FSAR Revision 36. Attachment 1 to Enclosure 1 contains the list of changes specific to system classification changes as a result of transitioning to a defueled facility. Attachment 2 to Enclosure 1 contains the list of changes specific to the implementation of the permanently defueled technical specifications at PNP.

Enclosure 2 contains a public version of the updated FSAR (Revision 36), with certain information redacted in accordance with NRG Regulatory Issue Summary (RIS) 2015-17, NOTICE: Enclosure 3 to this letter contains sensitive unclassified information. Upon separation of Enclosure 3 from this letter, this document becomes "DECONTROLLED."

SECURITY-RELAED INFORMATION Withhold Under 10 CFR 2.390

SECURITY-RELAED INFORMATION HDI PNP 2023-002 Withhold Under 10 CFR 2.390 Page 2 of 2 Review and Submission of Updates to Final Safety Analysis Reports, Emergency Preparedness Documents, and Fire Protection Documents. contains a non-public version (non-redacted) of the updated FSAR (Revision 36). contains security-related information, and HDI requests that this enclosure be withheld from public disclosure under 10 CFR 2.390, Public Inspections, exemptions, and requests for withholding, paragraph (d)(1 ).

For this FSAR update, no information has been removed in accordance with Appendix A to Nuclear Energy Institute (NEI) 98-03, Revision 1, Guidelines for Updating Final Safety Analysis Reports, as endorsed by Regulatory Guide 1.181, Content of the Updated Final Safety Analysis Report in Accordance with 10 CFR 50. 71(e).

This letter contains no new regulatory commitments and no revised commitments.

Should you have any questions or require additional information, please contact Jim Miksa, Regulatory Assurance Engineer at (269) 764-2945.

I declare under penalty of perjury that the foregoing is true and correct. Executed on March 30, 2023.

Respectfully, Jean A. Fleming Vice President, of Licensing, Regulatory Affairs & PSA Holtec International Enclosures 1 : Palisades Nuclear Plant Final (Defueled) Safety Analysis Report (FSAR/DSAR) Revision 36 List of Changes 2: CD-ROM Containing Final (Defueled) Safety Analysis Report (FSAR/DSAR)

Revision 36 (Public Version) 3: CD-ROM Containing Final (Defueled) Safety Analysis Report (FSAR/DSAR)

Revision 36 (Non-Public Version) (Security-Related Information, Withhold Under 10 CFR 2.390) cc: NRC Region Ill Regional Administrator NRC Decommissioning Inspector - Palisades Nuclear Plant NRC NMSS Project Manager - Palisades Nuclear Plant NOTICE: Enclosure 3 to this letter contains sensitive unclassified information. Upon separation of Enclosure 3 from this letter, this document becomes "DECONTROLLED."

SECURITY-RELAED INFORMATION Withhold Under 10 CFR 2.390

HDI PNP 2023-002 Page 1 of 8 Enclosure 1 to HDI PNP 2023-002 Palisades Nuclear Plant Final (Defueled) Safety Analysis Report (FSAR/DSAR) Revision 36 List of Changes

HDI PNP 2023-002 Page 2 of 8 Palisades Nuclear Plant Final (Defueled) Safety Analysis Report (FSAR/DSAR) Revision 36 List of Changes Log Affected FSAR/DSAR Sections, No. Figures, and Tables Description of Change EC 78385 installs a new skid mounted Sodium Hypochlorite delivery method for the Service Water Pump Bay and the Cooling 18-0032 Figure 9-1 Sh 1A and Figure 9-1 Sh 2 Tower/Condenser loops (A&B). FSAR Figure 9-1 Sh 1A and 9-1 Sh 2 are impacted by this change.

EC 88999, "Primary Coolant Pump Uncontrolled Bleed-off Re Alignment to Containment Sump," reconfigured the Flow Path of the Primary Coolant FSAR Figure 11-1 Sh 2, FSAR Pump vapor seal leakage from the Primary System Drain Tank to the Chapter 4 References, FSAR Section Containment Sump.21-001 4.3.5, FSAR Section 4.7, FSAR Table 11-2, FSAR Table 11-5 The DSAR revisions to the FSAR superseded the changes to FSAR Chapter 4 References, FSAR Section 4.3.5, FSAR Section 4.7, and FSAR Table 11-2.

Editorial change to FSAR Figure 6-2 Sh 1B. The figure has been revised to 21-002 Figure 6-2 Sh 1B correct a reference to E-904 Sh 1.

Surveillance Test Interval (STI) evaluation, STl-2021-001, changed the Tech Spec surveillance requirements (3.3.2.1 and 3.3.3.2) from 92 to 184 days in accordance with the Surveillance Frequency Control Program.21-004 Appendix 7A Section 7A.1.1 .1 FSAR sections were revised to reflect the changes in frequency.

The DSAR revisions to the FSAR superseded the changes to FSAR Appendix 7A Section 7A.1.1.1.

HDI PNP 2023-002 Page 3 of 8 Log Affected FSAR/DSAR Sections, No. Figures, and Tables Description of Change EC 89044, "C-7 Back up Extractor." This EC adds a new manual valve to 21-005 Figure 9-9 Sh 1 the Service Air System to throttle service air for C-917 "C-7 Back up Extractor".

EC 90144 changed the position of MV-DMW773, "Spent Fuel Pool PMW 21-006 Figure 9-18 Sh 1A Fill Isolation," from locked closed to closed.

EC 89606, "Revise Engineered Safeguards Room Heatup Calculations,"

replaces references to EA-D-PAL-93-242F-01, Revision 1, "Engineered Safeguards Room Heatup following LOCA in Conjunction with a LOOP,"

Section 9.8, Section 9 References, and with EA-EC516-05, Revision 1, "Calculation of Engineered Safeguards21-007 Table 9-1 Room Temperature Following a LOCA."

The DSAR revisions to the FSAR superseded the changes to FSAR Section 9.8, Section 9 References, and Table 9-1.

Administrative change to reinstate Fig.8-3, Sh 2 that was removed in error 21-008 Figure 8-3, Sh 2 during a previous FSAR update.

EC 90291 modifies the non-critical service water system by adding a new 21-010 Figure 9-1 and Table 9-1 pipeline, heat exchanger and valves to support the addition of E-924, "Plant HTG Condensate Return Heat Exchanger."

Administrative change to Figure 10-1. To replace an electronic document 21-011 Figure 10-1 copy that was illegible when magnified with a clearer electronic copy.

HDI PNP 2023-002 Page 4 of 8 Log Affected FSAR/DSAR Sections, No. Figures, and Tables Description of Change Offsite Dose Calculation Manual (ODCM) Radiological Environmental Monitoring Program (REMP), Revision 32 change which enhanced the 21-012 Section 2.6.3 and Table 2-20 REMP thermoluminescent dosimeters (TLD) program by reducing the number of control TLDs from 3 to 1 and relocating 4 TLDs. FSAR revised to reflect the reduction in control TLDs.

Renewed Facility Operating License (RFOL) Amendment 266, Administrative Controls for a Permanently Defueled Condition, Amendment 272, Technical Specifications for Permanently Defueled Condition, and Exemption from 10 CFR 73.55 allowing CFH to suspend security measures22-001 See Attachment 2 implementation. Amendment 272 retitled the PNP UFSAR to a Defueled Safety Analysis Report (DSAR) which revised every UFSAR page.

See HDI PNP 2023-002 Enclosure 1, Attachment 2 for specific change details.

ADMIN 7.28, "Diesel Fuel Oil Program," procedure implementation to Section 1.9.1.9, reflect Palisades Permanently Defueled Technical Specifications. FSAR 22-002 Chapter 1 References, Number 36 revised to remove reference to a duplicate ASTM diesel fuel centrifuge method.

Surveillance Test Interval (STI) evaluation, STl-2022-001, changed the Tech Spec surveillance requirements (3.3.1.5 and 3.3.3.2) from 92 to 184 days in accordance with the Surveillance Frequency Control Program.

Appendix 7A Section 7A.1.1.1,22-003 FSAR sections were revised to reflect the changes in frequency.

Appendix 7A Section 7A.1.1.3 The DSAR revisions to the FSAR superseded the changes to FSAR Appendix 7A Sectio_n 7A.1.1.1 and Appendix 7A Section 7A.1.1.3.

HDI PNP 2023-002 Page 5 of 8 Log Affected FSAR/DSAR Sections, No. Figures, and Tables Description of Change Offsite Dose Calculation Manual (ODCM), Revision 33, incorporated changes to the ODCM due to implementation of Renewed Facility Operating License Amendment 272, Permanently Defueled Technical 22-005 Section 11.5.4 Specifications. ODCM Revision 33 changes resulted in revision to FSAR section 11.5.4.

Section 5.1.3.8, Section 8.1.2, Section 8.2.2, 8.2.3, Section 8.3.1.1, 8.3.1.2, 8.3.1.3, Section 8.3.2.1, 8.3.2.2, 8.3.2.3, Section 8.4.1.2, EC92138, Permanently Air Gap Motor Operated Switch 26H5 to Support 22-006 Section 8.6.2, Unenrollment from NERC Following Permanent Plant Shutdown, removed Figure 7.14 Sh 2, MOD-26H5 to disconnect the Main Transformer (EX-10) from the grid.

I Figure 7.14 Sh 10, Figure 8.1 Sh 1, Figure 8.2, Figure 8.3 Sh 1

HDI PNP 2023-002 Page 6 of 8 Log Affected FSAR/DSAR Sections, No. Figures, and Tables Description of Change Section 1.1.2, Section 2.1, Section 2.5.2.3, Section 5.2.2.8, '

Section 12.1.1, Renewed Facility Operating License (RFOL) Amendment 273, Transfer of Section 12.2.1.2, Palisades Facility ownership and operating license from Entergy Nuclear Section 12.3.1, Palisades, LLC to Holtec Palisades, LLC and from Entergy Nuclear 22-007 Section 12.4, Operations, Inc. to Holtec Decommissioning International, respectively.

Section 15.1.1, 15.1.2 Implementation of RFOL Amendment 273 revised the listed DSAR sections Figure 12-1 to reflect this change in ownership.

Table 1-1 Table 1-9 Table of Contents EC 92298, 25F7, Generator Breaker, and 25H9, Generator Breaker, relay modification to remove trip function that opens the main generator output Section 8.2 breakers.

Figure 7.14 Sh. 1 22-010 Figure 7.14 Sh. 2 The DSAR revisions to the FSAR superseded the changes to Figure 7.14 Sh. 10 Figure 7.14 Sheet 1, Figure 7.14 Sh. 2, and Figure 7.14 Sh. 10. Section 8.2 changes were incorporated into the DSAR.

HDI PNP 2023-002 Page 7 of 8 Log Affected FSAR/DSAR Sections, No. Figures, and Tables Description of Change Section 3.3 Section 4.2, 4.3, 4.5, 4.8 Section 5.1, 5.2, 5.5, 5.7, 5.8 Section 6.1, 6.2, 6.3, 6.4, 6.10 EC92577, "Decommissioning Equipment Classification and FSAR Section 7.1, 7.2, 7.4, 7.6, 7.7 Markups," revised structures, systems, and component (SSC) safety Section 8.1, 8.2, 8.3, 8.4, 8.5, 8.7 classifications to reflect a permanently defueled reactor. The FSAR Section 9.1, 9.2, 9.3, 9.4, 9.5, 9.7, 9.8,22-012 revisions were made to reflect these changes.

9.10, 9.11 Section 10.1 See HDI PNP 2023-002 Enclosure 1, Attachment 1 for specific change Table 4.2 details.

Table 5.2-1, 5.2-2, 5.2-3, 5.2-4, 5.2-5 Table 5.4-1 Table 9.1 Table 9.9 EC92493- "Administrative Engineering Change to correct drawing E0017-0017 (Rev. 3) to show the proper logic per CR-PLP-2022-00392" EC92493.22-013 Figure 7.14 Sh. 10 The DSAR revisions to the FSAR superseded the changes to Figure 7.14 Sheet 10.

Section 8.4 Section 8.5 Renewed Facility Operating License Amendment 272, Defueled Technical Section 8.9 Specifications revised the Palisades fire protection program requirements.

Section 9.5 22-014 These changes to the FSAR were made to reflect implementation of the Section 9.6 defueled fire protection program requirements at Palisades.

Section 9.10 Table 9-21 Table of Contents

HDI PNP 2023-002 Page 8 of 8 Log Affected FSAR/DSAR Sections, No. Figures, and Tables Description of Change Renewed Facility Operating License Amendment 273, the transfer of Palisades RFOL and General license for Dry Fuel Storage from Entergy Section 1.8 Nuclear Operations, Inc. (Entergy) to Holtec Decommissioning Section 12.1 International, LLC (HDI) implementation included the adoption for the DOI 22-017 Section 15.1 Decommissioning Quality Assurance Program (DQAP) at Palisades. The Table 1-5 changes to the FSAR were made to reflect implementation of the DQAP at Table of Contents Palisades.

Attachments: 1. LBDCR Log Number 22-012, Decommissioning Equipment Classification, Description of Changes - Details

2. LBDCR Log Number 22-001, Permanently Defueled Technical Specifications, Description of Changes -

Details

HDI PNP 2023-002 Page 1 of 7 Attachment 1 to Enclosure 1 HDI PNP 2023-002 Palisades Nuclear Plant LBDCR Log Number 22-012 Decommissioning Equipment Classification Description of Changes - Details

HDI PNP 2023-002 Page 2 of 7 Palisades Nuclear Plant LBDCR Log Number 22-012 Description of Changes - Details Section Title Change Description of Change 3.3 Reactor Design Modify Add statement that the reactor design information in Section 3.3 will be historical/information only and not impose design requirements following defuel.

Mark design requirements (ASME Classes, Seismic Classes, etc. as historical).

The reactor will no longer perform a design function.

4.2 Design Basis Modify Add statement that the PCS design information will be historical/information only (Primary Coolant and not impose design requirements following defuel.

System Chapter) 4.3 System Design Modify Add statement that the PCS design information will be historical/information only and Operation and not impose design requirements following defuel.

4.5 Tests and Modify Add statement that the PCS design information will be historical/information only Inspection and not impose design requirements following defuel.

4.8 Primary Coolant Modify Add statement that the PCS design information will be historical/information only Gas Vent System and not impose design requirements following defuel.

5.1.7.2 General Design Modify Revise statement that Shutdown Cooling may be utilized to augment SFP cooling Criteria - with Service Water System instead. This change is not adverse - procedures Criterion 61 - exist to provide Service Water to the Spent Fuel Pool, the system capacity of the Fuel Storage and Service Water System is sufficient to provide SWS to SFP, and the SWS is a Handling and Seismic Category I system.

Radioactivity Control

HDI PNP 2023-002 Page 3 of 7 Section Title Change Description of Change 5.2 Classification of Modify 5.2.1.1 - Add discussion that SSCs were subjected to reclassification upon Structures, decommissioning of the facility.

Systems, and 5.2.2.4 - Note that QAPM procedures were still utilized to reclassify SSCs for Components decommissioning.

5.2.2. 7 - Note that EQ and 1E requirements are no longer applicable in accordance with 10 CFR 50.49(a).

5.2.2.8.2 - Clarify definition of Important to Safety and Augmented Quality.

5.5 Missile Protection Modify Remove "safety related" in 5.5.1.3.2 and 5.5.4 as the components listed in the sections are no longer SR.

5.7 Seismic Design Modify Add reference to DSAR Tables 5.2-2, 5.2-3, 5.2-4, and 5.2-5 for seismic classification. The design method of seismic evaluation is not altered.

5.8 Containment Modify Note the design information for containment is historic, but that the containment Structure must retain its structural integrity during decommissioning.

6.1 Safety Injection Modify Throughout the section, note that the design requirements are historical as the System systems are no longer SR or AQ.

6.2 Containment Modify Throughout the section, note that the design requirements are historical as the Spray System system is no longer SR or AQ.

6.3 Containment Modify Throughout the section, note that the design requirements are historical as the Air Coolers system is no longer SR or AQ.

6.4 Containment Modify Throughout the section, note that the design requirements are historical as the Sump pH system is no longer SR or AQ.

Control

HDI PNP 2023-002 Page 4 of 7 Section Title Change Description of Change 6.10 Control Room Modify Throughout the section, note that the design requirements are historical as the Habitability system is no longer SR or AQ.

7.1 Instrumentation Modify Note that Class 1E is no longer applicable per 10 CFR 50.49(a).

and Controls Introduction 7.2 Reactor Modify Note that RPS "was" Class 1 instead of "is" Class 1E.

Protective System 7.4 Other Safety Modify Note that the systems listed in the section were reevaluated following permanent Related defuel.

Protection, Control, and Display Systems 7.6 Plant Process Modify Note that Seismic 11/1 am no longer a concern for the PPG as it is longer in the Computer and proximity of the remaining augmented quality electrical cabinets.

Miscellaneous Instrumentation 7.7 Operating Control Modify Remove "safety related" as the cabinets are no longer safety related.

Stations 8.1 Electrical Modify Note that Class 1E is no longer applicable per 10 CFR 50.49(a) and that Systems information within is historic.

Introduction

HDI PNP 2023-002 Page 5 of 7 Section Title Change Description of Change 8.2.4 Transmission Modify Remove historic/ obsolete information regarding switchyard ownership (former System companies listed).

Ownership 8.3 Station Modify Note that Class 1E is no longer applicable per 10 CFR 50.49(a)

Distribution Note that Seismic Categories are per Table 5.2-4 for electrical equipment and that other references to seismic design are historical.

8.4 Emergency Modify Note that Class 1E is no longer applicable per 10 CFR 50.49(a)

Power Sources Note that Seismic Categories are per Table 5.2-4 for electrical equipment and that other references to seismic design are historical.

8.5 Raceway and Modify Add "historically" to "safety-related" as the cables described in the section are Cabling not specific and some are and are not safety-related post-operation.

Systems 8.7 Physical Modify Add note that the information in this section is historically related to the "two train" Separation and separation original design theory.

Support Systems 9.1 Service Water Modify Note that the critical system is provided to support Spent Fuel Pool Cooling via System Component Cooling Water.

9.2 Reactor Modify Throughout the section, note that the design requirements are historical as the Primary Shield system is no longer SR or AQ.

Cooling System 9.3 Component Modify Note that sometimes in the defueled condition, zero CCW pumps may be Cooling System running (as the section currently states one or two pumps will be running).

This is to maintain the temperature of the SFP within its analyzed bands.

HDI PNP 2023-002 Page 6 of 7 Section Title Change Description of Change 9.4 Spent Fuel Pool Modify Revise SFP makeup sources from Safety Injection Refueling Water Tank and Cooling System Recycled Boric Acid Storage Tank to Service Water System and Fire Protection System. These sources provide equivalent design levels of makeup (that is, SWS is Seismic Category I as the SIRWT was (although, later determined not to be as described in other sections of the FSAR) and FPS is not, similar to the Recycled BAST). As such, the same level of inventory makeup is available. The FSAR and DSAR allow for unborated makeup sources. Remove SOC connections consistent with 5.1.

9.5 Compressed Modify Throughout the section, note that the design requirements are historical as the Air Systems system is no longer SR or AQ.

9.7 Auxiliary Modify Throughout the section, note that the design requirements are historical as the Feedwater system is no longer SR or AQ.

System 9.8 Heating, Modify Throughout the section, note that the design requirements are historical as the Ventilation, and system is no longer SR or AQ.

Air-Conditioning System 9.10 Chemical and Modify Throughout the section, note that the design requirements are historical as the Volume Control system is no longer SR or AQ.

System 9.11 Fuel Handling Modify Revise SFP makeup sources consistent with 9.4.

and Storage Systems

HDI PNP 2023-002 Page 7 of 7 Section Title Change Description of Change

{

10.1 Steam and Modify Throughout the section, note that the design requirements are historical as the Power system is no longer SR or AQ.

Conversion

System Design

Basis

HDI PNP 2023-002 Page 1 of 281 Attachment 2 to Enclosure 1 HDI PNP 2023-002 Palisades Nuclear Plant LBDCR Log Number 22-001 Permanently Defueled Technical Specifications Description of Changes - Details

HDI PNP 2023-002 Page 2 of 281 Palisades Nuclear Plant LBDCR Log Number 22-001 Description of Changes - Details Section Title Change Description of Change All Use of "plant," Modify The UFSAR is modified to replace the words "plant," "station" and "unit" with "station," and "unit" the word "facility." This is an administrative change to reflect that PNP will be permanently shut down and defueled. As a result, power operations and electrical generation will no longer occur. The principal activities will be the safe storage of spent nuclear fuel and the management of radioactive wastes. C3iven that status, PNP is better described as a facility versus a plant. This justification applies to all uses of "plant," station" and "unit" throughout the UFSAR which are modified to "facility."

"FSAR" is replaced with "DSAR" as this document is referred to as Defueled Safety Analysis Report" since Amendment 272 was implemented.

1.1 Introduction Modify This section is modified to replace the word "plant" with the word "facility."

The discussion of licensing activity during operation has been replaced with a discussion of licensing related to Amendment 272 (cessation of operation) and a description of the DSAR.

1.1.1 General Modify This section is revised to add recent licensing history related to Amendment 272 and the defueled condition 1.1.2 Licensing History Modify This section is modified to replace the word "plant" with the word "facility,"

add discussion of the licensing actions related to permanent shutdown and defueling, and delete reference to plant operating limits.

After implementation of Amendment 272, plant operation can no longer occur and plant operating limits are no longer applicable.

HDI PNP 2023-002 Page 3 of 281 Section Title Change Description of Change 1.2 General Plant Modify The title of this section is modified to replace the word "Plant" with the word Description "Facility."

1.2.1 Plant Site Modify The titie and text of this section is modified to replace the word "Plant" with the word "Facility."

1.2.2 Plant Arrangement Modify The title and text of this section is modified to replace the word "Plant" with the word "Facility." This section is further modified by eliminating the description of fuel transfer, which is not credited or required in the defueled condition and removing discussion regarding resin leakage.

After implementation of Amendment 272, fuel can no longer be placed in the reactor vessel and fuel transfer cannot occur.

1.2.3 Containment Modify This section is modified by eliminating discussion of the design functions and capability of the containment and associated SSCs to withstand internal pressure associated with a loss of coolant accident.

Amendment 272 removed Tech Spec Section 3.6, "Containment Systems,"

and the facility license no longer contains requirements for the containment building and associated systems. The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. Therefore, this FSAR section is modified to remove design and safety functional requirements.

HDI PNP 2023-002 Page 4 of 281 Section Title Change Description of Change 1.2.4 Nuclear Steam Modify This section is modified by eliminating discussions of design functions of the Supply System NSSS and support systems. Pressure Control System, Reactor Control, (NSSS) CVCS, Chemical Treatment, Nuclear Control and Instrumentation, and Shutdown Cooling are deleted in their entirety. Physical descriptions of SSCs are retained.

Amendment 272 removed accident scenarios related to the NSSS.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, the design functions of NSSS and support system are no longer relevant.

1.2.5 Turbine Generator Modify This secti,on is modified by eliminating discussions of design functions of the turbine generator. Physical descriptions of SSCs are retained.

Certifications have been submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, the design functions of the turbine generator are no longer relevant.

HDI PNP 2023-002 Page 5 of 281 Section Title Change Description of Change 1.4.1 Station Design Modify The title and text of this section is modified to replace the word "Station" with the word "Facility."

This section is modified by removing discussion of operating parameters and transients and limiting discussion to design codes and standards.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible.

1.4.2 Reactor Delete This section is proposed to be deleted in its entirety.

The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore there are no pertinent reactor design criteria or design functions in the permanently defueled condition.

HDI PNP 2023-002 Page 6 of 281 Section Title Change Description of Change 1.4.3 Primary Coolant and Delete This section is proposed to be deleted in its entirety.

Auxiliary Systems The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore there are no pertinent design criteria or design functions for the primary coolant and auxiliary Systems in the permanently defueled condition.

1.4.4 Containment System Modify This section is modified by eliminating the discussions of the capability of the containment to withstand internal pressure associated with a loss of coolant accident. In addition, the section is updated to reflect that the containment must maintain its structural integrity in the permanently shutdown and defueled condition to ensure that it does not impact the safe storage of spent fuel.

Amendment 272 removed Tech Spec Section 3.6, "Containment Systems,"

and the facility license no longer contains requirements for the containment building and associated systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

HDI PNP 2023-002 Page 7 of 281 Section Title Change Description of Change 1.4.5 Engineered Delete This section is proposed to be deleted in its entirety.

Safeguards Amendment 272 removed Tech Spec Section 3.5, ECCS, and the facility license no longer contains requirements for the ECCS and associated systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no pertinent engineered safeguards design criteria or design functions in the permanently defueled condition.

1.4.6 Instrumentation and Delete This section is proposed to be deleted in its entirety.

Control Amendment 272 removed Tech Spec Section 3.3, Instrumentation, and the facility license no longer contains requirements for instrumentation systems.

The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit any active systems.

Therefore, there are no pertinent instrumentation or control design criteria or design functions in the permanently defueled condition.

HDI PNP 2023-002 Page 8 of 281 Section Title Change Description of Change 1.4.7 Electrical Systems Modify This section is modified to replace the word "plant" with the word "facility."

Amendment 272 removed Tech Spec Section 3.8, Electrical, and the facility license no longer contains requirements for electrical systems. Therefore, discussion is revised to remove references to safe shutdown. Electrical systems support is limited to those systems supporting SFC and auxiliaries required during any normal facility conditions.

1.4.8 Radioactive Wastes Modify This section is modified to replace the word "plant" with the word "facility."

and Radiation Protection 1.4.10 Fire Protection Modify The text of this section is modified to replace the word "Plant" with the word "Facility."

This section is modified to reflect that the licensing basis for fire protection changed to 10 CFR 50.48(f) after the certifications required by 10 CFR 50.82(a)(1) were docketed in accordance with 10 CFR 50.82(a)(2).

Amendment 272 removed License Condition 2.C.(3) of Facility License DPR-20 for PNP regarding the Fire Protection Program. This license condition is deleted to reflect the permanently defueled condition of the facility. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits 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 fire protection program will be revised to take into account the decommissioning facility conditions and activities. PNP will continue to utilize the defense-in-depth concept, placing special emphasis on detection and suppression in order to minimize the potential for radiological releases to the environment.

HDI PNP 2023-002 Page 9 of 281 Section Title Change Description of Change 1.4.11 Circulating Water Delete This section is proposed to be deleted in its entirety.

System The circulating water system provided the condensers with a continuous supply of cooling water, for removing the heat rejected by the turbine generator, and the ability to inject sodium hypochlorite. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Therefore, nuclear steam cannot be produced, electrical power cannot be generated, and there are no pertinent circulating water design criteria or design functions.

1.4.12 Security Modify This section is modified to replace the word "plant" with the word "facility."

1.4.13 Emergency Planning Modify This section is modified to replace the word "plant" with the word "facility."

1.4.14 Plant Operation Modify This section is modified to replace the word "plant" with the word "facility."

This section is modified to reflect the revised TS.

1.4.15 Structures Modify This section is modified to replace the word "plant" with the word "facility."

HDI PNP 2023-002 Page 10 of 281 Section Title Change Description of Change 1.5 Major Plant Modify This section is modified to replace the word "plant" with the word "facility" Modifications and delete certain descriptions with no current safety significance:

(Design/ Condenser Retubing, Condenser Replacement, Steam Generator Tube Construction) Plugging - Old Generators, Operational information for Replacement Steam Generators, Auxiliary Feedwater modification - Bechtel/Bechtel, and High Head Auxiliary Feedwater Pump Installation and cross connection of Storage Tanks.

This section is further modified by eliminating some discussion of operating parameters. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur. Historical information is retained.

1.7 Research and Delete This section (and subsections) is proposed to be deleted in its entirety.

Development Requirements Amendment 272 removed the SSCs discussed in this section, and the TSs no longer contain requirements for these SSCs. Therefore, test and analysis of these SSCs can be removed from the UFSAR.

1.7.1 Flow Mixing and Delete See 1. 7 above Flow Distribution 1.7.2 Control Rod Tests Delete See 1. 7 above 1.7.3 Control Rod Drive Delete See 1. 7 above Mechanisms 1.7.4 Fuel Bundle Design Delete See 1. 7 above

HDI PNP 2023-002 Page 11 of 281 Section Title Change Description of Change 1.7.5 Reactor Vessel Flow Delete See 1. 7 above Tests 1.8.1.3 Continuing Modify This section is modified to replace the word "plant" with the word "facility."

Applicability and Interpretation of SEP Information 1.8.2 TMI Action Items Delete Section is deleted in its entirety (NUREG-0737)

NUREG 737 requirements only apply to operating reactors. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

1.8.4 Seismic Analysis for Modify This section is modified to replace the word "plant" with the word "facility."

As-Built Safety-Related Piping Systems (ie Bulletin 79-14)

HDI PNP 2023-002 Page 12 of 281 Section Title Change Description of Change 1.8.5 Unresolved Safety Modify This section is modified to replace the word "plant" with the word "facility" Issues (NUREG- and delete discussion of the SIRWT.

0410)

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids which do not rely on the SIRWT for mitigation.

1.8.6 Environmental Delete This section is deleted in its entirety.

Qualification of "Safety-Related" Certifications for permanent cessation of operations and permanent removal Electrical Equipment of fuel from the reactor vessel were submitted to the NRC in accordance (EEQ) with 10 CFR 50.82(a)(1)(i) and(ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids which do not create any of the conditions related to environmental qualification.

HDI PNP 2023-002 Page 13 of 281 Section Title Change Description of Change 1.8.7 Control Room Delete Amendment 272 removed License Condition 2.C.(7), CONTROL ROOM Habitability ENVELOPE HABITABILITY, and Tech Spec Sections 3.7.10 and 3.7.11, (NUREG-0696) control room ventilation filtration and cooling, and the facility license no longer contains requirements for the control room ventilation systems. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit control room cooling or filtration.

1.8.8 Effects of Pipe Delete This Section is deleted in its entirety.

Rupture (SEP Topics iii.5.a and b) Amendment 272 removed accident scenarios related to the NSSS.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, pipe rupture, and its associated dynamic effects, is no longer a credible scenario.

1.8.10 Safe Shutdown Delete This Section is deleted in its entirety.

This section is deleted to reflect that The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. Therefore, discussion of safe shutdown is no longer relevant.

HDI PNP 2023-002 Page 14 of 281 Section Title Change Description of Change 1.9.1 Summary Modify The text of this section is modified to replace the word "Plant" with the word Descriptions of "Facility."

Aging Management Programs 1.9.1.2 ASME Section XI, Modify The text of this section is modified to replace the word "Plant" with the word Subsections IWB, "Facility."

IWC, IWD, IWF lnservice Inspection Program 1.9.1.8 Containment Delete This section is proposed to be deleted in its entirety.

Leakage Testing Program Amendment 272 removed License Condition 2.D regarding Appendix J testing, and the facility license no longer requires a leakage testing program for containment. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur. Consequently, the Containment is no longer required to perform a function in the permanently shut down and defueled state. Thus, the Containment Leakage Testing Program no longer applies to a plant system, structure, or component that is within the 10 CFR 54.4 Scope for License Renewal and may be eliminated.

HDI PNP 2023-002 Page 15 of 281 Section Title Change Description of Change 1.9.1.16 Reactor Vessel Delete This section is deleted in its entirety.

. i. *. . -~-

Integrity Surveillance Program The requirements in 10 CFR 50 Appendix H are only applicable to nuclear plants that are performing power operations in the reactor critical operating mode. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). In addition, Amendment 272 deleted License Condition 2.J on the surveillance capsule program. Consequently, requirements for the surveillance program are no longer applicable.

1.9.1.17 Reactor Vessel Delete This section is deleted in its entirety.

Internals Inspection Program Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, the reactor vessel internal inspection program is no longer relevant.

HDI PNP 2023-002 Page 16 of 281 Section Title Change Description of Change 1.9.1.18 Steam Generator Delete This section is proposed to be deleted in its entirety.

Tube Integrity Program Amendment 272 removed TS 5.5.8, "Steam Generator (SG) Program,"

which ensures that SG tube integrity is maintained, and the license will no longer contain requirements for tube integrity. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit SG tube integrity.

Consequently, the Steam Generator Tube Integrity Program no longer applies to a plant system, structure, or component that is within the 10 CFR 54.4 Scope for License Renewal and may be eliminated.

1.9.1.19 Structural Monitoring Modify The text of this section is modified to replace the word "plant" with the word Program "facility."

1.9.1.23 Compressed air Modify The text of this section is modified to replace the word "plant" with the word monitoring program "facility."

1.9.2.1 Reactor Vessel Delete This section is deleted in its entirety.

Neutron Embrittlement The requirements in 10 CFR 50 Appendix H are only applicable to nuclear plants that are performing power operations in the reactor critical operating mode. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). In addition, Amendment 272 deleted License Condition 2.J on the surveillance capsule program. Consequently, vessel embrittlement and requirements for the surveillance program are no longer applicable.

HDI PNP 2023-002 Page 17 of 281 Section Title Change Description of Change 1.9.2.2 Metal Fatigue Modify This section is modified to remove discussion of specific metal fatigue analyses. Discussion of the Fatigue Monitoring Program is retained.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and components will not incur any additional fatigue cycles. After implementation of Amendment 272, calculation of usage factors for metal SSC!:> is no longer relevant.

1.9.2.3 Environmental Delete This section is deleted in its entirety.

Qualification of Electrical Equipment Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not create any of the conditions related to environmental qualification.

HDI PNP 2023-002 Page 18 of 281 Section Title Change Description of Change 1.9.2.4 Containment Liner Modify This section is modified by eliminating discussion of the design functions Plate, Metal and capability of the containment and associated SSCs to withstand internal Containments and pressure associated with a loss of coolant accident.

Penetrations Fatigue Analysis Amendment 272 removed Tech Spec Section 3.6, "Containment Systems,"

and the facility license no longer contains requirements for the containment buildihg and associated systems. The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. In addition, power operations and electrical generation can no longer occur, and components will not incur any additional fatigue cycles. Therefore, containment tendons and containment liner plate and penetration fatigue are no longer relevant.

1.9.2.5 Other Plant-Specific Modify This section is modified to remove discussion of Alloy 600, primary coolant Time-Limited Aging pump flywheel, and reactor vessel underclad. Discussion of crane TLAA is Analyses retained.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and {ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. TLAA of Alloy 600, primary coolant pump flywheel, and or reactor vessel underclad have no bearing on the remaining accidents.

HDI PNP 2023-002 Page 19 of 281 Section Title Change Description of Change 1.0 References Modify Deleted Reference 17 EQ and 10 CFR 50.49 only apply to operating reactors Table 1-1 Chronological Modify Additions are proposed to the licensing events to add Amendment 272 Licensing Events Amendment and defueled certification to the NRC.

Table 1-2 Palisades Design Modify The information in this table regarding operational parameters for the Characteristics reactor and steam cycles is proposed for deletion. Equipment descriptions (Nominal Values) and operational parameters for equipment required to support SFP cooling and the defueled condition is retained.

This table is revised to reflect that The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

Operational parameters on equipment required for power operations, electrical generation, and core related design basis accidents is deleted.

Table 1-3 Systematic Modify Table is modified to remove deleted references from Section 5.1.

Evaluation Program Numerous GDC no longer apply rendering the associated SEP item (SEP) and irrelevant.

Integrated Assessment Program (IAP),

Palisades Plant -

NUREG-0820

HDI PNP 2023-002 Page 20 of 281 Section Title Change Description of Change Table 1-4 Post-TMI Delete Table is deleted in its entirety.

Requirements for Consumers Power NUREG-0737 only applies to operating power reactors.

Company's, Palisades Plant -

NUREG-0737 Table 1-9 Applicable to Modify The following commitments are deleted Palisades 1-9 Long-Term 1 - Actions required by this commitment were completed and no longer Commitments for require retention to support a permanently defueled facility License Renewal of Palisades Nuclear 2, 3, 29, 30, 31, 32 and 33 - The requirements in 10 CFR 50 Appendix H are Plant only applicable to nuclear plants that are performing power operations in the reactor critical operating mode. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) arid are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). In addition, Amendment 272 deleted License Condition 2.J on the surveillance capsule program.

Consequently, requirements for the surveillance program are no longer applicable.

4 &5 - Plant system operation that results in concerns over charging line and pressurizer temperature elements fatigue will no longer occur since the RFOL does not authorize reactor operation 8 - Actions required by this commitment were completed and no longer require retention to support a permanently defueled facility

HDI PNP 2023-002 Page 21 of 281 Section Title Change Description of Change 2.5.5.1 X/Q Determination Modify This section is revised to delete X/Q values greater than the 0-2 time period.

for TIO Analyses This section is revised to reflect that The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. The analyses for these events assume an immediate release and only utilize the 0-2 hour X/Q values.

2.5.5.2 X/Q Determination Modify This section is revised to delete X/Q values greater than the 0-2 time period.

for AST Analyses This section is revised to reflect that The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. The analyses for these events assume an immediate release and only utilize the 0-2 hour X/Q values.

HDI PNP 2023-002 Page 22 of 281 Section Title Change Description of Change 2.5.5.2.1 Offsite X/Q Modify This section is revised to delete X/Q values greater than the 0-2 time period.

Determination This section is revised to reflect that The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. The analyses for these events assume an immediate release and only utilize the 0-2 hour X/Q values.

2.5.5.2.2 Control Room X/Q Modify This section is revised to change a Table reference in Chapter 14.

Determination Table 2-17 Relative Dispersion Modify This table is revised to delete X/Q values greater than the 0-2 time period.

(X/Q) Values (s/m 3)

Versus Averaging This table is revised to reflect that The certifications required by 1O Time, Turbine CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 Building license prohibits operation of the reactor or emplacement or retention of fuel Vent - Ground Level in the reactor vessel in accordance with 10 CFR 50.82{a)(2). Thus, power Release Exclusion operations and electrical generation can no longer occur and core related Area Boundary design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. The analyses for these events assume an immediate release and only utilize the 0-2 hour X/Q yalues.

HDI PNP 2023-002 Page 23 of 281 Section Title Change Description of Change Table 2-18 Relative Dispersion Modify This table is revised to delete X/Q values greater than the 0-2 time period.

(X/Q) Values (s/m 3 )

Versus Averaging This table is revised to reflect that The certifications required by Time, Turbine 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part Building 50 license prohibits operation of the reactor or emplacement or retention of Vent - Ground Level fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, Release Low power operations and electrical generation can no longer occur and core Population Zone related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. The analyses for these events assume an immediate release and only utilize the 0-2 hour X/Q values.

Table 2-21 X/Q Values (s/m 3 ) - Modify This table is revised to delete X/Q values greater than the 0-2 time period.

Ground Level Release - Exclusion This table is revised to reflect that The certifications required by Area Boundary 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. The analyses for these events assume an immediate release and only utilize the 0-2 hour X/Q values.

HDI PNP 2023-002 Page 24 of 281 Section Title Change Description of Change Table 2-22 X/Q Values (s/m 3) - Modify This table is revised to delete X/Q values greater than the 0-2 time period.

Ground Level Release - Low This table is revised to reflect that The certifications required by Population Zone 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. The analyses for these events assume an immediate release and only utilize the 0-2 hour X/Q values.

3.1 Introduction Modify This section is modified by eliminating discussions of reactor design, operation and reactivity control.

Amendment 272 deleted TS Sections 2.0, 3.1, 3.2 and 4.2, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

As a result, this section is modified by eliminating the discussion of the reactor operation and control. The reactor vessel will never be loaded with fuel again.

HDI PNP 2023-002 Page 25 of 281 Section Title Change Description of Change 3.2.1 Performance Delete This section is deleted in its entirety.

Objectives Amendment 272 deleted TS Sections 2.0, 3.1, 3.2 and 4.2, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

As a result, there are no performance objectives for the reactor.

3.2.2 Design Objective Delete This section is deleted in its entirety.

Amendment 272 deleted TS Sections 2.0, 3.1, 3.2 and 4.2, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

As a result, there are no design objectives for the reactor.

HDI PNP 2023-002 Page 26 of 281 Section Title Change Description of Change 3.2.3 Design Limits Modify This section is modified by eliminating discussions of reactor vessel design limits. Title is revised to "FUEL AND CONTROL ROD DESIGN LIMITS."

Amendment 272 deleted TS Sections 2.0, 3.1, 3.2 and 4.2, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from,the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

As a result, this section is modified by eliminating the discussion of the reactor vessel and the control rod drive mechanism design limits. The reactor vessel will never be loaded with fuel again. In addition, the control rod drive mechanisms perform no function in the defueled state. The information regarding the fuel bundles will be retained, because they will continue to be stored in the Spent Fuel Pool (SFP) or the Independent Spent Fuel Storage Installation (ISFSI) until permanent removal from the site.

HDI PNP 2023-002 Page 27 of 281 Section Title Change Description of Change 3.3.1 General Summary Modify This section is modified by eliminating discussions of reactor power distribution and control mechanisms.

Amendment 272 deleted TS Sections 2.0, 3.1, 3.2 and 4.2, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

As a result, this section is modified by eliminating the discussion of the reactor operation. The information regarding the fuel assemblies and control rods will be retained, because they will continue to be stored in the Spent Fuel Pool (SFP) or the Independent Spent Fuel Storage Installation (ISFSI) until permanent removal from the site.

HDI PNP 2023-002 Page 28 of 281 Section Title Change Description of Change 3.3.2 Nuclear Design and Delete This section is deleted in its entirety along with the associated subsections Evaluation Amendment 272 deleted TS Sections 2.0, 3.1, 3.2 and 4.2, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

This section discusses reactor reactivity, reactivity control, reactor stability and neutron fluence. The reactor vessel will never be loaded with fuel again and this information is obsolete. Additional information on ASME stress limits and seismic analysis is also deleted.

3.3.2.1 Reactivity and Delete See 3.3.2 above Control Requirement 3.3.2.2 Reactivity Delete See 3.3.2 above Coefficients 3.3.2.3 Control Blade Delete See 3.3.2 above Worths 3.3.2.4 Reactivity Insertion Delete See 3.3.2 above Rates 3.3.2.5 Power Distribution Delete See 3.3.2 above and Power Escalation Rates

HDI PNP 2023-002 Page 29 of 281 Section Title Change Description of Change 3.3.2.6 Neutron Fluence on Delete See 3.3.2 above Pressure Vessel 3.3.2.7 Nuclear Evaluation Delete See 3.3.2 above 3.3.2.8 Reactor Stability Delete See 3.3.2 above 3.3.3 Thermal-Hydraulic Delete This section is deleted in its entirety along with the associated subsections.

Design and Evaluation Amendment 272 deleted TS Sections 2.0, 3.1, 3.2 and 4.2, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

This section discusses reactor reactivity, reactivity control, reactor stability and neutron fluence. The reactor vessel will never be loaded with fuel again and this information is obsolete. Additional information on ASME stress limits and seismic analysis is also deleted.

HDI PNP 2023-002 Page 30 of 281 Section Title Change Description of Change 3.3.3.1 Thermal-Hydraulic Delete This section is deleted in its entirety.

Design Criteria Amendment 272 deleted TS Sections 2.0, 3.1, 3.2 and 4.2, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Since the reactor vessel will never be loaded with fuel again, thermal-hydraulic criteria are obsolete.

3.3.3.2 Plant Parameter Delete This section is deleted in its entirety.

Variations Amendment 272 deleted TS Sections 2.0, 3.1, 3.2 and 4.2, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

Since the reactor vessel will never be loaded with fuel again, parameter variations are not relevant.

HDI PNP 2023-002 Page 31 of 281 Section Title Change Description of Change 3.3.3.3 Core Flow Delete This section is deleted in its entirety.

Distribution Amendment 272 deleted TS Sections 2.0, 3.1, 3.2 and 4.2, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). The reactor vessel will never be loaded with fuel again and therefore core flow information is obsolete.

3.3.3.4 Trip Set Points Delete This section is deleted in its entirety.

Amendment 272 deleted TS Section 3.3, Instrumentation, including all required instrumentation setpoints, rendering discussion regarding trip setpoints obsolete. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PN_P, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

HDI PNP 2023-002 Page 32 of 281 Section Title Change Description of Change 3.3.4 Mechanical Design Modify This section of the IP2 UFSAR provides information regarding the and Evaluation mechanical design limits for the reactor internals and core components. It will be modified to eliminate the discussions regarding the reactor internals and reactor operations.

The title of the section is changed from "Mechanical Design and Evaluation" to "Mechanical Design."

Amendment 272 deleted TS Sections 2.0, 3.1, 3.2 and 4.2, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. As a result, the discussions regarding the reactor internals (with the exception of the fuel rods, fuel assemblies, and rod cluster control assemblies) and reactor operations are obsolete. The discussions regarding the fuel pellets, fuel rods, fuel assemblies, and rod cluster control assemblies will be retained, but are modified to eliminate the information regarding nuclear fuel operation or emplacement in the reactor vessei and retain the information regarding fuel design that is applicable to storage in the SFP or the ISFSI.

3.3.4.1 Reactor Internals Modify This section is modified to delete design and operational aspects of reactor internals. Physical descriptions of internal components is retained.

Amendment 272 deleted TS Sections 2.0, 3.1, 3.2 and 4.2, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. As a result, the discussions regarding the reactor internals design requirements and reactor operations are obsolete.

HDI PNP 2023-002 Page 33 of 281 Section Title Change Description of Change 3.3.4.2 Control Rod Drive Modify This section is modified to delete design and operational aspects of control Mechanism rod drive mechanisms (CROM). Physical descriptions of the CRDMs is retained.

Amendment 272 deleted TS Sections 2.0, 3.1, 3.2 and 4.2, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. The reactor vessel will never be loaded with fuel again and therefore CROM design information and operational aspects are obsolete.

3.3.4.3 Core Mechanical Modify This section is modified to delete core design information and operational Design aspects of fuel bundles, control rods and sources. Design information and physical descriptions for fuel bundles, fuel rods, control rods and neutron sources is retained.

Amendment 272 deleted TS Sections 2.0, 3.1, 3.2 and 4.2, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. The reactor vessel will never be loaded with fuel again and therefore core design requirements and operational aspects are obsolete.

The information regarding the fuel rods, fuel assemblies, control rods and neutron sources will be retained, because they will continue to be stored in the Spent Fuel Pool (SFP) or the Independent Spent Fuel Storage Installation (ISFSI) until permanent removal from the site.

3.0 References Delete This section is deleted in its entirety. There are no remaining references in Section 3.0

HDI PNP 2023-002 Page 34 of 281 Section Title Change Description of Change Table 3-1 Primary Stress Delete This table is deleted in its entirety. Discussion of reactor vessel stresses is Limits for Critical deleted from 3.2.2.

Reactor Vessel Internal Structures Figure 3-2 Position of Fuel Delete This figure is deleted in its entirety.

Assemblies and Control Rod Groups Amendment 272 reflects the permanent cessation of operations at PNP and in the Palisades permanent removal of fuel from the PNP reactor vessel. Certifications for Core permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

The reactor vessel will never be loaded with fuel again and therefore position information for fuel assemblies and control rods is obsolete.

Figure 3-3 Control Rod Delete This figure is deleted in its entirety.

Insertion Limits Amendment 272 reflects the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

The reactor vessel will never be loaded with fuel again and therefore insertion limits are rendered obsolete.

HDI PNP 2023-002 Page 35 of 281 Section Title Change Description of Change Figure 3-4 Reactivity Difference Delete This figure is deleted in its entirety.

Between Fundamental and Amendment 272 reflects the permanent cessation of operations at PNP and Excited States of a permanent removal of fuel from the PNP reactor vessel. Certifications for Bare Cylindrical permanent cessation of operations and permanent removal of fuel from the Reactor Cylindrical reactor vessel were submitted to the NRC in accordance with 10 Reactor CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

The reactor vessel will never be loaded with fuel again and therefore information on reactivity, reactor control and flux distribution is rendered obsolete.

Figure 3-5 Thermal Neutron Delete This figure is deleted in its entirety.

Flux at the Center of the Core vs Time Amendment 272 reflects the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR part 50 license no longer permits operation of the reactor or placement of fuel in 1the reactor vessel in accordance with 10 CFR 50.82(a)(2).

The reactor vessel will never be loaded with fuel again and therefore information on reactivity, reactor control and flux distribution is rendered obsolete.

HDI PNP 2023-002 Page 36 of 281 Section Title Change Description of Change Figure 3-6 Damping Coefficient Delete This figure is deleted in its entirety.

vs Reactivity Difference Between Amendment 272 reflects the permanent cessation of operations at PNP and Fundamental and permanent removal of fuel from the PNP reactor vessel. Certifications for Excited State permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

The reactor vessel will never be loaded with fuel again and therefore information on reactivity, reactor control and flux distribution is rendered obsolete.

Figure 3-7 End of Life Axial Delete This figure is deleted in its entirety.

Oscillations With Doppler Feedback, Amendment 272 reflects the permanent cessation of operations at PNP and Full Power (2-Hour permanent removal of fuel from the PNP reactor vessel. Certifications for Time Steps) permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

The reactor vessel will never be loaded with fuel again and therefore information on reactivity, reactor control and flux distribution is rendered obsolete.

HDI PNP 2023-002 Page 37 of 281 Section Title Change Description of Change Figure 3-8 Split Detector Delete This figure is deleted in its entirety.

Response to Axial Power Profiles in the Amendment 272 reflects the permanent cessation of operations at PNP and Core permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

The reactor vessel will never be loaded with fuel again and therefore information on reactivity, reactor control and flux distribution is rendered obsolete.

4.1 Introduction Modify This section is modified by eliminating discussions of design and safety functions of the primary coolant system. Physical descriptions of SSCs are retained.

Amendment 272 deleted TS Section 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2).

As a result, this section is modified by eliminating the discussion of Primary Coolant System operation and design requirements.

4.2 Design Basis Modify Reference to Tables 4-1 and 4-2 are relocated to this section.

HDI PNP 2023-002 Page 38 of 281 Section Title Change Description of Change 4.2.1 Performance Modify This section is modified to remove performance objectives and operating Objectives and parameters.

Parameters for Normal Conditions Amendment 272 deleted TS Section 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Therefore, the performance objectives and parameters for normal operation of the primary coolant system are no longer relevant. Table 4-1 is retained in Section 4.2 to provide initial design parameters.

4.2.2 Design Cyclic Loads Delete This section is deleted in its entirety.

Amendment 272 deleted TS Section 3.4, Primary Coolant System, reflecting the permanent c;essation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Therefore, the design cyclic loads of the primary coolant system are no longer relevant. Table 4-2 is retained in Section 4.2 to provide Code requirements.

HDI PNP 2023-002 Page 39 of 281 Section Title Change Description of Change 4.2.3 Design Service Life Delete This section is deleted in its entirety.

Considerations Amendment 272 deleted TS Section 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Therefore, the design service life considerations of the primary coolant system are no longer relevant.

4.2.5 Safety Delete This section is deleted in its entirety.

Considerations of Design Parameters Amendment 272 deleted TS Section 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Therefore, the performance objectives and parameters for normal operation of the primary coolant system are no longer relevant.

HDI PNP 2023-002 Page 40 of 281 Section Title Change Description of Change 4.2.6 Primary Coolant Delete This section is deleted in its entirety.

System Asymmetric Loads Amendment 272 deleted TS Section 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Therefore, the performance objectives and parameters for normal operation of the primary coolant system are no longer relevant.

4.3 System Design and Modify Section header is revised to System Design Operation 4.3.1 General Description Modify This section is modified by eliminating discussions of primary coolant system operation and safety and design functions.

Amendment 272 deleted TS Section 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Therefore, safety and design functions, along with operational aspects, of the primary coolant system are no longer relevant.

HDI PNP 2023-002 Page 41 of 281 Section Title Change Description of Change 4.3.2 Interfaces with Other Modify This section is modified by eliminating functional descriptions of interfacing Systems systems. Physical descriptions of SSCs are retained.

Amendment 272 deleted TS Section 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Therefore, design functions of systems connected to the primary coolant system are no longer relevant.

4.3.3 Reactor Vessel Modify This section is modified by eliminating discussions of reactor vessel design requirements. Physical descriptions of vessel components are retained.

Amendment 272 deleted TS Section 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Therefore, design functions of the reactor vessel are no longer relevant.

HDI PNP 2023-002 Page 42 of 281 Section Title Change Description of Change 4.3.4 Steam Generator Modify This section is modified by eliminating discussions of SG operational and design requirements. Physical descriptions of SG components are retained.

Amendment 272 deleted TS Section 3.4, Primary Coolant System, and TS 5.5.8, St~am Generator Program, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement 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 and, therefore, design requirements of the SGs are no longer relevant.

4.3.4.1 Steam Generator Delete This section deleted in its entirety.

Tube Degradation Amendment 272 deleted TS Section 3.4, Primary Coolant System, and TS 5.5.8, Steam Generator Program, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement 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, SG tube degradation is no longer relevant.

HDI PNP 2023-002 Page 43 of 281 Section Title Change Description of Change 4.3.5 Primary Coolant Modify This section is modified by eliminating discussions of pump operational and Pumps design requirements. Physical descriptions of RCP components are retained.

Amendment 272 deleted TS Section 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, the primary coolant pumps will no longer be required to operate, and pump design functions are no longer relevant.

4.3.6 Primary Coolant Modify This section is modified by eliminating discussions of primary coolant piping Piping design requirements and operational issues. Physical descriptions of piping are retained.

Amendment 272 deleted TS Section 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, the primary coolant piping will no longer be utilized, and piping design requirements and operational issues are no longer relevant.

HDI PNP 2023-002 Page 44 of 281 Section Title Change Description of Change 4.3.7 Pressurizer Modify This section is modified by eliminating discussions of pressurizer safety functions, design requirements and operational issues. Physical descriptions of SSCs are retained.

Amendment 272 deleted TS Section 3.4, Primary Coolant System, including TS 3.4.9, Pressurizer, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, pressurizer safety functions and design requirements are no longer relevant.

4.3.8 Quench Tank Modify This section is modified by eliminating discussions of pressurizer quench tank operation and design requirements. Physical descriptions of SSCs are retained.

Amendment 272 deleted TS Section 3.4, Primary Coolant System, including TS 3.4.9, Pressurizer, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, pressurizer quench tank operation and design requirements are no longer relevant.

HDI PNP 2023-002 Attachment 2 Page 45 of 281 Section Title Change Description of Change 4.3.9.1 General Criteria Delete This section is deleted in its entirety.

Amendment 272 deleted TS Section 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, primary coolant valves no longer have safety or design functions.

4.3.9.2 Pressurizer Delete This section deleted in its entirety.

Throttling (spray)

Control Valves Amendment 272 deleted TS Section 3.4, Primary Coolant System, including TS 3.4.9, Pressurizer, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, pressurizer throttling control valve functional and design requirements are no longer relevant.

HDI PNP 2023-002 Page 46 of 281 Section Title Change Description of Change 4.3.9.3 Power-Operated Modify This section is modified by eliminating discussions of PORV functional and Relief Valves design requirements. Physical descriptions of SSCs are retained.

(PORV) and Block Valves Amendment 272 deleted TS Section 3.4, Primary Coolant System, including TS 3.4.9,.Pressurizer, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, PORV functional and design requirements are no longer relevant.

4.3.9.4 Spring-Actuated Modify This section is modified by eliminating discussions of Pressurizer Safety Primary Safety Valves functional and design requirements. Physical descriptions of SSCs Valves are retained.

Amendment 272 deleted TS Section 3.4, Primary Coolant System, including TS 3.4.10, Pressurizer Safety Valves, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, Pressurizer Safety Valves functional and design requirements are no longer relevant.

HDI PNP 2023-002 Page 47 of 281 Section Title Change Description of Change 4.3.10 Environmental Modify This section is modified by eliminating discussions of missile protection and protection accident loading. Seismic characteristics of the NSSS are retained.

Amendment 272 deleted TS Section 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, missile protection and accident loading in a seismic event are no longer relevant.

4.3.11 Materials exposed to Delete This section is deleted in its entirety. Amendment 272 deleted TS Section coolant 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reacto_r or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, SSC exposure to coolant is no longer relevant.

HDI PNP 2023-002 Page 48 of 281 Section Title Change Description of Change 4.3.12 Insulation Modify This section is modified by eliminating discussions of insulation performance. Physical characteristics of the insulation are retained.

Amendment 272 deleted TS Section 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, functional requirements of insulation is no longer relevant.

4.4 System design Delete This section header is deleted as it has no content.

evaluation 4.4.1 Design margin Delete This section is deleted in its entirety. Amendment 272 deleted TS Section 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. As a result, the design margin of the primary coolant system is longer relevant.

HDI PNP 2023-002 Page 49 of 281 Section Title Change Description of Change 4.4.2 Prevention of brittle Delete This section is deleted in its entirety. Amendment 272 deleted TS Section fracture 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. As a result, primary coolant system pressure temperature limits and brittle fracture prevention is longer relevant.

4.5 Tests and modify Section Header is revised to "INSPECTIONS." This is an editorial change to Inspections reflect revised section content.

4.5.2 Nil ductility transition Delete This section is deleted in its entirety. Amendment 272 deleted TS Section temperature 3.4, Primary Coolant System, reflecting the permanent cessation of determination operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Consequently, nil ductility of the primary coolant system is longer relevant.

HDI PNP 2023-002 Page 50 of 281 Section Title Change Description of Change 4.5.3 Surveillance Delete This section is deleted in its entirety. The requirements in 10 CFR 50 program Appendix H are only applicable to nuclear plants that are performing power operations in the reactor critical operating mode. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). In addition, Amendment 272 deleted License Condition 2.J on the surveillance capsule program. Consequently, requirements for the surveillance program are no longer applicable.

4.5.6 lnservice inspection Modify This section is modified to remove reference to the SG tube inspection program and the vessel surveillance program which were removed in Amendment 272. See UFSAR Sections 4.5.3 and 4.3.4.1.

4.5.7 NOTT of other Delete This section is deleted in its entirety. Amendment 272 deleted TS Section primary system 3.4, Primary Coolant System, reflecting the permanent cessation of components operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Consequently, nil ductility of primary coolant system SSCs is no longer relevant.

HDI PNP 2023-002 Page 51 of 281 Section Title Change .,

Description of Change 4.6 Operating limitation Delete This section is deleted in its entirety. Amendment 272 deleted TS Section 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, primary coolant system operating limits are no longer relevant.

4.7 Primary coolant Delete This header is deleted in its entirety as there are no remaining subsections.

pressure boundary Amendment 272 deleted TS Sections 3.4.14 PCS Operational LEAKAGE, leakage detection 3.4.14 PCS Pressure Isolation Valve (PIV) Leakage, and 3.4.15 PCS Leakage Detection Instrumentation. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, primary coolant system operating*,. limits are no longer relevant.

4.7.1 Leak detection Delete This section is deleted in its entirety. Amendment 272 deleted TS Sections 3.4.14 PCS Operational LEAKAGE, 3.4.14 PCS Pressure Isolation Valve (PIV) Leakage, and 3.4.15 PCS Leakage Detection Instrumentation.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, primary coolant system leakage is no longer relevant.

HDI PNP 2023-002 Page 52 of 281 Section Title Change Description of Change 4.7.2 Operator action Delete This section is deleted in its entirety. Amendment 272 deleted TS Sections following leak 3.4.14 PCS Operational LEAKAGE, 3.4.14 PCS Pressure Isolation Valve detection (PIV) Leakage, and 3.4.15 PCS Leakage Detection Instrumentation.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, operator actions upon detection of primary coolant system leakage is no longer relevant.

4.8 Primary coolant gas Modify This section is modified to remove operational aspects of the primary vent system coolant gas vent system. Physical description and design information of SSCs is retained. Amendment 272 deleted TS Section 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, primary coolant gas vent system operation is no longer relevant.

HDI PNP 2023-002 Page 53 of 281 Section Title Change Description of Change Table 4-1 Primary coolant Delete This table is deleted to remove operating parameters. Amendment 272 system parameters deleted TS Section 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, primary coolant system operating parameters are no longer relevant.

Table 4-2 Primary coolant Modify Title is revised to Primary Coolant System Codes system code requirements Table 4-4 Steam generator Modify This table is modified to remove operating parameters. Amendment 272 parameters deleted TS Section 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, SG operating parameters are no longer relevant.

HDI PNP 2023-002 Page 54 of 281 Section Title Change Description of Change Table 4-5 Secondary Safety Modify This table is modified to remove operating parameters. Amendment 272 Valve Parameters deleted TS Section 3.7.1, Main Steam Safety Valves, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from ~he PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, safety valve operating parameters are no longer relevant.

Table 4-6 Primary Coolant Modify This table is modified to remove operating parameters. Amendment 272 Pump Parameters deleted TS Section 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PN P, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, pump operating parameters are no longer relevant.

HDI PNP 2023-002 Page 55 of 281 Section Title Change ', Description of Change Table 4-8 Pressurizer Modify This table is modified to remove operating parameters. Amendment 272 Parameters deleted TS Section 3.4, Primary Coolant System, including TS 3.4.9, Pressurizer, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, pressurizer operating parameters are no longer relevant.

Table 4-9 Pressurizer Normal Delete This table is deleted in its entirety. Amendment 272 deleted TS Section 3.4, Level Control Primary Coolant System, including TS 3.4.9, Pressurizer, reflecting the Program/Pressurizer permanent cessation of operations at PNP and permanent removal of fuel Backup Level from the PNP reactor vessel. Certifications for permanent cessation of Control Program operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, pressurizer operating parameters are no longer relevant.

HDI PNP 2023-002 Page 56 of 281 Section Title Change Description of Change Table 4-10 Pressurizer Safety Delete This table is deleted in its entirety. Amendment 272 deleted TS Section 3.4, Valve Parameters Primary Coolant System, including TS 3.4.10, Pressurizer Safety Valves, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, Pressurizer Safety Valves functional parameters are no longer relevant.

Table 4-11 Quench Tank Modify This table is modified to remove operating parameters. Amendment 272 Parameters deleted TS Section 3.4, Primary Coolant System, including TS 3.4.9, Pressurizer, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, quench tank operating parameters are no longer relevant.

HDI PNP 2023-002 Page 57 of 281 Section Title Change Description of Change Table 4-12 Actuator-Operated Delete This table is deleted in its entirety. Amendment 272 deleted TS Section 3.4, Throttling Valve Primary Coolant System, including TS 3.4.9, Pressurizer, reflecting the Parameters permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, pressurizer throttling control valve operating parameters are no longer relevant.

Table 4-13 Actuator-Operated Delete This table is deleted in its entirety. Amendment 272 deleted TS Section 3.4, Block Valve Primary Coolant System, including TS 3.4.9, Pressurizer, reflecting the Parameters permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, block valve operating parameters are no longer relevant.

HDI PNP 2023-002 Page 58 of 281 Section Title Change Description of Change Table 4-14 Pressurizer Power- Modify This table is modified to remove operating parameters. Amendment 272 Operated Relief deleted TS Section 3.4, Primary Coolant System, including TS 3.4.11 Valve Parameters Pressurizer Power Operated Relief Valves (PO RVs), reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, PORV operating parameters are no longer relevant.

Table 4-16 Primary Coolant Delete This table is deleted in its entirety. Amendment 272 deleted TS Section 3.4, Chemistry Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, primary coolant chemistry parameters are no longer relevant.

Table 4-17 Summary of Delete This table is deleted in its entirety. The requirements in 10 CFR 50 Specimens Provided Appendix H are only applicable to nuclear plants that are performing power for Each Exposure operations in the reactor critical operating mode. In addition, Amendment Location / Summary 272 deleted License Condition 2.J on the surveillance capsule program.

of Specimens Consequently, requirements for the surveillance program are no longer Provided for Each applicable.

Supplemental Surveillance Capsule

HDI PNP 2023-002 Page 59 of 281 Section Title Change Description of Change Table 4-20 Reactor Vessel Delete This table is deleted in its entirety. The requirements in 10 CFR 50 Surveillance Coupon Appendix H are only applicable to nuclear plants that are performing power Removal Schedule operations in the reactor critical operating mode. In addition, Amendment 272 deleted License Condition 2.J on the surveillance capsule program.

Consequently, requirements for the surveillance program are no longer applicable.

Figure 4-5 Deleted Delete Previously Deleted Figure 4-7 Primary Coolant Delete This figure is deleted in its entirety. Amendment 272 deleted TS Section Pump 3.4, Primary Coolant System, reflecting the permanent cessation of Characteristics operations at PNP and permanent removal of fuel from the PNP reactor Curve vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Consequently, operational parameters of the primary coolant system are longer relevant.

Figure 4-9 Temperature Control Delete This figure is deleted in its entirety. Amendment 272 deleted TS Section Program 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent

- removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Consequently, operational parameters of the primary coolant system are longer relevant.

,--------------------------~-------------- --

HDI PNP 2023-002 Attachment 2 Page 60 of 281 Section Title Change Description of Change Figure 4- Pressurizer Level Delete This figure is deleted in its entirety. Amendment 272 deleted TS Section 3.4, 10 Set Point vs TAVG Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Consequently, operational parameters of the primary coolant system are longer relevant.

Figure 4- Location of Delete This figure is deleted in its entirety. The requirements in 10 CFR 50 11 Surveillance Appendix H are only applicable to nuclear plants that are performing power Capsule Assemblies operations in the reactor critical operating mode. In addition, Amendment 272 deleted License Condition 2.J on the surveillance capsule program.

Consequently, requirements for the surveillance program are no longer applicable.

Figure 4- Typical Surveillance Delete This figure is deleted in its entirety. The requirements in 10 CFR 50 12 Capsule Assembly Appendix H are only applicable to nuclear plants that are performing power operations in the reactor critical operating mode. In addition, Amendment 272 deleted License Condition 2.J on the surveillance capsule program.

Consequently, requirements for the surveillance program are no longer applicable.

Figure 4- Typical Charpy Delete This figure is deleted in its entirety. The requirements in 10 CFR 50 13 Impact Appendix H are only applicable to nuclear plants that are performing power Compartment operations in the reactor critical operating mode. In addition, Amendment Assembly 272 deleted License Condition 2.J on the surveillance capsule program.

Consequently, requirements for the surveillance program are no longer applicable.

HDI PNP 2023-002 Page 61 of 281 Section Title Change Description of Change Figure 4- Typical Tensile - Delete This figure is deleted in its entirety. The requirements in 10 CFR 50 14 Monitor Appendix H are only applicable to nuclear plants that are performing power Compartment operations in the reactor critical operating mode. In addition, Amendment Assembly 272 deleted License Condition 2.J on the surveillance capsule program.

Consequently, requirements for the surveillance program are no longer applicable.

Figure 4- Variable LTOP Delete This figure is deleted in its entirety. Amendment 272 deleted TS Section 15 Setpoints 3.4, Primary Coolant System, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Consequently, initial inspection and qualification of components of the primary coolant system is longer relevant.

4.0 References Delete References deleted from text and tables were removed from Section. This resulted in deletion of entire reference section.

HDI PNP 2023-002 Page 62 of 281 Section Title Change Description of Change 5.1.1 Introduction Modify This section is modified to refer to the permanently defueled condition, replace the word "Plant" with the word "Facility," change "FSAR" to "DSAR."

Use of "Plant" is retained when used in historical reference.

Certi-fjcations have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. In the permanently defueled condition, certain aspects of the GDC are no longer applicable. After implementation of Amendment 272, the document will be referred to as Defueled Safety Analysis Report.

5.1.2.3 Criterion 3 - Fire Modify This section is modified to replace the word "Plant" with the word "Facility,"

Protection and "safe reactor shutdown" is replaced by "safe and stable conditions." Use of "Plant" is retained when used in historical reference. This section is revised to reflect that The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. Therefore, discussion of safe shutdown is replaced with safe and stable conditions related to spent fuel storage.

HDI PNP 2023-002 Page 63 of 281 Section Title Change ' Description of Change 5.1.2.4 Criterion 4 - Modify This section is modified to remove discussion of accident conditions and Environmental and scenarios. SEP topics on pipe breaks and internal missiles are deleted.

Missile Design This section is revised to reflect that The certifications required by Bases 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, discussion of accident conditions and pipe whip scenarios inside containment is deleted.

5.1.2.5 Criterion 5 - Sharing Modify This section is modified to replace the word "Plant" with the word "Facility."

of Structures, Systems and Components 5.1.2.6 Conclusions Modify This section is modified to replace the word "Plant" with the word "Facility."

The text is revised to reference "applicable" criteria as some aspects of Group 1 criteria are no longer applicable (See 5.1.2.3 and 5.1.2.4).

HDI PNP 2023-002 Page 64 of 281 Section Title Change Description of Change 5.1.3.1 Criterion 10 - Modify This section is modified to remove discussion of reactor core operations and Reactor Design transients. Reference to TS Section 2.1 is deleted, and information on fuel design is retained. Amendment 272 deleted TS Sections 2.0, Safety Limits, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. This section is revised to reflect that the certifications required by 10 CFR 50.82(a)(1) are docketed for PN P, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur. Therefore, discussion of operating parameters is deleted.

5.1.3.2 Criterion 11 - Modify This section is modified to remove discussion of reactor core operations and Reactor Inherent note that Criterion 11 is not applicable in the defueled condition. This Protection section is revised to reflect that The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur. Therefore, discussion of reactor core nuclear coefficients is deleted.

HDI PNP 2023-002 Page 65 of 281 Section Title Change Description of Change 5.1.3.3 Criterion 12 - Modify This section is modified to remove discussion of reactor core operations and Suppression of note that Criterion 12 is not applicable in the defueled condition.

Reactor Power Amendment 272 deleted TS Sections 3.1, REACTIVITY CONTROL Oscillations SYSTEMS, and 3.2, POWER DISTRIBUTION LIMITS, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). As a result, reactor power oscillations are not possible and Criterion 13 no longer applies.

5.1.3.4 Criterion 13 - Modify This section is modified to remove discussion of reactor core operations and Instrumentation and note that Criterion 12 is not applicable in the defueled condition.

Control Amendment 272 deleted TS Section 3.3, INSTRUMENTATION, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer possible and the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These accidents do not credit any instrumentation or operator action and, consequently, Criterion 13 no longer applies.

HDI PNP 2023-002 Page 66 of 281 Section Title Change Description of Change 5.1.3.6 Criterion 15 - Modify This section is modified to remove discussion of accident conditions and Reactor Coolant scenarios. This section is revised to reflect that The certifications required System Design by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, discussion of normal reactor operation and transients is deleted along with reference to the Tech Specs.

5.1.3.7 Criterion 16 - Modify This section is modified to remove discussion of containment leakage and Containment Design Technical Specifications. Amendment 272 removed Tech Spec Section 3.6, "Containment Systems," and the facility license no longer contains requirements for the containment building and associated systems. The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. Therefore, discussion of containment leakage is deleted along with reference to the Tech Specs.

HDI PNP 2023-002 Page 67 of 281 Section Title Change Description of Change 5.1.3.8 Criterion 17 - Delete This section is deleted in its entirety. Amendment 272 deleted TS Section Electrical Power 3.8, ELECTRICAL POWER SYSTEMS, reflecting the permanent cessation Systems of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer possible and the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These accidents do not credit any electrical power sources and, consequently, Criterion 18 no longer applies.

5.1.3.9 Criterion 18 - Modify This section is modified to remove discussion of facility electrical systems Inspection and and note that Criterion 18 is not applicable in the defueled condition.

Testing of Electrical Amendment 272 deleted TS Section 3.8, ELECTRICAL POWER Power Systems SYSTEMS, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer possible and the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These accidents do not credit any electrical power sources and, consequently, Criterion 18 no longer applies.

HDI PNP 2023-002 Page 68 of 281 Section Title Change Description of Change 5.1.3.10 Criterion 19 - Control Modify This section modified to remove discussion of control room habitability Room systems, hot shut down and cold shutdown, and is modified to replace the word "Plant" with the word "Facility." Amendment 272 deleted TS 3.7.10, Control Room Ventilation (CRV) Filtration, and TS 3.7.11, Control Room Ventilation (CRV) Cooling, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel.

Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer possible and the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes' or radioactive liquids. These accident analyses do not credit any control room habitability systems while still maintaining CR doses within licensing basis requirements. Hot and cold shutdown are not applicable in the defueled condition and are deleted.

5.1.3.11 Conclusions Modify This section is modified to replace the word "Plant" with the word "Facility."

The text is revised to reference "applicable" criteria as some aspects of Group II criteria are no longer applicable (See 5.1.3.1, 5.3.1.2, 5.3.1.6 and 5.3.1.7, and 5.3.1.10).

HDI PNP 2023-002 Page 69 of 281 Section Title Change Description of Change 5.1.4.1 Criterion 20 - Modify This section is modified to remove discussion of the RPS and note that Protection System Criterion 20 is not applicable in the defueled condition. Amendment 272 Functions deleted TS Section 3.3, INSTRUMENTATION, including 3.3.1 Reactor Protective System (RPS) Instrumentation, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer possible and the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These accidents do not credit any protective systems and, consequently, RPS is no longer required.

5.1.4.2 Criterion 21 - Modify This section is modified to remove discussion of protection systems and Protection System note that Criterion 21 is not applicable in the defueled condition.

Reliability and Amendment 272 deleted TS Section 3.3, INSTRUMENTATION, including Testability 3.3.1 Reactor Protective System (RPS) Instrumentation, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer possible and the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These accidents do not credit any protection systems and, consequently, reliability and testability is no longer applicable.

HDI PNP 2023-002 Page 70 of 281 Section Title Change Description of Change 5.1.4.3 Criterion 22 - Modify This section is modified to remove discussion of protection systems and Protection System note that Criterion 22 is not applicable in the defueled condition.

Independence Amendment 272 deleted TS Section 3.3, INSTRUMENTATION, including 3.3.1 'Reactor Protective System (RPS) Instrumentation, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer possible and the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These accidents do not credit any protection systems and, consequently, independence is no longer applicable.

5.1.4.4 Criterion 23 - Modify This section is modified to remove discussion of protection system failure Protection System modes and note that Criterion 23 is not applicable in the defueled condition.

Failure Modes Amendment 272 deleted TS Section 3.3, INSTRUMENTATION, including 3.3.1 Reactor Protective System (RPS) Instrumentation, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer-pqssible and the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These accidents do not credit any protection systems and, consequently, independence is no longer applicable.

HDI PNP 2023-002 Page 71 of 281 Section Title Change Description of Change 5.1.4.5 Criterion 24 - Modify This section is modified to remove discussion of protection systems Separation of separation and note that Criterion 24 is not applicable in the defueled Protection and condition. Amendment 272 deleted TS Section 3.3, INSTRUMENTATION, Control System including 3.3.1 Reactor Protective System (RPS) Instrumentation, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer possible and the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These accidents do not credit any protection systems and, consequently, separation is no longer applicable.

5.1.4.6 Criterion 25 - Modify This section is modified to remove discussion of reactivity control system Protection System malfunctions and note that Criterion 25 is not applicable in the defueled Requirements for condition. Amendment 272 deleted TS SECTION 3.1, REACTIVITY Reactivity Control CONTROL SYSTEMS, and TS Section 3.3, INSTRUMENTATION, including Malfunctions 3.3. t~eactor Protective System (RPS) Instrumentation, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no

~

longer possible and the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These accidents do not credit any protection systems and, consequently, system malfunctions are no longer applicable.

HDI PNP 2023-002 Page 72 of 281 Section Title Change Description of Change 5.1.4.7 Criterion 26 - Modify This section is modified to remove discussion of reactivity control systems Reactivity Control and note that Criterion 26 is not applicable in the defueled condition.

System Redundancy Amendment 272 deleted TS SECTION 3.1, REACTIVITY CONTROL and Capability SYSTEMS, and TS Section 3.3, INSTRUMENTATION, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, reactivity control is no longer applicable 5.1.4.8 Criterion 27 - Modify This section is modified to remove discussion of protection systems and Combined Reactivity note that Criterion 27 is not applicable in the defueled condition.

Control Systems Amendment 272 deleted TS SECTION 3.1, REACTIVITY CONTROL Capability SYSTEMS, and TS Section 3.3, INSTRUMENTATION, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, reactivity control is no longer applicable

HDI PNP 2023-002 Page 73 of 281 Section Title Change Description of Change 5.1.4.9 Criterion 28 - Modify This section is modified to remove discussion of reactivity control systems Reactivity Limits and note that Criterion 28 is not applicable in the defueled condition.

Amendment 272 deleted TS SECTION 3.1, REACTIVITY CONTROL SYSTEMS, and TS Section 3.3, INSTRUMENTATION, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, reactivity control and reactivity limits are no longer applicable 5.1.4.10 Criterion 29 - Modify This section is modified to remove discussion of anticipated operational Protection Against occurrences and note that Criterion 29 is not applicable in the defueled Anticipated condition. Certifications for permanent cessation of operations and Operational permanent removal of fuel from the reactor vessel were submitted to the Occurrences NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, there are no anticipated operational occurrences related to protection and reactivity control systems.

5.1.4.11 Conclusions Modify This section is modified to replace the word "Plant" with the word "Facility."

The text is revised to reference "applicable" criteria as some aspects of Group Ill criteria are no longer applicable.

HDI PNP 2023-002 Page 74 of 281 Section Title Change Description of Change 5.1.5.1 Criterion 30 - Quality Modify This section is modified to remove discussion of RCS leakage and of Reactor Coolant associated references. Amendment 272 deleted 3.4.13, PCS Operational Pressure Boundary LEAKAGE, and TS, 3.4.15 PCS Leakage Detection Instrumentation, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). RCS leakage limits are no longer applicable 5.1.5.2 Criterion 31 - Modify This section is modified to remove discussion of fracture prevention and Fracture Prevention note that Criterion 31 is not applicable in the defueled condition. The of Reactor Coolant requirements in 10 CFR 50 Appendix H are only applicable to nuclear plants Pressure Boundary that are performing power operations in the reactor critical operating mode.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). In addition, Amendment 272 deleted License Condition 2.J on the surveillance capsule program. Consequently, requirements for fracture prevention are no longer applicable.

HDI PNP 2023-002 Page 75 of 281 Section Title Change Description of Change 5.1.5.3 Criterion 32 - Modify This section is modified to delete reference to unit shutdown and the RPV Inspection of material surveillance program (see 5.1.5.2), remove reference to TS Section Reactor Coolant 3.4 and SEP V-5, and is modified to replace the word "Plant" with the word Pressure Boundary "Facility." Amendment 272 deleted TS SECTION 3.4, PRIMARY COOLANT SYSTEM, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). SEP V-5 concerns PCS leakage detection and is also deleted (See 5.1.5.1 ).

5.1.5.4 Criterion 33 - Modify This section is modified to remove discussion of reactor coolant makeup Reactor Coolant and note that Criterion 33 is not applicable in the defueled condition.

Makeup Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, there are no anticipated operational occurrences

/ requiring* reactor coolant makeup.

5.1.5.5 Criterion 34 - Modify This section is modified to remove reference to shutdown cooling and note Residual Heat that Criterion 34 is not applicable in the defueled condition.

Removal Amendment 272 deleted TS SECTION 3.4, PRIMARY COOLANT SYSTEM, and 3.5, EMERGENCY CORE COOLING SYSTEMS, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Therefore, shutdown cooling is no longer applicable.

HDI PNP 2023-002 Page 76 of 281 Section Title Change Description of Change 5.1.5.6 Criterion 35 - Modify This section is modified to remove reference to ECCS and note that Emergency Core Criterion 35 is not applicable in the defueled condition. Amendment 272 Cooling deleted TS Section 3.5, EMERGENCY CORE COOLING SYSTEMS, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not rely on ECCS for mitigation. Therefore, ECCS is no longer applicable.

5.1.5.7 Criterion 36 - Modify This section is modified to remove reference to ECCS and note that Inspection of Criterion 36 is not applicable in the defueled condition. Amendment 272 Emergency Core deleted TS Section 3.5, EMERGENCY CORE COOLING SYSTEMS, Cooling System reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in

' accordance with 10 CFR 50.82(a)(2). After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not rely on ECCS for mitigation. Therefore, ECCS inspection is no longer applicable.

HDI PNP 2023-002 Page 77 of 281 Section Title Change Description of Change 5.1.5.8 Criterion 37 - Modify This section is modified to remove reference to ECCS testing and note that Testing of Criterion 37 is not applicable in the defueled condition. Amendment 272 Emergency Core deleted TS Section 3.5, EMERGENCY CORE COOLING SYSTEMS, Cooling System reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not rely on ECCS for mitigation. Therefore, ECCS requirements are no longer applicable.

5.1.5.9 Criterion 38 - Modify This section is modified to remove reference to containment cooling and containment heat note that Criterion 38 is not applicable in the defueled condition.

removal Amendment 272 deleted TS 3.6.6, Containment Cooling Systems, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not rely on containment cooling for mitigation. Therefore, containment cooling requirements are no longer applicable.

HDI PNP 2023-002 Page 78 of 281 Section Title Change Description of Change 5.1.5.10 Criterion 39 - Modify This section is mpdified to remove reference to containment cooling Inspection of inspection and note that Criterion 39 is not applicable in the defueled Containment Heat condi!ion. Amendment 272 deleted TS 3.6.6, Containment Cooling Removal System Systems, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not rely on containment cooling for mitigation. Therefore, containment cooling requirements are no longer applicable.

5.1.5.11 Criterion 40 - Modify This section is modified to remove reference to testing of containment Testing of cooling SSCs and note that Criterion 40 is not applicable in the defueled Containment Heat condition. Amendment 272 deleted TS 3.6.6, Containment Cooling Removal System Systems, and associated testing requirements, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not rely on containment cooling for mitigation. Therefore, containment cooling testing requirements are no longer applicable.

HDI PNP 2023-002 Page 79 of 281 Section Title Change Description of Change 5.1.5.12 Criterion 41 - Modify This section is modified to remove reference to testing of containment Containment atmosphere cleanup and note that Criterion 41 is not applicable in the Atmosphere defueled condition. Amendment 272 deleted TS 3.5.5, Containment Sump Cleanup Buffering Agent and Weight Requirements, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not rely on containment cleanup for mitigation. Therefore, containment atmosphere cleanup requirements are no longer applicable.

5.1.5.13 Criterion 42 - Modify This section is modified to remove reference to inspection of sodium Inspection of tetraborate baskets and note that Criterion 42 is not applicable in the Containment defueled condition. Amendment 272 deleted TS 3.5.5, Containment Sump Atmosphere Buffering Agent and Weight Requirements, reflecting the permanent Cleanup Systems cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not rely on containment cleanup for mitigation. Therefore, inspection of the sodium tetraborate baskets is no longer applicable.

HDI PNP 2023-002 Page 80 of 281 Section Title Change Description of Change 5.1.5.14 Criterion 43 - Modify This section is modified to remove discussion of testing of sodium Testing of tetraborate baskets and note that Criterion 43 is not applicable in the Containment defueled condition. Amendment 272 deleted TS 3.5.5, Containment Sump Atmosphere Buffering Agent and Weight Requirements, reflecting the permanent Cleanup Systems cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not rely on containment cleanup for mitigation. Therefore, discussion of testing of the sodium tetraborate baskets is no longer applicable.

5.1.5.15 Criterion 44 - Modify This section is modified to remove reference to cooling water systems and Cooling Water note that Criterion 44 is not applicable in the defueled condition.

Amendment 272 deleted TS 3.7.7, Component Cooling Water (CCW)

System, TS 3.7.8, Service Water System (SWS), and 3.7.9, Ultimate Heat Sink (UHS), reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not rely on cooling water systems for mitigation. Therefore, cooling water systems are no longer relevant.

HDI PNP 2023-002 Page 81 of 281 Section Title Change Description of Change 5.1.5.16 Criterion 45 - Modify This section is modified to remove reference to inspection and testing of Inspection of cooling water systems and note that Criterion 45 and 46 are not applicable Cooling Water in the defueled condition. Amendment 272 deleted TS 3.7.7, Component System and Cooling Water (CCW) System, TS 3.7.8, Service Water System (SWS), and Criterion 46 - 3.7.9, Ultimate Heat Sink (UHS), reflecting the permanent cessation of Testing of Cooling operations at PNP and permanent removal of fuel from the PNP reactor Water System vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not rely on cooling water systems for mitigation. Therefore, cooling water systems are no longer relevant.

5.1.5.17 Conclusions Modify This section is modified to replace the word "Plant" with the word "Facility."

The text is revised to reference "applicable" criteria as some aspects of Group IV criteria are no longer applicable.

5.1.6.1 Criterion 50 - Modify This section is modified to delete containment design basis information and Containment Design note that Criterion 50 is not applicable in the defueled condition.

Basis Amendment 272 removed Tech Spec Section 3.6, "Containment Systems,"

and the facility license no longer contains requirements for the containment building and associated systems. The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. Therefore, containment design basis is no longer pertinent.

HDI PNP 2023-002 Page 82 of 281 Section Title Change Description of Change 5.1.6.2 Criterion 51 - Modify This section is modified to delete fracture prevention information and note Fracture Prevention that Criterion 51 is not applicable in the defueled condition.

of Containment Amendm_ent 272 removed Tech Spec Section 3.6, "Containment Systems,"

Pressure Boundary and the facility license no longer contains requirements for the containment building and associated systems. The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. Therefore, containment fracture prevention is no longer pertinent.

5.1.6.3 Criterion 52 - Modify This section is modified to delete containment testing information and note Capability for that Criterion 52 is not applicable in the defueled condition.

Containment Amendment 272 removed Tech Spec Section 3.6, "Containment Systems,"

Leakage Rate and the facility license no longer contains requirements for the containment Testing building and associated systems. The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. Therefore, containment testing is no longer pertinent.

5.1.6.4 Criterion 53 - Modify This section is modified to delete containment inspection and testing Provisions for information and note that Criterion 53 is not applicable in the defueled Containment Testing condition. Amendment 272 removed Tech Spec Section 3.6, "Containment and Inspection Systems," and the facility license no longer contains requirements for the containment building and associated systems. The reactor containment no longer performs an isolation function in the permanently shut down and defueled 1condition, nor is it required to perform an active function following any of the remaining accidents. Therefore, containment inspection and testing is no longer pertinent.

HDI PNP 2023-002 Page 83 of 281 Section Title Change Description of Change 5.1.6.5 Criterion 54 - Piping Modify This section is modified to delete containment penetration design and Systems Penetrating leakage testing information and note that Criterion 54 is not applicable in the Containment defueled condition. Amendment 272 removed Tech Spec Section 3.6, "Containment Systems," and the facility license no longer contains requirements for the containment building and associated systems. The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. Therefore, containment penetration design and leakage testing is no longer pertinent.

5.1.6.6 Criterion 55 - Modify This section is modified to delete PCS pressure boundary design Primary Coolant information and note that Criterion 55 is not applicable in the defueled Pressure Boundary condition. Amendment 272 removed Tech Spec 3.4.14 PCS Pressure Penetrating Isolation Valve (PIV) Leakage," and the facility license no longer contains Containment requirements for the PCS PIV leakage. The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. Therefore, PCS pressur~ boundary information is no longer pertinent.

5.1.6.7 Criterion 56 - Modify This section is modified to delete containment penetration isolation Primary information and note that Criterion 56 is not applicable in the defueled Containment condition. Amendment 272 removed Tech Spec Section 3.6, "Containment Isolation Systems," and the facility license no longer contains requirements for the containment building and associated systems. The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. Therefore, containment penetration isolation is no longer pertinent.

HDI PNP 2023-002 Page 84 of 281 Section Title Change Description of Change 5.1.6.8 Criterion 57 - Closed Modify This section is modified to delete containment penetration isolation System Isolation information and note that Criterion 57 is not applicable in the defueled Valves condition. Amendment 272 removed Tech Spec Section 3.6, "Containment Systems," and the facility license no longer contains requirements for the containment building and associated systems. The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. Therefore, containment penetration isolation is no longer pertinent.

5.1.6.9 Conclusions Modify Section is modified to note that Group V criteria are not applicable in the permanently defueled condition (See 5.1.6.1 through 5.1.6.8).

Amendment 272 removed Tech Spec Section 3.6, "Containment Systems,"

and the facility license no longer contains requirements for the containment building and associated systems. The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents.

5.1.7.1 Criterion 60 - Control Modify This section is modified to remove reference to defective fuel and to replace of Releases of the word "Plant" with the word "Facility."

Radioactive Materials to the Environment 5.1.7.2 Criterion 61 - Fuel Modify This section is modified to replace the word "Plant" with the word "Facility."

Storage and Handling and Radioactivity Control

HDI PNP 2023-002 Page 85 of 281 Section Title Change Description of Change 5.1.7.4 Criterion 63 - Modify This section is modified to replace the word "Plant" with the word "Facility."

Monitoring Fuel and Waste Storage 5.1.7.5 Criterion 64 - Modify This section is revised to remove reference to monitors no longer credited in Monitoring safety analyses, and is modified to replace the word "Plant" with the word Radioactivity "Facility." Amendment 272 removed Tech Spec 3.3.3, "Engineered Safety Releases Features (ESF) Instrumentation," 3.3.6, "Refueling Containment High Radiation- (CHR) Instrumentation, and 3.3.10, "Engineered Safeguards Room Ventilation (ESRV) Instrumentation," and the facility license no longer contains requirements for the radiation monitors. Certifications have been submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not rely on radiation monitors for mitigation.

5.1.7.6 Conclusions Modify This section is modified to replace the word "Plant" with the word "Facility."

The text is revised to reference "applicable" criteria as some aspects of Group IV criteria are no longer applicable (See 5.1.7.5).

5.1.8 Overall Conclusion Modify This section is modified to replace the word "Plant" with the word "Facility."

5.2.1 Background Modify This section is modified to replace the word "Plant" with the word "Facility."

Information 5.2.1.2 Original Palisades Modify This section is modified to replace the word "Plant" with the word "Facility."

Design Review

HDI PNP 2023-002 Page 86 of 281 Section Title Change Description of Change 5.2.2.3 Design - Class 3 Modify This section is modified to replace the word "Plant" with the word "Facility."

5.2.2.7 Service - Electrical Modify This section is modified to revise reference to FSAR to the DSAR. After and Instrumentation implementation of Amendment 272, the document will be referred to as and Controls Defueled Safety Analysis Report.

Equipment Classification 5.2.2.8.2 Important to Safety Modify This section is modified to revise reference to FSAR to the DSAR. After implementation of Amendment 272, the document will be referred to as Defueled Safety Analysis Report.

5.4.1.1 Description of Modify This section is modified to replace the word "Plant" with the word "Facility."

Events 5.4.1.2 Effects on Modify This section is modified to replace the word "Plant" with the word "Facility."

Consumers Design Class 1 Structures and Safety-Related Equipment 5.4.2 Flooding and Modify This section is modified to replace the word "Plant" with the word "Facility."

Wetting from Plant Sources *,. -:-

Table of Auxiliary Building Modify Error in TOC. Section title in TOC is revised from "Intake Structure" to Contents TSC/EER/HVAC "Auxiliary Building TSC/EER/HVAC Addition." No change to DSAR text.

5.5.1.1.2 Addition

HDI PNP 2023-002 Page 87 of 281 Section Title Change Description of Change Table of Diesel Fuel Oil Modify Error in TOG. Section title in TOC is revised from "Auxiliary Building Contents Storage Tank Radwaste Addition" to "Diesel Fuel Oil Storage Tank Housing." No change 5.5.1.1.3 Housing to DSAR text.

5.5.1.1.4 Condensate Storage Modify Error in TOG. Section title in TOG is revised from "Auxiliary Building And Table Tank TSC/EER/HVAC Addition" to "Condensate Storage Tank" and is modified to of replace the word "Plant" with the word "Facility." No change to DSAR text.

Contents Table of Equipment Hatch Modify Error in TOG. Section title in TOG is revised from "Diesel Fuel Oil Storage Contents Tank Housing" to "Equipment Hatch."

5.5.1.1.5 Table of Condensate Storage Delete Error in TOG. Reference to 5.5.1.1.6 is removed from TOG. There are only Contents Tank 5 subsections.

5.5.1.1.6 5.5.1.2 Structural Modify This section is modified remove reference to missile impact to operation of Considerations safety related systems (which are no longer required to operate) and to replace t.be word "Plant" with the word "Facility."

5.5.1.3 Facility Reevaluation Modify This section is modified to replace the word "Plant" with the word "Facility."

5.5.1.3.2 Summary Modify This section is modified to replace the word "Plant" with the word "Facility."

HDI PNP 2023-002 Page 88 of 281 Section Title Change Description of Change 5.5.2 Turbine Missiles Delete This section is deleted in its entirety. This section is revised to reflect that the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur. Therefore, turbine missiles are no longer a credible scenario.

5.5.3 Internally Generated Delete This section is deleted in its entirety. This section is revised to reflect that Missiles the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur. Therefore, internally generated missiles are no longer a credible scenario.

5.5.4 Site Proximity Modify This section is modified to revise safe shutdown to maintain fuel in a safe Missiles condition, delete reference to backups for safety related equipment, and replace the word "Plant" with the word "Facility." Amendment 272 removed accident scenarios related to the NSSS. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and safe shutdown is no longer applicable. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit any active SSCs rendering "backup systems" irrelevc;1nt.

HDI PNP 2023-002 Page 89 of 281 Section Title Change Description of Change 5.5 References Modify References removed from text are deleted.

5.6 Dynamic Effects of Modify The sub-sections in 5.6 are deleted with the exception of 5.6.7.3.

Pipe Rupture Amendment 272 removed accident scenarios related to the NSSS.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, pipe rupture, and its associated dynamic effects, is no longer a credible scenario. Pipe break in the two moderate energy systems has no safety impact (see 5.6.7.3).

5.6.1 Definitions Delete See Section 5.6 5.6.2 Design Bases Delete See Section 5.6 5.6.3 Criteria Used to Delete See Section 5.6 Define Breaks 5.6.4 Protective Measures Delete See Section 5.6 5.6.5 Jet Impingement Delete See Section 5.6

HDI PNP 2023-002 Page 90 of 281 Section Title Change Description of Change 5.6.6 Plant Modification Delete See Section 5.6 Line-Break Analysis 5.6.7 History of Palisades Delete See Section 5.6 High-Energy Line-Break Analysis 5.6.7.1 High-Energy Line Delete See Section 5.6 Breaks Outside Containment 5.6.7.2 High-Energy Line Delete See Section 5.6 Breaks Inside Containment 5.6.7.3 Moderate-Energy Modify The sections is revised to note no safety impact from pipe break in CCW or

. System Pipe-Break SWS. Amendment 272 removed accident scenarios related to the NSSS .

Evaluation - Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer, possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, pipe rupture, and its associated dynamic effects, is no longer a credible scenario. Pipe break in the two moderate energy systems has no safety impact (see 5.6.7.3).

5.6 References Delete See Section 5.6

HDI PNP 2023-002 Page 91 of 281 Section Title Change Description of Change 5.7 Seismic Design Modify This section is modified to replace the word "Plant" with the word "Facility."

5.7.1.1 Design Bases Modify Section is revised to remove definition of Operating Basis Earthquake (OBE) and revise SSE to safe storage of spent nuclear fuel. This section is modified to revise reference to FSAR to the DSAR. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Reference to plant operation or safe shutdown is no longer relevant, and safe shutdown has been replaced with safe storage of spent fuel. After implementation of Amendment 272, the document will be referred to as Defueled Safety Analysis Report.

5.7.4 Seismic Analysis of Modify This section is modified to replace the word "Plant" with the word "Facility."

CP CO Design Class 1 Piping 5.7.8 Seismic Analysis of Modify This section is modified to replace the word "Plant" with the word "Facility."

Buried Structures and Components 5.7.9 Seismic Modify This section is modified to replace the word "Plant" with the word "Facility."

Instrumentation

HDI PNP 2023-002 Page 92 of 281 Section Title Change Description of Change 5.8.1 Design Basis Modify This section is modified to remove discussion of accident conditions and scenarios. This section is revised to reflect that the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

Therefore, discussion of accident conditions and scenarios inside containment is deleted.

5.8.2 General Description Modify This section is revised to remove reference to section 5.8.8.3, which has been deleted, and is modified to replace the word "Plant" with the word "Facility." .

5.8.3.1.2 Working Stress Modify This section is modified to remove loadings associated with operation and Condition accident conditions. Amendment 272 removed Tech Spec Section 3.6, "Containment Systems," and Tech Spec Section 5.5.5, "Containment Structural Integrity Surveillance Program," and the facility license no longer contains requirements for the containment building and associated systems.

The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. However, it will continue to be required to maintain its structural integrity to ensure that it does not have any impact on the safe storage of spent fuel in the SFP.

Therefore, operational and accident conditions are removed from the stress requirements.

HDI PNP 2023-002 Page 93 of 281 Section Title Change Description of Change 5.8.3.1.3 Yield Strength Modify This section is modified to remove loadings associated with operation of Condition accident conditions. Amendment 272 removed Tech Spec Section 3.6, "Containment Systems," and Tech Spec Section 5.5.5, "Containment Structural Integrity Surveillance Program," and the facility license no longer contains requirements for the containment building and associated systems.

The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. However, it will continue to be required to maintain its structural integrity to ensure that it does not have any impact on the safe storage of spent fuel in the SFP.

Therefore, operational and accident conditions are removed from the yield strength requirements.

5.8.3.2.1 Liner Plate Modify This section is modified to remove loadings associated with operational and accident conditions. Amendment 272 removed Tech Spec Section 3.6, "Containment Systems," and Tech Spec Section 5.5.5, "Containment Structural Integrity Surveillance Program," and the facility license no longer contains requirements for the containment building and associated systems.

The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. However, it will continue to be required to maintain its structural integrity to ensure that it does not have any impact on the safe storage of spent fuel in the SFP.

Therefore, operational and accident conditions are removed from the structure load requirements.

HDI PNP 2023-002 Page 94 of 281 Section Title Change Description of Change 5.8.3.2.2 Liner Plate Anchors Modify This section is modified to remove loadings associated with operational and accident conditions. Amendment 272 removed Tech Spec Section 3.6, "Containment Systems," and Tech Spec Section 5.5.5, "Containment Structural Integrity Surveillance Program," and the facility license no longer contains requirements for the containment building and associated systems.

The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. However, it will continue to be required to maintain its structural integrity to ensure that it does not have any impact on the safe storage of spent fuel in the SFP.

Therefore, operational and accident conditions are removed from the fatigue load requirements.

5.8.4.1.1 General Modify This section is modified to remove loadings associated with operational and accident conditions. Amendment 272 removed Tech Spec Section 3.6, "Containment Systems," and Tech Spec Section 5.5.5, "Containment Structural Integrity Surveillance Program," and the facility license no longer contains requirements for the containment building and associated systems.

The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. However, it will continue to be required to maintain its structural integrity to ensure that it does not have any impact on the safe storage of spent fuel in the SFP.

Therefore, operational and accident conditions are removed from the load requirements.

HDI PNP 2023-002 Page 95 of 281 Section Title Change Description of Change 5.8.5.1 Design Basis Modify This section is modified to remove reference to accident conditions and leak tightness and is modified to replace the word "Plant" with the word "Facility."

Amendment 272 removed Tech Spec Section 3.6, "Containment Systems,"

and Tech Spec Section 5.5.5, "Containment Structural Integrity Surveillance Program," and the facility license no longer contains requirements for the containment building and associated systems. The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. However, it will continue to be required to maintain its structural integrity to ensure that it does not have any impact on the safe storage of spent fuel in the SFP. Therefore, reference to operational and accident conditions are removed.

5.8.5.2.1 General Criteria Modify This section is modified to remove reference to accident conditions and leak tightness. Reference to Section 5.8.8.2, which has been deleted, is also removed. Amendment 272 removed Tech Spec Section 3.6, "Containment Systems," and Tech Spec Section 5.5.5, "ContainmentStructural Integrity Surveillance Program," and the facility license no longer contains requirements for the containment building and associated systems. The reactor c6ntainment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. However, it will continue to be required to maintain its structural integrity to ensure that it does not have any impact on the safe storage of spent fuel in the SFP.

Therefore, reference to operational and accident conditions are removed.

HDI PNP 2023-002 Page 96 of 281 Section Title Change Description of Change 5.8.5.4.1 General Modify This section is modified to remove reference to accident conditions and leak tightness. Amendment 272 removed Tech Spec Section 3.6, "Containment Systems," and Tech Spec Section 5.5.5, "Containment Structural Integrity Surveillance Program," and the facility license no longer contains requirements for the containment building and associated systems. The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. However, it will continue to be required to maintain its structural integrity to ensure that it does not have any impact on the safe storage of spent fuel in the SFP.

Therefore, reference to operational and accident conditions are removed.

5.8.5.4.2 Liner Plate Modify This section is modified to remove reference to accident conditions.

Amendment 272 removed Tech Spec Section 3.6, "Containment Systems,"

and Tech Spec Section 5.5.5, "Containment Structural Integrity Surveillance Program," and the facility license no longer contains requirements for the containment building and associated systems. The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. However, it will continue to be required to maintain its structural integrity to ensure that it does not have any impact on the safe storage of spent fuel in the SFP. Therefore, reference to operational and accident conditions are removed.

HDI PNP 2023-002 Page 97 of 281 Section Title Change Description of Change 5.8.6.1 Design Basis Modify This section is modified to remove reference to accident conditions.

Amendment 272 removed Tech Spec Section 3.6, "Containment Systems,"

and Tech Spec Section 5.5.5, "Containment Structural Integrity Surveillance Program," and the facility license no longer contains requirements for the containment building and associated systems. The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. However, it will continue to be required to maintain its structural integrity to ensure that it does not have any impact on the safe storage of spent fuel in the SFP. Therefore, reference to operational and accident conditions are removed.

5.8.6.2 General Description Modify This section is modified to remove reference to leak tightness.

Amendment 272 removed Tech Spec Section 3.6, "Containment Systems,"

and Tech Spec Section 5.5.5, "Containment Structural Integrity Surveillance Program," and the facility license no longer contains requirements for the containment building and associated systems. The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. However, it will continue to be required to maintain its structural integrity to ensure that it does not have any impact on the safe storage of spent fuel in the SFP. Therefore, reference to leak tightness is removed.

HDI PNP 2023-002 Page 98 of 281 Section Title Change Description of Change 5.8.6.2.1 Personnel and Modify This section is modified to remove references to leak testing.

Equipment Amendment 272 removed Tech Spec Section 3.6, "Containment Systems,"

Openings and L'.icense Condition 2.D regarding Appendix J testing, and the facility license will no longer require a leakage testing program for containment.

The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. However, it will continue to be required to maintain its structural integrity to ensure that it does not have any impact on the safe storage of spent fuel in the SFP. Therefore, reference to leak testing is removed.

5.8.6.2.2 Other Openings Modify This section is modified to remove references to leak testing.

Amendment 272 removed Tech Spec Section 3.6, "Containment Systems,"

and License Condition 2.D regarding Appendix J testing, and the facility license will no longer require a leakage testing program for containment.

The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. However, it will continue to be required to maintain its structural integrity to ensure that it does not have any impact on the safe storage of spent fuel in the SFP. Therefore, reference to leak testing is removed.

HDI PNP 2023-002 Page 99 of 281 Section Title Change Description of Change 5.8.6.4.1 Small Penetrations Modify This section is modified to remove reference to accident conditions.

Amendment 272 removed Tech Spec Section 3.6, "Containment Systems,"

and Tech Spec Section 5.5.5, "Containment Structural Integrity Surveillance Program," and the facility license no longer contains requirements for the containment building and associated systems. The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. However, it will continue to be required to maintain its structural integrity to ensure that it does not have any impact on the safe storage of spent fuel in the SFP. Therefore, reference to operational and accident conditions are removed.

5.8.8 Containment Delete This section is deleted in its entirety. Amendment 272 removed Tech Spec Structure Testing Section 3.6, "Containment Systems," and License Condition 2.D regarding Appendix J testing, and the facility license will no longer require a leakage testing program for containment. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits 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.

5.8.9.2 Containment Modify This Section is modified to replace the word "Plant" with the word "Facility."

Reevaluation

HDI PNP 2023-002 Page 100 of 281 Section Title Change Description of Change 5.8.10 Containment Delete This section is deleted in its entirety Amendment 272 removed Tech Spec Structural Integrity Section 3.6, "Containment Systems," and Tech Spec Section 5.5.5, Surveillance "Containment Structural Integrity Surveillance Program," and the facility Program license no longer contains requirements for the containment building and associated systems. The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. The surveillance program was established to satisfy the requirements of the facility Technical Specifications therefore, this program is no longer required.

5.8 References Modify References removed from text are deleted 5.9.1.4 Loads Common to Modify This Section is modified to replace the word "Plant" with the word "Facility."

All Structures

HDI PNP 2023-002 Page 101 of 281 Section Title Change Description of Change 5.9.2.1 General Description Modify This section is revised to remove reference to functional requirements related to internally generated missiles and pipe whip and is modified to revise reference to FSAR to the DSAR. Physical descriptions of SSCs are retained. Amendment 272 removed accident scenarios related to the NSSS. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents and associated structural loadings are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, and internal missiles and pipe whip are no longer applicable. After implementation of Amendment 272, the document will be referred to as Defueled Safety Analysis Report.

5.9.2.2 Loads Modify This section is modified to delete reference to Subsection 5.5.3, which has been deleted.

5.9.3.1 General Description Modify This section is revised to remove reference to pipe whip and associated jet forces. See 5.6.3 which was deleted. Amendment 272 removed accident scenarios related to the NSSS. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents and associated pipe whip are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

HDI PNP 2023-002 Page 102 of 281 Section Title Change Description of Change 5.9.5.1 General Description Modify This section is modified to change FSAR to DSAR. After implementation of Amendment 272, the document will be referred to as Defueled Safety Analysis Report.

5.9.6.1 General Description Modify Section is modified by deleting reference to NUREG 0737. NUREG 0737 only 8-PPlies to operating power reactors.

5.10.3.2.2 Identification Modify This Section is modified to replace the word "Plant" with the word "Facility."

Table 5.5- Burst Probability for Delete Reference to Table is deleted in text 5.5.2.3 2 Each LP Rotor and Total Unit at 120%

Rated Speed Table 5.6- High-Energy Pipe Delete Section 5.6 is deleted 1 Failures Outside Containment -

Summary of Operating Stresses -

Main Steam Table 5.6- High-Energy Pipe Delete Section 5.6 is deleted 2 Failures Outside Containment -

Summary of Operating Stresses -

Feedwater r- .

HDI PNP 2023-002 Page 103 of 281 Section Title Change Description of Change Table 5.6- High-Energy Pipe Delete Section 5.6 is deleted 3 Failures Outside Containment -

Summary of Operating Stresses -

Main Steam Dump Table 5.6- Summary of Delete Section 5.6 is deleted 4 Eliminated Hardware Resulting from Application of Generic Letter 87-11, "Relaxation of Arbitrary Pipe Rupture Requirements" Table 5.8- Containment Delete Reference to Table is deleted in text 5.8.8.2.3 4 Penetrations and Appendix J Test Requirements Figure 5.8- Containment Delete Reference to Figure is deleted in text 5.8.4.1.2 10 Structure, OBA Thermal Gradients Across Containment Wall, No Insulation Figure 5.8- Containment Delete Reference to Figure is deleted in text 5.8.6.4.1 18 Structure, Thermal Gradient at Main Steam Penetration

HDI PNP 2023-002 Page 104 of 281 Section Title Change Description of Change Figure 5.8- Containment Delete Reference to Figure is deleted in text 5.8.8.4.4 24 Structure, Location and Identification of Eleven Surveillance Tendons for One-and Three-Year Surveillances Figure 5.8- Sh 1 Containment Delete Reference to Figure is deleted in text 5.8.8.4.4 25 Structure, Structural Integrity Test Inside Hoop Strain Profiles, Typical Section Figure 5.8- Sh 2 containment Delete Reference to Figure is deleted in text 5.8.8.4.4 25 structure, structural integrity test outside meridional strain profiles, typical section Figure 5.8- Containment Delete Reference to Figure is deleted in text 5.8.8.4.4 26 Structure, Pressure Test Displacement Profiles Figure 5.8- Sh 1 Containment Delete Reference to Figure is deleted in text 5.8.8.4.4 27 Structure, Pressure Test Tend on Load Change

HDI PNP 2023-002 Page 105 of 281 Section Title Change Description of Change Figure 5.8- Sh 2 Containment Delete Reference to Figure is deleted in text 5.8.8.4.4 27 Structure, Pressure Test Tendon Load Change Figure 5.8- Containment Delete Reference to Figure is deleted in text 5.8.8.6.3 28 Structure, End Anchorage Surveillance Program, Crack Surveillance Locations 6.1.1 Design Bases Modify Section is revised to delete information on safety functions and accident parameters. SSC classifications were retained along with information on the EQ program. Amendment 272 removed Tech Spec Section 3.5, ECCS, and the facility license no longer contains requirements for the ECCS and associated systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no pertinent engineered safeguards design criteria or design functions in the permanently defueled condition. SSC Classification and EQ program descriptions are retained as these are not addressed in Amendment 272.

HDI PNP 2023-002 Page 106 of 281 Section Title Change Description of Change 6.1.2.1 General Description Modify Section is revised to delete information on safety functions and accident parameters. SSC physical descriptions were retained. Amendment 272 removed Tech Spec Section 3.5, ECCS, and the facility license no longer contains requirements for the ECCS and associated systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or empl~cement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no pertinent engineered safeguards design criteria or design functions in the permanently defueled condition. SSC physical descriptions are retained in accordance with RG 1.184.

6.1.2.2 Component Design Modify Section is revised to delete information on safety functions and accident and operational parameters of ECCS components. SSC physical descriptions were retained. Amendment 272 removed Tech Spec Section 3.5, ECCS, and the facility license no longer contains requirements for the ECCS and associated systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no pertinent engineered safeguards design criteria or design functions in the permanently defueled condition. SSC physical descriptions are retained in accordance with RG 1.184.

HDI PNP 2023-002 Page 107 of 281 Section Title Change Description of Change 6.1.2.3 Operation Delete Section .is deleted in its entirety. Amendment 272 removed Tech Spec Section 3.5, ECCS, and the facility license no longer contains requirements for the ECCS and associated systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no pertinent engineered safeguards operational modes in the permanently defueled condition.

6.1.3 Testing Delete All subsections are deleted.

Subsections 6.1.3.1 Operational Testing Delete Section is deleted in its entirety. Amendment 272 removed TS SECTION 3.5, EMERGENCY CORE COOLING SYSTEMS (ECCS), as well as Tech Spec 3.3.3, Engineered Safety Features (ESF) Instrumentation, 3.3.4, Engineered Safety Features Logic and Manual Initiation, and 3.3.5, Diesel Generator (DG) - Undervoltage Start (UV Start) Instrumentation. Therefore, there are no testing requirements for logic circuits, pumps, or power-actuated valves in the Safety Injection System. Amendment 272 removed the TS definition of inservice testing and associated references in Section 3.0. lnservice testing in accordance with 10 CFR 50.55a is not required in the permanently defueled condition.

6.1.3.2 Environmental Delete Section is deleted in its entirety. 10 CFR 50.49 only applies to operating Testing power reactors.

HDI PNP 2023-002 Page 108 of 281 Section Title Change Description of Change 6.1.4 Design Analysis Modify Section is revised to delete information on safety functional requirements, design requirements and accident parameters. SSC classifications were retained. Amendment 272 removed Tech Spec Section 3.5, ECCS, and the facility license no longer contains requirements for the ECCS and associated systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no pertinent engineered safeguards safety functional requirements in the permanently defueled condition. SSC Classification descriptions are retained as these are not addressed in Amendment 272.

6.2.1 Design Basis Modify Secti.on is revised to delete information on safety functional requirements, design requirements and accident parameters. SSC classifications were retained. Amendment 272 removed Tech Spec Section 3.5, CONTAINMENT SYSTEMS, including TS 3.6.6, Containment Cooling Systems, and the facility license no longer contains requirements for the containment systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no pertinent safety functional requirements for containment spray in the permanently defueled condition. SSC Classification descriptions are retained as these are not addressed in Amendment 272.

HDI PNP 2023-002 Page 109 of 281 Section Title Change Description of Change 6.2.2.1 General Description Modify Section is revised to delete information on safety functional requirements, operation descriptions, design requirements and accident parameters. SSC classifications and physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.5, CONTAINMENT SYSTEMS, including TS 3.6.6, Containment Cooling Systems, and the facility license no longer contains requirements for the containment systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no pertinent safety functional requirements for containment spray in the permanently defueled condition. SSC Classification and physical descriptions are retained as these are not addressed in Amendment 272.

6.2.2.3 System operation Delete Section is deleted in its entirety. Amendment 272 removed Tech Spec Section 3.5, CONTAINMENT SYSTEMS, including TS 3.6.6, Containment Cooling Systems, and the facility license no longer contains requirements for the containment systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no operational or functional requirements for containment spray in the permanently defueled condition.

HDI PNP 2023-002 Page 110 of281 Section Title Change Description of Change 6.2.3 Design Analysis Delete Section is deleted in its entirety. Amendment 272 removed Tech Spec Section 3.5, CONTAINMENT SYSTEMS, including TS 3.6.6, Containment Cooling Systems, and the facility license no longer contains requirements for the containment systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no margin of safety requirements for containment spray in the permanently defueled condition.

6.3.1 Design Bases Modify Section is revised to delete information on safety and design functional requirements and accident parameters. SSC classifications and physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.5, CONTAINMENT SYSTEMS, including TS 3.6.6, Containment Cooling Systems, and the facility license no longer contains requirements for the containment systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no safety and design functional requirements for containment air coolers in the permanently defueled condition.

HDI PNP 2023-002 Page 111 of 281 Section Title Change Description of Change 6.3.2.1 General Description Modify Section*is revised to delete information on functional requirements and system operation. SSC classifications and physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.5, CONTAINMENT SYSTEMS, including TS 3.6.6, Containment Cooling Systems, and the facility license no longer contains requirements for the containment systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no functional requirements for containment air coolers in the permanently defueled condition.

6.3.2.2 System Operation Delete Section is deleted in its entirety. Amendment 272 removed Tech Spec Section 3.5, CONTAINMENT SYSTEMS, including TS 3.6.6, Containment Cooling Systems, and the facility license no longer contains requirements for the containment systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no functional requirements for containment air coolers in the permanently defueled condition.

HDI PNP 2023-002 Page 112 of 281 Section Title Change Description of Change 6.3.3 Design Analysis Delete Section is deleted in its entirety. Amendment 272 removed Tech Spec Section 3.5, CONTAINMENT SYSTEMS, including TS 3.6.6, Containment Cooling Systems, and the facility license no longer contains requirements for the containment systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no safety or design functional requirements for containment air coolers in the permanently defueled condition.

6.4.1 Design Basis Modify Section is revised to delete information on qualification and functional requirements of paint inside containment. Physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.5, CONTAINMENT SYSTEMS, including TS 3.6.6, Containment Cooling Systems, and the facility license no longer contains requirements for the containment systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no qualification and functional requirements related to paint in the permanently defueled condition.

HDI PNP 2023-002 Page 113 of 281 Section Title Change Description of Change 6.4.2.1 General Description Modify Section is revised to delete information on functional requirements. SSC physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.5, CONTAINMENT SYSTEMS, including TS 3.6.6, Containment Cooling Systems, and the facility license no longer contains requirements for the containment systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no functional requirements related to sump pH control in the permanently defueled condition.

6.4.2.2 Operation Delete Section is deleted in its entirety. Amendment 272 removed Tech Spec Section 3.5, CONTAINMENT SYSTEMS, including TS 3.6.6, Containment Cooling Systems, and the facility license no longer contains requirements for the containment systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no operational requirements related to sump pH control in the permanently defueled condition.

HDI PNP 2023-002 Page 114 of 281 Section Title Change Description of Change 6.4.2.3 Materials Modify Section is revised to delete information on safety and design functional requirements. SSC physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.5, CONTAINMENT SYSTEMS, including TS 3.6.6, Containment Cooling Systems, and the facility license no longer contains requirements for the containment systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no safety or design functional requirements related to sump pH control in the permanently defueled condition.

6.4.2.4 Paint Modify Section is revised to delete information on qualification and functional requirements of paint inside containment. Physical descriptions are retained.

Amendment 272 removed Tech Spec Section 3.5, CONTAINMENT SYSTEMS, including TS 3.6.6, Containment Cooling Systems, and the facility license no longer contains requirements for the containment systems.

The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no qualification and functional requirements related to paint in the permanently defueled condition.

HDI PNP 2023-002 Page 115 of 281 Section Title Change Description of Change 6.5.1 General Modify Section is revised to delete information on iodide generation post OBA. The physical description of the containment charcoal filter is retained. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. Therefore, iodide production during a OBA is not possible.

6.7 Containment Delete Section and subsections are deleted in their entirety. Amendment 272 Isolation System removed Tech Spec Section 3.5, CONTAINMENT SYSTEMS, including TS 3.6.3, Containment Isolation Valves, and the facility license no longer contains requirements for the containment isolation. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no requirements for containment isolation in the permanently defueled condition.

6.8 Reactor Cavity Modify This section is modified to remove discussion of post OBA operation.

Flooding System Physical descriptions are retained.

6.8.1 System Operation Modify This section is modified to remove discussion of post OBA operation.

Physical descriptions are retained.

HDI PNP 2023-002 Page 116 of 281 Section Title Change Description of Change 6.9.2 Pump and Valve Delete Section is deleted in its entirety. Amendment 272 removed the TS definition Testing Program of inservice testing and associated references in Section 3.0. lnservice testing in accordance with 10 CFR 50.55a is not required in the permanently defueled condition.

6.9.2.1 Pump Testing Delete Section is deleted in its entirety. Amendment 272 removed the TS definition Program of inservice testing and associated references in Section 3.0. lnservice testing in accordance with 10 CFR 50.55a is not required in the permanently defueled condition.

6.9.2.2 Valve Testing Delete Section is deleted in its entirety. Amendment 272 removed the TS definition Program of inservice testing and associated references in Section 3.0. lnservice testing in accordance with 10 CFR 50.55a is not required in the permanently defueled condition.

6.10.1 Design Basis Delete This section is deleted in its entirety. Amendment 272 deleted TS 3.7.10, Control Room Ventilation (CRV) Filtration, and TS 3.7.11, Control Room Ventilation (CRV) Cooling, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. After certifications are submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer possible, and the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These accident analyses do not credit any control room habitability systems while still maintaining CR doses within licensing basis requirements, and therefore there is no safety design basis for control room habitability.

HDI PNP 2023-002 Page 117 of 281 Section Title Change Description of Change 6.10.2 System Design Modify This section modified to remove discussion of safety functions and accident conditions. Amendment 272 deleted TS 3.7.10, Control Room Ventilation (CRV} Filtration, and TS 3.7.11, Control Room Ventilation (CRV} Cooling, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. After certifications are submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer possible, and the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These accident analyses do not credit any control room habitability systems while still maintaining CR doses within licensing basis requirements, and therefore reference to safety functions and accident conditions are deleted.

6.10.3 Design Analysis Delete This section is deleted in its entirety. Amendment 272 deleted TS 3. 7 .10, Control Room Ventilation (CRV) Filtration, and TS 3. 7 .11, Control Room Ventilation (CRV) Cooling, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. After certifications are submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer possible, and the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These accident analyses do not credit any control room habitability systems while still maintaining CR doses within licensing basis requirements, and therefore there is no safety design basis for control room habitability.

HDI PNP 2023-002 Page 118 of 281 Section Title Change Description of Change 6.0 References Modify This section is modified to delete references which have been removed from the text. In addition, Reference 23, which is the license amendment that deleted hydrogen recombiners and is not used in the text, is deleted.

Table 6-1 Safety Injection and Modify The information in this table regarding operational parameters for the tank is Refueling Water deleted. Equipment descriptions are retained. Amendment 272 deleted Tank Design Tech Spec Section 3.5, EMERGENCY CORE COOLING SYSTEMS, Parameters reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Operational parameters on equipment required for core related design basis accidents is deleted.

HDI PNP 2023-002 Page 119 of 281 Section Title Change Description of Change Table 6-2 Low Pressure Safety Modify The information in this table regarding operational and DBA parameters for Injection Pump Data the LPSI pump is deleted. Equipment descriptions are retained.

Summary Amendment 272 deleted Tech Spec Section 3.5, EMERGENCY CORE COOLING SYSTEMS, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Operational and DBA parameters on equipment required for core related design basis accidents is deleted.

Table 6-3 High Pressure Modify The information in this table regarding operational and DBA parameters for Safety Injection the HPSI pump is deleted. Equipment descriptions are retained.

Pump Data Amendment 272 deleted Tech Spec Section 3.5, EMERGENCY CORE Summary COOLING SYSTEMS, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Operational and DBA parameters on equipment required for core related design basis accidents is deleted.

HDI PNP 2023-002 Page 120 of 281 Section Title Change Description of Change Table 6-4 Shutdown Cooling Modify The information in this table regarding operational and OBA parameters for Heat Exchanger the heat exchanger is deleted. Equipment descriptions are retained.

Data Summary This table is revised to reflect that the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Operational and OBA parameters on equipment required for core related design basis accidents is deleted.

Table 6-5 Safety Injection Modify The information in this table regarding operational and OBA parameters for Tank Design the SI tank is deleted. Equipment descriptions are retained.

Parameters Amendment 272 deleted Tech Spec Section 3.5, EMERGENCY CORE COOLING SYSTEMS, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Operational and OBA parameters on equipment required for core related design basis accidents is deleted.

HDI PNP 2023-002 Page 121 of 281 Section Title Change Description of Change Table 6-6 Containment Spray Modify The information in this table regarding operational and DBA parameters for System Component containment spray is deleted. Equipment descriptions are retained.

Description Amendment 272 deleted Tech Spec Section 3.5, EMERGENCY CORE COOLING SYSTEMS, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Operational and DBA parameters on equipment required for core related design basis accidents is deleted.

Table 6-7 Containment Air Modify The information in this table regarding operational and DBA parameters for Cooler Component air co0olers is deleted. Equipment descriptions are retained. This table is Description revised to reflect that the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Operational and DBA parameters on equipment required for core related design basis accidents is deleted.

HDI PNP 2023-002 Page 122 of 281 Section Title Change Description of Change Table 6-8 Containment Air Delete This table is deleted in its entirety. Amendment 272 deleted Tech Spec Coolers Section 3.5, EMERGENCY CORE COOLING SYSTEMS, reflecting the Performance Data permanent cessation of operations at PNP and permanent removal of fuel for Normal from the PNP reactor vessel. The certifications required by Operation 10 CFR.50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Operational parameters on equipment required for core related design basis accidents is deleted.

Table 6-9 Containment Air Delete This table is deleted in its entirety. Amendment 272 deleted Tech Spec Coolers Section 3.5, EMERGENCY CORE COOLING SYSTEMS, reflecting the Performance Data permanent cessation of operations at PNP and permanent removal of fuel for Post-OBA from the PNP reactor vessel. The certifications required by Conditions 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. OBA parameters on equipment required for core related design basis accidents is deleted.

Table 6-13 lnservice Pump Test Delete Table is deleted in its entirety. Amendment 272 removed the TS definition Program Summary of inservice testing and associated references in Section 3.0. lnservice testing in accordance with 10 CFR 50.55a is not required in the permanently defueled condition.

HDI PNP 2023-002 Page 123 of 281 Section Title Change Description of Change Table 6-14 Technical Delete Table is deleted in their entirety. Amendment 272 removed Tech Spec Specification 3.6.3, Section 3.5, CONTAINMENT SYSTEMS, including TS 3.6.3, Containment "Containment Isolation Valves, and the facility license no longer contains requirements for Isolation Valves," the containment isolation. The certifications required by 10 CFR 50.82(a)(1)

Applicability are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no requirements for containment isolation in the permanently defueled condition.

Figure 6-3 Containment Air Delete This figure is deleted in its entirety. Amendment 272 deleted Tech Spec Coolers Relief Panel Section 3.5, EMERGENCY CORE COOLING SYSTEMS, and 3.6,

& Condensate Drain CONTAINMENT SYSTEMS, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. This figure provides operational and OBA features for the air coolers and is deleted.

HDI PNP 2023-002 Page 124 of 281 Section Title Change Description of Change Figure 6-7 Capacity Curve Delete This figure provides operational information for core spray is deleted in its 1713a Nozzle entirety. Amendment 272 deleted Tech Spec Section 3.5, EMERGENCY CORE COOLING SYSTEMS, and 3.6, CONTAINMENT SYSTEMS, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. The certifications required by 10 CFR 50.82{a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Operational parameters on equipment required for core related design basis accidents is deleted.

7.1 Introduction Modify This section is revised to delete discussion of control plant operations, instrumentation safety functions, and EQ. Also, "Plant" is replace with "Facility." Amendment 272 removed Tech Spec Section 3.3, Instrumentation, and the facility license no longer contains requirements for instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems. Therefore, there are no pertinent instrumentation or control functional requirements in the permanently defueled condition. In addition, EQ and 10 CFR 50.49 only apply to operating power reactors.

HDI PNP 2023-002 Page 125 of 281 Section Title Change Description of Change 7.2.1 General Modify This section is revised to delete functional and design requirements of the RPS. Physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.3, Instrumentation, including TS 3.3.1, Reactor Protective System (RPS) Instrumentation, and the facility license no longer contains requirements for instrumentation systems. The certifications required by 10 CFR 50 .82( a)( 1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems. Therefore, there are no pertinent RPS design or functional requirements in the permanently defueled condition.

7.2.2 Design Bases Delete This section is deleted in its entirety. Amendment 272 removed Tech Spec Section 3.3, Instrumentation, including TS 3.3.1, Reactor Protective System (RPS) Instrumentation, and the facility license no longer contains requirements for instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems. Therefore, the design basis of the RPS instrumentation is no longer pertinent.

HDI PNP 2023-002 Page 126 of 281 Section Title Change Description of Change 7.2.3 Reactor Protective Delete This section is deleted in its entirety. Amendment 272 removed Tech Spec System Actions Section 3.3, Instrumentation, including TS 3.3.1, Reactor Protective System (RPS) Instrumentation, and the facility license no longer contains requirements for instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems. Therefore, there are no pertinent RPS functional requirements in the permanently defueled condition.

7.2.4 Signal Generation Delete This section is deleted in its entirety. Amendment 272 removed Tech Spec Section 3.3, Instrumentation, including TS 3.3.1, Reactor Protective System (RPS) Instrumentation, and the facility license no longer contains requirements for instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wast~s or radioactive liquids. These do not credit operator action or any active systems. Therefore, there are no pertinent RPS functional requirements in the permanently defueled condition.

HDI PNP 2023-002 Page 127 of 281 Section Title Change Description of Change 7.2.5 Logic Operation Delete This section is deleted in its entirety. Amendment 272 removed Tech Spec Section 3.3, Instrumentation, including TS 3.3.1, Reactor Protective System (RPS) Instrumentation, and the facility license no longer contains requirements for instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems.

Therefore, there are no pertinent RPS functional requirements in the permanently defueled condition.

7.2.6 Testing Delete This section is deleted in its entirety. Amendment 272 removed Tech Spec Section 3.3, Instrumentation, including TS 3.3.1, Reactor Protective System (RPS) Instrumentation, and the facility license no longer contains requirements for instrumentation systems. Therefore, there are no RPS testing requirements.

HDI PNP 2023-002 Page 128 of 281 Section Title Change Description of Change 7.2.7 Effects of Failures Delete This section is deleted in its entirety. Amendment 272 removed Tech Spec Section 3.3, Instrumentation, including TS 3.3.1, Reactor Protective System (RPS) Instrumentation, and the facility license no longer contains requirements for instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems. Therefore, there are no pertinent RPS failure effects in the permanently defueled condition.

7.2.8 Power sources Delete This section is deleted in its entirety. Amendment 272 removed Tech Spec Section 3.3, Instrumentation, including TS 3.3.1, Reactor Protective System (RPS) Instrumentation, and the facility license no longer contains requirements for instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems. Therefore, there are no power requirements for the RPS in the permanently defueled condition.

HDI PNP 2023-002 Page 129 of 281 Section Title Change Description of Change 7.2.9 Physical Separation Delete This section is deleted in its entirety. Amendment 272 removed Tech Spec and Electrical Section 3.3, Instrumentation, including TS 3.3.1, Reactor Protective System Isolation (RPS) Instrumentation, and the facility license no longer contains requirements for instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems. Therefore, there are no separation requirements of the RPS in the permanently defueled condition.

7.2.10 Reactor Trip and Delete This section is deleted in its entirety. Amendment 272 removed Tech Spec Pretrip Set Points Section 3.3, Instrumentation, including TS 3.3.1, Reactor Protective System (RPS) Instrumentation, and the facility license no longer contains requirements for instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems. Therefore, there are no pertinent RPS functional requirements in the permanently defueled condition.

HDI PNP 2023-002 Page 130 of 281 Section Title Change Description of Change 7.3 Engineered Delete This section is deleted in its entirety. Amendment 272 removed Tech Spec Safeguards Controls Section 3.3, Instrumentation, including TS 3.3.3, Engineered Safety Features (ESF) Instrumentation, and TS 3.3.4, Engineered Safety Features (ESF) Logic and Manual Initiation, and the facility license no longer contains requirements for instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems. Therefore, there are no pertinent design, functional or testing requirements for ECCS instrumentation in the permanently defueled condition.

7.4 Other Safety Modify This section is modified to limit discussion to mitigation of uncontrolled Related Protection, release of radioactive effluents. Amendment 272 removed Tech Spec Control and Display Section 3.3, Instrumentation, and the facility license no longer contains Systems requirements for instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possitile. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems. Therefore, discussion of RPS and ECCS protective functions is deleted.

HDI PNP 2023-002 Page 131 of 281 Section Title Change .. Description of Change 7.4.1 Reactor Shutdown Delete This section is deleted in its entirety. The certifications required by Controls 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, reactor shutdown is no longer pertinent.

7.4.2 Primary Coolant Delete This section is deleted in its entirety. Amendment 272 removed Tech Spec Boundaries Section 3.3, Instrumentation, and the facility license no longer contains Protection requirements for instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. Therefore, reactor coolant leakage and boundary protection is not pertinent.

7.4.3 Auxiliary Feedwater Delete This section is deleted in its entirety. Amendment 272 removed Tech Spec Controls Section 3.3, Instrumentation, and TS 3.7.5, Auxiliary Feedwater (AFW)

System, the facility license no longer contains requirements for AFW controls. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. Therefore, AFW controls are not pertinent.

HDI PNP 2023-002 Page 132 of 281 Section Title Change Description of Change 7.4.4 Containment Delete Section is deleted. Hydrogen recombiners were abandoned previously and Hydrogen Controls are considered obsolete.

7.4.4.1 Design Basis Delete Section is deleted. Hydrogen recombiners were abandoned previously and are considered obsolete.

7.4.5.1 Control Room Delete This section is deleted in its entirety. Amendment 272 removed Tech Spec 3.7.10, Control Room Ventilation (CRV) Filtration, and 3.7.11, Control Room Ventilation (CRV) Cooling, and the facility license no longer contains requirements for control room ventilation. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems. Therefore, control room ventilation instrumentation has no functional requirements.

7.4.5.2 Engineered Delete This section is deleted in its entirety. Amendment 272 removed TS 3.3.10, Safeguards Pump Engineered Safeguards Room Ventilation (ESRV) Instrumentation, and the Rooms facility license no longer contains requirements for pump room ventilation and associated instrumentation. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems. Therefore, pump room ventilation instrumentation has no functional requirements.

HDI PNP 2023-002 Page 133 of 281 Section Title Change Description of Change 7.4.6 Other Safety Delete This section is deleted in its entirety. Amendment 272 removed TS 3.3.7, Related Display Post Accident Monitoring (PAM) Instrumentation, the certifications required System by 10 CFR 50.82(a)(1) are docketed for PNP, and the 10 CFR Part 50 license will longer contain requirements for the RG 1.97 instrumentation in Section 7.4.6. Therefore, design and functional requirements for this instrumentation are deleted.

7.5.1 Design Bases Delete This section is deleted in its entirety. Amendment 272 has been implemented and the certifications required by 10 CFR 50.82(a)(1) have been--'docketed, therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur, there are no functional requirements for primary or secondary regulating controls, and the design bases can be deleted.

7.5.2.1 Reactor Regulating Modify This section is modified to delete design requirements for reactor regulating controls. Physical descriptions are retained. Amendment 272 has been implemented and the certifications required by 10 CFR 50.82(a)(1) have been docketed, therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur, there are no functional requirements for primary regulating controls, and the design bases can be deleted.

7.5.2.2 Primary Pressure Delete This section is deleted to delete design requirements for primary pressure Regulating regulating controls. Amendment 272 has been implemented and the certifications required by 10 CFR 50.82(a)(1) have been docketed, therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur, there are no functional requirements for primary regulating controls, and the design bases can be deleted.

HDI PNP 2023-002 Page 134 of 281 Section Title Change Description of Change 7.5.2.3 Feedwater Delete This section is deleted to delete design requirements for feedwater Regulating regulating controls. Amendment 272 has been implemented and the certifications required by 10 CFR 50.82(a)(1) have been docketed, therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur, there are no functional requirements for feedwater regulating controls, and the design bases can be deleted.

7.5.2.4 Pressurizer Level Delete This section is deleted to delete design requirements for pressurizer level Regulating regulating controls. Amendment 272 has been implemented and the certifications required by 10 CFR 50.82(a)(1) have been docketed, therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur, there are no functional requirements for pressurizer level regulating controls, and the design bases can be deleted.

7.5.2.5 Steam Dump and Modify This section is deleted to delete design requirements for steam dump and Bypass bypass controls. Physical descriptions are retained. Amendment 272 has been implemented and the certifications required by 10 CFR 50.82(a)(1) have been docketed, therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur, there are no functional requirements for steam dump and bypass controls, and the design bases can be deleted.

HDI PNP 2023-002 Page 135 of 281 Section Title Change Description of Change 7.5.2.6 Turbine Generator Delete This section is deleted to delete design requirements for Turbine generator Controls controls. Physical descriptions are retained. Amendment 272 has been implemented and the certifications required by 10 CFR 50.82(a)(1) have been docketed, therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur, there are no functional requirements for turbine generator controls, and the design bases can be deleted.

7.5.3 System Evaluation Delete This section is deleted in its entirety. Amendment 272 has been implemented and the certifications required by 10 CFR 50.82(a)(1) have been docketed, therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur, there are no functional requirements for primary or secondary regulating controls, and associated system evaluations can be deleted.

7.6 Nuclear Steam Modify Title to Editorial changes are made to this section to remove reference to deleted Supply System Plant Process FSAR sections.

Instrumentation Computer and Miscellaneous Instrumentation 7.6.1.1 Process Delete This section is deleted in its entirety. Amendment 272 has been Instrumentation implemented and the certifications required by 10 CFR 50.82(a)(1) have been docketed, therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur and there are no functional requirements for primary or secondary process instrumentation.

HDI PNP 2023-002 Page 136 of 281 Section Title Change Description of Change 7.6.1.2 Nuclear Delete This section is deleted in its entirety. Amendment 272 has been Instrumentation implemented and the certifications required by 10 CFR 50.82(a)(1) have been docketed, therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur and there are no functional requirements for nuclear instrumentation.

7.6.1.3 Control Rod Position Delete This section is deleted in its entirety. Amendment 272 removed Tech Spec Instrumentation Section 3.1, REACTIVITY CONTROL SYSTEMS, and the facility license no longer contains requirements for control rod position instrumentation.

Amendment 272 has been implemented and the certifications required by 10 CFR 50.82(a)(1) have been docketed, therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur and there are no functional requirements for control rod position indication instrumentation.

7.6.1.4 lncore Delete This section is revised to delete functional and design requirements of Instrumentation incore instrumentation. Amendment 272 removed TS 3.2.1 Linear Heat Rate (LHR), and the facility license no longer contains requirements for incore instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and there are no functional requirements for incore instrumentation.

HDI PNP 2023-002 Page 137 of 281 Section Title Change Description of Change 7.6.1.5 Palisades Plant Modify This section is revised to delete reference to instrumentation associated with Computer (PPC) reactor and primary systems operation, and to change plant to facility.

Amendment 272 removed Tech Spec Sections 3.1, REACTIVITY CONTROL SYSTEMS, 3.2, POWER DISTRIBUTION LIMITS, and 3.3, INSTRUMENTATION, and the facility license no longer contains requirements for these instrumentation systems:

1. Reactor Protective System
2. Engineered Safeguards Controls
3. Reactor Shutdown Controls
4. Fluid Systems Protection
5. Regulating Controls
6. Primary Plant Process Instruments The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. Therefore, there are no functional requirements for this instrumentation.

7.6.2.1 Process Delete This section is revised to delete functional descriptions of the process Instrumentation instrumentation. Amendment 272 removed Tech Spec Sections 3.1, REACTIVITY CONTROL SYSTEMS, 3.2, POWER DISTRIBUTION LIMITS, and 3.3, INSTRUMENTATION, and the facility license no longer contains requirements for process instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. Therefore, there are no functional requirements for process instrumentation.

HDI PNP 2023-002 Page 138 of 281 Section Title Change Description of Change 7.6.2.2 Nuclear Modify This section is revised to delete functional descriptions of the nuclear Instrumentation instrumentation. Physical descriptions of the RPS are retained.

Amendment 272 removed Tech Spec Sections 3.1, REACTIVITY CONTRQL SYSTEMS, 3.2, POWER DISTRIBUTION LIMITS, and 3.3, INSTRUMENTATION, and the facility license no longer contains requirements for process instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. Therefore, there are no functional requirements for nuclear instrumentation.

7.6.2.3 Control rod position Delete This section is deleted in its entirety. Amendment 272 removed Tech Spec Instrumentation Section 3.1, REACTIVITY CONTROL SYSTEMS, and the facility license no longer contains requirements for control rod position instrumentation.

Amendment 272 has been implemented and the certifications required by 10 CFR 50.82(a)(1) have been docketed, therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, all control rods have been removed from the core and there are no functional requirements for control rod position indication instrumentation.

HDI PNP 2023-002 Page 139 of 281 Section Title Change 'i Description of Change 7.6.2.4 lncore Delete This section is revised to delete functional and physical descriptions of Instrumentation incore instrumentation. Amendment 272 removed TS 3.2.1 Linear Heat Rate (LHR), and the facility license no longer contains requirements for incore instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, incore instrumentation has no function and will no longer be installed in the core.

7.6.2.5 Palisades Plant Modify Section is revised to change plant to facility Computer 7.7.1 General Layout Modify This section is revised to delete reference to normal and emergency plant operations and change Plant to Facility. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. Therefore, the operations referred to are no longer applicable.

HDI PNP 2023-002 Page 140 of 281 Section Title Change Description of Change 7.7.2 Control Room Modify This section is revised to delete reference to OBA conditions, safe shutdown, and temperature restrictions on RPS, Engineered Safeguard and Thermal Margin Monitor instrumentation. Design features and physical descriptions of the control room are retained. Amendment 272 removed Tech Spec Sections 3.1, REACTIVITY CONTROL SYSTEMS, 3.2, POWER DISTRIBUTION LIMITS, and 3.3, INSTRUMENTATION, and the facility license no longer contains requirements for instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. Therefore, OBA and safe shutdown are not relevant and there are no functional requirements for the instrumentation.

7.7.3 Engineered Modify This section is revised to remove functional description and fire protection Safeguards Auxiliary features of the safeguards auxiliary panel. A physical description of the Panel (C-33) panel is retained. Amendment 272 removed Tech Spec Section 3.3, Instrumentation, including TS 3.3.3, Engineered Safety Features (ESF)

Instrumentation, and TS 3.3.4, Engineered Safety Features (ESF) Logic and Manual Initiation, and the facility license no longer contains requirements for instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems. Therefore, there are no pertinent design or functional requirements for engineered safeguards instrumentation in the permanently defueled condition.

HDI PNP 2023-002 Page 141 of 281 Section Title Change Description of Change 7.7.4 Auxiliary Hot Modify This section is revised to remove functional description and fire protection Shutdown Control features of the safeguards auxiliary panel. A physical description of the Panels panel is retained. Amendment 272 removed Tech Spec Section 3.3, (C-150/C-150A) Instrumentation, including TS 3.3.8, Alternate Shutdown System, and the facility license no longer contains requirements for alternate shutdown instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems. Therefore, there are no pertinent design or functional requirements for alternate shutdown features.

7.8 Quality Control Delete Section 7.8 is deleted in its entirety. Amendment 272 removed Tech Spec Section 3.3, Instrumentation, including TS 3.3.1, Reactor Protective System (RPS) Instrumentation, and the facility license no longer contains requirements for instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems, and no pertinent RPS design or functional requirements in the permanently defueled condition. Therefore, quality control aspects of initial procurement and construction are no longer pertinent.

HDI PNP 2023-002 Page 142 of 281 Section Title Change Description of Change 7.0 References Modify Revised to reflect references deleted in the text Appendix "Engineered Delete This Appendix is removed in its entirety. Amendment 272 removed Tech 7A Safeguard Testing Spec 3.3.3, Engineered Safety Features (ESF) Instrumentation, TS 3.3.4, Engineered Safety Features (ESF) Logic and Manual Initiation, Tech Spec Section 3.5, EMERGENCY CORE COOLING SYSTEMS (ECCS), Tech Spec Section 3.6, CONTAINMENT SYSTEMS, and requirements for lnservice Testing. The facility license no longer contains requirements for Engineered Safeguard Testing. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems. Therefore, there are no pertinent design or functional requirements for engineered safeguards in the permanently defueled condition.

HDI PNP 2023-002 Page 143 of 281 Section Title Change Description of Change Appendix "Regulatory Guide Modify This Appendix is modified by eliminating instrumentation required for core 7C 1.97 Rev 3, related accident scenarios. Radiation monitoring and meteorological Parameter Summary instrumentation required for the remaining accidents is retained.

Table" Amendment 272 removed accident scenarios related to the NSSS and deleted Tech Spec 3.3.7, Post Accident Monitoring (PAM) Instrumentation.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, instrumentation required for core related accident scenarios are no longer relevant.

Table 7-1 Reactor Protective Delete This table is deleted in its entirety. Section 7.2.5 has been deleted and this System Relays table is no longer utilized.

Table 7-2 Regulating Rods Delete This table is deleted in its entirety. Reference to Table 7-2 has been Withdrawal removed from 7.5.2.1. Amendment 272 has been implemented and the Interlocks certifications required by 10 CFR 50.82(a)(1) have been docketed, therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur, there are no functional requirements for primary regulating controls, and the design bases can be deleted.

HDI PNP 2023-002 Page 144 of 281 Section Title Change Description of Change Table 7-3 Source/Wide-Range Delete This table is deleted in its entirety. Reference to Table 7-3 has been Nuclear Instrument removed from 7.6.2.2. Amendment 272 removed Tech Spec Sections 3.1, Channel Trip Unit REACTIVITY CONTROL SYSTEMS, 3.2, POWER DISTRIBUTION LIMITS, Actions and 3.3, INSTRUMENTATION, and the facility license no longer contains requirements for process instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. Therefore, there are no functional requirements for nuclear instrumentation.

Table 7-4 Power-Range Safety Delete This table is deleted in its entirety. Reference to Table 7-4 has been Channel Trip Unit removed from 7.6.2.2. Amendment 272 removed Tech Spec Sections 3.1, Actions REACTIVITY CONTROL SYSTEMS, 3.2, POWER DISTRIBUTION LIMITS, and 3.3, INSTRUMENTATION, and the facility license no longer contains requirements for process instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. Therefore, there are no functional requirements for nuclear instrumentation.

HDI PNP 2023-002 Page 145 of 281 Section Title Change Description of Change Table 7-5 Control Rod Position Delete This table is deleted in its entirety. Reference to Table 7-5 has been Light Matrix removed from 7.6.2.3. Amendment 272 removed Tech Spec Section 3.1, REACTIVITY CONTROL SYSTEMS, and the facility license no longer contains requirements for control rod position instrumentation. Amendment 272 has been implemented and the certifications required by 10 CFR 50.82(a)(1) have been docketed, therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur, and there are no functional requirements for control rod position indication instrumentation.

Figure 7-1 Reactor Protective Delete This figure is deleted in its entirety. Reference to Figure 7-1 thru 7-5, 7-7 System Block through 7-13, have been deleted from Sections 7.2. Amendment 272 Diagram removed Tech Spec Section 3.3, Instrumentation, including TS 3.3.1, Reactor Protective System (RPS) Instrumentation, and the facility license no longer contains requirements for RPS instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems. Therefore, the design basis, functional requirements and schematics of the RPS instrumentation is no longer pertinent.

Figure 7-2 Reactor Protective Delete This figure is deleted. See Figure 7-1 basis.

System Functional Diagram

HDI PNP 2023-002 Page 146 of 281 Section Title Change Description of Change Figure 7-3 Typical Delete This figure is deleted. See Figure 7-1 basis.

Measurement Channel Functional Diagram Figure 7-4 Schematic Diagram, Delete This figure is deleted. See Figure 7-1 basis.

Pressurizer Pressure ATWS Figure 7-5 Schematic Diagram, Delete This figure is deleted. See Figure 7-1 basis.

Pressurizer Pressure ATWS Figure 7-6 Low Flow Protective Delete This figure is deleted in its entirety. Figure 7-6 is not referenced in the System Functional UFSAR. Amendment 272 removed Tech Spec Sections 3.1, REACTIVITY Diagram CONTROL SYSTEMS, 3.2, POWER DISTRIBUTION LIMITS, and 3.3, INSTRUMENTATION, and the facility license no longer contains requirements for process instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. Therefore, there are no functional requirements for process instrumentation.

Figure 7-7 Logic for Thermal Delete This figure is deleted. See Figure 7-1 basis.

Margin Monitor

HDI PNP 2023-002 Page 147 of 281 Section Title Change Description of Change Figure 7-8 Neutron Flux Delete This figure is deleted. See Figure 7-1 basis.

Monitoring System Start- Up and Logarithmic Range Channels Figure 7-9 Neutron Flux Delete This figure is deleted. See Figure 7-1 basis.

Monitoring System Power Range Channels Figure 7- Power Rate-of- Delete This figure is deleted. See Figure 7-1 basis.

10 Change Trip and Pretrip Interface with RPS Figure 7- Zero Power Mode Delete This figure is deleted. See Figure 7-1 basis.

11 Bypass Figure 7- Reactor Protective Delete This figure is deleted. See Figure 7-1 basis.

12 System Interfaces

HDI PNP 2023-002 Page 148 of 281 Section Title Change Description of Change Figure 7- Logic Diagram, Delete This figure is deleted in its entirety. Reference to Figures 7-13, 7-14 Sh 2, 13 Safety Injection 7-15 thru 7-26, and 7-30 thru 32 have been deleted from Sections 7.3.

Initiation Amendment 272 removed Tech Spec Section 3.3, Instrumentation, including TS 3.3.3, Engineered Safety Features (ESF) Instrumentation, and 3.3.4, Engineered Safety Features (ESF) Logic and Manual Initiation, and the facility license no longer contains requirements for ESF instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems. Therefore, the design basis, functional requirements and schematics of the EFS instrumentation is no longer pertinent.

Figure 7- Sh. 1 Logic Delete Figure 7-14 Sh 1 and all other 7-14 sheets are deleted. Amendment 272 14 Diagram, Main removed Tech Spec Section 3.3, Instrumentation, including TS 3.3.3, Generator Protection Engineered Safety Features (ESF) Instrumentation, and 3.3.4, Engineered Safety Features (ESF) Logic and Manual Initiation, and the facility license no longer contains requirements for ESF instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems. Therefore, there are no instrumentation functional requirements and instrumentation are no longer pertinent.

HDI PNP 2023-002 Page 149 of 281 Section Title Change Description of Change Figure 7- Sh 2 Logic Diagram, Delete This figure is deleted. See Figure 7-13 basis.

14 Turbine-Generator Trips and Fast Transfer Figure 7- Sh 3 Logic Diagram, Delete This figure is deleted. See Figure 7-14 Sh 1 basis.

14 2400 Volt Load Shed Figure 7- Sh 4 Logic Diagram, Delete This figure is deleted. See Figure 7-14 Sh 1 basis.

14 Diesel Start (CPCO)

Figure 7- Sh 5 Logic Diagram, Delete This figure is deleted. See Figure 7-14 Sh 1 basis.

14 Diesel Engine Control, Trips and Alarms Figure 7- Sh 6 Logic Diagram, Delete This figure is deleted. See Figure 7-14 Sh 1 basis.

14 Diesel Generator Breakers Figure 7- Sh 7 Logic Diagram, Delete This figure is deleted. See Figure 7-14 Sh 1 basis.

14 Bus 1C and 1D Incoming Breakers Figure 7- Sh 8 Logic Diagram, Delete This figure is deleted. See Figure 7-14 Sh 1 basis.

14 Power to Bus 1E, 1F and 1G Incoming Breakers

HDI PNP 2023-002 Page 150 of 281 Section Title Change Description of Change Figure 7- Sh 9 Logic Diagram, Delete This figure is deleted. See Figure 7-14 Sh 1 basis.

14 Bus 1A& 1B Incoming Breakers Figure 7- Sh 10 Logic Delete This figure is deleted. See Figure 7-14 Sh 1 basis.

14 Diagram, Generator Breaker and M.O.D.

Control Figure 7- Sh 11 Logic Delete This figure is deleted. See Figure 7-14 Sh 1 basis.

14 Diagram, Start-up Xfmr.

Protection Figure 7- Sh 12 Logic Delete This figure is deleted. See Figure 7-14 Sh 1 basis.

14 Diagram, Safeguard Transformer 1-1 Figure 7- Sh 13 Logic Delete This figure is deleted. See Figure 7-14 Sh 1 basis.

14 Diagram, Circuit Breaker Operation Figure 7- Schematic Diagram, Delete This figure is deleted. See Figure 7-13 basis.

15 Safety Injection Signal Auxiliary Circuits Figure 7- Schematic Diagram, Delete This figure is deleted. See Figure 7-13 basis.

16 Safety Injection Signal Auxiliary Circuits

HDI PNP 2023-002 Page 151 of 281 Section Title Change Description of Change Figure 7- Schematic Diagram, Delete This figure is deleted. See Figure 7-13 basis.

17 Safety Injection and Sequence Loading Circuits Figure 7- Schematic Diagram, Delete This figure is deleted. See Figure 7-13 basis.

18 Safety Injection and Sequence Loading Circuits Figure 7- Schematic Diagram, Delete This figure is deleted. See Figure 7-13 basis.

19 Safety Injection and Sequence Loading Circuits Figure 7- Schematic Diagram, Delete This figure is deleted. See Figure 7-13 basis.

20 Safety Injection and Sequence Loading Circuits Figure 7- Schematic Diagram, Delete This figure is deleted. See Figure 7-13 basis.

21 Safety Injection and Sequence Loading Test Circuit Figure 7- Schematic Diagram, Delete This figure is deleted. See Figure 7-13 basis.

22 Safety Injection and Sequence Loading Test Circuit

HDI PNP 2023-002 Page 152 of 281 Section Title Change Description of Change Figure 7- Schematic Diagram, Delete This figure is deleted. See Figure 7-13 basis.

23 Safety Injection and Sequence Loading Test Circuit Figure 7- Logic Diagram, Delete This figure is deleted. See Figure 7-13 basis.

24 Containment High Pressure Signal Figure 7- Logic Diagram, Delete This figure is deleted. See Figure 7-13 basis.

25 Containment High Radiation Figure 7- Schematic Diagram, Delete This figure is deleted. See Figure 7-13 basis.

26 Containment High Pressure, High Radiation and SIRW Tank Low Level

HDI PNP 2023-002 Page 153 of 281 Section Title Change Description of Change Figure 7- Schematic Diagram, Delete This figure is deleted in its entirety. Amendment 272 removed Tech Spec 27 Containment High Section 3.3, Instrumentation, including TS 3.3.3, Engineered Safety Pressure, High Features (ESF) Instrumentation, and TS 3.3.4, Engineered Safety Features Radiation and SIRW (ESF) Logic and Manual Initiation, and the facility license no longer contains Tank Low Level requirements for instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems. Therefore, there are no pertinent design, functional or testing requirements for containment sump recirculation initiation in the permanently defueled condition.

Figure 7- Schematic Diagram, Delete This figure is deleted in its entirety. Amendment 272 removed Tech Spec 28 Containment Section 3.3, Instrumentation, including TS 3.3.3, Engineered Safety Isolation on High Features (ESF) Instrumentation, and TS 3.3.4, Engineered Safety Features Pressure or High (ESF) Logic and Manual Initiation, and the facility license no longer contains Radiation requirements for instrumentation systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These do not credit operator action or any active systems. Therefore, there are no pertinent design, functional or testing requirements for containment isolation instrumentation in the permanently defueled condition.

HDI PNP 2023-002 Page 154 of 281 Section Title Change Description of Change Figure 7- Schematic Diagram, Delete This figure is deleted. See Figure 7-28 Basis.

29 Containment Isolation on High *.. ,.

Pressure or High Radiation Figure 7- Logic Diagram, SIS Delete This figure is deleted. See Figure 7-13 basis.

30 Test and RAS Figure 7- Schematic Diagram, Delete This figure is deleted. See Figure 7-13 basis.

31 SIRW Tank and Containment Sump Valves Figure 7- Schematic Diagram, Delete This figure is deleted. See Figure 7-13 basis.

32 SIRW Tank and Containment Sump Valves Figure 7- Logic Diagram, Delete This Figure is deleted. All logic diagrams have been deleted from Chapter 7 33 Legend and Notes and there is no need for diagram legends and notes.

Figure 7- Logic Diagram, Delete This Figure is deleted. All logic diagrams have been deleted from Chapter 7 34 Legend and Notes and there is no need for diagram legends and notes.

Figure 7- Logic Diagram, Delete This Figure is deleted. All logic diagrams have been deleted from Chapter 7 35 Legend and Notes and there is no need for diagram legends and notes.

HDI PNP 2023-002 Page 155 of 281 Section Title Change Description of Change Figure 7- Schematic Diagram, Delete This figure is deleted in its entirety. Reference to Figures 7-36 thru 7-52 36 Steam Generator have been deleted from Sections 7.4. The certifications required by Level 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Instrumentation 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reaGtor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. Therefore, AFW controls are not pertinent.

Figure 7- Logic Diagram, Delete This figure is deleted. See Figure 7-36.

37 Auxiliary Feedwater Actuation System Figure 7- Logic Diagram, Delete This figure is deleted. See Figure 7-36.

38 Motor Driven Auxiliary Feedwater Pump P-8A Figure 7- Logic Diagram, Delete This figure is deleted. See Figure 7-36.

39 Motor Driven Auxiliary Feedwater Pump P-8C Figure 7- Sh 1 Logic Diagram, Delete This figure is deleted. See Figure 7-36.

40 Turbine Driven Auxiliary Feedwater Pump P-8B

HDI PNP 2023-002 Page 156 of 281 Section Title Change Description of Change Figure 7- Sh 2 Logic Diagram, Delete This figure is deleted. See Figure 7-36.

40 Turbine Driven Auxiliary Feedwater Pump P-88 Figure 7- Interface Loop Delete This figure is deleted. See Figure 7-36.

41 Diagram, Pump Low Suction Pressure Trip Figure 7- Sh 1 Logic Diagram Delete This figure is deleted. See Figure 7-36.

41 Turbine Driven Auxiliary Feedwater Pump P-88 Figure 7- Sh 2 Logic Diagram Delete This figure is deleted. See Figure 7-36.

41 Turbine Driven Auxiliary Feedwater Pump P-88 Figure 7- Logic Diagram, Delete This figure is deleted. See Figure 7-36.

42 Auxiliary Feedwater Pumps Low Suction Pressure Trip Figure 7- Interface Loop Delete This figure is deleted. See Figure 7-36.

43 Diagram, Flow Control Figure 7- Interface Loop Delete This figure is deleted. See Figure 7-36.

44 Diagram, Flow Control

HDI PNP 2023-002 Page 157 of 281 Section Title Change Description of Change Figure 7- Interface Loop Delete This figure is deleted. See Figure 7-36.

45 Diagram, Flow and Pressure Indication Figure 7- Logic Diagram, Aux Delete This figure is deleted. See Figure 7-36.

46 Feedwater Flow Control and Pump Test Logic Figure 7- Logic Diagram, Delete This figure is deleted. See Figure 7-36.

47 Auxiliary Feedwater Flow Control and Pump Test Logic Figure 7- Logic Diagram, Delete This figure is deleted. See Figure 7-36.

48 Auxiliary Feedwater Actuation System Figure 7- Logic Diagram, Delete This figure is deleted. See Figure 7-36.

49 Auxiliary Feedwater Steam Generator Isolation Valves Figure 7- Logic Diagram, Delete This figure is deleted. See Figure 7-36.

50 Auxiliary Feedwater Steam Generator Isolation Valves

HDI PNP 2023-002 Page 158 of 281 Section Title Change Description of Change Figure 7- Logic Diagram, Delete This figure is deleted. See Figure 7-36.

51 AF AS-FOGG Remote Display and t':

Annunciator Assignment Figure 7- Logic Diagram, Delete This figure is deleted. See Figure 7-36.

52 AFAS-FOGG Remote Display and Annunciator Assignment Figure 7- Reactor Shutdown Delete This figure is deleted in its entirety. Reference to Figure 7-53 thru 7-59 have 53 Controls been deleted from Sections 7.5. Amendment 272 has been implemented and the certifications required by 10 CFR 50.82(a)(1) have been docketed, therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur, there are no functional requirements for primary or secondary regulating controls, and the figures can be deleted.

Figure 7- Reactor Regulating Delete This figure is deleted. See Figure 7-53.

54 System Block Diagram Figure 7- Rod Drive Control Delete This figure is deleted. See Figure 7-53.

55 System Schematic Diagram Figure 7- Rod Position Set Delete This figure is deleted. See Figure 7-53.

56 Points

HDI PNP 2023-002 Page 159 of 281 Section Title Change Description of Change Figure 7- Pressure Control Delete This figure is deleted. See Figure 7-53.

57 Program Figure 7- Block Diagram, Delete This figure is deleted. See Figure 7-53.

58 Steam Dump and Bypass System Figure 7- Pressurizer Level Delete This figure is deleted. See Figure 7-53.

59 Control System Failures Study -

Mode "A" Failure 8.1.1 Design Basis Modify This section is modified by deleting the requirements of GDC 17 (see 5.1.3.8), deleting reference to accident conditions and engineered safeguards functional requirements, and deleting reference to turbine generator. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for the electrical systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, there are no applicable accident conditions.

HDI PNP 2023-002 Page 160 of 281 Section Title Change Description of Change 8.1.2 Description and Modify This section is modified by deleting the requirements of GDC 17 (see Operation 5.1.3.8), reference to operational conditions, and turbine generator power.

An editorial change is made to the description of offsite power to match 8.2.2 and 8.2.3. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for the electrical systems. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous waste~ or radioactive liquids. Therefore, there are no applicable accident or abnormal operational conditions.

8.1.3 Environmental Delete This section provided the licensing history relate to EQ and is deleted in its Qualification of entirety. The certifications required by 10 CFR 50.82(a)(1) are docketed for Electrical Equipment PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. With no postulated loss of coolant accidents, harsh environments no longer exist.

HDI PNP 2023-002 Page 161 of 281 Section Title Change Description of Change 8.1.5 Station Blackout Delete This section is deleted in its entirety. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur. 10 CFR 50.63, Loss of all alternating current power, limits itself to plants "licensed to operate," as stated below: 50.63(a)

Requirements. (1) Each light-water-cooled nuclear power plant licensed to operate under this part.... Therefore, station blackout is no longer applicable.

8.2.1 Design Basis Modify The section is modified by deleting reference to plant operation and unit trip.

Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for the offsite power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur. Therefore, switchyard functional requirements are no longer applicable.

8.2.2 Description and Modify The section is modified by deleting referen_ce to plant operation and unit trip.

Operation Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for the offsite power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur.

HDI PNP 2023-002 Page 162 of 281 Section Title Change Description of Change 8.2.3 Design Analysis Modify The section is modified by deleting the functional requirements of GDC 17 (see 5.1.3.8) and deleting reference to plant operation and unit trip.

Ame11dment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for the offsite power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible.

8.3.1.1 Design Basis Modify The section is modified by deleting the reference to DBA conditions and operational requirements. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no operational requirements for 4160V systems.

HDI PNP 2023-002 Page 163 of 281 Section Title Change Description of Change 8.3.1.2 Description and Modify The section is modified by deleting the reference to main generator power, Operation 4160V functional requirements, 4160V testing, and plant operation and unit trip. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional requirements for 4160V systems.

8.3.1.3 Design Analysis Modify The section is modified to remove reference to turbine generator power, generator coastdown and shutdown. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional requirements for 4160V systems.

HDI PNP 2023-002 Page 164 of 281 Section Title Change Description of Change 8.3.2.1 Design Basis Modify This Section is modified by deleting the reference to functional requirements, testing and operation of the 2400V system. Physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with

  • 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for 2400V systems.

8.3.2.2 Description and Modify This Section is modified by deleting the reference to functional Operation requirements, testing and operation of the 2400V system. Physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for 2400V systems.

HDI PNP 2023-002 Page 165 of 281 Section Title Change Description of Change 8.3.2.3 Design Analysis Modify This Section is modified by deleting the reference to functional requirements, testing and operation of the 2400V system. Physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operntions and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for 2400V systems.

8.3.3.1 Design Basis Modify This section is modified by deleting the reference to functional requirements, testing and operation of the 480V system. Physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for 480V systems.

HDI PNP 2023-002 Page 166 of 281 Section Title Change Description of Change 8.3.3.2 Description and Modify This section is modified by deleting the reference to functional requirements, Operation testing and operation of the 480V system. Physical descriptions are retained .. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for 480V systems.

8.3.4 Control Rod Drive Delete Section 8.3.4 is deleted in its entirety. Amendment 272 removed Tech Spec Power Sections 3.1, REACTIVITY CONTROL SYSTEMS, 3.2, POWER DISTRIBUTION LIMITS, and 3.8 "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for control rod power.

The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and no functional or operational requirements for control rod power.

HDI PNP 2023-002 Page 167 of 281 Section Title Change Description of Change 8.3.5.1 Design Basis Modify This section is modified by deleting the reference to functional requirements, testing and operation of the DC and Preferred AC systems. Physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for DC and Preferred AC systems.

8.3.5.2 Description and Modify This section is modified by deleting the reference to functional requirements, Operation testing and operation of the DC and Preferred AC systems. Physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the'reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for DC and Preferred AC systems.

HDI PNP 2023-002 Page 168 of 281 Section Title Change Description of Change 8.3.5.3 Design Analysis Delete This section is deleted. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for DC and Preferred AC systems.

8.3.6.2 Description and Modify This section is modified by deleting the reference to functional requirements, Operation testing and operation of the Instrument AC system. Physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for Instrument AC systems.

HDI PNP 2023-002 Page 169 of 281 Section Title Change Description of Change 8.3.6.3 Design Analysis Modify This section is modified by deleting the reference to functional requirements, testing and operation of the Instrument AC system. Physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for Instrument AC systems.

8.4 Emergency Power Modify This section is modified by deleting the reference to functional requirements, Sources testing and operation of the Emergency Power systems. Physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for Emergency Power systems.

HDI PNP 2023-002 Page 170 of 281 Section Title Change Description of Change 8.4.1.1 Design Basis Delete This section is deleted. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for Emergency Power systems.

8.4.1.2 Description and Modify This section is modified by deleting the reference to functional requirements, Operation testing and operation of the Emergency Power systems. Physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for Emergency Power systems.

HDI PNP 2023-002 Page 171 of 281 Section Title Change Description of Change 8.4.1.3 Design Analysis Modify This section is modified by deleting the reference to functional requirements, testing and operation of the Emergency Power systems. Physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for Emergency Power systems.

8.4.2.1 Design Basis Delete This section is deleted. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for Emergency Power systems.

HDI PNP 2023-002 Page 172 of 281 Section Title Change Description of Change 8.4.2.2 Description and Modify This section is modified by deleting the reference to functional requirements, Operation testing and operation of the Emergency Power systems. Physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for Emergency Power systems.

8.4.2.3 Design Analysis Delete This section is deleted. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for Emergency Power systems.

HDI PNP 2023-002 Page 173 of 281 Section Title Change Description of Change 8.4.2.4 Dedicated Battery Modify This section is modified by deleting the reference to functional requirements, Supply to Address testing and operation of the Emergency Power systems. Physical Fire Scenarios descriptions are retained. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for Emergency Power systems.

8.4.3 Turbine Generator Delete This section is deleted in its entirety. Amendment 272 removed Tech Spec Co astd own Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for Emergency Power systems.

HDI PNP 2023-002 Page 174 of 281 Section Title Change Description of Change 8.4.4 Emergency Power Delete This section is deleted in its entirety. Amendment 272 removed Tech Spec Supply for Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no Pressurizer Heaters longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for Emergency Power systems.

8.4.5.1 Design Basis Modify This section is modified by deleting the reference to functional requirements, testing and operation of the Emergency Power systems. Physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for Emergency Power systems.

HDI PNP 2023-002 Page 175 of 281 Section Title Change Description of Change 8.4.5.2 Description and Modify This section is modified by deleting the reference to functional requirements, Operation testing and operation of the Emergency Power systems. Physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for Emergency Power systems.

8.5.1.2 Electrical Delete This section is deleted in its entirety. Amendment 272 removed Tech Spec Penetrations of Section 3.6, "Containment Systems," and the facility license no longer Reactor contains requirements for the containment building and associated systems.

Containment The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. Therefore, this FSAR section is modified to remove design and safety functional requirements.

8.5.2 Design Description Modify The section and subsections are modified by deleting the reference to functional requirements and separation criteria. Physical descriptions are retained. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and there are no functional or operational requirements for Emergency Power systems.

HDI PNP 2023-002 Page 176 of 281 Section Title Change Description of Change 8.5.3 Design Evaluation Modify This section is modified to delete reference to containment penetrations.

Amendment 272 removed Tech Spec Section 3.6, "Containment Systems,"

and the facility license no longer contains requirements for the containment building and associated systems. The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. Therefore, this section is modified to remove containment penetration design and safety functional requirements.

8.5.3.1 Compliance with Modify The text of this section is modified to replace the word "Plant" with the word Regulatory Guide "Facility."

1.75 8.5.3.2 Raceway and Modify The section is modified to delete reference to cable separation design Cabling Separation criteria in its entirety. Physical descriptions and historical design information Criteria is retained. Amendment 272 deleted TS Sections 3.3, -

INSTRUMENTATION, and 3.8, ELECTRICAL POWER SYSTEMS, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer possible, and the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These accidents do not credit any electrical or control systems and GDC 24, Separation of Protection and Control Systems, is no longer applicable to PNP (See 5.1.4.5). Consequently, cable separation is no longer applicable.

HDI PNP 2023-002 Page 177 of 281 Section Title Change Description of Change 8.5.3.3 Raceway and Modify The section is modified to delete reference to safe shutdown.

Cabling Fire Barriers Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and safe shutdown is no longer applicable to PNP.

8.5.3.5 Cable Penetration Modify The section is modified to delete reference to safe shutdown.

Rooms Protection Certifications have been submitted to the NRC in accordance with Design 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and safe shutdown is no longer applicable to PNP.

8.5.3.7 Safety-Related Modify The section is modified by clarifying routing cables through non-safety areas Cabling Routing Via does not affect safe storage of spent fuel. The certifications required by 10 Nonsafety-Related CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 Areas license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur, and the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These accident scenarios do not rely on electrical power, therefore a fire in the switchgear room will not impact safe storage of spent fuel.

HDI PNP 2023-002 Page 178 of 281 Section Title Change Description of Change 8.5.3.8 Containment Modify The section is modified to delete reference to safe shutdown.

Building Routing Certifications have been submitted to the NRC in accordance with Protection 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and safe shutdown is no longer applicable to PNP.

8.5.3.9 Other Areas Routing Modify The section is modified to delete reference to safe shutdown.

Protection Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and safe shutdown is no longer applicable to PNP.

8.6 Automatic Transfer, Delete The section is deleted in its entirety. Amendment 272 deleted TS Sections Voltage Protection 3.3, INSTRUMENTATION, and 3.8, ELECTRICAL POWER SYSTEMS, and Load Shedding reflecting the permanent cessation of operations at PNP and permanent Controls removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer possible, and the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These accidents do not credit any active protection systems and therefore transfer, voltage protection and load shedding are no longer applicable to PNP.

HDI PNP 2023-002 Page 179 of 281 Section Title Change Description of Change 8.7 Physical Separation, Modify This section title is revised, and the subsections are modified by removing Electrical Isolation reference to electrical separation. See 8.7.1 and Support Systems 8.7.1 Electrical Isolation Delete The section is deleted in its entirety. Amendment 272 deleted TS Sections (see Figure 8- 1) 3.3, INSTRUMENTATION, and 3.8, ELECTRICAL POWER SYSTEMS, reflecting the permanent cessation of operations at PNP and permanent removal of fuel from the PNP reactor vessel. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, core related design basis accidents are no longer possible, and the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These accidents do not credit any protection systems and therefore GDC 24, Separation of Protection and Control Systems, is no longer applicable to PNP (See 5.1.4.5). Consequently, isolation is no longer applicabte.

8.7.2.1 General Modify The section is modified by deleting discussion of alternate shutdown.

The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur, and the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Since power operations can no longer occur alternate shutdown is no longer applicable.

HDI PNP 2023-002 Page 180 of 281 Section Title Change Description of Change 8.7.2.5 Switchgear Rooms Modify The section is modified by clarifying an unmitigated fire in the switchgear Protection rooms would not affect safe storage of spent fuel. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur, and the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. These accident scenarios do not rely on electrical power, therefore a fire in the switchgear room will not impact safe storage of spent fuel.

8.7.2.6 Emergency Modify The section is modified by removing reference to transfer of diesel fuel and Generators Rooms loss of one diesel generator due to fire. Discussion of fire protection Protection features is retained. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur, and core related design basis accidents are no longer possible. There are no functional requirements for diesel generators and therefore no functional requirements for fuel transfer.

HDI PNP 2023-002 Page 181 of 281 Section Title Change Description of Change 8.7.3.1 Ventilation Modify The section is modified by removing reference to plant operation, loss of offsite power, and diesel generator HVAC operations. Amendment 272 removed Tech Spec Section 3.8, "ELECTRICAL POWER SYSTEMS," and the facility license no longer contains requirements for electrical power. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur, core related design basis accidents are no longer possible, and loss of offsite power is not applicable. There are no functional requirements for diesel generators and therefore no functional or operational requirements for DG Room HVAC.

8.10 Quality Control Modify Reference to Section 7.8.7 is deleted as 7.8.7 has been deleted.

8.0 References Modify This section is modified to delete references which have been removed from the text.

Table 8-6 Diesel 1-1 Sequence Delete See 8.6 Start Table 8-7 Diesel 1-2 Sequence Delete See 8.6 Start

HDI PNP 2023-002 Page 182 of 281 Section Title Change Description of Change 9.1.1 Design Basis Modify This section is modified by eliminating discussion of SWS safety functional requir.ements, shutdown and DBA operations, and testing. Operations supporting spent fuel cooling, physical descriptions and other non-safety aspects are retained. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Amendment 272 removed Tech Spec 3.7.8, Service Water System (SWS), and the facility license no longer contains requirements for the service water system. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit SWS or any active SSCs. Therefore, the safety functional requirements of SWS are no longer relevant. /

9.1.2.1 System Description Modify This section is modified by eliminating discussion of SWS safety functional requirements, shutdown and DBA operations, and testing. Operations supporting spent fuel cooling, physical descriptions and other non-safety aspects are retained. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Amendment 272 removed Tech Spec 3.7.8, Service Water System (SWS), and the facility license no longer contains requirements for the service water system. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit SWS or any active SSCs. Therefore, the safety functional requirements of SWS are no longer relevant.

HDI PNP 2023-002 Page 183 of 281 Section Title Change Description of Change 9.1.2.3 System Operation Modify This section is modified by eliminating discussion of SWS safety functional requirements, shutdown and OBA operations, and testing. Operations supporting spent fuel cooling, physical descriptions and other non-safety aspects are retained. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Amendment 272 removed Tech Spec 3.7.8, Service Water System (SWS), and the facility license no longer contains requirements for the service water system. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit SWS or any active SSCs. Therefore, the safety functional requirements of SWS are no longer relevant.

9.1.3 Design Analysis Delete This section is deleted in its entirety. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Amendment 272 removed Tech Spec 3.7.8, Service Water System (SWS), and the facility license no longer contains requirements for the service water system. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit SWS or any active SSCs. Therefore, the safety functional requirements of SWS are no longer relevant.

HDI PNP 2023-002 Page 184 of 281 Section Title Change Description of Change 9.2.1 Design Basis Modify This section is modified by eliminating discussion of functional requirements, operations, and safety margins. Physical descriptions are retained.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur and there are no temperature gradients or thermal stresses on the biological shield.

Amendment 272 removed Tech Spec Section 3.6, "Containment Systems,"

and the facility license no longer contains requirements for the containment building and associated systems. Therefore, the functional requirements and operation of the shield cooling system are no longer relevant.

9.2.2.1 System Description Modify This section is modified by eliminating discussion of functional requirements, operations, and safety margins. Physical descriptions are retained.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur and there are no temperature gradients or thermal stresses on the biological shield.

Amendment 272 removed Tech Spec Section 3.6, "Containment Systems,"

and the facility license no longer contains requirements for the containment building and associated systems. Therefore, the functional requirements and operation of the shield cooling system are no longer relevant.

HDI PNP 2023-002 Page 185 of 281 Section Title Change Description of Change 9.2.2.2 Component Modify This section is modified by eliminating discussion of functional requirements, Description operations, and safety margins. Physical descriptions are retained.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur and there are no temperature gradients or thermal stresses on the biological shield.

Amendment 272 removed Tech Spec Section 3.6, "Containment Systems,"

and the facility license no longer contains requirements for the containment building and associated systems. Therefore, the functional requirements and operation of the shield cooling system are no longer relevant.

9.2.2.3 System Operation Delete This section is modified by eliminating discussion of functional requirements, operations, and safety margins. Physical descriptions are retained.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur and there are no temperature gradients or thermal stresses on the biological shield.

Amendment 272 removed Tech Spec Section 3.6, "Containment Systems,"

and the facility license no longer contains requirements for the containment building and associated systems. Therefore, the functional requirements and operation of the shield cooling system are no longer relevant.

HDI PNP 2023-002 Page 186 of 281 Section Title Change Description of Change 9.2.3 Design analysis Delete This section is deleted in its entirety. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur and there are no temperature gradients or thermal stresses on the biological shield. Amendment 272 removed Tech Spec Section 3.6, "Containment Systems," and the facility license no longer contains requirements for the containment building and associated systems.

Therefore, the functional requirements and operation of the shield cooling system are no longer relevant.

9.3.1 Desigh Basis Modify This section is modified by eliminating discussion of CCW safety functional requirements, shutdown and OBA operations, and testing. Operation requirements supporting spent fuel cooling, physical descriptions and other non-safety aspects are retained. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Amendment 272 removed Tech Spec 3.7.7, Component Cooling Water (CCW) System, and the facility license no longer contains requirements for the service water system. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit CCW or any active SSCs. Therefore, the safety functional requirements of CCW are no longer relevant.

HDI PNP 2023-002 Page 187 of 281 Section Title Change Description of Change 9.3.2.1 System Description Modify This section is modified by eliminating discussion of CCW safety functional requirements, shutdown and OBA operations, and testing. Operation requirements supporting spent fuel cooling, physical descriptions and other non-safety aspects are retained. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Amendment 272 removed Tech Spec 3.7.7, Component Cooling Water (CCW) System, and the facility license no longer contains requirements for the service water system. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit CCW or any active SSCs. Therefore, the safety functional requirements of CCW are no longer relevant.

9.3.2.2 Component Modify This section is modified by eliminating discussion of CCW safety functional Description requirements, shutdown and OBA operations, and testing. Operation requirements supporting spent fuel cooling, physical descriptions and other non-safety aspects are retained. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Amendment 272 removed Tech Spec 3.7.7, Component Cooling Water (CCW) System, and the facility license no longer contains requirements for the service water system. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit CCW or any active SSCs. Therefore, the safety functional requirements of CCW are no longer relevant.

HDl PNP 2023-002 Page 188 of 281 Section Title Change Description of Change 9.3.2.3 System Operation Modify This section is modified by eliminating discussion of CCW safety functional requirements, shutdown and OBA operations, and testing. Operation requirements supporting spent fuel cooling, physical descriptions and other non-safety aspects are retained. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Amendment 272 removed Tech Spec 3.7.7, Component Cooling Water (CCW) System, and the facility license no longer contains requirements for the service water system. After implementation of Amendment 272, the only remaining accidents are the FHA,:cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit CCW or any active SSCs. Therefore, the safety functional requirements of CCW are no longer relevant.

9.3.3.1 Margins of Safety Delete This section is deleted in its entirety. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Amendment 272 removed Tech Spec 3.7.7, Component Cooling Water (CCW) System, and the facility license no longer contains requirements for the service water system. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit CCW or any active SSCs. Therefore, the safety functional requirements of CCW are no longer relevant.

HDI PNP 2023-002 Page 189 of 281 Section Title Change Description of Change 9.3.3.2 Provisions for Modify This section is modified by eliminating discussion of CCW safety functional Testing and requirements, shutdown and OBA operations, and testing. Operation Inspection requirements supporting spent fuel cooling, physical descriptions and other non-safety aspects are retained. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are dq_cketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Amendment 272 removed Tech Spec 3.7.7, Component Cooling Water (CCW) System, and the facility license no longer contains requirements for the service water system. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit CCW or any active SSCs. Therefore, the safety functional requirements of CCW are no longer relevant.

9.4.2.3 System Operation Modify This section is modified by eliminating discussion of Shutdown and post accident operations. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. Therefore, shutdown and post accident operation are no longer relevant.

9.4.3.2 Provisions for Delete Section is deleted in its entirety. Amendment 272 removed the TS definition Testing. of inservice testing and associated references in Section 3.0. Pump testing in accordance with 10 CFR 50.55a is not required in the permanently defueled condition.

HDI PNP 2023-002 Page 190 of 281 Section Title Change Description of Change 9.5.1.3 Component Modify This section is modified by eliminating discussion of containment isolation Description Amendment 272 removed Tech Spec Section 3.6, "Containment Systems,"

and the facility license no longer contains requirements for the containment building and associated systems. The reactor containment no longer performs an isolation function in the permanently shut down and defueled condition, nor is it required to perform an active function following any of the remaining accidents. Therefore, this FSAR section is modified to remove safety functional requirements for containment isolation valves.

9.5.1.4 System Operation Modify This section is modified by eliminating discussion of shutdown and post accident operations. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit any active SSCs.

Therefore, shutdown and post accident operation of instrument air are no longer relevant.

HDI PNP 2023-002 Page 191 of 281 Section Title Change Description of Change 9.5.1.5 Design analysis Modify This section is modified by eliminating discussion of failure analysis.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit any active SSCs.

Therefore, failure analyses of instrument air are no longer relevant.

9.5.2.1 Design Basis Modify This section is modified by eliminating accident conditions, safety functional requirements and margins, and discussion of shutdown and post OBA operation. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit any active SSCs.

Therefore, there are no safety functional requirements or margins, and discussion of shutdown and post OBA operation is no longer relevant.

HDI PNP 2023-002 Page 192 of 281 Section Title Change Description of Change 9.5.2.2 System Description Modify This section is modified by eliminating accident conditions, safety functional requirements and margins, and discussion of shutdown and post OBA operation. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit any active SSCs.

Therefore, there are no safety functional requirements or margins, and discussion of shutdown and post OBA operation is no longer relevant.

9.5.2.4 System Operation Modify This section is modified by eliminating accident conditions, safety functional requirements and margins, and discussion of shutdown and post OBA operation. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit any active SSCs.

Therefore, there are no safety functional requirements or margins, and discussion of shutdown and post OBA operation is no longer relevant.

HDI PNP 2023-002 Page 193 of 281 Section Title Change Description of Change 9.5.2.5 Design Analysis Delete This section is deleted in its entirety. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no IOnger possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit any active SSCs.

Therefore, there are no safety functional requirements or margins, and discussion of shutdown and post OBA operation is no longer relevant.

9.5.3.1 Design Basis Modify. This section is modified by eliminating discussion of accident conditions, beyond- design-basis events, station blackout and functional requirements.

Physical descriptions are retained. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit any active SSCs.

Therefore, there are no functional requirements, no credit taken, for backup nitrogen.

HDI PNP 2023-002 Page 194 of 281 Section Title Change Description of Change 9.5.3.4 System Operation Delete This section is deleted in its entirety. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit any active SSCs.

Therefore, there are no functional requirements, no credit taken, for backup nitrogen.

9.5.3.5 Design Analysis Delete This section is deleted in its entirety. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit any active SSCs.

Therefor~, there are no functional requirements, no credit taken, for backup nitrogen.

9.5.4.4 System Operation Modify This section is modified to remove reference to emergency diesels.

Amendment 272 removed Tech Spec Section 3.8, Electrical, and the facility license no longer contains requirements for electrical systems. Therefore, discussion is revised to remove references to diesel generators.

HDI PNP 2023-002 Page 195 of 281 Section Title Change Description of Change 9.6.1 Design Basis Modify This section is revised by changing reference to "achieving safe and stable conditions" to "maintaining safe and stable conditions." Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. With no OBA accidents, the facility will already be in a safe and stable condition should a fire be detected.

9.6.3 Design Analysis Modify This section is revised by changing reference to "achieving safe and stable conditions" to "maintaining safe and stable conditions." Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. With no OBA accidents, the facility will already be in a safe and stable condition should a fire be detected.

HDI PNP 2023-002 Page 196 of 281 Section Title Change Description of Change 9.7.1 Design Basis Modify This section is modified by eliminating functional requirements and operational aspects of auxiliary feedwater systems. Physical descriptions are retained. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and Amendment 272 removed Tech Spec 3.7.5, Auxiliary Feedwater (AFW) System. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit any active SSCs. Therefore, functional requirements and operational aspects of auxiliary feedwater systems are no longer relevant.

9.7.2.1 System Description Modify This section is modified by eliminating functional requirements and operational aspects of auxiliary feedwater systems. Physical descriptions are retained. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and Amendment 272 removed Tech Spec 3.7.5, Auxiliary Feedwater (AFW) System. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit any active SSCs. Therefore, functional requirements and operational aspects of auxiliary feedwater systems are no longer relevant.

HDI PNP 2023-002 Page 197 of 281 Section Title Change Description of Change 9.7.2.3 System Operation Delete This section is deleted in its entirety. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generatiqn can no longer occur, and core related design basis accidents are no longer possible, and Amendment 272 removed Tech Spec 3.7.5, Auxiliary Feedwater (AFW) System. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit any active SSCs. Therefore, functional requirements and operational aspects of auxiliary feedwater systems are no longer relevant.

9.7.3 Design Analysis Delete This section is deleted in its entirety. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and Amendment 272 removed Tech Spec 3.7.5, Auxiliary Feedwater (AFW) System. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit any active SSCs. Therefore, functional requirements and operational aspects of auxiliary feedwater systems are no longer relevant.

HDI PNP 2023-002 Page 198 of 281 Section Title Change Description of Change 9.7.4 System Reliability Delete This section is deleted in its entirety. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and Amendment 272 removed Tech Spec 3.7.5, Auxiliary Feedwater (AFW) System. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit any active SSCs. Therefore, functional requirements and operational aspects of auxiliary feedwater systems are no longer relevant.

9.7.5 Tests and Inspection Delete This section is deleted in its entirety. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and Amendment 272 removed Tech Spec 3.7.5, Auxiliary Feedwater (AFW) System. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit any active SSCs. Therefore, functional requirements and operational aspects of auxiliary feedwater systems are no longer relevant.

HDI PNP 2023-002 Page 199 of 281 Section Title Change Description of Change 9.8.1 Design basis Modify This section is modified by deleting discussion of non-FHA accident scenarios, safety functional requirements of CR HVAC, safety functional requirements and operation of ESRV and other essential HVAC systems, plant operational and emergency modes, arid cold shutdown. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, DBAs are no longer possible, and Amendment 272 removed Tech Spec 3.7.10 Control Room Ventilation (CRV) Filtration, 3.7.11 Control Room Ventilation (CRV) Cooling, 3.7.12 Fuel Handling Area Ventilation System, and 3.7.13 Engineered Safeguards Room Ventilation (ESRV) Dampers. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit HVAC.

Therefore, non-FHA accident scenarios, safety functional requirements of CR HYAC, safety functional requirements and operation of ESRV, plant operatio*nal and emergency modes, and cold shutdown are no longer relevant.

HDI PNP 2023-002 Page 200 of 281 Section Title Change Description of Change 9.8.2.1 System Description Modify Section is revised to: Remove reference to OBA, normal, cold and hot shutdown conditions. Remove reference to PCS leakage detection (See

4. 7). Remove reference to containment air and engineered safeguards room cooler operations. Remove reference to SSCs as "essential" coolers This section is modified by deleting discussion of non-FHA accident scenarios, safety functional requirements of CR HVAC, safety functional requirements and operation of ESRV and other essential HVAC systems, plant operational and emergency modes, and cold shutdown. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, DBAs are no longer possible, and Amendment 272 removed Tech Spec 3.7.10 Control Room Ventilation (CRV) Filtration, 3.7.11 Control Room Ventilation (CRV) Cooling, 3.7.12 Fuel Handling Area Ventilation System, and 3.7.13 Engineered Safeguards Room Ventilation (ESRV) Dampers. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit HVAC.

Therefore, non-FHA accident scenarios, safety functional requirements of CR HVAC, safety functional requirements and operation of ESRV, plant operational and emergency modes, and cold shutdown are no longer relevant.

HDI PNP 2023-002 Page 201 of 281 Section Title Change Description of Change 9.8.2.2 Component Modify Section is revised to remove reference to emergency operation Description This section is modified by deleting discussion of non-FHA accident scenarios, safety functional requirements of CR HVAC, safety functional requirements and operation of ESRV and other essential HVAC systems, plant operational and emergency modes, and cold shutdown. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, DBAs are no longer possible, and Amendment 272 removed Tech Spec 3. 7.10 Control Room Ventilation (CRV) Filtration, 3.7.11 Control Room Ventilation (CRV) Cooling, 3.7.12 Fuel Handling Area Ventilation System, and 3. 7.13 Engineered Safeguards Room Ventilation (ESRV) Dampers. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit HVAC.

Therefore, non-FHA accident scenarios, safety functional requirements of CR HVAC, safety functional requirements and operation of ESRV, plant operational and emergency modes, and cold shutdown are no longer relevant.

HDI PNP 2023-002 Page 202 of 281 Section Title Change Description of Change 9.8.2.4 Operation Modify Section is revised to: Remove reference to CR HVAC emergency modes.

Rem.ave cooling requirements for RPS. Remove operational information on engineered safeguards room coolers.

This section is modified by deleting discussion of non-FHA accident scenarios, safety functional requirements of CR HVAC, safety functional requirements and operation of ESRV and other essential HVAC systems, plant operational and emergency modes, and cold shutdown. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, DBAs are no longer possible, and Amendment 272 removed Tech Spec 3.7.10 Control Room Ventilation (CRV) Filtration, 3.7.11 Control Room Ventilation (CRV) Cooling, 3.7.12 Fuel Handling Area Ventilation System, and 3.7.13 Engineered Safeguards Room Ventilation (ESRV) Dampers. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit HVAC.

Therefore, non-FHA accident scenarios, safety functional requirements of CR HVAC, safety functional requirements and operation of ESRV, plant operational and emergency modes, and cold shutdown are no longer relevant.

HDI PNP 2023-002 Page 203 of 281 Section Title Change Description of Change 9.8.3 Tests and Modify This section is modified by deleting reference to Technical Specification Inspections testing requirements. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PN P, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, DBAs are no longer possible, and Amendment 272 removed Tech Spec 3.7.10 Control Room Ventilation (CRV) Filtration, and 3.7.12 Fuel Handling Area Ventilation System.

9.8.4 Loss of instrument Modify This section is modified by deleting discussion of non-FHA accident air to scenarios, safety functional requirements of CR HVAC, safety functional ventilation dampers requirements and operation of ESRV and other essential HVAC systems, plant operational and emergency modes, and cold shutdown. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part.50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, DBAs are no longer possible, and Amendment 272 removed Tech Spec 3.7.10 Control Room Ventilation (CRV) Filtration, 3.7.11 Control Room Ventilation (CRV) Cooling, 3.7.12 Fuel Handling Area Ventilation System, and 3.7.13 Engineered Safeguards Room Ventilation (ESRV) Dampers. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit HVAC.

Therefore, non-FHA accident scenarios, safety functional requirements of CR HVAC, safety functional requirements and operation of ESRV, plant operational and emergency modes, and cold shutdowff are no longer .

relevant.

HDI PNP 2023-002 Page 204 of 281 Section Title Change Description of Change 9.8.5.1 Introduction Delete This section is deleted in its entirety. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and Amendment 272 removed Tech Spec 3.7.5, Auxiliary Feedwater (AFW) System. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit any active SSCs. Therefore, functional requirements and operational aspects of auxiliary feedwater systems are no longer relevant.

HDI PNP 2023-002 Page 205 of 281 Section Title Change Description of Change 9.8.5.2 Evaluation Modify This section is modified by deleting discussion of non-FHA accident scenarios, safety functional requirements of CR HVAC, safety functional requirements and operation of ESRV and other essential HVAC systems, plant operational and emergency modes, and cold shutdown. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, DBAs are no longer possible, and Amendment 272 removed Tech Spec 3.7.10 Control Room Ventilation (CRV) Filtration, 3.7.11 Control Room Ventilation (CRV) Cooling, 3.7.12 Fuel Handling Area Ventilation System, and 3.7.13 Engineered Safeguards Room Ventilation (ESRV) Dampers. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, which do not credit HVAC.

Therefore, non-FHA accident scenarios, safety functional requirements of CR HVAC, safety functional requirements and operation of ESRV, plant operational and emergency modes, and cold shutdown are no longer relevant.

9.9.1 Design Basis Modify This section is modified by eliminating discussions of plant operation, DBAs, and post accident sampling. Physical descriptions of SSCs are retained.

Certifications have been submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. Therefore, sampling for plant operation, DBAs and post accident conditions is no longer relevant.

HDI PNP 2023-002 Page 206 of 281 Section Title Change Description of Change 9.9.2 System Description Modify This section is modified by eliminating discussions of plant operation, DBAs, and and post accident sampling. Physical descriptions of SSCs are retained.

Operation Certifications have been submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. Therefore, sampling for plant operation, DBAs and post accident conditions is no longer relevant.

. 9.10.2.2 Volume Control Modify The section is revised to remove discussion of pressurizer level control.

See 4.3.7 9.10.2.4 Reactivity Control Delete This section is deleted in its entirety. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and Amendment 272 deleted Tech Spec Section 3.1, REACTIVITY CONTROL SYSTEMS. Therefore, discussion of reactivity control is no longer relevant.

HDI PNP 2023-002 Page 207 of 281 Section Title Change Description of Change 9.10.2.5 Pressure Leakage Delete This section is deleted in its entirety. Certifications have been submitted to Test System the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and Amendment 272 deleted Tech Spec Section 3.4 Primary Coolant System (PCS), and 3.4.13, PCS Operational Leakage.

Therefore, discussion of PCS leak testing while the plant is at power and hydrostatically testing the PCS at design pressure is no longer relevant.

9.10.3 Operations Delete This section is deleted in its entirety. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. Therefore, discussion of CVC system operation in normal or emergency conditions is no longer relevant.

9.10.4 Design Analysis Modify This section is revised to delete discussion of diesel generators operating under emergency conditions. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible, and Amendment 272 deleted Tech Spec Section 3.8, ELECTRICAL POWER SYSTEMS. Therefore, discussion of EDGs operating under emergency conditions is no longer relevant.

HDI PNP 2023-002 Page 208 of 281 Section Title Change Description of Change 9.10.5 Testing and Delete This section is deleted in its entirety. Amendment 272 removed the TS Inspection definition of inservice testing and associated references in Section 3.0.

lnservice testing in accordance with 10 CFR 50.55a is not required in the permanently defueled condition.

9.11.2 New Fuel Storage Modify This section is revised to delete discussion of new fuel handling. Physical descriptions are retained. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, new fuel will no longer be received or handled.

9.11.3.1 Original Design Modify Section was modified to change tense for fuel transfer activities from present ("is") to past tense ("was"). Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Therefore, fuel transfer to/from containment is longer allowed.

9.11.3.4 Prevention of Modify Section title is modified to "Prevention of Criticality During Storage."

Criticality During Certifications have been submitted to the NRC in accordance with Transfer and 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the Storage 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Therefore, fuel transfer to/from containment is longer allowed.

HDI PNP 2023-002 Page 209 of 281 Section Title Change Description of Change 9.11.3.5.1 Radiation Shielding Modify Section was modified to delete reference to refueling. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Therefore, fuel transfer to/from containment is longer allowed.

9.11.3.5.3 Airborne Doses Modify Editorial - "UFSAR" revised to "DSAR" 9.11.3.5.4 General Area Doses Modify Editorial - "UFSAR" revised to "DSAR" 9.11.3.5.5 Protection Against Modify Section was modified to delete reference to refueling. Certifications have Radioactivity been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii)

Release and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Therefore, fuel transfer to/from containment is longer allowed.

9.11.4.1 General Modify Section is revised to delete reference to new fuel handling, refueling and fuel transfer. "UFSAR" is revised to "DSAR." Certifications have been submitted to the NRC in accordance with 10 CFR 50.82{a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Therefore, no new fuel will be handled, and fuel transfer to/from containment is longer allowed.

HDI PNP 2023-002 Page 210 of 281 Section Title Change Description of Change 9.11.4.2 Fuel Handling Modify Section is revised to delete reference to refueling activities. Physical Structures descriptions of SSCs is retained. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Therefore, refueling activities are longer allowed.

9.11.4.3 Major Fuel Handling Modify Section is revised to delete reference to refueling activities. Physical Equipment descriptions of equipment is retained. Spent fuel handling and crane information is retained. "UFSAR" is revised to "DSAR." Reference numbering is corrected. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Therefore, refueling activities are longer allowed.

9.11.4.4 System Evaluation Modify Section is revised to delete reference to refueling activities and limit discussion to fuel handing in the SFP. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Therefore, refueling activities are longer allowed.

9.11.4.5 Test Program Delete Section is deleted in its entirety. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Therefore, refueling activities are longer allowed.

HDI PNP 2023-002 Page 211 of 281 Section Title Change Description of Change 9.11.5 Spent Fuel Storage Modify Editorial - Corrected References.

AtAn Independent Spent Fuel Storage Installation 9.12.1 Design Basis Modify This section is modified by eliminating discussions of plant operation, shutdown and DBAs. Certifications have been submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Amendment 272 deleted Tech Spec 3.7.9 Ultimate Heat Sink (UHS). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. Therefore, discussion of plant operation, DBAs and post accident conditions is no longer relevant.

9.12.2.1 System Description Modify This section is modified by eliminating discussions of cooling tower operation, plant operation, shutdown and DBAs. Certifications have been submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Amendment 272 deleted Tech Spec 3.7.9 Ultimate Heat Sink (UHS). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. Therefore, discussion of plant operation, DBAs and post accident conditions is no longer relevant.

HDI PNP 2023-002 Page 212 of 281 Section Title Change Description of Change 9.12.2.2 System Operation Modify This section is modified by eliminating discussions plant operation, shutdown and DBAs. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Amendment 272 deleted Tech Spec 3.7.9 Ultimate Heat Sink (UHS). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible.

Therefore, discussion of plant operation, DBAs and post accident conditions is no longer relevant.

9.12.3 Design Analysis Delete This section is deleted in its entirety. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Amendment 272 deleted Tech Spec 3.7.9 Ultimate Heat Sink (UHS). Thus, power operations and electrical generation can no longer occur, core related design basis accidents are no longer possible, and the UHS is not credited in any safety analyses. Therefore, there are no safety functional requirements or safety margins, no required testing or inspections, and hot shutdown is no longer relevant.

9.0 References Modify Revised list of references to denote deleted references.

Table 9-1 Service Water Modify Table is modified to remove operational and DBA flow values. See 9.1.1 System Flow Requirements

HDI PNP 2023-002 Page 213 of 281 Section Title Change Description of Change Table 9-2 Service Water Modify Table is modified to remove design values and revise title. Physical System Design descriptions are retained. See 9.1.1 Ratings and Construction of Components Table 9-3 Reactor Primary Modify Table is modified to remove design values and revise title. Physical Shield Cooling descriptions are retained. See 9.2.1

System Design

Ratings and Construction of Components Table 9-4 Component Cooling Modify Table is modified to remove shutdown cooling and DBA heat loads.

System Heat Loads See 9.3.1 Table 9-5 Component Cooling Modify Table is modified to remove operational and design values. Physical Water System descriptions are retained. See 9.3.1 Design Ratings and Construction of Components Table 9-6 Component Cooling Modify Table is modifiec;I to remove operational and OBA flow values. See 9.3.1 System Required Flow Rates Table 9-8 Instrument Air Modify Deleted reference to Nitrogen Bottle design pressure. See 9.5.3.1

System Design

Ratings and Construction of Components

--* J

HDI PNP 2023-002 Page 214 of 281 Section Title Change Description of Change Table 9-9 Effect of Loss of Air Modify Table is modified to remove position information for primary, secondary, and to Air-Operated engineered safeguards systems which are no longer in service. Information Valves for SWS, CCW and radwaste systems are retained. Amendment 272 deleted Tech Spec Section 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), Section 3.6 CONTAINMENT SYSTEMS, and LCO 3.7.5 Auxiliary Feedwater (AFW) System. Certifications have been submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. The only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, none of which credit active components. Therefore, there are no credited "Safety Positions" for air-operated valves and discussion of loss of air position is no longer relevant.

Table 9-12 Auxiliary Feedwater Modify Table is modified to remove design values and revise title. Physical System Design descriptions are retained. See 9.7.1 Ratings and Construction of Components Table 9-13 Design Basis Modify Table is modified to remove accident conditions. See 9.8.1 Ambient Conditions

HDI PNP 2023-002 Page 215 of 281 Section Title Change Description of Change Table 9-15 Ventilation Dampers: Modify Table is modified to remove shutdown and OBA auto actuation positions.

Functions and Certifications have been submitted to the NRC in accordance with Positions for Various 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the Modes of Plant 10 CFR Part 50 license no longer permits operation of the reactor or Operation placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and core related design basis accidents are no longer possible. The only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids, none of which credit active components. Therefore, shutdown and OBA auto actuation positions are no longer relevant.

Table 9-17 Sample Point Modify Table is revised to remove sample points for NSSS and Steam Cycles.

Summary Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, and sampling for NSSS and Steam Cycles are no longer relevant.

Table 9-18 Chemical and Modify Table is modified to remove operational values. See 9.10.3 Volume Control

System Design

Parameters Table 9-19 Fuel Handling Data Modify Table is modified to remove reference to refueling. See 9.10.3

HDI PNP 2023-002 Page 216 of 281 Section Title Change Description of Change Figure 9-3 Nominal Operating Delete Figure is deleted in its entirety. See 9.2.2.3.

Conditions Cooling Coil Centerline Figure 9-4 Nominal Operating Delete Figure is deleted in its entirety. See 9.2.2.3.

Conditions Mid- Span of Two Cooling Coils Figure 9-5 Bounding Design Delete Figure is deleted in its entirety. See 9.2.2.3.

Cooling Coil Centerline Figure 9-6 Bounding Design Delete Figure is deleted in its entirety. See 9.2.2.3.

Conditions and Mid- Span of Two Cooling Coils Figure 9- Boron Concentration Delete Figure is deleted in its entirety. See 9.10.2.4.

19 vs Core Lifetime 10.1 Design Basis Modify This Chapter is modified to remove functional requirements and operational information. Certifications have been submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur. Therefore, functional requirements and operational information for the steam and power conversion systems is no longer pertinent.

HDI PNP 2023-002 Page 217 of 281 Section Title Change Description of Change 10.2.1 System General Modify This Section is modified to remove functional requirements and operational Description information. See 10.1 10.2.2 System Turbine Modify This Section is modified to remove functional requirements and operational information. See 10.1 10.2.2.1 High-Pressure Modify This Section is modified to remove functional requirements and operational Turbine information. See 10.1 10.2.2.2 Low-Pressure Modify This Section is modified to remove functional requirements and operational Turbine information. See 10.1 10.2.2.3 Electrical Generator Modify This Section is modified to remove functional requirements and operational information. See 10.1 10.2.2.4 Exciter Modify This Section is modified to remove functional requirements and operational information. See 10.1 10.2.3.1 Condensate System Modify This Section is modified to remove functional requirements and operational information. See 10.1 10.2.3.3 Feedwater Delete This section is deleted in its entirety. See 10.1 Regulating System

HDI PNP 2023-002 Page 218 of 281 Section Title Change Description of Change 10.2.4 Circulating Water Modify This Section is modified to remove functional requirements and operational System information. See 10.1 10.2.4.1 Cooling Towers Modify This Section is modified to remove functional requirements and operational information. See 10.1 10.2.4.2 Makeup and Delete This section is deleted in its entirety. See 10.1 Slowdown 10.2.4.3 Dilution Delete This section is deleted in its entirety. See 10.1 10.2.5 Codes and Modify This Section is modified to remove functional requirements and operational Standards information.

See 10.1 10.3 System Analysis Delete This section is deleted in its entirety. See 10.1 10.4 Tests and Modify This Section is modified to remove functional requirements and operational Inspections information. See 10.1 Table 10-3 Signal System Delete Table is deleted. See 10.1 Operating Conditions

HDI PNP 2023-002 Page 219 of 281 Section Title Change Description of Change 11.1 Source Terms Modify This section is modified by eliminating discussions of coolant activity during plant operation. Editorial: Reference to Table 11-1 0 is corrected to Table 11-17. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, plant operation can no longer occur and tube leaks are no longer pertinent.

11.2.2.1 Clean Waste Modify This section is modified by eliminating discussions of plant operations.

Section Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, plant startup and shutdowns can no longer occur.

11.2.3.1 Clean Waste Modify This section is modified by eliminating discussions of plant operations and Section refueling. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, plant operation and refueling can no longer occur.

11.2.5 System Evaluation Modify This section is modified by eliminating discussions of steam generator tube leakage. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, plant operation can no longer occur and tube leaks are no longer pertinent.

HDI PNP 2023-002 Page 220 of 281 Section Title Change Description of Change 11.4.2.2 Radioactive Waste Modify This section is modified by correcting errors and making administrative Storage Facilities changes.

11.4.2.3 Alternate Radwaste Modify This section is modified by correcting errors and making administrative Processing Systems changes.

Standard Dewatering System 11.5.1 Design Basis Modify This section is modified by making administrative changes.

11.5.4 System Evaluation Modify This section is modified to remove functional requirements for containment high range gamma monitors. Amendment 272 removed Tech Spec Section 3.3, Instrumentation, including TS 3.3.7, Post Accident Monitoring (PAM)

Instrumentation, and since the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license no longer contains requirements for the RG 1.97 instrumentation.

11.6.1.1 Radiation Exposure Modify This section is modified by replacing "Maximum Hypothetical Accident of Personnel (MHA)" with "Chapter 14 accidents." RFOL Amendment 272 removed accident scenarios related to the NSSS. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore the MHA is no longer possible.

HDI PNP 2023-002 Page 221 of 281 Section Title Change Description of Change 11.6.1.2 Radiation Exposure Modify This section is modified by deleting reference to "Maximum Hypothetical of Materials and Accident (MHA)." Amendment 272 removed accident scenarios related to Components the NSSS. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, the_refore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore the MHA is no longer possible.

11.6.3 General Design Modify This section is modified by making administrative changes.

Considerations 11.6.3.1 Specific Design 'Modify This section is modified by making administrative changes.

Values 11.6.4.1 Containment Modify This section is modified by eliminating reference to plant operations and the Building Shell maximum hypothetical accident. Amendment 272 removed accident scenarios related to the NSSS. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, plant operations and the maximum hypothetical accident are no longer relevant.

HDI PNP 2023-002 Page 222 of 281 Section Title Change Description of Change 11.6.4.2 Containment Modify This section is modified by removing reference to dose rates incurred during Building Interior operation. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur. Therefore operational dose rates are no longer applicable.

11.6.4.3 Auxiliary Building Modify This section is modified by eliminating discussions of plant operations and (Including Radwaste DBAs. Amendment 272 removed accident scenarios related to the NSSS.

Building Addition) Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore plant operations and DBAs are no longer relevant.

HDI PNP 2023-002 Page 223 of 281 Section Title Change Description of Change 11.6.4.4 Turbine Building Modify This section is modified by eliminating discussions of plant operations and DBAs. Amendment 272 removed accident scenarios related to the NSSS.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuer in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids. Therefore, plant operations and DBAs are no longer relevant.

11.6.4.5 General Facility Modify This section is modified by eliminating discussions of plant operations.

Yard Areas Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur. Therefore plant operations is no longer relevant.

11.6.5.2 System Description Modify This section is modified to remove functional requirements for containment high range gamma monitors and reference to NUREG 737.

Amendment 272 removed Tech Spec Section 3.3, Instrumentation, including TS 3.3.7, Post Accident Monitoring (PAM) Instrumentation, and since the certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, the 10 CFR Part 50 license no longer contains requirements for the RG 1.97 instrumentation.

HDI PNP 2023-002 Page 224 of 281 Section Title Change Description of Change 11.6.6.1 Facilities Modify This section is modified by eliminating discussions of primary coolant samples. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur. Therefore, primary coolant sampling is no longer relevant.

11.6.6.5 Shielding Modify This section is modified by eliminating discussions of plant operations.

Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur.

11.6.6.6 Access Control Modify This section is modified by changing reference to primary thermoluminescence dosemeter to just primary dosimeters and administrative changes related to program management. This is a administrative change to more accurately describe radiation protection practices.

11.6.6.10 External Radiation Modify This section is modified by changing reference to primary Dose Determination thermoluminescence dosemeter to just primary dosimeters. This is a administrative change to more accurately describe radiation protection practices.

11.6.7.4 Personal Monitoring Modify This section is modified by changing reference to primary Instrumentation thermoluminescence dosemeter to just primary dosimeters. This is a administrative change to more accurately describe radiation protection practices.

HDI PNP 2023-002 Page 225 of 281 Section Title Change Description of Change 11.6.8.1 Shielding Modify This section is modified to remove reference to surveys conducted during plant operations. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a}(2).

11.6.8.4 Radiation Protection Modify This section is modified by changing reference to primary Instrumentation thermoluminescence dosemeter to just primary dosimeters. This is an administrative change to more accurately describe radiation protection practices.

Table 11-1 Primary Coolant Modify This table is modified to remove data on primary coolant activity during Fission and normal operations.

Corrosion Product Certifications have been submitted to the NRC in accordance with 10 CFR Activities 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, normal primary coolant activites levels are no longer applicable.

Table 11-2 Radioactive Waste Modify This table is modified to remove data on radioactive waste generated during Quantities of startup, operation, shutdown or refueling. Certifications have been Significant Activity submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, there are no radioactive wastes from startup, operation, shutdown or refueling.

HDJ PNP 2023-002 Page 226 of 281 Section Title Change Description of Change Table 11- Activity in Gaseous Modify This table is modified to remove data on primary coolant activity during 11 Waste normal operations. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, normal primary coolant activities levels are no longer applicable.

12.2 Training Modify Removed reference to plant operations.

Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur.

12.2.1.1 Plant Access Modify Removed reference to plant operations. Certifications have been submitted Training to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations can no longer occur.

12.2.1.3 Licensed and Modify Revised title to Certified Fuel Handler Training Program in accordance with Nonlicensed Amendment 266 and replaced Operator training programs with Fuel Handler Operator Training training Program 12.3.1 Procedure Control Modify Revised procedure scope in safe storage of spent fuel and deleted Requirements reference to refueling. Deleted reference to SFCP in accordance with POTS.

HDI PNP 2023-002 Page 227 of 281 Section Title Change Description of Change 12.3.2 Upgrade and Delete EOPs have been removed in accordance with Amendment 266.

Maintenance of Emergency Operating Procedures 12.3.3 Operating Modify Deleted reference to SFCP in accordance with POTS.

Requirements Manual (ORM)

Table 12-1 Entergy Nuclear Site Modify Corrected name of Table Leadership Table 12-2 Plant Specific Titles Delete Deleted Table 12-2 as titles in section 5.1 and 5.2 have been revised in for Generic Titles Amend 266 to match Plant Specific Title and therefore the need for an Located in the "equivalent title" table is no longer necessary.

Technical Specifications Figure 12- Entergy Nuclear Site Modify Figure is revised to correct title and revise "GM, Plant Operations" to "Plant 1 Leadership Manager" Figure 12- Plant Specific Titles Delete Table is deleted.

2 for Generic Titles Functions described in the table are obsolete Located in the Technical Specifications

HDI PNP 2023-002 Page 228 of 281 Section Title Change Description of Change 13.1 Tests Prior to Modify Section modified to remove reference to preop tests on systems which can Reactor Fueling no longer operate. Certifications have been submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur. Therefore, preops for primary, steam and power conversion systems are no longer pertinent.

13.2 Reactor Fueling and Delete Section deleted in its entirety. Certifications have been submitted to the Physics Tests NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, refueling and physics test are longer pertinent.

13.3 Post Criticality and Delete Section deleted in its entirety. Certifications have been submitted to the Power Escalation NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur. Therefore, criticality and power escalation tests are no longer pertinent.

14.1 Introduction Modify This section is modified to replace the word "plant" with the word "facility."

The references for this section are revised to add the calculation for the spent fuel cask drop accident. EA-CDA-98-01, Revision 1, "Offsite Radiological Dose Consequences of a Cask Drop in the Spent Fuel Pool,"

February 7, 2001, (4931/1906) is inserted Reference 24 in support of Table 14.1-4.

HDI PNP 2023-002 Page 229 of 281 Section Title Change Description of Change 14.1.1 Background Delete The chronology and discussion of PNP licensing and analysis activities prior to issues of Amendment 272 have no bearing on the post defueled facility and are deleted.

14.1.2 Analyses at Nominal Delete After Amendment 272 is implemented there are no analyses required for Power Level of 2,650 MWt. The certifications required by 10 CFR 50.82(a)(1) are docketed 2,650 MWt for PN'P, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

14.1.3 Analyses Performed Delete After Amendment 272 is implemented there are no analyses required for at 2,580.6 MWT 2,580 MWt. The certifications required by 10 CFR 50.82(a)(1) are docketed Including for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the Uncertainty reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

14.2 Uncontrolled Control Delete This section is deleted in its entirety. The certifications required by Rod Withdrawal 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits 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 accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

HDI PNP 2023-002 Page 230 of 281 Section Title Change Description of Change 14.3 Boron Dilution Delete This section is deleted in its entirety. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits 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 accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

14.4 Control Rod Drop Delete This section is deleted in its entirety. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a){2). Thus, this accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

14.5 Core Barrel Failure Delete This section is deleted in its entirety. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

HDI PNP 2023-002 Page 231 of 281 Section Title Change Description of Change 14.6 Control Rod Delete This section is deleted in its entirety. The certifications required by Misoperation 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits 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 accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

14.7 Decreased Reactor Delete This section is deleted in its entirety. The certifications required by Coolant Flow 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits 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 accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

14.8 Start-up of An Delete This section is deleted in its entirety. The certifications required by Inactive Loop 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits 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 accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

HDI PNP 2023-002 Page 232 of 281 Section Title Change Description of Change 14.10 Increase in Steam Delete This section is deleted in its entirety. The certifications required by Flow (Excess Load) 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits 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 accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

14.11.1 Event Description Modify Section is modified by changing "plant" to "facility."

14.11.2.1.1 Analysis of Cask Modify This section is modified to delete the cask drop scenarios with 30 day Drop Scenarios decayed fuel. The cask drop scenario uses 90 day decayed fuel.

The 30 day scenarios are no longer credible considering new License Condition C.(5), which prohibits cask movement when irradiated fuel assemblies decayed less than 90 days are in the spent fuel pool.

14.11.3.1.1 Radiological Modify This section is modified to remove reference to previous Cask Drop Consequences of a Scenarios crediting FHB charcoal filters. In the NRC SER for Amendment Cask Drop in the 272, the only remaining cask drop scenario is a cask drop onto 90 day Spent Fuel Pool. decayed fuel without the FHB Charcoal Filter operating.

14.11.3.2.1 Radiological Modify This section is modified to remove reference to previous Cask Drop Consequences of a Scenarios crediting FHB charcoal filters. In the NRC SER for Amendment Cask Drop in the 272, the only remaining cask drop scenario is a cask drop onto 90 day Spent Fuel Pool. decayed fuel without the FHB Charcoal Filter operating 14.11.3.3.1 Radiological Modify This section is modified to remove reference to previous Cask Drop Consequences of a Scenarios crediting FHB charcoal filters. In the NRC SER for Amendment Cask Drop in the 272, the only remaining cask drop scenario is a cask drop onto 90 day Spent Fuel Pool. decayed fuel without the FHB Charcoal Filter operating

__J

HDI PNP 2023-002 Page 233 of 281 Section Title Change Description of Change 14.11 References Modify Reference 11 is removed as it is no longer applicable.

14.12 Loss of External Delete This section is deleted in its entirety. The certifications required by 10 CFR Load 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits 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 accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

14.13 Loss of Normal Delete This section is deleted in its entirety. The certifications required by Feedwater 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits 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 accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

14.14 Steam Line Rupture Delete This section is deleted in its entirety. Certifications for permanent cessation Incident of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82{a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82{a){2). After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

HD! PNP 2023-002 Page 234 of 281 Section Title Change Description of Change 14.15 Steam Generator Delete This section is deleted in its entirety. The certifications required by Tube Rupture With a 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Loss of Offsite 10 CFR Part 50 license prohibits operation of the reactor or emplacement or Power retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, this accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

14.16 Control Rod Ejection Delete This section is deleted in its entirety. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits 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 accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

14.17 Loss of Coolant Delete This section is deleted in its entirety. Certifications for permanent cessation Accident of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a){2). Thus, this accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

HDI PNP 2023-002 Page 235 of 281 Section Title Change Description of Change 14.18 Containment Delete This section is deleted in its entirety. Certifications for permanent cessation Pressure and of operations and permanent removal of fuel from the reactor vessel were Temperature submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and Analysis are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, this accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

14.19.1 Event Description Modify This section is modified to remove discussion of accidents during in containment refueling activities. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). After permanent shutdown and full core offload, all fuel will be in the spent fuel pool (SFP) or the Independent Spent Fuel Storage Installation (ISFSI).

14.19.3.2 Bounding Event Modify This section is modified to define the bounding FHA event as 17 days after Input shutdown in the spent fuel pool. "Plant" is also revised to "facility." The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Since the certifications required by 10 CFR 50.82(a)(1) have been docketed 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.

HDI PNP 2023-002 Page 236 of 281 Section Title Change Description of Change 14.19.3.3 Analysis of Results Modify This section is modified to delete reference to a fuel handling accident inside containment and to delete reference to the control room charcoal filters.

The licensing basis FHA identified in Amendment 272 takes place in the spent fuel pool and does not credit charcoal filtration. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement 'of fuel in 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, at which time the described FHA becomes effective.

14.19.4 Conclusions Modify This section is modified to delete reference to a fuel handling accident inside containment. The licensing basis FHA identified in Amendment 272 takes place in the spent fuel pool and does not credit charcoal filtration.

Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRG in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement 'of fuel in 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, at which time the described FHA becomes effective.

14.20.1 Event Description Modify Deleted reference to the VCT rupture. The VCT rupture scenario is deleted in Amendment 272.

14.20.3.1 Analysis Method Modify Deleted reference to the VCT rupture. The VCT rupture scenario is deleted in Amendment 272.

HDI PNP 2023-002 Page 237 of 281 Section Title Change Description of Change 14.20.4 Conclusions Modify "Plant" is revised to "Facility" 14.21 Waste Gas Incident Modify Calculation No. EA-EC89582-01, Revision 0, "Post-Permanent Shutdown Fuel Handling Accident and Waste Gas Tank Rupture," dated April 26, 2021 is added at end of section as Reference 3 14.21.1.3.1 Analysis Method Modify Description changed from "waste gas accident" to "waste gas incident" 14.21.1.3.2 Bounding Event Modify "Plant" is revised to "Facility" Input 14.21.1.3.3 Analysis of Results Modify This section is revised to reflect analysis presented in Amendment 272 dated June 1, 2021. The Gas Decay Tank Rupture (GDTR) consequences are bounded by the FHA.

14.21.2 Volume Control Delete This section is deleted in its entirety. The VCT rupture scenario was deleted Tank Rupture in Amendment 272.

14.21.3 Conclusions Modify This section is revised to reflect analysis presented in Amendment 272 dated June 1, 2021. The GDTR consequences are bounded by the FHA.

14.22 Maximum Delete This section is deleted in its entirety. The certifications required by Hypothetical 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Accident 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

HDI PNP 2023-002 Page 238 of 281 Section Title Change Description of Change 14.23 Radiological Delete This section is deleted in its entirety. The certifications required by Consequences of 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Failure of Small 10 CFR Part 50 license prohibits operation of the reactor or emplacement or Lines Carrying retention of fuel in the reactor vessel in accordance with Primary Coolant 10 CFR 50.82(a)(2). Thus, this accident scenario is not plausible. After Outside implementation of Amendment 272, the only remaining accidents are the Containment FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

14.24 Control Room Delete This section provides the basis for determining required start times for the Radiological CRHVAC during accident scenarios. Per Amendment 272, CRHVAC is no Habitability longer credited in any accident analysis.

Table Specified Delete This table is deleted in its entirety. The certifications required by 14.1-1 Acceptable Fuel 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Design Limits 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Fuel will only be located in the SFP and, therefore, fuel design limits are no longer pertinent.

Table Trip Setpoints for Delete This table is deleted in it's entirety. The certifications required by 14.1-3 Analysis of 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Palisades Reactor at 10 CFR Part 50 license prohibits operation of the reactor or emplacement or 2,530 MWt retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur, related design basis accidents are no longer possible, and trip setpoints are no longer relevant.

HDI PNP 2023-002 Page 239 of 281 Section Title Change Description of Change Table Disposition of Modify This table is modified by eliminating the discussions of core related design 14.1-4 Events Summary for basis accidents and changing the title to Disposition of Events Summary for Palisades Cycle 21 Palisades Post-Permanent Shutdown. FHA, cask drop and accidents involving the potential release of gaseous wastes or radioactive liquids are retained and the consequences updated per Amendment 272. The certifications required by 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

Table Cycle 21 Summary Delete This table is deleted in its entirety. The results of the remaining accidents, 14.1-5 of Results for cask drop, FHA and accidents involving the potential release of gaseous Standard Review wastes or radioactive liquids, are addressed in Table 14.1-6. Certifications Plan Chapter 15 for permanent cessation of operations and permanent removal of fuel from Events the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

HDI PNP 2023-002 Page 240 of 281 Section Title Change Description of Change Table Summary of Modify This table is modified by eliminating the discussions of core related design 14.1-6 Radiological basis accidents, and modifying the FHA scenario to 17 day decay times, Consequences of and modifying the spent fuel cask drop to 90 day decay times in accordance the Chapter 14 with License Condition C.(5). Accidents involving the potential release of Events gaseous wastes or radioactive liquids are retained and the consequences updated per Amendment 272. Certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) and are docketed for PNP, therefore the 10 CFR Part 50 license no longer permits operation of the reactor or placement of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

Table Event Summary for Delete This table is deleted in its entirety. The certifications required by 14.2.1-1 the Uncontrolled 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Bank Withdrawal 10 CFR Part 50 license prohibits operation of the reactor or emplacement or from a Low Power retention of fuel in the reactor vessel in accordance with Event 10 CFR 50.82(a)(2). Thus, this accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

Table Event Summary for Delete See Table 14.2.1-1 14.2.2-1 the Uncontrolled Rod Bank Withdrawal Event from Power

HDI PNP 2023-002 Page241 of281 Section Title Change Description of Change Table Event Summary for Delete This table is deleted in its entirety. The certifications required by 14.7.1-1 The Loss of Forced 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Reactor Coolant 10 CFR Part 50 license prohibits operation of the reactor or emplacement or Flow retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, this accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

Table Event Summary for Delete This table is deleted in its entirety. The certifications required by 14.7.2-1 the Reactor Coolant 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Pump Rotor Seizure 10 CFR Part 50 license prohibits 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 accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

Table Sequence of Events Delete This Table is deleted in its entirety. The certifications required by 14.10-1 for Excess Load 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Limiting MDNBR 10 CFR Part 50 license prohibits operation of the reactor or emplacement or Case retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, this accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

Table Spent Fuel Cask Modify This table is modified to reflect the remaining cask drop scenario of 90 days.

14.11-3 Drop Radiological Per Amendment 272, control room ventilation and filtration are no longer Analysis - Inputs credited and the 30 day scenarios are no longer credible. Table references and Assumptions are corrected to reflect the DSAR.

HDI PNP 2023-002 Page 242 of 281 Section Title Change Description of Change Table Event Summary for Delete This table is deleted in its entirety. The certifications required by 14.12-1 Loss of Load 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

Table Initial Conditions for Delete This table is deleted in its entirety. The certifications required by 14.13-1 the Loss of Normal 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Feedwater Analysis 10 CFR Part 50 license prohibits 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 accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

Table Sequence of Events Delete See Table 14.13-1 14.13-2 for Loss of Normal Feedwater Flow ,.

Analysis with Offsite Power Available and Steam Dump System Disabled

HDI PNP 2023-002 Attachment 2 Page 243 of 281 Section Title Change Description of Change Table Sequence of Events Delete See Table 14.13-1 14.13-3 for Loss of Normal Feedwater Flow Analysis with Offsite Power Available and Steam Dump System Available Table Sequence of Events Delete See Table 14.13-1 14.13-4 for Loss of Normal Feedwater Flow Analysis without Offsite Power Available and Steam Dump System Disabled Table Results Summary Delete See Table 14.13-1 14.13-5 for Loss of Normal Feedwater Table Main Steam Line Delete This table is deleted in its entirety. The certifications required by 14.14-1 Break Input 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Parameters and 10 CFR Part 50 license prohibits operation of the reactor or emplacement or Assumptions retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, this accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

L

HDI PNP 2023-002 Page 244 of 281 Section Title Change Description of Change Table Steam Line Break Delete See Table 14.14-1 14.14-2 Sequence of Events During LHR-Limiting Transient (HZP, Offsite Power Available)

Table Overall Core Delete See Table 14.14-1 14.14-3 Conditions at Time of Peak LHR Table Steam Line Break Delete See Table 14.14-1 14.14-4 Sequence of Events During DNBR-Limiting Transient (HZP, Loss of Offsite Power)

Table Overall Core Delete See Table 14.14-1 14.14-5 Conditions at Time of MDNBR Table Main Steam Line Delete See Table 14.14-1 14.14-6 Break (MSLB)

Radiological Analysis - Inputs and Assumptions

HDI PNP 2023-002 Page 245 of 281 Section Title Change Description of Change Table Main Steam Line Delete See Table 14.14-1 14.14-7 Break (MSLB)

Radiological Analysis - Intact SG Steam Release Rate Table Initial Conditions for Delete This table is deleted in its entirety. The certifications required by 14.15-1 The Steam 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Generator Tube 10 CFR Part 50 license prohibits operation of the reactor or emplacement or Rupture with a Loss retention of fuel in the reactor vessel in accordance with of Offsite Power 10 CFR 50.82(a)(2). Thus, this accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

Table Setpoints for The Delete See Table 14.15-1 14.15-2 Steam Generator Tube Rupture with a Loss of Offsite Power Table Sequence of Events Delete See Table 14.15-1 14.15-3 for The Steam Generator Tube Rupture with a Loss of Offsite Power

HDI PNP 2023-002 Page 246 of 281 Section Title Change Description of Change Table Integrated Delete See Table 14.15-1 14.15-4 Parameters for The Steam Generator Tube Rupture with a Loss of Offsite Power Table Steam Generator Delete See Table 14.15-1 14.15-5 Tube Rupture (SGTR) Radiological Analysis - Inputs and Assumptions Table SGTR Radiological Delete See Table 14.15-1 14.15-6 Analysis-Integrated Mass Releases Table SGTR Radiological Delete See Table 14.15-1 14.15-7 Analysis - Flashing Fraction for Flow from Broken Tube Table SGTR Radiological Delete See Table 14.15-1. Note typo in UFSAR TOC: 14.18 in lieu of 14.16.

14.18-8 Analysis - 40

µCl/GM D.E. 1-131 Activities

HDI PNP 2023-002 Page 247 of 281 Section Title Change Description of Change Table SGTR Radiological Delete See Table 14.15-1 14.15.9 Analysis - Iodine Equilibrium Appearance Assumptions Table SGTR Radiological Delete See Table 14.15-1 14.15-10 Analysis-Concurrent (335 X)

Iodine Spike Appearance Rate Table SGTR Radiological Delete See Table 14.15-1 14.15-11 Analysis - Affected Steam Generator Water Level and Decontamination Factors for Flashed Flow Table Event Summary for Delete This table is deleted in its entirety. The certifications required by 14.16-1 The EOG HZP 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Control Rod Ejection 10 CFR Part 50 license prohibits 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 accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

HDI PNP 2023-002 Page 248 of 281 Section Title Change Description of Change Table Control Rod Ejection Delete See Table 14.16-1 14.16-2 Radiological Analysis - Inputs and Assumptions Table Control Rod Ejection Delete See Table 14.16-1 14.16-3 Radiological Analysis - Steam Release Table Sampled LBLOCA Delete This table is deleted in its entirety. The certifications required by 14.17.1-1 Parameters 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits 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 accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop, and the potential release of gaseous wastes or radioactive liquids.

Table Plant Operating Delete See Table 14.17.1-1 14.17.1-2 Range Supported by the LOCA Analysis Table Statistical Delete See Table 14.17.1-1 14.17.1-3 Distribution Used for Process Parameters Table Summary of Major Delete See Table 14.17.1-1 14.17.1-4 Parameters for the Limiting PCT Case

HDI PNP 2023-002 Page 249 of 281 Section Title Change Description of Change Table Summary of Hot Delete See Table 14.17.1-1 14.17.1-5 Rod Limiting PCT Results Table Calculated Event Delete See Table 14.17.1-1 14.17.1-6 Times for The Limiting PCT Case Table Containment Heat Delete See Table 14.17.1-1 14.17.1-7 Sink Data Table Containment Initial Delete See Table 14.17.1-1 14.17.1-8 and Boundary Conditions Table System Parameters Delete See Table 14.17.1-1 14.17.2-1 and Initial Conditions used in The Palisades SBLOCA Analysis Table PCT Results of The Delete See Table 14.17.1-1 14.17.2-2 Palisades SBLOCA Analysis Table Sequence of Events Delete See Table 14.17.1-1 14.17.2-3 for The Palisades SBLOCA Event Table SBLOCA Analysis Delete See Table 14.17.1-1 14.17.2-4 Calculation Results

HDI PNP 2023-002 Page 250 of 281 Section Title Change Description of Change Table Maximum Stresses, Delete See Table 14.17.1-1 14.17.3-1 Pressures and Deflections in Critical Reactor Internals Following a Major Loss of Coolant Accident Table Asymmetric Loads Delete See Table 14.17.1-1 14.17.3-2 Analysis - Reactor Vessel Internal Component Stress Margins Table LOCA Analysis Delete This table is deleted in its entirety. The certifications required by 14.18.1-1 Containment 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Building Heat 10 CFR Part 50 license prohibits operation of the reactor or emplacement or Sinks/Sources retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, this accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

Table LOCA Analysis Delete See Table 14.18.1-1 14.18.1-2 Engineered Safeguards Equipment Alignment Table LOCA Initial Delete See Table 14.18.1-1 14.18.1-3 Conditions

HDI PNP 2023-002 Page 251 of 281 Section Title Change Description of Change Table Containment Delete See Table 14.18.1-1 14.18.1-4 Building Response to LOCA Double Ended Guillotine Break in a Hot Leg Table LOCA Analysis Delete See Table 14.18.1-1 14.18.1-5 Parameter Assumptions Table Initial Conditions for Delete See Table 14.18.1-1 14.18.2-1 The MSLB Containment Analysis Table Initial Conditions for Delete See Table 14.18.1-1 14.18.2-2 The MSLB Containment Analysis Table MSLB Containment Delete See Table 14.18.1-1 14.18.2-3 Analysis Results Table MSLB Analysis Delete See Table 14.18.1-1 14.18.2-4 Containment Building Heat Sinks/Sources Table Reactor Cavity Delete See Table 14.18.1-1 14.18.3-1 Geometric Factors

HDI PNP 2023-002 Page 252 of 281 Section Title Change Description of Change Table Geometry and Peak Delete See Table 14.18.1-1 14.18.3-2 Pressures in Steam Generator Compartments Table Differential Delete See Table 14.18.1-1 14.18.3-3 Pressures at Various Locations Table Fuel Handling Modify The table is revised to reflect the analysis described in Amendment 272; 14.19-1 Accident (FHA) 17day delay in fuel movement, 22.6 water level above spent fuel, no control Radiological room or FHB filtration, and revised dispersion factors.

Analysis - Inputs and Assumptions Table Fuel Handling Modify Table is replaced with new Table, POST-PERMANENT SHUTDOWN AST 14.19-2 Accident FHA - SOURCE TERM. The new source term values are those provided in Radiological Amendment 272 accident analysis.

Analysis - Source Term Table MHA Sequence of Delete This table is deleted in its entirety. The certifications required by 14.22-1 Events for The Dose 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Consequence 10 CFR Part 50 license prohibits operation of the reactor or emplacement or Analysis retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, power operations and electrical generation can no longer occur and core related design basis accidents are no longer possible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

HDI PNP 2023-002 Page 253 of 281 Section Title Change Description of Change Table Maximum Delete See Table 14.22-1 14.22-2 Hypothetical Accident / Loss of Coolant Accident (MHA/LOCA)

Radiological Analysis - Inputs and Assumptions Table MHA/LOCA Source Delete See Table 14.22-1 14.22-3 Term Table MHA/LOCA Release Delete See Table 14.22-1 14.22-4 Phases Table MHA/LOCA Time Delete See Table 14.22-1 14.22-5 Dependent SIRWT pH Table MHA/LOCA Time Delete See Table 14.22-1 14.22-6 Dependent SIRWT Total Iodine Concentration Table MHA/LOCA Time Delete See Table 14.22-1 14.22-7 Dependent SIRWT Liquid Temperature Table MHA/LOCA Time Delete See Table 14.22-1 14.22-8 Dependent SIRWT Elemental Iodine Fraction

HDI PNP 2023-002 Page 254 of 281 Section Title Change Description of Change Table MHA/LOCA Time Delete See Table 14.22-1 14.22-9 Dependent SIRWT Partition Coefficient Table MHA/LOCA Delete See Table 14.22-1 14.22-10 Adjusted Release Rate from SIRWT Table Small Line Break Delete This table is deleted in its entirety. The certifications required by 14.23-1 Outside of 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Containment 10 CFR Part 50 license prohibits operation of the reactor or emplacement or Radiological retention of fuel in the reactor vessel in accordance with Analysis - Inputs 10 CFR 50.82(a)(2). Thus, this accident scenario is not plausible. After and Assumptions implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

Table Small Line Break Delete This table is deleted in its entirety. The certifications required by 14.23-2 Outside of 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Containment 10 CFR Part 50 license prohibits operation of the reactor or emplacement or Radiological retention of fuel in the reactor vessel in accordance with Analysis- 10 CFR 50.82(a)(2). Thus, this accident scenario is not plausible. After Concurrent (500 X) implementation of Amendment 272, the only remaining accidents are the Iodine Spike FHA, cask drop and the potential release of gaseous wastes or radioactive Appearance Rate liquids.

Table Time Dependent Delete This table is deleted in its entirety. The control room emergency HVAC was 14.24-1 Control Room deleted from the POTS, no credit is taken for filtration in any remaining Parameters Chapter 14 accident, and there are no time dependent parameters in any remaining analyses.

HDI PNP 2023-002 Page 255 of 281 Section Title Change Description of Change Table Control Room Delete This table is deleted in its entirety. The atmospheric dispersion factors used 14.24-2 Atmospheric in the current accident analyses were provided in Amendment 272 and are Dispersion (X/Q) contained in Table 14.19-4.

Factors for AST Analysis Events Table Release-Receptor Delete This table is deleted in its entirety. The atmospheric dispersion factors used 14.24-3 Point Pairs Assumed in the current accident analyses were provided in Amendment 272 and are for AST Analysis contained in Table 14.19-4.

Events Figure Palisades Scram Delete This figure is deleted in its entirety. The certifications required by 14.1-3 Curve 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Fuel will only be located in the SFP and, therefore, fuel design limits are no longer pertinent.

Figure Control Rod Delete This figure is deleted in its entirety. The certifications required by 14.2.1-1 Withdrawal Incident 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the HZP Reactivity 10 CFR Part 50 license prohibits operation of the reactor or emplacement or Insertion Curve retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, this accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

Figure Control Rod Delete See Figure 14.2.1-1 14.2.1-2 Withdrawal Incident HZP Reactivity Feedbacks

HDI PNP 2023-002 Page 256 of 281 Section Title Change Description of Change Figure Control Rod Delete See Figure 14.2.1-1 14.2.1-3 Withdrawal Incident HZP Total Reactivity Figure Control Rod Delete See Figure 14.2.1-1 14.2.1-4 Withdrawal Incident HZP Power and Heat Flux Figure Control Rod Delete See Figure 14.2.1-1 14.2.1-5 Withdrawal Incident HZP System Pressure Figure Control Rod Delete See Figure 14.2.1-1 14.2.1-6 Withdrawal Incident HZP Inlet Enthalpy Figure Reactivities for Delete See Figure 14.2.1-1 14.2.2-1 Uncontrolled Bank Withdrawal at Full Power Figure Reactor Power Level Delete See Figure 14.2.1-1 14.2.2-2 for Uncontrolled Bank Withdrawal Full Power

HDI PNP 2023-002 Page 257 of 281 Section Title Change Description of Change Figure Core Average Heat Delete See Figure 14.2.1-1 14.2.2-3 Flux for Uncontrolled Bank Withdrawal at Full Power Figure Pressurizer Delete See Figure 14.2.1-1 14.2.2-4 Pressure for Uncontrolled Bank Withdrawal at Full Power Figure Pressurizer Liquid Delete See Figure 14.2.1-1 14.2.2-5 Level for Uncontrolled Bank Withdrawal at Full Power Figure PCS Mass Flow Delete See Figure 14.2.1-1 14.2.2-6 Rate for Uncontrolled Bank Withdrawal at Full Power Figure PCS Temperatures Delete See Figure 14.2.1-1 14.2.2-7 for Uncontrolled Bank Withdrawal at Full Power Figure Secondary Pressure Delete See Figure 14.2.1-1 14.2.2-8 for Uncontrolled Bank Withdrawal at Full Power

HDI PNP 2023-002 Page 258 of 281 Section Title Change Description of Change Figure S/G Liquid Level for Delete See Figure 14.2.1-1 14.2.2-9 Uncontrolled Bank Withdrawal at Full Power Figure Primary Coolant Delete This figure is deleted in its entirety. The certifications required by 14.7.1-1 System Mass Flow 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Rate for Loss of 10 CFR Part 50 license prohibits operation of the reactor or emplacement or Forced Flow retention of fuel in the reactor vessel in accordance with 10 CFR 50.82(a)(2). Thus, this accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

Figure Reactor Power Level Delete See Figure 14.7.1-1 14.7.1-2 for Loss of Forced Flow Figure Core Average Heat Delete See Figure 14.7.1-1 14.7.1-3 Flux for Loss of Forced Flow Figure Pressurizer Delete See Figure 14. 7.1-1 14.7.1-4 Pressure for Loss of Forced Flow Figure Primary Coolant Delete See Figure 14.7.1-1 14.7.1-5 System Temperatures for Loss of Forced Flow

HDI PNP 2023-002 Page 259 of 281 Section Title Change Description of Change Figure Primary Coolant Delete This figure is deleted in its entirety. The certifications required by 14.7.2-1 System Mass Flow 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Rate for Reactor 10 CFR Part 50 license prohibits operation of the reactor or emplacement or Coolant Pump Rotor retention of fuel in the reactor vessel in accordance with Seizure 10 CFR 50.82(a)(2). Thus, this accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

Figure Reactor Power Level Delete See Figure 14.7.2-1 14.7.2-2 for Reactor Coolant Pump Rotor Seizure Figure Core Average Heat Delete See Figure 14.7.2-1 14.7.2-3 Flux for Reactor Coolant Pump Rotor Seizure Figure Pressurizer Delete See Figure 14.7.2-1 14.7.2-4 Pressure for Reactor Coolant Pump Rotor Seizure Figure Primary Coolant Delete See Figure 14.7.2-1 14.7.2-5 System Temperatures for Reactor Coolant Pump Rotor Seizure

HDI PNP 2023-002 Page 260 of 281 Section Title Change Description of Change Figure Power Comparisons Delete This figure is deleted in its entirety. The certifications required by 14.10-1 - Excess Load 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits 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 accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

Figure PCS Coolant Delete See Figure 14.10-1 14.10-2 Temperature -

Excess Load Figure Pressurizer Delete See Figure 14.10-1 14.10-3 Pressure - Excess Load Figure Pressurizer Delete See Figure 14.10-1 14.10-4 Collapsed Liquid Level - Excess Load Figure Components of Delete See Figure 14.10-1 14.10-5 Reactivity - Excess Load

HDI PNP 2023-002 Page 261 of 281 Section Title _Change Description of Change Figure Reactor Power Level Delete This figure is deleted in its entirety. The certifications required by 14.12-1 for Loss of External 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Load Event 10 CFR Part 50 license prohibits 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 accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

Figure Primary Pressures Delete See Figure 14.12-1 14.12-2 for Loss of External Load Event Figure Pressurizer Liquid Delete See Figure 14.12-1 14.12-3 Volume for Loss of External Load Event Figure Primary Coolant Delete See Figure 14.12-1 14.12-4 System Temperatures for Loss of External Load Event Figure Secondary Delete See Figure 14.12-1 14.12-5 Pressures for Loss of External Load Event

HDI PNP 2023-002 Page 262 of 281 Section Title Change Description of Change Figure Reactor Power, Delete This figure is deleted in its entirety. The certifications required by 14.13-1 LNFF Analysis with 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Off-Site Power 10 CFR Part 50 license prohibits operation of the reactor or emplacement or Available and Steam retention of fuel in the reactor vessel in accordance with Dump System 10 CFR 50.82(a)(2). Thus, this accident scenario is not plausible. After Disabled implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

Figure Primary Coolant Delete See Figure 14.13-1 14.13-2 System Loop Temperatures, LNFF Analysis with Offsite Power Available and Steam Dump System Disabled Figure Primary Coolant Delete See Figure 14.13-1 14.13-3 System Loop Flow, LNFF Analysis with Off-Site Power c *-,

Available and Steam Dump System Disabled Figure Pressurizer Delete See Figure 14.13-1 14.13-4 Pressure, LNFF Analysis with Off-Site Power Available and Steam Dump System Disabled

HDI PNP 2023-002 Page 263 of 281 Section Title Change Description of Change Figure Pressurizer Spray Delete See Figure 14.13-1 14.13-5 Flow, LNFF Analysis with Off-Site Power Available and Steam Dump System Disabled Figure Pressurizer SRV Delete See Figure 14.13-1 14.13-6 Flow, LNFF Analysis with Off-Site Power Available and Steam Dump System Disabled Figure Pressurizer Level, Delete See Figure 14.13-1 14.13-7 LNFF Analysis with Off-Site Power Available and Steam Dump System Disabled Figure SG Auxiliary Delete See Figure 14.13-1 14.13-8 Feedwater Flow, LNFF Analysis with Off-Site Power Available and Steam Dump System Disabled

HDI PNP 2023-002 Page 264 of 281 Section Title Change Description of Change Figure SG Dome Pressure, Delete See Figure 14.13-1 14.13-9 LNFF Analysis with Off-Site Power Available and Steam Dump System Disabled Figure SG Liquid Mass Delete See Figure 14.13-1 14.13-10 Inventory, LNFF Analysis with Off-Site Power Available and Steam Dump System Disabled Figure Reactor Power, Delete See Figure 14.13-1 14.13-11 LNFF Analysis with Off- Site Power Available and Steam Dump System Available Figure Primary Coolant Delete See Figure 14.13-1 14.13-12 System Loop Temperatures, LNFF Analysis with Off- Site Power Available and Steam Dump System Available

HDI PNP 2023-002 Page 265 of 281 Section Title Change Description of Change Figure Primary Coolant Delete See Figure 14.13-1 14.13-13 System Loop Flow, LNFF Analysis with Off-Site Power Available and Steam Dump System Available Figure Pressurizer Delete See Figure 14.13-1 14.13-14 Pressure, LNFF Analysis with Off-Site Power Available and Steam Dump System Available Figure Pressurizer Spray Delete See Figure 14.13-1 14.13-15 Flow, LNFF Analysis with Off-Site Power Available and Steam Dump System Available Figure Pressurizer SRV Delete See Figure 14.13-1 14.13-16 Flow, LNFF Analysis with Off-Site Power Available and Steam Dump System Available

HDI PNP 2023-002 Page 266 of 281 Section Title Change Description of Change Figure Pressurizer Level, Delete See Figure 14.13-1 14.13-17 LNFF Analysis with Off-Site Power Available and Steam Dump System Available Figure SG Auxiliary Delete See Figure 14.13-1 14.13-18 Feedwater Flow, LNFF Analysis with Off-Site Power Available and Steam Dump System Available Figure SG Dome Pressure, Delete See Figure 14.13-1 14.13-19 LNFF Analysis with Off-Site Power Available and Steam Dump System Available Figure SG Liquid Mass Delete See Figure 14.13-1 14.13-20 Inventory, LNFF Analysis with Off-Site Power Available and Steam Dump System Available

HDI PNP 2023-002 Page 267 of 281 Section Title Change Description of Change Figure Reactor Power, Delete See Figure 14.13-1 14.13-21 LNFF Analysis without Off-Site Power Available and Steam Dump Systems Disabled Figure Primary Coolant Delete See Figure 14.13-1 14.13-22 System Loop Temperatures, LNFF Analysis without Off-Site Power Available and Steam Dump Systems Disabled Figure Primary Coolant Delete See Figure 14.13-1 14.13-23 System Loop Flow, LNFF Analysis without Off-Site Power Available and Steam Dump Systems Disabled Figure Pressurizer Delete See Figure 14.13-1 14.13-24 Pressure, LNFF Analysis without Off-Site Power Available and Steam Dump Systems Disabled

HDI PNP 2023-002 Page 268 of 281 Section Title Change Description of Change Figure Pressurizer Level, Delete See Figure 14.13-1 14.13-25 LNFF Analysis without Off-Site Power Available and Steam Dump Systems Disabled Figure SG Auxiliary Delete See Figure 14.13-1 14.13-26 Feedwater Flow, LNFF Analysis without Off-Site Power Available and Steam Dump Systems Disabled Figure SG Dome Pressure, Delete See Figure 14.13-1 14.13-27 LNFF Analysis without Off-Site Power Available and Steam Dump Systems Disabled Figure SG Liquid Mass Delete See Figure 14.13-1 14.13-28 Inventory, LNFF Analysis without Off-Site Power Available and Steam Dump Systems Disabled

HDI PNP 2023-002 Page 269 of 281 Section Title Change Description of Change Figure Break Flow Rates Delete This figure is deleted in its entirety. The certifications required by 14.14-1 During LHR-Limiting 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Transient 10 CFR Part 50 license prohibits 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 accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

Figure Steam Generator Delete See Figure 14.14-1 14.14-2 Pressures During LHR-Limiting Transient Figure Steam Generator Delete See Figure 14.14-1 14.14-3 Heat Transfer Rates During LHR -Limiting Transient Figure Steam Generator Delete See Figure 14.14-1 14.14-4 Secondary-Side Total Fluid Inventories During LHR-Limiting Transient Figure Core Inlet Delete See Figure 14.14-1 14.14-5 Temperatures During LHR

- Limiting Transient

HDI PNP 2023-002 Page 270 of 281 Section Title Change Description of Change Figure Core Inlet Flow Delete See Figure 14.14-1 14.14-6 Rates During LHR - Limiting Transient Figure Pressurizer Delete See Figure 14.14-1 14.14-7 Pressure During LHR - Limiting Transient Figure Pressurizer liquid Delete See Figure 14.14-1 14.14-8 level during LHR - limiting transient Figure Total HPSI Flow Delete See Figure 14.14-1 14.14-9 Rate During LHR - Limiting Transient Figure Reactivity During Delete See Figure 14.14-1 14.14-10 LHR - Limiting Transient Figure Reactor Power Delete See Figure 14.14-1 14.14-11 During LHR -Limiting Transient Figure Break Flow Rates Delete See Figure 14.14-1 14.14-12 During DNBR - Limiting Transient

HDI PNP 2023-002 Page 271 of 281 Section Title Change Description of Change Figure Steam Generator Delete See Figure 14.14-1 '

14.14-13 Pressures During DNBR -Limiting Transient Figure Steam Generator Delete See Figure 14.14-1 14.14-14 Heat Transfer Rates During DNBR - Limiting Transient Figure Steam Generator Delete See Figure 14.14-1 14.14-15 Secondary-Side Total Fluid Inventories During DNBR Limiting Transient Figure Core Inlet Delete See Figure 14.14-1 14.14-16 Temperatures During DNBR - Limiting Transient Figure Core Inlet Flow Delete See Figure 14.14-1 14.14-17 Rates During DNBR - Limiting Transient

HDI PNP 2023-002 Page 272 of 281 Section Title Change Description of Change Figure Pressurizer Delete See Figure 14.14-1 14.14-18 Pressure During DNBR - Limiting Transient Figure Pressurizer Liquid Delete See Figure 14.14-1 14.14-19 Level During DNBR - Limiting Transient C Figure Total Hpsi Flow Rate Delete See Figure 14.14-1 14.14-20 During DNBR - Limiting Transient Figure Reactivity During Delete See Figure 14.14-1 14.14-21 DNBR - Limiting Transient Figure Reactor Power Delete See Figure 14.14-1 14.14-22 During DNBR - Limiting Transient Figure SGTR with LOAC: Delete This figure is deleted in its entirety. The certifications required by 14.15-1 Core Power vs Time 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits 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 accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

HDI PNP 2023-002 Page 273 of 281 Section Title Change Description of Change Figure SGTR with LOAC: Delete See Figure 14.15-1 14.15-2 Core Coolant Temperatures vs Time .

Figure SGTR with LOAC: Delete See Figure 14.15-1 14.15-3 Primary Coolant System Pressure vs Time Figure SGTR with LOAC: Delete See Figure 14.15-1 14.15-4 Steam Generator Pressure vs Time Figure SGTR with LOAC: Delete See Figure 14.15-1 14.15-5 Tube Leak Flow Rate vs Time Figure SGTR with LOAC: Delete See Figure 14.15-1 14.15-6 Integrated Tube Leak Flow vs Time Figure SGTR with LOAC: Delete See Figure 14.15-1 14.15-7 Pressurizer Liquid Volume vs Time Figure SGTR with LOAC: Delete See Figure 14.15-1 14.15-8 Affected Steam Generator Safety Valve (MSSV) Flow Rate vs Time

HDI PNP 2023-002 Page 274 of 281 Section Title Change Description of Change Figure SGTR with LOAC: Delete See Figure 14.15-1 14.15-9 Affected Steam Generator Safety Valve (MSSV)

Integrated Flow vs Time Figure SGTR with LOAC: Delete See Figure 14.15-1 14.15-10 Steam Generators Liquid Mass vs Time Figure SGTR with LOAC: Delete See Figure 14.15-1 14.15-11 Core Power vs Time Figure SGTR with LOAC: Delete See Figure 14.15-1 14.15-12 Core Coolant Temperatures vs Time Figure SGTR with LOAC: Delete See Figure 14.15-1 14.15-13 Primary Coolant System Pressure vs Time Figure SGTR with LOAC: Delete See Figure 14.15-1 14.15-14 Steam Generators Pressure vs Time Figure SGTR with LOAC: Delete See Figure 14.15-1 14.15-15 Pressurizer Liquid Volume vs Time

HDI PNP 2023-002 Page 275 of 281 Section Title Change Description of Change Figure SGTR with LOAC: Delete See Figure 14.15-1 14.15-16 Tube Leak Flow Rate vs Time Figure SGTR Integrated Delete See Figure 14.15-1 14.15-17 Leak Flow vs Time Figure SGTR ADV Flow Delete See Figure 14.15-1 14.15-18 Rate vs Time Figure SGTR Integrated Delete See Figure 14.15-1 14.15-19 ADV Flow vs Time Figure SGTR PCS Delete See Figure 14.15-1 14.15-20 Subcooling vs Time Figure SGTR HPSI Flow Delete See Figure 14.15-1 14.15-21 Rate vs Time Figure Control Rod Delete This figure is deleted in its entirety. The certifications required by 14.16-1 Ejection, EOC HZP 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the case: Core Power 10 CFR Part 50 license prohibits 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 accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

HDI PNP 2023-002 Page 276 of 281 Section Title Change Description of Change Figure Control Rod Delete See Figure 14.16-1 14.16-2 Ejection, EOC HZP Case: Core Average Heat-Flux-Based LHR Figure Control Rod Delete See Figure 14.16-1 14.16-3 Ejection, EOC HZP Case:

Total Core Reactivity Figure Scatter Plot of Delete This figure is deleted in its entirety. The certifications required by 14.17.1-1 Operational 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the Parameters 10 CFR Part 50 license prohibits 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 accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive

_liquids.

Figure PCT Versus PCT Delete See Figure 14.17.1-1 14.17.1-2 Time Scatter Plot From Transient Calculations Figure PCT Versus Break Delete See Figure 14.17.1-1 14.17.1-3 Size Scatter Plot From Transient Calculations

HDI PNP 2023-002 Page 277 of 281 Section Title Change Description of Change Figure Total Oxidation Vs. Delete See Figure 14.17.1-1 14.17.1-4 PCT Scatter Plot from Transient Calculations Figure Maximum Oxidation Delete See Figure 14.17.1-1 14.17.1-5 Versus PCT Scatter Plot from Transient Calculations Figure Peak Cladding Delete See Figure 14.17.1-1 14.17.1-6 Temperature for the Limiting Case Figure Break Flow for the Delete See Figure 14.17.1-1 14.17.1-7 Limiting Case Figure Core Inlet Mass Flux Delete See Figure 14.17.1-1 14.17.1-8 for the Limiting Case Figure Core Outlet Mass Delete See Figure 14.17.1-1 14.17.1-9 Flux for the Limiting Case Figure Void Fraction at Delete See Figure 14.17.1-1 14.17.1- PCS Pumps for the 10 Limiting Case

HDI PNP 2023-002 Page 278 of 281 Section Title Change " Description of Change Figure ECCS Flows Delete See Figure 14.17.1-1 14.17.1- (Includes SIT, HPSI, 11 and LPSI) for the Limiting Case Figure Upper Plenum Delete See Figure 14.17.1-1 14.17.1- Pressure for the 12 Limiting Case Figure Collapsed Liquid Delete See Figure 14.17.1-1 14.17.1- Level in the 13 Downcomer for the Limiting Case Figure Collapsed Liquid Delete See Figure 14.17.1-1 14.17.1- Level in the Lower 14 Plenum for the Limiting Case Figure Collapsed Liquid Delete See Figure 14.17.1-1 14.17.1- Level in the Core for 15 the Limiting Case Figure Containment and Delete See Figure 14.17.1-1 14.17.1- Loop Pressures for 16 the Limiting Case

HDI PNP 2023-002 Page 279 of 281 Section Title Change Description of Change Figure Break Mass Flow Delete This figure is deleted in its entirety. The certifications required by 14.17.2-1 Rate (Limiting Case) 10 CFR 50.82{a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits 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 accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

Figure Primary and Delete See Figure 14.17.2-1 14.17.2-2 Secondary Pressures (Limiting Case)

Figure Normalized Reactor Delete See Figure 14.17.2-1 14.17.2-3 Power (Limiting Case)

Figure Total HPSI Mass Delete See Figure 14.17.2-1 14.17.2-4 Flow Rate (Limiting Case)

Figure Total SIT Mass Flow Delete See Figure 14.17.2-1 14.17.2-5 Rate (Limiting Case)

Figure Loop Seal Void Delete See Figure 14.17.2-1 14.17.2-6 Fractions (Limiting Case)

Figure Break Void Fraction Delete See Figure 14.17.2-1 14.17.2-7 (Limiting Case)

HDI PNP 2023-002 Page 280 of 281 Section Title Change Description of Change Figure Reactor Vessel and Delete See Figure 14.17.2-1 14.17.2-8 PCS Mass Inventories (Limiting Case)

Figure Hot Channel Delete See Figure 14.17.2-1 14.17.2-9 Collapsed Level (Limiting Case)

Figure Fluid and Cladding Delete See Figure 14.17.2-1 14.17.2- Temperatures 10 (Limiting Case)

Figure SG Narrow Range Delete See Figure 14.17.2-1 14.17.2- Liquid Levels 11 (Limiting Case)

Figure AFW Flow Rates Delete See Figure 14.17.2-1 14.17.2- (Limiting Case) 12 Figure Total MSSV Flow Delete See Figure 14.17.2-1 14.17.2- (Limiting Case) 13

HDI PNP 2023-002 Page 281 of 281 Section Title Change Description of Change Figure LOCA Containment Delete This figure is deleted in its entirety. The certifications required by 14.18.1-1 Pressure Profile 10 CFR 50.82(a)(1) are docketed for PNP, and therefore the 10 CFR Part 50 license prohibits 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 accident scenario is not plausible. After implementation of Amendment 272, the only remaining accidents are the FHA, cask drop and the potential release of gaseous wastes or radioactive liquids.

Figure LOCA Containment Delete See Figure 14.18.1-1 14.18.1-2 Temperature Profile Figure MSLB Containment Delete See Figure 14.18.1-1 14.18.2-1 Response Maximum Pressure Profile Figure MSLB Containment Delete See Figure 14.18.1-1 14.18.2-2 Response Environmental Qualification Profile

HDI PNP 2023-002 Page 1 of 1 Enclosure 2 to HDI PNP 2023-002 Palisades Nuclear Plant CD-ROM Containing Final (Defueled) Safety Analysis Report (FSAR/DSAR) Revision 36 (Public Version)

HDI PNP 2023~002 Page 1 of 1 Enclosure 3 to HDI PNP 2023-002 Palisades Nuclear Plant CD-ROM Containing Final (Defueled) Safety Analysis Report (FSAR/DSAR) Revision 36 (Security-Related information, Withhold Under 10 CFR 2.390)