ML18152A929

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Palisades Nuclear Plant - License Amendment Request to Revise Emergency Diesel Generator Degraded Voltage Surveillance Requirement
ML18152A929
Person / Time
Site: Palisades Entergy icon.png
Issue date: 05/30/2018
From: Halter M K
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML18152A922 List:
References
PNP 2018-010
Download: ML18152A929 (30)
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Text

PNP 2018-010 May 30 , 2018 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington , DC 20555-0001 Entergy Nuclear Operations , Inc. Palisades Nuclear Plant 27780 Blu e S tar Memor ia l High wa y Covert , Ml 49043-9530 269-764-2000 Mandy K. Halte r D irec t or , Nuclear Licensing

SUBJECT:

License Amendment Request to Revise Emergency Diesel Generator Degraded Voltage Surveillance Requirement Pa l isades Nuclear Plant Docket 50-255 Renewed Facility Operating License No. DPR-20

REFERENCE:

NRC inspection report , Palisades Nuclear Plant Component Design Bases Inspection 05000255/2014008 , dated December 2 , 2014 (ADAMS Accession Number ML 14338A848).

Dear Sir or Madam:

Pursuant to Title 10 of the Code of Federal Regulations , Part 50 , Section 90 (10 CFR 50.90), Application for amendment of license , construction permit , or early site permit , Entergy Nuclear Operations , Inc. (ENO) hereby requests an amendment to the Renewed Facility Operating License (RFOL) for the Palisades Nuclear Plant (PNP). ENO requests that RFOL Technical Specification (TS) 3.3.5 , Diesel Generator (DG) -Undervoltage Start (UV Start), Surveillance Requ i rement (SR) 3.3.5.2a be revised by the addition of a channel calibration requirement for the combined time delay setpoints for the degraded voltage sensing relay and the degraded voltage time delay relay. Upon approval , this change would correct a non-conservative TS SR documented in the reference. The proposed changes have been evaluated in accordance with 10 CFR 50.91 (a), Notice for public comment , subparagraph (1 ), using the standards in 10 CFR 50.92 , Issuance of amendment , paragraph (c), and it has been determined that the changes involve no significant haza r ds consideration.

The basis for this determinat i on is included in Attachment 1 . ENO requests approval of the proposed license amendment by May 30, 2019, with the amendment being implemented within 60 days. D l fDN.tf-PNP 2018-010 Page 2 of 2 Attachment 1 provides a detailed description and evaluation of the proposed change. Attachment 2 con t a i ns the proposed RFOL page changes (markup). Attachment 3 conta i ns the proposed revised RFOL pages. Attachment 4 contains ma r ked up TS Bases pages that reflect the proposed changes, and is provided for information only. Attachments 5, 6, 7, and 8 provide supporting calculations.

In accordance w i th 10 CFR 50.91 (b), State consultation, ENO is notifying the State of Michigan of this proposed license amendment by transmitting a copy of this letter to the designated State official.

This submittal contains no proprietary information.

This letter identifies no new regulatory commitments and no revisions to existing regulatory commitments.

I declare under penalty of perjury that the foregoing is true and correct. Executed on May 30 , 2018. Sincerely , ," fl?a-;fl/./UQ MKH/jse Attachments

1. Description and Evaluation of Proposed Operating License Change 2. Proposed Palisades Nuclear Plant Renewed Facil i ty Operating License Page Changes (markup) 3. Renewed Facility Operating License Page Change Instructions and Revised Palisades Nuclear Plant Renewed Facility Operating License Pages 4. Markup of Technical Specification Bases Pages (for information only) 5. Second Level UndeNoltage Relay Setpoint Calculation
6. Second Level UndeNoltage Time Delay Relays 162-153 and 162-154 Uncertainty Analysis 7. Palisades SLUR Time Delay Calculation
8. LOCA With Offsite Power Available Calculation cc: Administrator, Region Ill, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades , USNRC State of Michigan PNP 2018-010 ATTACHMENT 1 Description and Evaluation of Proposed Operating License Change 13 pages follow ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE 1.0

SUMMARY

DESCRIPTION Pursuant to Title 10 of the Code of Federal Regulations, Part 50 , Section 90 (1 O CFR 50.90), Application for amendment of license, construction permit , or early site permit, Entergy Nuclear Operations , Inc. (ENO) hereby requests an amendment to the Renewed Facility Operating License (RFOL) for the Palisades Nuclear Plant (PNP). ENO requests that RFOL Technical Specification (TS) 3.3.5, Diesel Generator (DG) -Undervoltage Start (UV Start), Surveillance Requirement (SR) 3.3.5.2a be revised by the addition of a channel calibration requirement for the combined time delay setpoints for the degraded voltage sensing relay and the degraded voltage time delay relay. This TS SR currently requires calibration of the degraded voltage sensing relay time delay setpoint only. It does not include calibration of the combined setpoints for the degraded voltage sensing relay time delay and the nominal six-second delay for the time delay relay. This requested change would correct a non-conservative TS SR documented In Reference 1 . 2.0 DETAILED DESCRIPTION Description of Proposed Change TS SR 3.3.5.2a currently requires the following degraded voltage channel calibration of the setpoint values for the degraded voltage sensing relay time delay. Perform CHANNEL CAL/BRA TION on each Loss of Voltage and Degraded Voltage channel with setpoints as follows: a. Degraded Voltage Function~

2187 V and :5 2264 V Time delay:~ 0.5 seconds and :5 0.8 seconds; and In this proposed license amendment request (LAR), TS SR 3.3.5.2a would be revised by adding a degraded voltage channel calibration for the setpoints for the combined time delays for the degraded voltage sensing relay and the time delay relay, as follows: Perform CHANNEL CAL/BRA TION on each Loss of Voltage and Degraded Voltage channel with setpoints as follows: a. Degraded Voltage Function~

2187 V and :5 2264 V 1. Time delay (degraded voltage sensing relay):~ 0.5 seconds and :5 0.8 seconds; and 2. Time delay (degraded voltage sensing relay plus time delay relay):~ 6.2 seconds and :5 7. 1 seconds. 1 of 13 ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE The frequency of TS SR 3.3.5.2 is not affected by the proposed change. Also, the existing TS SR 3.3.5.2a is retained as TS SR 3.3.5.2a.1 and a description of the relay is added, but this TS SR is not otherwise affected by the proposed change. Reason for Proposed Change As documented in the inspection report in Reference 1, NRC inspectors identified a finding at PNP for the failure to ensure that the time delay setpoint for the degraded voltage monitor was included in TS SR 3.3.5.2a.

The inspection report states that TS SR 3.3.5.2 requires the site to "Perform a CHANNEL CALIBRATION on each Loss of Voltage and Degraded Voltage channel with setpoints

... :" and that, currently, SR 3.3.5.2a gives the degraded voltage function setpoint only for the time delay associated with the voltage sensing relay of the degraded voltage monitor. However, the report notes that a channel of the degraded voltage monitor contains both a voltage sensing relay and a nominal six-second delay due to a time delay relay which has to time out before the trip relay actuates and the offsite power supply breaker is opened. The time delay associated with the degraded voltage monitor voltage sensing relay described in the inspection report refers to the built-in (internal) nominal 0.65-second time delay in the second level undervoltage relays (SLURs) (PNP equipment numbers 127-7 and 127-8). The nominal six-second delay timer described in the inspection report refers to the nominal six-second delay in the external time delay relays (PNP equipment numbers 162-153 and 162-154).

As noted in the inspection report, the finding was entered into the ENO corrective action program, and ENO determined the degraded voltage channels were operable , but degraded or non-conforming, based on review of the calibration of the time delays performed within TS surveillance test procedures.

TS SR 3.3.5.2a requires a delay setpoint of greater than or equal to 0.5 seconds and less than or equal to 0.8 seconds for the degraded voltage sensing relays on each channel (also known as the SLURs). As noted above, this SR does not include the delay setpoint of nominally six seconds for the time delay relay on each channel. Since TS SR 3.3.5.2a does not include the six-second time delay relays, it does not ensure that the relays would avoid spurious trips of offsite power sources , ensure that the relays do not exceed the time limits of engineering safeguards actuation assumed in the safety analyses, or ensure that safety related equipment will be available following sustained degraded voltage conditions.

Therefore , TS SR 3.3.5.2a is deemed non-conservative.

The non-conservative TS SR 3.3.5.2a was dispositioned as a degraded or non-conforming condition within the PNP corrective action system in accordance with the provisions of NRC Administrative Letter (AL) 98-10, Dispositioning of Technical 2 of 13 ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE Spec i f i cat i ons tha t are Insufficient to Assure Plant Safety , to assure that plant safety is maintained.

This LAR is submitted in accordance with the g ui dance i n AL 98-10 as a corrective action to resolve the non-conservative TS. As an immediate action to address the condition , ENO revised TS Surveillance Procedures RE-137 , Calibration of Bus 1C Undervoltage and Time Delay Relays , and RE-138 , Calibration of Bus 1 D Undervoltage and Time Delay Relays , to add acceptance criteria to ensure that the sum total of the time delays for the degraded voltage sensing relay and the time delay relays are within the proposed TS SR time delay setpoints.

3.0 TECHNICAL EVALUATION System Description The two safety related 2400 V buses (1 C and 10) are each equipped with two levels of undervoltage relay protection

a f i rst level undervoltage relay (FLUR) for loss of voltage conditions , and a SLUR degraded voltage sensing relay with an additional time delay relay for degraded voltage conditions. Upon sensing a sudden loss of voltage , actuation of the FLURs will trip their respective incoming bus circuit breakers , and start their respective emergency diesel generator (EOG), initiate bus load shed, and transfer the safety related buses to their respective EOG. Upon sensing a degraded voltage condition , there are two time delays that occur: a bui l t-in nominal 0.65-second delay within the SLURs and a nominal six-second delay due to the time delay relays. Each SLUR is set at approximately 92% of rated voltage , with one voltage mon i toring relay for each of the three phases. These relays protect against sustained degraded voltage conditions on the corresponding bus using a three-out-of-three coincidence logic. The EOGs provide backup power to the 2400 V safety related buses in the event of a loss of off-site power or a loss of power to the associated 2400 V bus. If a 2400 V bus experiences an undervoltage condition , the SLUR initiates start of its associated EOG after a nom i nal 0.65-second time delay. If the bus undervoltage exists after the additional , nom i nal six-second t i me delay , the associated bus incoming circuit breakers from offsite power sources are tripped , and a bus load shed is initiated.

When EOG output voltage is appropriate, the safety related bus is then transferred to its EOG and the required load breakers are closed onto the bus in a sequential manner. Following a loss of offsite power , each EOG must be capable of starting and connecting to its respective 2400 V bus, within 10 seconds after receipt of an EOG start signal. Each EOG must also be capable of accepting required loads within the assumed 3 of 13 ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE loading sequence intervals, and continue to operate until offsite power can be restored to the 2400 V safety related buses. Determination of Combined Time Delays for SLURs and Time Delay Relays This LAR proposes adding a requirement to TS SR 3.3.5.2a for degraded voltage channel calibration of the combined time delay setpoints for the SLURs and the time delay relays. The proposed minimum and maximum setpoints for the combined time delays were determined as described below. The setpoints for the SLUR time delays in the existing TS SR 3.3.5.2a are based on a nominal setpoint of 0.65 seconds. Attachment 5 , Second Level Undervoltage Relay Setpoint Calculation , determined a SLUR time delay setpoint total error of plus or minus 0.0809 seconds. The delay for the time delay relays is nominally six seconds. The maximum calculated total errors associated with these time delay relays are +0.258 seconds and -0.216 seconds , as calculated in Attachment 6, Second Level Undervoltage Time Delay Relays 162-153 and 162-154 Uncertainty Analysis.

Adding together the time delay setpoint for the SLUR, with its total errors , and the time delay relay setpoint, with its total errors, yields the following minimum and maximum setpoints:

Minimum setpoint:

(0.65 sec -0.0809 sec) + (6 sec -0.216 sec)= 6.3531 sec Maximum setpoint:

(0.65 sec+ 0.0809 sec) + (6 sec+ 0.258 sec) = 6.9889 sec In order to bound these delay time setpoints, the delay time setpoints for the proposed TS SR 3.3.5.2a.2 are chosen to be greater than or equal to 6.2 seconds and less than or equal to 7.1 seconds. The Figure 1 schematic depicts the time delay setpoints.

The proposed combined minimum time delay 6.2-second setpoint is long enough to override any short term voltage disturbances, such as by the start of motors. The evaluation of load flow and dynamic motor starts in Attachment 8 , LOCA With Offsite Power Available Calculation, indicates that voltages on the safety related 1 C and 1 D 2400 V buses under various postulated accident scenarios will recover to a value above the SLUR voltage trip setpoint in 5.817 seconds or less. The 6.2-second setpoint provides margin with respect to the worst-case voltage recovery time. Table 1 below summarizes the results of the Attachment 8 calculation.

The appendices in the Attachment 8 calculation contain transient voltage plots that depict the recovery of bus voltage under the postulated accident scenarios.

4 of 13 ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE Table 1 Summary Results of Attachment 8, LOCA With Offsite Power Available Calculation (Acronyms defined in Attachment 8.) Calculation Bus 1C SLUR Bus 1D SLUR SLUR Reset Section Scenario Reset Time Reset Time < 6.2 sec (sec) (sec) (V, N, N/A) 8.1.2 Scenario A2-1 D , EGGS and MOV Motor 3.290 3.500 y Starting , (Transient)

Load Shed Complete 8.1.3 Scenario A4-1 D , EGGS Motors Running with SLURs do not SLURs do not N/A Bus 1 E Re-Energized drop-out drop-out 8.1.4 Scenario A4.1-1 D , EGGS Motors Running , Bus SLURs do not SLURs do not N/A 1 E Energized , L TC On , CS Start drop-out drop-out 8.2.2 Scenario 82-1 D , EGGS and MOV Motor 4.24 5.08 y Starting , (Transient)

Load Shed Complete 8.2.3 Scenario 84-1 D , EGGS Motors Running with SLURs do not SLURs do not N/A Bus 1 E Re-Energized drop-out drop-out 8.2.4 Scenario 84.1-1 D, EGGS Motors Running, Bus SLURs do not SLURs do not N/A 1 E Energized , L TC On, CS Start drop-out drop-out 8.2.5 Scenario 82.1-1 D, ECCS Motor Start , Delayed 5.562 5.657 y P54NB Start Concurrent w/ S LUR Reset 8.3.2 Scenario A2-1 C , EGGS and MOV Motor 3.333 3.389 y Starting , (Transient)

Load Shed Complete 8.3.3 Scenario A4-1 C , EGGS Motors Running with SLURs do not SLURs do not N/A Bus 1 E Re-Energized drop-out drop-out 8.3.4 Scenario A4.1-1 C , EGGS Motors Running , Bus SLURs do not SLURs do not N/A 1 E Energized , L TC Off drop-out drop-out 8.4.2 Scenario 82-1 C, EGGS and MOV Motor 4.597 4.659 y Starting , (Transient)

Load Shed Complete 8.4.3 Scenario 84-1 C , EGGS Motors Running with SLURs do not SLURs do not N/A Bus 1 E Re-Ene rgized drop-out drop-out 8.4.4 Scenario 84.1-1 C , EGGS Motors Running , Bus SLURs do not SLURs do not N/A 1 E Energized , L TC Off drop-out drop-out 8.4.5 Scenario 82.1-1 C , EGGS Motor Start , Delayed 5.582 5.603 y P54NB Start Concurrent w/ SLUR Reset 8.5.1.2 Scenario SU-1 C-82, EGGS and MOV Motor Bounded by the analysis completed for the normal Starting , (Transient)

Load Shed Complete configuration.

See Section 8.5.1 .2. 8.5.2.2 Scenario SU-1 D-82, EGGS and MOV Motor Bus 1 C recovered but bus 1 D did not. Addition al Starting , (Transient) Load Shed Complete cases were run for bus 1 D with higher voltages. Evaluated further in Section 8.5.3.2. 8.5.3.2 Scenario SU-1 D-2355-82 , EGGS and MOV Bus 1 C recovered but bus 1 D did not. Motor Starting , (Transient)

Load Shed Bounded by a more restrictive scenario. Complete See S ection 8.5.5.2 and Engineering Change 77648 (markup of EA-ELEC-EDSA-03 in Attachment 8). 5 of 13 8.5.4.2 8.5.4.3 8.5.4.4 8.5.4.5 8.5.5.2 8.5.5.3 8.5.5.4 8.5.5.5 ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE Split Bus Scenario SU-CD-1 C-B2 , ECCS and 4.920 4.968 MOV Motor Starting , (Transient)

Load Shed Complete Split Bus Scenario SU-CD-1 C-B4 , ECCS SLURs do not SLURs do not Motors Running with Bus 1 E Re-Energized drop-out drop-out Split Bus Scenario SU-CD-1 C-B4.1 , ECCS 2.96 2.97 Motors Runn ing, Bus 1 E Energized , L TC OFF , CS Start Split Bus Scenario SU-CD-1 C-B2.1 , ECCS 5.606 5.632 Motor Start , Delayed P54NB Start Concurrent w/ SLUR Reset Split Bus Scenario SU-C D-1 D-B2 , ECCS and 4.008 4.356 MOV Motor Starting , (Transient)

Load Shed Complete Spl i t Bus Scenario SU-CD-1 D-B4 , ECCS SLURs do not SLURs do not Motors Running with Bus 1 E Re-Energized drop-out drop-out Split Bus Scenario SU-CD-1 D-B4.1 , ECCS 2.60 2.83 Motors Running , Bus 1 E Energized , L TC OFF , CS Start Split Bus Scenario SU-CD-1 D-B2.1 , ECCS 5.669 5.8 17 Motor Start , Delayed P54NB Start Concurrent w/ SLUR Reset y N/A y y y N/A y y The proposed maximum combined time delay 7.1-second setpoint is within the time delays assumed in the PNP Final Safety Analysis Report accident analyses for engineered safeguards actuation.

Upon a loss of offsite power , the accident analyses assume that an E OG starts and connects to it s bus in 10 seconds. The proposed maximum combined time delay setpoint of 7.1 seconds is reached before the assumed EOG starting and connection time of 10 seconds. Therefore , the proposed maximum setpoint is within the time delays assumed in the accident analyses.

The combined delay time is also short enough to not result in failure of safety related equipment due to operation under sustained degraded voltage conditions.

A primary concern is that , when a motor is subjected to degraded voltage conditions , it is possible that the terminal voltage of that motor will be low enough for the motor to stall , thereby drawing currents near locked rotor values. Under these conditions, the motor will continue to draw thi s high current for up to the total time delay, which could cause the upstream protective device for that motor to trip. If the motor protective device trips , then the motor may be unavailable when loads are transferred to the EOG. The analysis provid e d in Attachm e nt 7, Palisades SLUR Tim e Delay Calculation, determined a bounding, maximum acceptable combined time delay for the degraded voltage function, using conservative assumptions, which will allow safety-related loads to perform their safety function during sustained undervoltage conditions for the safety relat e d 2400 V bus e s. 6 of 13 ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE The methodology used in the analysis is consistent with the guidance provided in Regulatory Issue Summary (RIS) 2011-12 (Reference 2). The analysis determined that all safety-related 2400 V motors can perform their safety function under a sustained degraded voltage condition with a combined time delay of at least 7.5 seconds, with the following exceptions:

  • Containment spray pump P-54A can support a total SLUR time delay of 7.2 seconds. Since the motors used for P-54A and P-54B are equivalent, the overcurrent relay setting of P-54B was subsequently raised to match the existing setting of P-54A to allow P-54B to support a total time delay of 7.2 seconds. This is acceptable as it is greater than the upper delay time setpoint of 7.1 seconds in the proposed TS SR 3.3.5.2a.2. With regard to auxiliary feedwater pump P-8A , if the total time delay is greater than seven seconds, the overcurrent relay of the P-8A motor breaker could potentially trip. However, the pump would not sequence on to the bus until 45 seconds into the transient, and the breaker relay reset time is only nine seconds. This means that the overcurrent relay will have reset prior to P-8A being powered from its safety related bus and associated EOG. The analysis also determined that all safety-related 480V loads can perform their safety functions under a sustained degraded grid voltage condition for a total time delay of at least 7.4 seconds with the exception of the containment cooler recirculation fans V-1A and V-3A, which can only support a total time delay of 2.1 seconds. The analysis stated that the overcurrent trip relays for the containment cooler recirculation fans have a nominal setting of 20 seconds with an allowable tolerance band of 7 seconds to 35 seconds. The minimum allowable tolerance of 7 seconds results in a total time delay of 2.1 seconds, due to the containment cooler recirculation fan overcurrent relays actuating in 2.1 seconds under sustained degraded grid voltage conditions.

Raising the minimum allowable tolerance of these overcurrent relays to 15 seconds would result in a total time delay of 7.6 seconds for the containment cooler recirculation fans (i.e., the fan overcurrent relays would actuate in 7.6 seconds under sustained degraded grid voltage conditions). A review of previous surveillance tests on these relays shows that a minimum tolerance of 15 seconds provides sufficient margin to previous as-found values , so raising the minimum allowable tolerance from 7 seconds to 15 seconds could be achieved by tightening the setpoint acceptance criteria without changing the actual calibration setting of the protective device. As recommended in the analysis, the 7 of 13

-A TTA CHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE allowa ble minimum tolerance fo r the containment cooler recirculat i on fans V-1A and ove r current trip relays was subsequently raised from 7 seconds to 15 seconds by ning the setpoint calibration acceptance criteria.

The change in acceptance V-3A tighte criteri a allows the containment cooler recirculation fans to support a total time delay of conds. 7.6 se The a nalysis also determined that the Class 1 E distribution breakers will allow for a total elay up to 9.8 seconds, and all Class 1 E fuses evaluated will allow for a total time up to 10 seconds. timed delay Figure 1 below depicts the time delay setpoints associated with the SLURs and time relays , the proposed TS SR , the maximum allowed degraded voltage time , and aximum bus voltage recovery time. delay them Figure 1 Schematic Depiction of Time Delay Setpoints Max i mum allowed degraded voltage time before ton safety related equipment=

7.2 sec impac Proposed TS upper value= 7.1 sec Ca l culated setpo i nt upper limit: 6.65+0.3389 = 6.9889 sec Exist i ng SLUR plus time delay relay setooint:

6+0.65 = 6.65 sec Calculated setpoint lower lim i t: 6.65-0.2969

= 6.3531 sec Proposed TS lower value = 6.2 sec Max i mum bus voltage recovery time dur i ng LOCA with offsite power per Table 1 = 5.817 sec 8 of 13 /\ Total max i mum positive time delay error: 0.258+0.0809

= 0.3389 sec , 1; , I\ Tot a l m a ximum negative t i me delay error: 0.216+0.0809

= 0.2969 sec '1 1 ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The changes described in the LAR comply with the following regulations and continue to meet the intent of the applicable General Design Criteria.

10 CFR Part 50.36 , Technical specifications, requires in subparagraph (c)(2)(ii)(C), Criterion 3 , that a technical specification limiting condition for operation be established for a structure , system , or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product bar r ier. 10 CFR 50.36(c)(2)(ii)(C), Criterion 3 , is satisfied by TS 3.3.5 , Diesel Generator (DG) -Undervoltage Start (UV Start). 10 CFR Part 50.36 also requires in subparagraph 50.36(c)(3), Surveillance requirements , that technical specifications include surveillance requirements relating to test , calibration , or inspection to assure that the necessary quality of systems and components is maintained , that facility operation will be within safety limits , and that the limiting conditions for operation will be met. With the proposed change , the PNP TS would continue to include surveillance requirements related to EOG test i ng to assure the components are maintained , fac i lity operation will be within safety limits , and the limiting conditions for DG operation will be met. 10 CFR 50 , Appendix A , General Design Criterion (GDC) 17 , Electric power systems , ensures an onsite electric power system is provided to permit functioning of structures , systems , and components important to safety. The design of the alternating current electrical power system shall provide independence , redundancy, and testability to ensure an available source of power to the engineered safety features systems. GDC 18 , Inspection and testing of electric power systems , ensures electric power systems important to safety are designed to permit appropriate periodic inspection and testing of important areas and features.

The a l ternating current electrical systems shall be designed to permit testing and inspection of the operability and functional performance of the components of the system as well as the operab i lity of the system as a whole. Per GDCs 17 and 18 , with the proposed change , the technical specifications would continue to contain surveillance requirements for EOG testing to assure that the components are maintained , facility operation will be within safety limits , and the limiting conditions for EOG operation will be met. 9 of 13 ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE Based on the review of the above requirements, ENO has determined that the proposed change does not require any exemptions or relief from regulatory requirements , other than revising the TS as described, and does not affect conformance with any of the above noted regulatory requirements or criteria.

4.2 Precedent No identical precedent is identified.

4.3 No Significant Hazards Consideration Determination Pursuant to Title 10 of the Code of Federal Regulations, Part 50, Section 90 (10 CFR 50.90), Application for amendment of license, construction permit, or early site permit, Entergy Nuclear Operations, Inc. (ENO) requests an amendment to the Renewed Facility Operating License (RFOL) for the Palisades Nuclear Plant (PNP). The amendment would revise RFOL Technical Specification (TS) 3.3.5, Diesel Generator (DG) -Undervoltage Start (UV Start), Surveillance Requirement (SR) 3.3.5.2a, for the degraded voltage function time delay setpoints by the addition of a channel calibration requirement for the combined time delay setpoints for the degraded voltage sensing relay and the degraded voltage time delay relay. This TS SR channel calibration currently includes the degraded voltage sensing relay time delay setpoint but not the combined sum of the degraded voltage sensing relay time delay setpoint and the time delay relay setpoint.

Pursuant to 10 CFR 50.92, Issuance of amendment, ENO has reviewed the proposed changes and concludes that the changes do not involve a significant hazards consideration since the proposed changes satisfy the standards in 10 CFR 50.92(c). These criteria require that operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. The discussion below addresses each of the no significant hazards criteria and demonstrates that the proposed amendment does not constitute a significant hazard. 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response:

No. The proposed amendment would revise a TS SR to include, for each degraded voltage channel, calibration of the time delay setpoint for the degraded voltage sensing relay in combination with the setpoint for the time delay relay. The minimum time delay setpoint in the revised TS SR would be long enough to override any brief voltage disturbances.

The maximum time delay setpoint in the revised TS SR would be short enough to not exceed the maximum time delays assumed in the PNP Final 1 O of 13 ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE Safety Analysis Report accident analyses for the operation of safety related equipment and to not result in failure of safety related equ i pment due to sustained degraded voltage conditions.

Therefore, safety related loads would be available to perform their required safety functions under these conditions.

The proposed change does not adversely affect accident initiators or precursors , and does not affect the design assumptions, conditions , or configuration of the plant , or the manner in which the plant is operated or maintained.

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

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

Response:

No. The proposed amendment would revise a TS SR to include, for each degraded voltage channel , calibration of the time delay setpoint for the degraded voltage sensing relay in combination with the time delay setpoint for the time delay relay. The conduct of surveillance tests on safety related plant equipment is a means of assuring that the equipment is capable of performing its functions that are credited in the safety analyses for the facility.

The proposed amendment would not affect the operation of safety related equipment assumed in accident analyses , and would not create any new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases. Therefore , the possibility of a new or different kind of accident from any previously evaluated has not been created. 3. Does the proposed amendment involve a significant reduction in a margin of safety? Response:

No. The proposed amendment would revise a TS SR to include , for each degraded voltage channel , calibration of the time delay setpoint for the degraded voltage sensing relay in combination with the time delay setpoint for the time delay relay. The conduct of surveillance tests on safety related plant equipment is a means of assuring that the equipment is capable of maintaining the margin of safety established in the safety analyses for the facility.

The proposed amendment would not introduce changes to limits established in the accident analyses. The minimum time delay setpoint in the revised TS SR would be long enough to override any brief voltage disturbances.

The maximum time delay setpoint in the revised TS SR would be short enough to not exceed the maximum time delays assumed in the PNP Final Safety Analysis Report accident analyses for the operation of safety related 11 of 13 ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE equipment and to not result in failure of safety related equipment due to sustained degraded voltage conditions.

Therefore, the proposed amendment does not involve a significant reduction in a margin of safety. Based on the above , ENO concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly , a finding of " no significant hazards consideration" is justified.

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner , (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. 5.0 ENVIRONMENTAL CONSIDERATION This amendment request meets the eligibility criteria for categorical exclusion from environmental review set forth in 10 CFR 51 , Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions , Preliminary Procedures , Classification of Licensing and Regulatory Actions; Section 51.22, Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review, subparagraph (c)(9), as follows: (i) The amendment involves no significant hazards consideration.

As described in Section 4.3 of this evaluation, the proposed change involves no significant hazards consideration. (ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite. The proposed amendment does not involve any physical alterations to the facility configuration that could lead to a change in the type or amount of effluent released offsite. (iii) There is no significant increase in individual or cumulative occupational radiation exposure.

12 of 13 ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE The proposed amendment does not involve a significant increase in individual or cumulative occupational radiation exposure.

Based on the above, ENO concludes that the proposed change meets the eligibility criteria for categorical exclusion as set forth in 10 CFR 51.22(c)(9). Therefore , pursuant to 10 CFR 51.22(b), no environmental assessment or environmental impact statement need be prepared in connection with the issuance of this amendment.

6.0 REFERENCES

1. NRC inspection report, Palisades Nuclear Plant Component Design Bases Inspection 05000255/2014008 , dated December 2 , 2014 (ADAMS Accession Number ML 14338A848).
2. NRC Regulatory Issue Summary 2011-12 , Revision 1 , Adequacy of Station Electric Distribution System Voltages, December 29, 2011 (ADAMS Accession Number ML 113050583).

13 of 13 PNP 2018-010 ATTACHMENT 2 Proposed Palisades Nuclear Plant Renewed Facility Operating License Page Changes (markup) (showing proposed changes; additions are highlighted and deletions are strikethrough)

Two pages follow (1) Pursuant to Section 104b of the Act , as amended , and 1 O CFR Part 50 , " Licensing of Production and Utilization Facilities

," (a) ENP to possess and use , and (b) ENO to possess , use and operate , the facility as a utilization facility at the designated location in Van Buren County , Michigan , in accordance with the procedures and limitation set forth in this license; (2) ENO , pursuant to the Act and 1 O CFR Parts 40 and 70 , to rece i ve , possess , and use source and special nuclear material as reactor fuel , i n accordance with the limitations for storage and amounts required for reactor operation , as described in the Updated Final Safety Analysis Report , as supplemented and amended; (3) ENO , pursuant to the Act and 1 O CFR Parts 30 , 40 , and 70 , to receive , possess , and use byproduct , source , and special nuclear material as sealed sources for reactor startup , reactor instrumentation , radiation monitoring equipment calibrat i on , and fission detectors in amounts as required; (4) ENO , pursuant to the Act and 10 CFR Parts 30 , 40 , and 70 , to receive , possess , and use in amounts as required any byproduct , source , or special nuclear material for sample analysis or instrument calibration , or associated with radioactive apparatus or components

and (5) ENO , pursuant to the Act and 1 O CFR Parts 30 , 40 , and 70 , to possess , but not separate , such byproduct and special nuclear materials as may be produced by the operations of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission

's regulations in 1 O CFR Chapter I and is subject to all applicable provisions of the Act; to the rules , regulations , and orders of the Commission now or hereafter in effect; and is subject to the addit i onal conditions specified or incorporated below: (1) ENO is authorized to operate the facility at steady-state reactor core power levels not in excess of 2565.4 Megawatts thermal (100 percent rated power) in accordance with the conditions specified herein. (2) The Technical Specifications contained in Appendix A , as revised through Amendment No. xxx , and the Environmental Protection Plan contained in Appendix B are hereby incorporated in the license. ENO shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. (3) Fire Protection ENO shall implement and maintain in effect all provisions of the approved fire protection program that comply with 1 O CFR 50.48(a) and 1 O CFR 50.48(c), as spec i fied in the license amendment request dated December 12 , 2012 and November 1 , 2017 , as supplemented by letters dated February 21 , 2013 , September 30 , 2013 , October 24 , 2013 , December 2 , 2013 , April 2 , 2014 , May 7 , Renewed License No. DPR-20 Amendment No. ~. 265 SURVEILLANCE REQUIREMENTS SR 3.3.5.2 SURVEILLANCE Perform CHANNEL CALIBRATION on each Loss of Voltage and Degraded Voltage channel with setpoints as follows: a. Degraded Voltage Function 2187 V and ::; 2264 V 1. Time delay (degraded voltage sensing relay): 0.5 seconds and ::; 0.8 seconds;and

2. Time delay (degraded voltage sensing relay plus time delay relay): 6.2 seconds and::; 7.1 seconds; and b. Loss of Voltage Function 1780 V and ::; 1940 V Time delay:~ 5.45 seconds and ::; 8.15 seconds at 1400 V. Palisades Nuclear Plant 3.3.5-2 DG -UV Start 3.3.5 FREQUENCY 18 months Amendment No. 189 PNP 2018-010 ATTACHMENT 3 Renewed Facility Operating License Page Change Instructions and Revised Palisades Nuclear Plant Renewed Facility Operating License Pages Th r ee pages follow Page Change Instructions ATTACHMENT TO LICENSE AMENDMENT NO. 2XX RENEWED FACILITY OPERATING LICENSE NO. DPR-20 DOCKET NO. 50-255 Remove the following pages of the Renewed Facility Operating License and Appendix A , Technical Specification , and replace them with the attached revised pages. The revised page is identified by amendment number and contains a line in the margin indicating the area of change. Renewed Facility Operating License pages: REMOVE Page 3 Appendix A , Technical Specification pages: REMOVE Page 3.3.5-2 INSERT Page 3 INSERT Page 3.3.5-2 (1) Pursuant to Section 104b of the Act , as amended , and 1 O CFR Part 50 , " Licensing of Production and Utilizat i on Facilities

," (a) ENP to possess and use , and (b) ENO to possess , use and operate , the facility as a utilization facility at the designated location in Van Buren County , Michigan , in accordance with the procedures and limitation set forth in this license; (2) ENO , pursuant to the Act and 1 O CFR Parts 40 and 70 , to receive , possess , and use source and special nuclear material as reactor fuel , in accordance with the limitations for storage and amounts required for reactor operation , as described i n the Updated Final Safety Analysis Report, as supplemented and amended; (3) ENO , pursuant to the Act and 10 CFR Parts 30 , 40 , and 70 , to receive , possess , and use byproduct , source , and special nuclear material as sealed sources for reactor startup , reactor instrumentation , radiation monitoring equipment cal i bration , and fission detectors in amounts as required; (4) ENO , pursuant to the Act and 10 CFR Parts 30 , 40 , and 70 , to receive , possess , and use in amounts as required any byproduct , source , or special nuclear mater i al for sample analysis or instrument calibration , or associated with radioactive apparatus or components

and (5) ENO , pursuant to the Act and 1 O CFR Parts 30 , 40 , and 70 , to possess , but not separate , such byproduct and special nuclear materials as may be produced by the operations of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission

's regulations in 1 O CFR Chapter I and is subject to all applicable provisions of the Act; to the rules , regulations , and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below: (1) ENO is authorized to operate the facility at steady-state reactor core power levels not in excess of 2565.4 Megawatts thermal (100 percent rated power) in accordance with the conditions specified herein. (2) The Technical Specifications contained in Appendix A , as revised through Amendment No. xxx , and the Environmental Protection Plan contained in Appendix B are hereby incorporated in the license. ENO shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. (3) Fire Protection ENO shall implement and maintain in effect all provis i ons of the approved fire protection program that comply with 1 O CFR 50.48(a) and 1 O CFR 50.48(c), as specified in the license amendment request dated December 12 , 2012 and November 1 , 2017 , as supplemented by letters dated February 21 , 2013 , September 30 , 2013 , October 24 , 2013 , December 2 , 2013, April 2 , 2014, May 7 , Renewed License No. DPR-20 Amendment No. 2-ea, xxx SURVEILLANCE REQUIREMENTS SR 3.3.5.2 SURVEILLANCE Perform CHANNEL CALIBRATION on each Loss of Voltage and Degraded Voltage channel with setpoints as follows: a. Degraded Voltage Function :::: 2187 V and ::; 2264 V 1. Time delay (degraded voltage sensing relay): :::: 0.5 seconds and::; 0.8 seconds; and 2. Time delay (degraded voltage sensing relay plus time delay relay): :::: 6.2 seconds and::; 7.1 seconds; and b. Loss of Voltage Function :::: 1780 V and ::; 1940 V Time delay: :::: 5.45 seconds and ::; 8.15 seconds at 1400 V. DG -UV Start 3.3.5 FREQUENCY 18 months Palisades Nuclear Plant 3.3.5-2 Amendment No. 4--00 , xxx PNP 2018-010 ATTACHMENT 4 Markup of Technical Specification Bases Pages (for information only) (additions are highlighted and deletions are strikethrough)

Six pages follow DG -UV Start B 3.3.5 B 3.3 INSTRUMENTATION B 3.3.5 Diesel Generator (DG) -Undervoltage Start (UV Start) BASES BACKGROUND Palisades Nuclear Plant The DGs provide a source of emergency power when offsite power is either unavailable or insufficiently stable to allow safe plant operation.

Undervoltage protection will generate a UV Start in the event a Loss of Voltage or Degraded Voltage condition occurs. There are two UV Start Functions for each 2.4 kV vital bus. Undervoltage protection and load shedding features for safety-related buses at the 2,400 V and lower voltage levels are designed in accordance with 10 CFR 50 , Appendix A , General Des i gn Criterion 17 (Ref. 1) and the following features: 1 . Two levels of automatic undervoltage protection from loss or degradation of offsite power sources are provided. The first level (loss of voltage) provides normal loss of voltage protection.

The second level of protection (degraded voltage) has voltage and time delay set points selected for automatic trip of the offsite sources to protect safety-related equipment from sustained degraded voltage conditions at all bus voltage levels. Coincidence logic is provided to preclude spurious trips. 2. The undervoltage protection system automatically prevents load shedding of the safety-related buses when the emergency generators are supplying power to the safeguards loads. 3. Control circuits for shedding of Class 1 E and non-Class 1 E loads during a Loss of Coolant Accident (LOCA) themselves are Class 1 E or are separated electrically from the Class 1 E portions. B 3.3.5-1 Revised 11/08/2017 BASES BACKGROUND (continued)

Palisades Nuclear Plant Description DG -UV Start B 3.3.5 Each 2,400 V Bus (1 C and 1 D) is equipped with two levels of undervoltage protection relays (Ref. 2). The first level (Loss of Voltage Function) relays 127-1 and 127-2 are set at approximately 77% of rated voltage with an inverse time relay. One of these relays measures voltage on each of the three phases. They protect against sudden loss of voltage as sensed on the corresponding bus using a three coincidence logic. The actuation of the associated auxiliary relays will trip the associated bus incoming circuit breakers , start its associated DG , initiate bus load shedding , and activate annunciators in the control room. The DG circuit breaker is closed automatically upon establishment of satisfactory voltage and frequency by the use of associated voltage sensing relay 1270-1 or 1270-2. The second level of undervoltage protection (Degraded Voltage Function) relays 127-7 and 127-8 are set at approximately 9J2% of rated voltage, with one relay monitoring each of the three phases. These voltage sensing relays protect against sustained degraded voltage conditions on the corresponding bus using a three-out-of-three coincidence logic. These relays have an internal (built-in) 0.65 second time delay , after which the associated DG receives a start signal and annunciators in the control room are actuated.

If a the bus undervoltage condition exists aftef for an additional six seconds (due to a six-second time delay relay), the associated bus incoming circuit breakers will be tripped and a bus load shed will be initiated. Trip Setpoints The trip setpoints are based on the analytical limits presented discussed in References 3 aAG 4 , and justified in Reference 5, 7, 9, and 10. The selection of these trip setpoints is such that adequate protection is provided when all sensor and processing time delays are taken into account. To allow for calibration tolerances , instrumentation uncertainties , and instrument drift , setpoints specified in SR 3.3.5.2 are conservatively adjusted with respect to the analytical limits. A detailed analysis of the degraded voltage protection is provided in References 3 and 4. The specified setpoints will ensure that the consequences of accidents will be acceptable , providing the plant is operated from within the LCOs at the onset of the accident and the equipment functions as designed.

B 3.3.5-2 Revised 11/08/2017 BASES APPLICABLE SAFETY ANALYSES LCO Palisades Nuclear Plant DG -UV Start B 3.3.5 The DG -UV Start i s required for Enginee r ed Safety Features (ESF) systems to function in any accident with a loss of offs i te power. Its design basis is that of the ESF Systems. Accident analyses credit the loading of the DG based on a loss of offsite power during a LOCA. The diesel load i ng has been included in the delay time associated with each safety system component requiring DG supplied power following a loss of offsite power. This delay time includes contributions from the DG start , DG loading , and Safety Injection System component actuation. The required channels of UV Start , in conjunction with the ESF systems powered from the DGs , provide plant protection in the event of any of the analyzed accidents discussed in Reference 6 , in which a loss of offsite power is assumed. UV Start channels are required to meet the redundancy and testability requirements of GDC 21 in 10 CFR 50 , Appendix A (Ref. 1 ). The delay times assumed in the safety analysis for the ESF equipment include the 1 O second DG start delay and the appropriate sequencing delay , if applicable. The response times for ESFAS actuated equipment include the app r opriate DG loading and sequencing delay. The DG -UV Start channels satisfy Criterion 3 of 1 O CFR 50.36(c)(2). The LCO for the DG -UV Start requires that three channels per bus of each UV Start instrumentation Function be OPERABLE when the associated DG is required to be OPERABLE. The UV Start supports safety systems associated with ESF actuation. The Bases for the trip setpoints are as follows: The voltage trip setpoint is set low enough such that spurious trips of the offsite source due to operation of the undervoltage relays are not expected for any combination of plant loads and normal grid voltages.

B 3.3.5-3 Revised 11/08/2017 BASES LCO ( continued)

APPLICABILITY ACTIONS Palisades Nuclear Plant DG -UV Start B 3.3.5 This setpoint at the 2 , 400 V bus and reflected down to the 480 V buses has been verified through an analysis to be greater than the minimum allowable motor voltage (90% of nominal voltage).

Motors are the most limiting equipment in the system. MCC contactor pickup and drop-out voltage is also adequate at the setpoint values. The analysis ensures that the distribution system is capable of starting and operating all safety-related equipment within the equipment voltage rating at the allowed source voltages.

The power distribution system model used in the analysis has been verified by actual testing (Refs. 5 and 7). The time delays involved will not cause any thermal damage as the setpoints are within voltage ranges for sustained operation.

They are long enough to preclude trip of the offsite source caused by the starting of large motors and yet do not exceed the time limits of ESF actuation assumed in FSAR Chapter 14 (Ref. 6) and validated by Reference

8. The time delays also will not result in failure of safety related equipment due to sustained degraded voltage conditions (Reference 9). Calibration of the undervoltage relays verify that the time delays are~ sufficient to avoid spurious trips. The DG -UV Start actuation Function is required to be OPERABLE whenever the associated DG is required to be OPERABLE per LCO 3.8.1 , " AC Sources -Operating ," or LCO 3.8.2 , " AC Sources -Shutdown ," so that it can perform its function on a loss of power or degraded power to the vital bus. A DG -UV Start channel is inoperable when it does not satisfy the OPERABILITY criteria for the channel's Function. In the event a channel's trip setpoint is found nonconservative with respect to the specified setpoint , or the channel is found inoperable , then all affected Functions provided by that channel must be declared inoperable and the LCO Condition entered. The required channels are specified on a per DG basis. B 3.3.5-4 Revised 11/08/2017 BASES ACTIONS ( continued)

SURVEILLANCE REQUIREMENTS Palisades Nuclear Plant A.1 DG -UV Start B 3.3.5 Condition A applies if one or more of the three phase UV sensors or relay logic is inoperable for one or more Functions (Degraded Voltage or Loss of Voltage) per DG bus. The affected DG must be declared inoperable and the appropriate Condition(s) entered. Because of the three-out-of-three logic in both the Loss of Voltage and Degraded Voltage Functions , the appropriate means of addressing channel failure is declaring the DG inoperable , and effecting repair in a manner consistent with other DG failures.

Required Action A.1 ensures that Required Actions for the affected DG inoperabilities are initiated. Depending upon plant MODE , the actions specified in LCO 3.8.1 or LCO 3.8.2 , as applicable , are required immediately.

SR 3.3.5.1 A CHANNEL FUNCTIONAL TEST is performed on each UV Start logic channel every 18 months to ensure that the logic channel will perform its intended function when needed. The Undervoltage sensing relays are tested by SR 3.3.5.2. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

The Frequency of 18 months is based on the plant conditions necessary to perform the test. B 3.3.5-5 Revised 11/08/2017 BASES SURVEILLANCE REQUIREMENTS (continued)

REFERENCES Palisades Nuclear Plant SR 3.3.5.2 DG -UV Start B 3.3.5 A CHANNEL CALIBRATION performed each 18 months verifies the accuracy of each component within the instrument channel. This includes calibration of the undervoltage relays and demonstrates that the equipment falls within the specified operating characteristics defined by the manufacturer.

The Surveillance verifies that the channel responds to a measured parameter within the necessary range and accuracy.

The Degraded Voltage Function time delay setpoints reflect the voltage sensing relay nominal 0.65-second time delay, and the voltage sensing relay nominal 0.65-second time delay combined with the nominal second delay due to the external time delay relay. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drift between successive calibrations to ensure that the channel remains operational between successive tests. CHANNEL CALIBRATIONS must be performed consistent with the setpoint analysis.

The Frequency of 18 months is a typical refueling cycle. Operating experience has shown this Frequency is acceptable.

1. 10 CFR 50 , Appendix A GDCs 17 and 21 2. FSAR , Section 8.6 3. Analysis EA-ELEC-VOL T-033 4. Analysis EA-ELEC-VOL T-034 5. Analysis EA-ELEC-EDSA-04
6. FSAR , Chapter 14 7. Analysis EA-ELEC-EDSA

-03 8. Analysis A-NL-92-111

9. Analysis 0098-0189-CALC-001-PLP
10. Analysis EA-EC11464-01 B 3.3.5-6 Revised 11/08/2017
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