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Category:Letter type:PNP
MONTHYEARPNP 2023-030, License Amendment Request to Revise Renewed Facility Operating License and Permanently Defueled Technical Specifications to Support Resumption of Power Operations2023-12-14014 December 2023 License Amendment Request to Revise Renewed Facility Operating License and Permanently Defueled Technical Specifications to Support Resumption of Power Operations PNP 2023-035, Withdrawal of License Amendment Request - Revise License Condition to Eliminate Cyber Security Plan Requirements2023-12-12012 December 2023 Withdrawal of License Amendment Request - Revise License Condition to Eliminate Cyber Security Plan Requirements PNP 2023-028, Application for Order Consenting to Transfer of Control of License and Approving Conforming License Amendments2023-12-0606 December 2023 Application for Order Consenting to Transfer of Control of License and Approving Conforming License Amendments PNP 2023-026, Pre-Submittal Meeting Presentation - Palisades Nuclear Plant License Transfer Application to Support Resumption of Power Operations2023-09-28028 September 2023 Pre-Submittal Meeting Presentation - Palisades Nuclear Plant License Transfer Application to Support Resumption of Power Operations PNP 2023-025, Request for Exemption from Certain Termination of License Requirements of 10 CFR 50.822023-09-28028 September 2023 Request for Exemption from Certain Termination of License Requirements of 10 CFR 50.82 PNP 2023-023, Special Report High Range Noble Gas Monitor Inoperable2023-08-0909 August 2023 Special Report High Range Noble Gas Monitor Inoperable PNP 2023-018, 2022 Annual Non-Radiological Environmental Operating Report2023-04-25025 April 2023 2022 Annual Non-Radiological Environmental Operating Report PNP 2023-007, and Big Rock Point, 2022 Annual Radioactive Effluent Release and Waste Disposal Reports2023-04-19019 April 2023 and Big Rock Point, 2022 Annual Radioactive Effluent Release and Waste Disposal Reports PNP 2023-008, 2022 Radiological Environmental Operating Report2023-04-18018 April 2023 2022 Radiological Environmental Operating Report PNP 2023-002, 6 to Updated Final Safety Analysis Report2023-03-31031 March 2023 6 to Updated Final Safety Analysis Report PNP 2023-006, Report of Changes to Security Plan, Revision 202023-03-29029 March 2023 Report of Changes to Security Plan, Revision 20 PNP 2023-012, Presentation on Regulatory Path to Reauthorize Power Operations2023-03-16016 March 2023 Presentation on Regulatory Path to Reauthorize Power Operations PNP 2023-001, Regulatory Path to Reauthorize Power Operations2023-03-13013 March 2023 Regulatory Path to Reauthorize Power Operations PNP 2023-004, Report of Changes to Palisades Nuclear Plant Technical Specification Bases2023-03-0808 March 2023 Report of Changes to Palisades Nuclear Plant Technical Specification Bases PNP 2023-005, Response to Palisades Nuclear Plant - Request for Additional Information Related to the Post-Shutdown Decommissioning Activities Report2023-03-0101 March 2023 Response to Palisades Nuclear Plant - Request for Additional Information Related to the Post-Shutdown Decommissioning Activities Report PNP 2022-037, Report of Changes to Security Plan, Revision 192022-12-14014 December 2022 Report of Changes to Security Plan, Revision 19 PNP 2022-036, Response to Request for Additional Information Regarding License Amendment Request for Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme2022-11-0808 November 2022 Response to Request for Additional Information Regarding License Amendment Request for Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme PNP 2022-035, International - Notification of Commitment Cancellations for Remaining Activities Related to Beyond-Design-Basis Seismic Hazard Reevaluations2022-11-0202 November 2022 International - Notification of Commitment Cancellations for Remaining Activities Related to Beyond-Design-Basis Seismic Hazard Reevaluations PNP 2022-026, Request for Exemption from 10 CFR 50.54(w)(1) Concerning Onsite Property Damage Insurance2022-10-26026 October 2022 Request for Exemption from 10 CFR 50.54(w)(1) Concerning Onsite Property Damage Insurance PNP 2022-024, Request for Exemption from 10 CFR 140.11(a)(4) Concerning Primary and Secondary Liability Insurance2022-10-26026 October 2022 Request for Exemption from 10 CFR 140.11(a)(4) Concerning Primary and Secondary Liability Insurance PNP 2022-031, License Amendment Request, Revise License Condition to Eliminate Cyber Security Plan Requirements2022-09-14014 September 2022 License Amendment Request, Revise License Condition to Eliminate Cyber Security Plan Requirements PNP 2022-025, Report of Changes to Palisades Nuclear Plant Security Plan, Revision 182022-09-12012 September 2022 Report of Changes to Palisades Nuclear Plant Security Plan, Revision 18 PNP 2022-032, 2022 Evacuation Time Estimate Report2022-09-0707 September 2022 2022 Evacuation Time Estimate Report PNP 2022-023, Report of Changes to Palisades Nuclear Plant Security Plan, Revision 172022-08-15015 August 2022 Report of Changes to Palisades Nuclear Plant Security Plan, Revision 17 PNP 2022-014, Report of Changes to Palisades Nuclear Plant Site Emergency Plan, Revision 342022-07-13013 July 2022 Report of Changes to Palisades Nuclear Plant Site Emergency Plan, Revision 34 PNP 2022-016, License Amendment Request: Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme2022-07-12012 July 2022 License Amendment Request: Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme PNP 2022-017, Request for Exemptions from Certain Emergency Planning Requirements of 10 CFR 50.47(b); 10 CFR 50.47(c)(2); and 10 CFR Part 50, Appendix E2022-07-11011 July 2022 Request for Exemptions from Certain Emergency Planning Requirements of 10 CFR 50.47(b); 10 CFR 50.47(c)(2); and 10 CFR Part 50, Appendix E PNP 2022-019, & Big Rock Point - Notification of Expected Date of Transfer of Ownership of Nuclear Plants to Holtec Palisades, LLC; and Notification of Receipt of All Required Regulatory Approvals2022-06-24024 June 2022 & Big Rock Point - Notification of Expected Date of Transfer of Ownership of Nuclear Plants to Holtec Palisades, LLC; and Notification of Receipt of All Required Regulatory Approvals PNP 2022-011, Termination of the Emergency Response Data System (Eros) Link2022-06-13013 June 2022 Termination of the Emergency Response Data System (Eros) Link PNP 2022-010, Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel2022-06-13013 June 2022 Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel PNP 2022-004, 2021 Radiological Environmental Operating Report2022-05-12012 May 2022 2021 Radiological Environmental Operating Report PNP 2022-003, and Big Pock Point Plant - 2021 Annual Radioactive Effluent Release and Waste Disposal Report2022-04-25025 April 2022 and Big Pock Point Plant - 2021 Annual Radioactive Effluent Release and Waste Disposal Report PNP 2022-007, 2021 Annual Non-Radiological Environmental Operating Report2022-04-21021 April 2022 2021 Annual Non-Radiological Environmental Operating Report PNP 2022-012, Response to Request for Additional Information Regarding License Amendment Request to Revise Facility Operating License and Technical Specifications for a Permanently Defueled Condition2022-04-21021 April 2022 Response to Request for Additional Information Regarding License Amendment Request to Revise Facility Operating License and Technical Specifications for a Permanently Defueled Condition PNP 2022-002, Annual Report of Changes in Emergency Core Cooling System Models2022-03-24024 March 2022 Annual Report of Changes in Emergency Core Cooling System Models PNP 2021-012, Report of Changes, Tests and Experiments, and Summary of Commitment Changes2021-10-0707 October 2021 Report of Changes, Tests and Experiments, and Summary of Commitment Changes PNP 2021-029, Pre-Notice of Disbursement from Decommissioning Trust2021-09-0202 September 2021 Pre-Notice of Disbursement from Decommissioning Trust PNP 2021-013, Request for Rescission of Interim Compensatory Measure from Order EA-02-0262021-07-21021 July 2021 Request for Rescission of Interim Compensatory Measure from Order EA-02-026 PNP 2021-020, Request for Partial Exemption from Record Retention Requirements in 10 CFR 50.122021-06-15015 June 2021 Request for Partial Exemption from Record Retention Requirements in 10 CFR 50.12 PNP 2021-005, License Amendment Request to Revise Renewed Facility Operating License and Technical Specifications for Permanently Defueled Condition2021-06-0101 June 2021 License Amendment Request to Revise Renewed Facility Operating License and Technical Specifications for Permanently Defueled Condition PNP 2021-026, Pre-Notice of Disbursement from Decommissioning Trust2021-05-27027 May 2021 Pre-Notice of Disbursement from Decommissioning Trust PNP 2021-016, 2020 Radiological Environmental Operating Report2021-05-12012 May 2021 2020 Radiological Environmental Operating Report PNP 2021-022, 2020 Annual Non-Radiological Environmental Operating Report2021-04-27027 April 2021 2020 Annual Non-Radiological Environmental Operating Report PNP 2021-015, and Big Rock Point, Submittal of 2020 Annual Radioactive Effluent Release and Waste Disposal Report2021-04-21021 April 2021 and Big Rock Point, Submittal of 2020 Annual Radioactive Effluent Release and Waste Disposal Report PNP 2021-017, Schedule Change to Open Phase Condition Detection Implementation2021-04-0101 April 2021 Schedule Change to Open Phase Condition Detection Implementation PNP 2021-003, 2020 Steam Generator Tube Inspection Report2021-03-25025 March 2021 2020 Steam Generator Tube Inspection Report PNP 2021-010, Annual Report of Changes in Emergency Core Cooling System Models2021-03-19019 March 2021 Annual Report of Changes in Emergency Core Cooling System Models PNP 2021-004, Report - Changes to Palisades Nuclear Plant Technical Specifications Bases2021-03-10010 March 2021 Report - Changes to Palisades Nuclear Plant Technical Specifications Bases PNP 2021-006, Pre-Notice of Disbursement from Decommissioning Trust2021-03-0808 March 2021 Pre-Notice of Disbursement from Decommissioning Trust PNP 2021-001, ASME Section XI 90-Day Owner'S Activity Report2021-01-12012 January 2021 ASME Section XI 90-Day Owner'S Activity Report 2023-09-28
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Entergy Nuclear Operations, Inc.
- En Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 Anthony J. Vitale Site Vice President PNP 2013-028 October 21, 2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Palisades Nuclear Plant 10 CFR 50 Appendix G Equivalent Margins Analysis Palisades Nuclear Plant Docket 50-255 License No. DPR-20
REFERENCES:
- 1. Palisades Nuclear Plant, Application for Renewed Operating License, dated March 22, 2005 (ADAMS Accession No. ML050940446)
- 2. Palisades Nuclear Plant, License Amendment Request for Primary Coolant System Pressure-Temperature Limits, dated March 7, 2011 (ADAMS Accession No. ML110730082)
Dear Sir or Madam:
In the Palisades Nuclear Plant (PNP) license renewal application (Reference 1),
Nuclear Management Company (NMC), the former license holder for PNP, committed to submit an equivalent margins analysis (EMA) for Nuclear Regulatory Commission (NRC) approval at least three years before any reactor vessel beltline material Charpy upper-shelf energy (USE) decreases to less than 50 ft-lb, in accordance with 10 CFR 50 Appendix G, Section IV, "Fracture Toughness Requirements."
The EMA is to demonstrate that material predicted to possess Charpy USE values less than 50 ft-lb will provide margins of safety against fracture equivalent to those required by Appendix G of Section Xl of the American Society of Mechanical Engineers (ASME)
Boiler and Pressure Vessel Code.
As documented in the PNP license amendment request for primary coolant system pressure-temperature limits (Reference 2), a plate material and a weld material in the PNP reactor vessel traditional beltline region are predicted to drop below the Appendix G 50 ft-lb screening criterion prior to the PNP end-of-license-extension
PNP 2013-028 Page 2 of 4 (EOLE). The lower shell (LS) plate material, D-3804-1, is predicted to drop below the screening criterion in December 2016 and the intermediate shell (IS) to LS circumferential weld material, 9-112 (heat no. 27204), is predicted to drop below the criterion in November 2027.
As documented in WCAP-17403-NP (Attachment 1), the Charpy USE of an upper shell (US) plate material, D-3802-3, in the reactor vessel extended beltline region is predicted to remain above the 50 ft-lb Appendix G screening criterion at EOLE when considering an initial Charpy USE value based on a curve-fit of the available Charpy V-Notch data. However, this material is predicted to drop below the Appendix G screening criterion, to 47.5 ft-lb at EOLE, when considering an initial Charpy USE value based only on the available 95% shear Charpy V-Notch data for this material.
The remaining beltline and extended beltline materials in the reactor vessel are projected to maintain above the Charpy USE screening criterion of 50 ft-lb at EOLE.
The results of the fluence calculations for the extended beltline region materials of the PNP reactor vessel are provided in Table E-2 of WCAP-1 5353 - Supplement 2 - NP (Attachment 2). Supplement 2 was generated to address the neutron fluence experienced by materials located in the extended beltline regions above and below the reactor core that were not included in either Revision 0 of WCAP-1 5353 or in Supplement 1 of that report.
In accordance with 10 CFR 50 Appendix G, this letter transmits for NRC review and approval the EMA report WCAP-1 7651-NP (Attachment 3) for the two traditional beltline and one extended beltline reactor vessel materials discussed above. Extended beltline US plate material D-3802-3 was analyzed due to the possibility that it may fall below the 50 ft-lb limit if future operation includes higher flux levels, longer operating cycles, or changes to the reactor internals. The analysis of the three materials used the equivalent margins methodology specified in ASME Code Section Xl, Division 1, Appendix K, "Assessment of Reactor Vessels with Low Upper Shelf Charpy Impact Energy Levels," and concluded that all three of the reactor vessel materials are acceptable.
The work described herein was performed in accordance with industry and NRC accepted practices.
The extended beltline regions of the reactor pressure vessel with EOLE neutron fluence (E > 1.0 MeV) greater than 1.0 E+1 7 n/cm2 have been included in the extended beltline evaluation in WCAP-17403-NP (Attachment 1). Figure 1-2 of the evaluation illustrates the boundary of the extended beltline region with neutron fluence in excess of 1.0 E+17 n/cm 2. It is noted that the neutron fluence for the inlet and outlet nozzles remain below 1.0 E+17 n/cm2 at EOLE. The evaluation of these regions concluded that the materials are predicted to remain below the pressurized thermal shock screening criteria and the traditional beltline materials remain limiting. Also, all adjusted
PNP 2013-028 Page 3 of 4 reference temperature values are predicted to remain below those contained in the analysis of record, so the pressure-temperature limit curves and low temperature overpressure protection (LTOP) setpoint limit curve continue to be governed by the traditional beltline materials.
The fluence evaluation in WCAP-1 5353 - Supplement 2 - NP (Attachment 2) used to assess the material properties is compliant with Regulatory Guide 1.190, "Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence." Previous PNP reactor pressure vessel neutron fluence evaluation submittals have been reviewed and approved by the NRC as being consistent with the requirements of Regulatory Guide 1.190. The methodology used for the WCAP-1 5353 fluence evaluation is detailed in
" WCAP-14040-NP-A, Revision 4, "Methodology Used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves," and
- WCAP-16083-NP-A, Revision 0, "Benchmark Testing of the FERRET Code for Least Squares Evaluation of Light Water Reactor Dosimetry,"
which have been previously reviewed and approved by the NRC.
The EMA in WCAP-1 7651-NP is based upon ASME Code Section XI, Division 1, Appendix K, but has been supplemented with additional criteria specified in Regulatory Guide 1.161, "Evaluation of Reactor Pressure Vessels with Charpy Upper-Shelf Energy Less Than 50 Ft-Lb," for material fracture toughness, transients, and fracture toughness resistance (J-R) model restrictions on sulfur content.
The USE values in the EMA have been matched to the proper orientation of the plate material. For axial flaws, the USE value for the lateral transverse "strong" orientation in the vessel wall has been used. Similarly, for circumferential flaws, the USE value for the transverse-lateral "weak" orientation has been used. In addition, the initial longitudinal USE values have been reduced to 65 percent per NUREG-0800 Branch Technical Position 5-3, "Fracture Toughness Requirements," to approximate the transverse "weak" direction.
Per Regulatory Guide 1.161, three additional cooldown transients at 100 °F/hr, 400 °F/hr, and 600 °F/hr have been considered in the EMA.
As discussed in the EMA, extended beltline plate material D-3802-3 and traditional beltline plate material D-3804-1 have sulfur content in excess of the J-R model 0.018 weight percent limitation. Additional analysis has been conducted using available information for the V-50 plate in NUREG/CR-5265, "Size Effects on J-R Curves for A 302-B Plate," to demonstrate that the PNP reactor vessel high sulfur plate materials
PNP 2013-028 Page 4 of 4 remains below the measured very conservative lower bound V-50 A-302 B plate J-R data.
Attachments 1, 2 and 3 contain no proprietary information.
ENO requests approval of the enclosed EMA by October 21, 2014.
Summary of Commitments This letter contains no new commitments and no revisions to existing commitments.
This letter completes the following commitment:
"NMC will submit an equivalent margins analysis, completed in accordance with 10 CFR 50 Appendix G Section IV.A.1, for NRC approval, at least three years before any reactor vessel beltline material upper shelf energy decreases to less than 50 ft-lb."
I declare under penalty of perjury that the foregoing is true and correct. Executed on October 21, 2013.
Sincerely, V AA ajv/jse Attachments: I 1. Westinghouse WCAP-17403-NP, Revision 1, "Palisades Nuclear Power Plant Extended Beltline Reactor Vessel Integrity Evaluation"
- 2. Westinghouse, WCAP-1 5353 - Supplement 2 - NP, Revision 0, "Palisades Reactor Pressure Vessel Fluence Evaluation"
- 3. Westinghouse WCAP-1 7651-NP, Revision 0, "Palisades Nuclear Power Plant Reactor Vessel Equivalent Margins Analysis" cc: Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC