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Application to Eliminate License Condition 2.F Requiring Reporting of Violations of Section 2.C of Operating License Using the Consolidated Line Item Improvement Process
	ML081270073
Person / Time
Site:	Palisades
Issue date:	05/05/2008
From:	Schwarz C; Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML081270073 (8)
	v • d • e

Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant EntW 27780 Blue Star Memorial Highway Covert, MI 49043 Tel 269 764 2000 May 5, 2008 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington , DC 20555-0001 Palisades Nuclear Plant Docket 50-255 License No. DPR-20 Application to Eliminate License Condition 2.F Requiring Reporting of Violations of Section 2.C of Operating License Using the Consolidated Line Item Improvement Process

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc (ENO) requests Nuclear Regulatory Commission (NRC) review and approval of a proposed license amendment for the Palisades Nuclear Plant. The proposed amendment would revise renewed facility operating license DPR-20 to remove license condition 2.F. This license condition describes reporting requirements for exceeding the facility steady-state reactor core power level described in license condition 2.C.(1). The proposed change is consistent with the NRC approved change notice published in the Federal Register on November 4, 2005, announcing the availability of this improvement through the consolidated line item improvement process. provides a description of the proposed change and confirmation of applicability. provides the existing license page marked up to show the proposed change. provides revised (clean) license page.

ENO requests approval of the proposed license amendment and proposed exemption requests by May 5, 2009, with the amendment being implemented within 90 days.

By letter dated May 5, 2008, ENO requested NRC review and approval of a license amendment to correct an error generated when the renewed facility operating license was created and also remove several outdated license conditions to DPR-20. ENO will work with the NRC project manager, as necessary, to coordinate the changes to the operating license.

Document Control Desk Page 2 A copy of this request has been provided to the designated representative of the State of Michigan.

Summary of Commitments This letter contains no new commitments and no revisions to existing commitments.

I declare under penalty of perjury that the foregoing is true and correct. Executed on May 5, 2008.

i V ristopher J. Sc Site Vice President Palisades Nuclear Plant Enclosures (3)

CC Regional Administrator, Region III, USNRC Project Manager, Palisades, USNRC NRC Resident Inspector, Palisades, USNRC

ENCLOSURE 1 DESCRIPTION OF REQUESTED CHANGES

1.0 INTRODUCTION

The proposed amendment would delete Section 2 . F of renewed facility operating license No. DPR-20 for the Palisades Nuclear Plant (PNP ), which requires reporting of violations of the requirements in Section 2.C(1) of the license. The availability of this operating license improvement was announced in the Federal Register on November 4, 2005, as part of the consolidated line item improvement process (CLIIP).

2.0 DESCRIPTION

OF PROPOSED AMENDMENT Consistent with the CLIIP Notice of Availability (70 FR 67202), the proposed amendment consists of deleting Section 2.F of renewed facility operating license DPR-20. The current requirements of the license condition are as follows:

F. The licensee shall report any violations of Section 2.C(1) of this license within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to the NRC Operations Center via the Emergency Notification System with written follow-up within 60 days in accordance with 10 CFR 50.73(b), (c), and (e).

The existing condition in Section 2.C(1) that is subject to the current reporting requirement consists of the following:

(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.

3.0 BACKGROUND

The background for this application is adequately addressed by the NRC Notice of Availability published on November 4, 2005 (70 FR 67202), and the Notice of Opportunity to Comment published on August 29, 2005 (70 FR 51098).

4.0 REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on November 4, 2005 (70 FR 67202), and the Notice of Opportunity to Comment published on August 29, 2005 (70 FR 51098).

5.0 TECHNICAL ANALYSIS

Entergy Nuclear Operations, Inc (ENO) has reviewed the safety evaluation (SE) published on August 29, 2005, as part of the CLIIP Notice of Opportunity to Comment. ENO has concluded that the justifications presented in the SE

prepared by the NRC staff are applicable to PNP and justify this proposed amendment to DPR-20 for PNP.

6.0 REGULATORY ANALYSIS

A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Opportunity to Comment published on August 29, 2005 (70 FR 51098).

7.0 NO SIGNIFICANT HAZARDS CONSIDERATION ENO has reviewed the proposed no significant hazards consideration determination published on August 29, 2005 (70 FR 51098), as part of the CLIIP Notice of Opportunity to Comment. ENO has concluded that the proposed determination presented in the notice is applicable to PNP and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

8.0 ENVIRONMENTAL EVALUATION ENO has reviewed the environmental evaluation included in the model SE published on August 29, 2005 (70 FR 51098), as part of the CLIIP Notice of Opportunity to Comment. ENO has concluded that the NRC staff's findings presented in that evaluation are applicable to PNP and the evaluation is hereby incorporated by reference for this application.

9.0 PRECEDENT This application is being made in accordance with the CLIIP. ENO is not proposing variations or deviations from the changes described in the NRC staff's model SE published on August 29, 2005 (70 FR 51098).

10.0 REFERENCES

1. Federal Register Notice of Opportunity to Comment on Model Safety Evaluation on Elimination of Typical License Condition Requiring Reporting of Violations of Section 2.C of Operating License Using the Consolidated Line Item Improvement Process, August 29, 2005 (70 FR 51098).

2. Federal Register Notice of Availability of Model Application Concerning Elimination of Typical License Condition Requiring Reporting of Violations of Section 2.C of Operating License Using the Consolidated Line Item Improvement Process, November 4, 2005 (70 FR 67202)

Page 2 of 2

ENCLOSURE2 APPLICATION CONCERNING ELIMINATION OF LICENSE CONDITION REQUIRING REPORTING OF VIOLATIONS OF SECTION 2.C OF OPERATING LICENSE USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS PROPOSED RENEWED FACILITY OPERATING LICENSE PAGE 6 (Mark-Up)

(showing proposed changes to facsimile license page)

(additions are highlighted; deletions are strikethrough) 1 Page Follows

D. The facility has been granted certain exemptions from the requirements of Section III, G of Appendix R to 10 CFR Part 50, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979." This section relates to fire protection features for ensuring the systems and associated circuits used to achieve and maintain safe shutdown are free of fire damage. These exemptions were granted in letters dated February 8, 1983, July 12, 1985, and July 23, 1985.

In addition, the facility has been granted certain exemptions from Appendix J to 10 CFR Part 50, "Primary Reactor Containment Leakage Testing for Water Cooled Power Reactors." This section contains leakage test requirements, schedules and acceptance criteria for tests of the leak-tight integrity of the primary reactor containment and systems and components which penetrate the containment. These exemptions were granted in a letter dated December 6, 1989.

These exemptions granted pursuant to 10 CFR 50.12, are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security. With these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

E. ENO shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Nuclear Management Company Palisades Nuclear Plant Physical Security Plan, Revision 2," submitted by letter dated May 10, 2006.

F. [del e ted]I The liGeRGee shall Fe p ert aR y vialations, Af- Sertien

-- 2 . G(I) of th is liGen6e Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to the NRG Operat'GRE; GeRter via the EmeFgeRGy NGtifiGatiGR System with wFi#eR follow u p within 60 da y s iR aGGordaRGe; . . A dh 10 C - F=R 5() . 73(b) , ( G) , aRd (e) .

G. ENP and ENO shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

Renewed License No. DPR-20 Revised by letter dated April 2 , 2007 Amendment No. 224

ENCLOSURE3 APPLICATION CONCERNING ELIMINATION OF LICENSE CONDITION REQUIRING REPORTING OF VIOLATIONS OF SECTION 2.C OF OPERATING LICENSE USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS PROPOSED RENEWED FACILITY OPERATING LICENSE PAGE 6 (shown on facsimile license page) 1 Page Follows