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Category:License-Technical Assistance Request (TAR)
MONTHYEARML1002101862010-01-20020 January 2010
Memo to Christine. A. Lipa Response to Region III Technical Assistance Request-Palisades Plant Multi-Assembly Sealed Basket No. 4 (Msb #4) - Weld Flaw Analysis
ML0813000962008-05-0909 May 2008
TIA Regarding LCO 3.0.4a
2010-01-20
[Table view]
Category:Memoranda
MONTHYEARML23297A0532023-11-27027 November 2023
Restart Panel Charter
ML20231A2202020-08-17017 August 2020
Summary of Public Webinar to Discuss the NRC 2019 End-Of-Cycle Plant Performance Assessment of the Palisades Nuclear Plant
ML16182A5142016-06-30030 June 2016
Summary of the June 23, 2016, Public Meeting Regarding Palisades Nuclear Plant
ML16138A1812016-05-16016 May 2016
EA-15-039 Palisades Federal Register Memo and Order
ML16088A2042016-03-28028 March 2016
Memo T Bowers from s Ruffin, Technical Assistance Requests - Review 2015 Tri-Annual Decommissioning Funding Plans for Multiple Independent Spent Fuel Storage Installations W/ Encl 2 (Template)
ML16088A2052016-03-28028 March 2016
Enclosure 1 - (72.30 DFP Reviews to Be Completed 2015) - Memo T Bowers from s Ruffin, Technial Assistance Requests - Review 2015 Tri-Annual Decommissioning Funding Plans for Multiple Independent Spent Fuel Storage Installations
ML15127A5692015-05-0707 May 2015
Final Task Interface Agreement-Regulatory Position on Design Life of Safety-Related Structures, Systems, & Components Related to Unresolved Items at D. C. Cook, Monticello, & Palisades (TIA 2014-01)
ML15054A3962015-04-0606 April 2015
Federal Register Notice on Final Director'S Decision on 10 CFR 2.206 Petition from Mr. Michael Mulligan at Palisades Nuclear Plant
ML13261A2282013-09-23023 September 2013
Notice of Forthcoming Conference Call with Entergy Nuclear Operations, Inc., on Palisades Equivalent Margins Analysis
ML13042A2932013-02-11011 February 2013
Meeting Summary with NRC to Discuss Nrc'S Perspectives on Leaks, and the Regulatory Requirements That Apply on the Repair of Such Leaks
ML12305A4512012-12-0101 December 2012
Branch Chief Reassignment
ML12306A3672012-11-0808 November 2012
Approval Memo Palisades Request for Deviation to the Reactor Oversight Process Action Matrix
ML12305A5472012-11-0101 November 2012
Pre-application Meeting Notice Palisades ME9852
ML1115704052011-06-0606 June 2011
Notice of Meeting with Entergy Operations, Inc., to Discuss Implementation of Quality Oversight and Verification Programs at Entergy Sites Including Actions Being Taken to Enhance Effectiveness
ML1111107222011-05-0303 May 2011
Final Response to TIA 2011-006, Palisades Nuclear Plant Reactor Vessel Bare Metal Head Exam - Compliance with Code Case N-729-1
ML1107504052011-03-21021 March 2011
Notice of Meeting with Entergy Operations, Inc., to Discuss Fleetwide Submittal for Proposed Technical Specification and Quality Assurance Program Manual Changes Related to Unit Staff Qualification Requirements
ML1012601282010-06-29029 June 2010
TIA Response
ML1015506112010-06-0909 June 2010
Notice of Pre-Application Meeting with Entergy Nuclear Operations Inc. to Discuss Pressurized Thermal Shock Analysis
ML1011604932010-04-27027 April 2010
05/12-13/2010 Notice of Meeting with Energy Nuclear Operations LLC (ENO) Regarding Response to Generic Letter 2004-02 for Palisades Nuclear Plant
ML1002101862010-01-20020 January 2010
Memo to Christine. A. Lipa Response to Region III Technical Assistance Request-Palisades Plant Multi-Assembly Sealed Basket No. 4 (Msb #4) - Weld Flaw Analysis
ML0927301372009-10-0909 October 2009
Safety Evaluation by the Office of Nuclear Reactor Regulation Corporate Restructuring Conversion of Companies and Stock Split-Off by Entergy Nuclear Operations, Inc and Subsidiaries
ML0925400322009-09-17017 September 2009
Final Task Interface Agreement - Re-Evaluation of Implementation of Limiting Condition for Operation 3.0.4a, Mode Change Limitations, at Palisades Nuclear Plant (TIA2009-005)
ML0912504972009-05-15015 May 2009
Summary of Telephone Conference Call Held on April 23, 2009, Between the U.S. Nuclear Regulatory Commission and Entergy Operations, Inc. Regarding Progress on National Fire Protection Association (NFPA) Standard 805 Transition Activities
ML0909601482009-04-17017 April 2009
(Pnp) - Summary of Telephone Conference Call Held on March 17, 2009, Between the U.S. Nuclear Regulatory Commission and Entergy Operations, Inc. Regarding Progress on National Fire Protection Association (NFPA) Standard 805 ...
ML0905507692009-02-25025 February 2009
Notice of Pre-Application Meeting with Palisades to Discuss Spent Fuel Criticality Amendment for Palisades Nuclear Plant
ML0835902692008-12-17017 December 2008
Memo 12/17/2008 Re 2006 Palisades Proposed Examination Not Available in ADAMS
ML0831908362008-12-15015 December 2008
Summary of Telephone Conference Call Held on November 3, 2008, Between the NRC and Entergy Operations, Inc. Concerning Request for Extension of Discretion for the Interim Enforcement Policy for Fire Protection Issues on 10 CFR 50.48(C), Nat
ML0833604952008-12-11011 December 2008
LIC-109 Acceptance Review for License Amendment Request for Spent Fuel Pool Region I Criticality for Palisades
ML0834301532008-12-0404 December 2008
Canceled - 12/16/2008 Meeting Notice, Meeting with Entergy Nuclear Operations, Inc. (Eno), Palisades Nuclear Plant
ML0823503502008-08-20020 August 2008
Memo to Christine Lipa Request for Additional Information; Region III TAR Requesting Assessment of Palisades Weld Flaw Analysis for Loaded Spend Fuel Cask Msb No. 4 (TAC A10126)
ML0813000962008-05-0909 May 2008
TIA Regarding LCO 3.0.4a
ML0807400842008-03-14014 March 2008
Draft Regulatory Guide for Comment
ML0708805192007-04-0909 April 2007
Memo J Cameron, Request for Additional Information, Region III, TAR Requesting Assessment of Palisades Weld Flaw Analysis for Loaded Spent Fuel Cask Msb No. 4, TAC No. A10126 (Dsfst 20070005)
ML0707207672007-03-20020 March 2007
Encl 1 - Staff'S Response to Petitioner'S Comments to 03/20/07 - Ltr T Lodge, Counsel for Petitioners, Issuance of Director'S Decision DD-07-02 Under 10 CFR 2.206 - Palisades Nuclear Plant, Docket Nos. 72-7, 50-255
ML0706101422007-03-0909 March 2007
February 2007 Report on the Status of Public Petitions Under Title 10 of the Code of Federal Regulations (10 Cfr), Section 2.206
ML0704001932007-02-22022 February 2007
Response Memo to Task Interface Agreement 2006-004
ML0701001592007-01-29029 January 2007
December 2006 Report on the Status of Public Petitions Under Title 10 of the Code of Federal Regulations, Section 2.206
ML0700402152007-01-22022 January 2007
Safety Evaluation by the Office of Nuclear Reactor Regulation Re Direct Transfer of Licenses from Consumers Energy Company to Entergy Nuclear Palisades, LLC and Entergy Nuclear Operations, Inc
ML0635404462007-01-11011 January 2007
Memo to Commission Fm Reyes Renewal of Full-Power Operating License for the Palisades Nuclear Plant
ML0634502502006-12-19019 December 2006
November 2006 Report on the Status of Public Petitions Under Title 10 of the Code of Federal Regulations, Section 2.206
ML0617805592006-07-10010 July 2006
Revised Closeout Letter for Bulletin 2003-01, Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized-Water Reactors.
ML0618102812006-06-29029 June 2006
Memo 06/29/06 Palisades DRS Input to DRP IR 06-004
ML0607401012006-03-14014 March 2006
04/05/06 - Forthcoming Meeting to Discuss the Draft Supplemental Environmental Impact Statement (Dseis) for License Renewal at Palisades Nuclear Plant (Palisades)
ML0602502942006-01-25025 January 2006
Canceled Notice of Meeting with Nuclear Management Company Regarding Fleet Transition to NFPA Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants
ML0601800802006-01-18018 January 2006
Notice of Forthcoming Meeting with Palisades Nuclear Plant and Nuclear Management Company (NMC) to Discuss Removing Trisodium Phosphate from the Containment at Palisades Nuclear Plant for One Cycle
ML0611102682005-11-0707 November 2005
Memorandum to Marc Dapas, Riii from Edwin Hacket, NRR Re Response to Task Interface Agreement 2005-06, Regarding Licensing Basis for, and Seismic Design of, the Palisades Independent Spent Fuel Storage Installation (ISFSI)
ML0530404252005-10-28028 October 2005
Summary of Telephone Conference Call Held on September 7, 2005, Between the U.S. Nuclear Regulatory Commission (NRC) and Nuclear Management Company, LLC, Concerning Draft Request for Additional Information Pertaining to the Palisades Nuclea
ML0520805482005-07-27027 July 2005
Forthcoming Exit Meeting with Nuclear Management Company to Present Results of the Palisades Nuclear Plant Aging Management Program and Aging Management Review Audits
ML0611102662005-05-12012 May 2005
Memorandum to James Lyons, NRR, from Marc Dapas, Riii Re Request for Technical Assistance-Licensing Basis for, and Seismic Design of, the Palisades Independent Spent Fuel Storage Installation (ISFSI) Supplemental Information
ML0511203112005-05-11011 May 2005
Transmittal of Summaries of Final ASP Analyses
2023-11-27
[Table view] |
Text
THIS DOCUMENT HAS BEEN SUPERSEDED BY TIA 2009-005 (ADAMS Accession No. ML092540032)
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 May 9, 2008 MEMORANDUM TO: Ho K. Nieh, Deputy Director Division of Policy and Rulemaking Office of Nuclear Reactor Regulation FROM: Gary L. Shear, Deputy Director Division of Reactor Projects
/RA by Cynthia D. Pederson for/
SUBJECT:
TASK INTERFACE AGREEMENT (TIA) - EVALUATION OF IMPLEMENTATION OF LIMITING CONDITION FOR OPERATION (LCO) 3.0.4a, MODE CHANGE LIMITATIONS, AT PALISADES NUCLEAR PLANT (TIA2008-002)
On January 14, 2008, with Palisades Nuclear Plant in Mode 3, the NRC resident inspector observed that radiation monitor RIA-1805 was declared inoperable, but the bi-stable associated with the instrument was not in the trip condition. The Palisades Technical Specifications (TSs) require the channel (bi-stable) to be placed in trip within seven days from time of discovery of the inoperable condition or be in shutdown in the following six hours. RIA-1805 is one of four containment radiation monitors required to be operable in Modes 1-4 by Limiting Condition for Operation (LCO) 3.3.3, Engineered Safety Features, Table 3.3.3-1, Function 6. The monitors are engineered safety features (ESF) instrumentation that actuate to isolate containment on a two out-of-four coincidence logic upon detection of a high radiation condition.
The NRC staff questioned the licensee operators if the radiation monitor was to be restored to an operable status or if the bi-stable was to be placed in trip prior to start-up. Limiting Condition for Operation 3.0.4a prohibits a transition from Mode 3 to Mode 2 unless the associated actions to be entered permit continued operation in the applicable Mode or other specified condition for an unlimited period of time. The operators stated the issue had been reviewed and no action was required prior transition to Mode 2.
However, following NRC discussions with plant management, the licensee decided to place the channel in trip and then proceed with the startup transition to Mode 2. The licensee wrote a Condition Report to address the issue.
Licensee Position:
The licensees position on the application of LCO 3.0.4a was that the seven day required completion time to place the unit in trip did not have to be completed prior to the mode transition. The licensee stated that although the TS actions to be entered permit operations for an unlimited time period, the required actions do not (emphasis added) need to be completed prior to the mode transition; rather a delay time equal to the allowed completion time, in this case seven days, is permitted.
THIS DOCUMENT HAS BEEN SUPERSEDED BY TIA 2009-005 (ADAMS Accession No. ML092540032)
THIS DOCUMENT HAS BEEN SUPERSEDED BY TIA 2009-005 (ADAMS Accession No. ML092540032)
H. Nieh The basis for the licensees position is that LCO 3.0.4 does not specifically require action prior to the mode transition because LCO 3.0.4a uses a future tense: Actions to be entered.
Secondly, LCO 3.0.4 does not contain a statement requiring compliance with a sooner completion time than the LCO 3.3.3 required completion time. The licensee also indicated that their position is supported by TS implementation training documents provided by Improved Technical Specifications (ITS) contractors which have the approval of the Nuclear Energy Institute (NEI) Technical Specifications Task Force. However, approval by NEI does not constitute an applicable regulatory position or NRC staff position.
Applicable Regulatory Position:
The NRC staff reviewed the applicable requirements in 10 CFR 50.36 in conjunction with the Palisades TS as well as the applicable staff position contained in Standard Technical Specifications and concluded that the plant specific Palisades TS and Bases for LCO 3.0.4 are consistent with that regulatory position on aforementioned application of LCO 3.0.4a.
The applicable staff position for Palisades in LCO 3.0.4a states:
When an LCO is not met, entry into a mode or other specified condition in the Applicability shall only be made:
- a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; Although the Palisades LCO contains the future looking statement to be entered the Palisades LCO 3.0.4a Bases clarify the intent of the LCO by stating:
Compliance with Required Actions that permit continued operation of the plant for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. Therefore, in such cases, entry into a MODE or other specified conditions in the Applicability may be made in accordance with the provisions of the Required Actions.
NRC Staff Guidance:
LCO 3.0.4.a indicates that entry into a Mode, i.e., transitioning from MODE 3 to 2, may only be made when (emphasis added) the associated ACTION to be entered permits continued operation for an unlimited period of time. For TS 3.3.3 this requires placing the affected bi-stable in trip. The unlimited period of time for operation cannot begin until the ACTION is complete because meeting the action establishes the basis for continued operation in the degraded condition while ensuring adequate safety for the plant is maintained. In the Palisades case, if the bi-stable is not tripped within seven days, the plant must shut down per TS Action 3.3.3.E.
THIS DOCUMENT HAS BEEN SUPERSEDED BY TIA 2009-005 (ADAMS Accession No. ML092540032)
THIS DOCUMENT HAS BEEN SUPERSEDED BY TIA 2009-005 (ADAMS Accession No. ML092540032)
H. Nieh
Conclusion:
Therefore, based on the applicable staff guidance provided in the Standard Technical Specifications, as illuminated by its Bases, the NRC staff inspection guidance is that LCO 3.0.4a prohibits a Mode transition while not in compliance with the Required Action.
Thus, the associated action which allows operations for an unlimited time (in this case tripping a bi-stable) must be completed prior to mode ascension in order to apply TS 3.0.4a. This NRC staff inspection guidance disagrees with the licensees interpretation of LCO 3.0.4a.
Docket: 50-255 cc via E-mail:
C. Pederson C. Haney M. Case, D/NRR/ADRO/DRP (MJC)
S. Rosenberg, C/NRR/PSPB (SLR1)
S. Peters, PM/NRR/PSPB (SEP)
G. Waig, C/NRR/ITSB (TJK1)
C. Schulten, NRR/ITSB (CSS1)
M. Chawla L. James J. Ellegood J. Giessner R. Lerch THIS DOCUMENT HAS BEEN SUPERSEDED BY TIA 2009-005 (ADAMS Accession No. ML092540032)
ML092540032)
H. Nieh
Conclusion:
Therefore, based on the applicable staff guidance provided in the Standard Technical Specifications, as illuminated by its Bases, the NRC staff inspection guidance is that LCO 3.0.4a prohibits a Mode transition while not in compliance with the Required Action.
Thus, the associated action which allows operations for an unlimited time (in this case tripping a bi-stable) must be completed prior to mode ascension in order to apply TS 3.0.4a. This NRC staff inspection guidance disagrees with the licensees interpretation of LCO 3.0.4a.
Docket: 50-255 cc via E-mail:
C. Pederson C. Haney M. Case, D/NRR/ADRO/DRP (MJC)
S. Rosenberg, C/NRR/PSPB (SLR1)
S. Peters, PM/NRR/PSPB (SEP)
G. Waig, C/NRR/ITSB (TJK1)
C. Schulten, NRR/ITSB (CSS1)
M. Chawla L. James J. Ellegood J. Giessner R. Lerch SUNSI Review Completed: ADAMS: Yes No Initials:
X Publicly Available Non-Publicly Available Sensitive X Non-Sensitive RI: RI D: NRR/ITSB NRR/ITSB/BC NRR/PSPB/PM CLipa:dtp G. Shear CSchulten RElliott SPeters CDP for 5/2/08 5/9/08 5/7/08 5/7/08 5/8/08 NRR/PSPB/BC NRR/DPR/DD SRosenberg HNieh M. Case for 5/8/08 5/8/08
