ML20071Q717

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Issuance of Amendment Nos. 292 and No. 267 Changes to Technical Specification Sections 1.1, 4.0, and 5.0 for a Permanently Defueled Condition
ML20071Q717
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 04/10/2020
From: Richard Guzman
NRC/NRR/DORL/LPL1
To:
Entergy Nuclear Operations
Guzman R
References
EPID L-2019-LLA-0081
Download: ML20071Q717 (59)


Text

April 10, 2020 Vice President, Operations Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 ISSUANCE OF AMENDMENT NOS. 292 AND 267 RE: CHANGES TO TECHNICAL SPECIFICATION SECTIONS 1.1, DEFINITIONS; 4.0, DESIGN FEATURES; AND 5.0, ADMINISTRATIVE CONTROLS, FOR A PERMANENTLY DEFUELED CONDITION (EPID L-2019-LLA-0081)

Dear Sir or Madam:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 292 to Renewed Facility Operating License No. DPR-26 for Indian Point Nuclear Generating Unit No. 2 (Indian Point 2) and Amendment No. 267 to Renewed Facility Operating License No. DPR-64 for Indian Point Nuclear Generating Unit No. 3 (Indian Point 3).

The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated April 15, 2019.

The amendments revise certain organization, staffing, and training requirements contained in TS Section 1.1, Definitions; Section 4.0, Design Features; and Section 5.0, Administrative Controls, of the Indian Point 2 and 3 TSs that will not be applicable to a permanently defueled facility once Indian Point 2, and subsequently Indian Point 3, are permanently defueled.

A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions biweekly Federal Register notice.

Sincerely,

/RA/

Richard V. Guzman, Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286

Enclosures:

1. Amendment No. 292 to DPR-26
2. Amendment No. 267 to DPR-64
3. Safety Evaluation cc: Listserv

ENTERGY NUCLEAR INDIAN POINT 2, LLC ENTERGY NUCLEAR OPERATIONS, INC.

DOCKET NO. 50-247 INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 292 License No. DPR-26

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Entergy Nuclear Operations, Inc. (the licensee) dated April 15, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR-26 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A, B, and C, as revised through Amendment No. 292, are hereby incorporated in the renewed license. ENO shall operate the facility in accordance with the Technical Specifications.

3. This license amendment will be effective upon the licensees submittal of the certifications required by 10 CFR 50.82(a)(1)(i) and (ii), and shall be implemented within 90 days of the effective date of the amendment, but will not exceed December 31, 2020.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

James G. Danna, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: April 10, 2020

ATTACHMENT TO LICENSE AMENDMENT NO. 292 INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 RENEWED FACILITY OPERATING LICENSE NO. DPR-26 DOCKET NO. 50-247 Replace the following page of the license with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Page Insert Page 3 3 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages iii iii iv iv 1.1-1 1.1-1 1.1-2 1.1-2 1.1-3 1.1-3 1.1-4 1.1-4 4.0-1 4.0-1 5.1-1 5.1-1 5.2-1 5.2-1 5.2-2 5.2-2 5.3-1 5.3-1 5.4-1 5.4-1 5.5-2 5.5-2 5.6-1 5.6-1 5.6-2 5.6-2 5.7-1 5.7-1 5.7-3 5.7-3

(3) ENO pursuant to the Act and 10 CFR Parts 30, 40, and 70, to Amdt. 42 receive, possess and use, at any time any byproduct, source 10-17-78 and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) ENO pursuant to the Act and 10 CFR Parts 30, 40 and 70, to Amdt. 42 receive, possess, and use in amounts as required any 10-17-78 byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; (5) ENO pursuant to the Act and 10 CFR Parts 30 and 70, to Amdt. 220 possess, but not separate, such byproduct and special 09-06-01 nuclear materials as may be produced by the operation of the facility.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and 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) Maximum Power Level ENO is authorized to operate the facility at steady state Amdt. 241 reactor core power levels not in excess of 3216 megawatts 10-27-04 thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A, B, and C, as revised through Amendment No. 292, are hereby incorporated in the renewed license. ENO shall operate the facility in accordance with the Technical Specifications.

(3) The following conditions relate to the amendment approving the conversion to Improved Standard Technical Specifications:

1. This amendment authorizes the relocation of certain Technical Specification requirements and detailed information to licensee controlled documents as described in Table R, "Relocated Technical Specifications from the CTS," and Table LA, "Removed Details and Less Restrictive Administrative Changes to the CTS" attached to the NRC staff's Safety Evaluation enclosed with this amendment. The relocation of requirements and detailed information shall be completed on or before the implementation of this amendment.

Amendment No. 292

Facility Operating License No. DPR-26 Appendix A - Technical Specifications TABLE OF CONTENTS 3.7 PLANT SYSTEMS 3.7.1 Main Steam Safety Valves (MSSVs) 3.7.2 Main Steam Isolation Valves (MSIVs) and Main Steam Check Valves (MSCVs) 3.7.3 Main Feedwater Isolation 3.7.4 Atmospheric Dump Valves (ADVs) 3.7.5 Auxiliary Feedwater (AFW) System 3.7.6 Condensate Storage Tank (CST) 3.7.7 Component Cooling Water (CCW) System 3.7.8 Service Water System (SWS) 3.7.9 Ultimate Heat Sink (UHS) 3.7.10 Control Room Ventilation System (CRVS) 3.7.11 Spent Fuel Pit Water Level 3.7.12 Spent Fuel Pit Boron Concentration 3.7.13 Spent Fuel Pit Storage 3.7.14 Secondary Specific Activity 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources - Operating 3.8.2 AC Sources - Shutdown 3.8.3 Diesel Fuel Oil and Starting Air 3.8.4 DC Sources - Operating 3.8.5 DC Sources - Shutdown 3.8.6 Battery Parameters 3.8.7 Inverters - Operating 3.8.8 Inverters - Shutdown 3.8.9 Distribution Systems - Operating 3.8.10 Distribution Systems - Shutdown 3.9 REFUELING OPERATIONS 3.9.1 Boron Concentration 3.9.2 Nuclear Instrumentation 3.9.3 Containment Penetrations 3.9.4 Residual Heat Removal (RHR) and Coolant Circulation - High Water Level 3.9.5 Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level 3.9.6 Refueling Cavity Water Level 4.0 DESIGN FEATURES 4.1 Site Location 4.2 Deleted 4.3 Fuel Storage Indian Point 2 iii Amendment No. 292

Facility Operating License No. DPR-26 Appendix A - Technical Specifications TABLE OF CONTENTS 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.2 Organization 5.2.1 Onsite and Offsite Organizations 5.2.2 Facility Staff 5.3 Facility Staff Qualifications 5.4 Procedures 5.5 Programs And Manuals 5.5.1 Offsite Dose Calculation Manual (ODCM) 5.5.2 Primary Coolant Sources Outside Containment 5.5.3 Radioactive Effluent Controls Program 5.5.4 Component Cyclic or Transient Limit 5.5.5 Reactor Coolant Pump Flywheel Inspection Program 5.5.6 Inservice Testing Program 5.5.7 Steam Generator (SG) Program 5.5.8 Secondary Water Chemistry Program 5.5.9 Ventilation Filter Testing Program (VFTP) 5.5.10 Explosive Gas and Storage Tank Radioactivity Monitoring Program 5.5.11 Diesel Fuel Oil Testing Program 5.5.12 Technical Specification (TS) Bases Control Program 5.5.13 Safety Function Determination Program (SFDP) 5.5.14 Containment Leakage Rate Testing Program 5.5.15 Battery Monitoring and Maintenance Program 5.5.16 Control Room Envelope Habitability Program 5.6 Reporting Requirements 5.6.1 Not Used 5.6.2 Annual Radiological Environmental Operating Report 5.6.3 Radioactive Effluent Release Report 5.6.4 Not Used 5.6.5 CORE OPERATING LIMITS REPORT (COLR) 5.6.6 Post Accident Monitoring Report 5.6.7 Steam Generator Tube Inspection Report 5.7 High Radiation Area Indian Point 2 iv Amendment No. 292

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions

- NOTE -

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

ACTUATION LOGIC TEST An ACTUATION LOGIC TEST shall be the application of various simulated or actual input combinations in conjunction with each possible interlock logic state required for OPERABILITY of a logic circuit and the verification of the required logic output. The ACTUATION LOGIC TEST, as a minimum, shall include a continuity check of output devices.

AXIAL FLUX DIFFERENCE AFD shall be the difference in normalized flux signals between (AFD) the top and bottom halves of a two section excore neutron detector.

CERTIFIED FUEL HANDLER A CERTIFIED FUEL HANDLER is an individual who complies with the provisions of the CERTIFIED FUEL HANDLER Training and Retraining Program required by TS 5.3.2.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps.

CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status INDIAN POINT 2 1.1-1 Amendment No. 292

Definitions 1.1 1.1 Definitions derived from independent instrument channels measuring the same parameter.

CHANNEL OPERATIONAL A COT shall be the injection of a simulated or actual signal into TEST (COT) the channel as close to the sensor as practicable to verify OPERABILITY of all devices in the channel required for channel OPERABILITY. The COT shall include adjustments, as necessary, of the required alarm, interlock, and trip setpoints required for channel OPERABILITY such that the setpoints are within the necessary range and accuracy. The COT may be performed by means of any series of sequential, overlapping, or total channel steps.

CORE ALTERATION CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components, within the reactor vessel with the vessel head removed and fuel in the vessel.

Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.

CORE OPERATING LIMITS The COLR is the unit specific document that provides cycle REPORT (COLR) specific parameter limits for the current reload cycle. These cycle specific parameter limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT I-131 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries per gram) that alone would produce the same dose when inhaled as the combined activities of iodine isotopes I-131, I-132, I-133, I-134, and I-135 actually present. If a specific isotope is not detected, it should be assumed to be present at the minimum detectable activity. The determination of DOSE EQUIVALENT I-131 shall be performed using Committed Effective Dose Equivalent (CEDE) dose conversion factors from Table 2.1 of EPA Federal Guidance Report No. 11, 1988.

DOSE EQUIVALENT XE-133 DOSE EQUIVALENT XE-133 shall be that concentration of Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-85, Kr-87, Kr-88, Xe-131m, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138 actually present. If a specific noble gas nuclide is not detected, it should be assumed to be present at the minimum detectable activity. The determination of DOSE Equivalent XE-133 shall be performed using effective dose conversion factors for air submersion listed INDIAN POINT 2 1.1-2 Amendment No. 292

Definitions 1.1 1.1 Definitions in Table III.1 of EPA Federal Guidance Report No. 12, 1993, External Exposure to Radionuclides in Air, Water, and Soil.

LEAKAGE LEAKAGE shall be:

a. Identified LEAKAGE
1. LEAKAGE, such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff), that is captured and conducted to collection systems or a sump or collecting tank,
2. LEAKAGE into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAGE, or
3. Reactor Coolant System (RCS) LEAKAGE through a steam generator to the Secondary System (primary to secondary LEAKAGE);
b. Unidentified LEAKAGE All LEAKAGE (except RCP seal water injection or leakoff) that is not identified LEAKAGE, and
c. Pressure Boundary LEAKAGE LEAKAGE (except primary to secondary LEAKAGE) through a nonisolable fault in an RCS component body, pipe wall, or vessel wall.

MASTER RELAY TEST A MASTER RELAY TEST shall consist of energizing each required master relays in the channel required for channel OPERABILITY and verifying the OPERABILITY of each required master relay. The MASTER RELAY TEST may be performed by means of any series of sequential, overlapping, or total steps.

MODE A MODE shall correspond to any one inclusive combination of core reactivity condition, power level, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

INDIAN POINT 2 1.1-3 Amendment No. 292

Definitions 1.1 1.1 Definitions NON-CERTIFIED OPERATOR A NON-CERTIFIED OPERATOR is a non-licensed operator who complies with the qualification requirements of Specification 5.3.1, but is not a CERTIFIED FUEL HANDLER.

OPERABLE - OPERABILITY A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

PHYSICS TESTS PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation. These tests are:

a. Described in UFSAR Chapter 13, Tests and Operations,
b. Authorized under the provisions of 10 CFR 50.59, or
c. Otherwise approved by the Nuclear Regulatory Commission.

QUADRANT POWER TILT QPTR shall be the ratio of the maximum upper excore detector RATIO (QPTR) calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater.

RATED THERMAL POWER RTP shall be a total reactor core heat transfer rate to the reactor (RTP) coolant of 3216 MWt.

INDIAN POINT 2 1.1-4 Amendment No. 292

Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site Location Indian Point 2 is located on the East bank of the Hudson River at Indian Point, Village of Buchanan, in upper Westchester County, New York. The site is approximately 24 miles north of the New York City boundary line. The nearest city is Peekskill which is 2.5 miles northeast of Indian Point.

The minimum distance from the reactor center line to the boundary of the site exclusion area and the outer boundary of the low population zone, as defined in 10 CFR 100.3, is 520 meters and 1100 meters, respectively. For the purpose of satisfying 10 CFR Part 20, the Restricted Area is the same as the Exclusion Area shown in UFSAR, Figure 2.2-2.

4.2 Deleted 4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

INDIAN POINT 2 4.0-1 Amendment No. 292

Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.1.1 The plant manager shall be responsible for overall facility operation and shall delegate in writing the succession to this responsibility during his absence.

The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment or modification to systems or equipment that affect nuclear safety.

5.1.2 The shift manager (SM) shall be responsible for the shift command function.

INDIAN POINT 2 5.1-1 Amendment No. 292

Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established for facility staff and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear fuel.

a. Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all decommissioning organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements including the facility-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications shall be documented in the UFSAR,
b. The plant manager shall be responsible for overall safe maintenance of the facility and shall have control over those onsite activities necessary for storage and maintenance of nuclear fuel.
c. The corporate officer with direct responsibility for IP2 shall have corporate responsibility for the safe storage and handling of nuclear fuel and shall take any measures needed to ensure acceptable performance of the staff in maintaining and providing technical support to the facility to ensure safe management of nuclear fuel, and
d. The individuals who train the CERTIFIED FUEL HANDLERS, carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their ability to perform their assigned functions.

5.2.2 Facility Staff The facility staff organization shall include the following:

a. Each duty shift shall be composed of at least one shift manager and one NON-CERTIFIED OPERATOR. The NON-CERTIFIED OPERATOR position may be filled by a CERTIFIED FUEL HANDLER.

INDIAN POINT 2 5.2-1 Amendment No. 292

Organization 5.2 5.2 Organization 5.2.2 Facility Staff (continued)

At least one person qualified to stand watch in the control room (NON-CERTIFIED OPERATOR or CERTIFIED FUEL HANDLER) shall be present in the control room when nuclear fuel is stored in the spent fuel pool.

b. Shift crew composition may be less than the minimum requirement of 5.2.2.a for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements and all of the following conditions are met:
1) No fuel movements are in progress;
2) No movement of loads over fuel are in progress; and
3) No unmanned shift positions during shift turnover shall be permitted while the shift crew is less than the minimum.
c. An individual qualified in radiation protection procedures shall be on site during fuel handling operations and during movement of heavy loads over the fuel storage racks. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.
d. Not Used.
e. The shift manager shall be a CERTIFED FUEL HANDLER.
f. Deleted.

INDIAN POINT 2 5.2-2 Amendment No. 292

Facility Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Facility Staff Qualifications 5.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 for comparable positions with exceptions specified in the IPEC Quality Assurance Program Manual (QAPM).

5.3.2 An NRC approved training and retraining program for CERTIFIED FUEL HANDLERS shall be maintained.

INDIAN POINT 2 5.3-1 Amendment No. 292

Procedures 5.4 5.0 ADMINISTRATIVE CONTROLS 5.4 Procedures 5.4.1 Written procedures shall be established, implemented, and maintained covering the following activities:

a. The procedures applicable to the safe storage of nuclear fuel recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978 except as provided in the quality assurance program described or referenced in the Updated FSAR;
b. Deleted;
c. Quality assurance for effluent and environmental monitoring;
d. Fire Protection Program implementation;
e. All programs specified in Technical Specification 5.5; and
f. Personnel radiation protection consistent with the requirements of 10 CFR 20.

INDIAN POINT 2 5.4-1 Amendment No. 292

Programs and Manuals 5.5 5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals 5.5.2 Primary Coolant Sources Outside Containment Deleted 5.5.3 Radioactive Effluent Controls Program This program conforms to 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable. The program shall be contained in the ODCM, shall be implemented by procedures, and shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:

INDIAN POINT 2 5.5-2 Amendment No. 292

Reporting Requirements 5.6 5.6 Reporting Requirements 5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.

5.6.1 Not Used 5.6.2 Annual Radiological Environmental Operating Report

- NOTE -

A single submittal may be made for a multiple unit/facility station. The submittal should combine sections common to all units/facilities at the station.

The Annual Radiological Environmental Operating Report covering the operation of the unit/facility during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

A full listing of the information to be contained in the Annual Radiological Environmental Operating Report is provided in the ODCM.

INDIAN POINT 2 5.6-1 Amendment No. 292

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.3 Radioactive Effluent Release Report

- NOTE -

A single submittal may be made for a multiple unit/facility station. The submittal shall combine sections common to all units/facilities at the station; however, for units/facilities with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit/facility.

The Radioactive Effluent Release Report covering the operation of the unit/facility in the previous year shall be submitted prior to May 1 of each year in accordance with 10 CFR 50.36a. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit/facility. The material provided shall be consistent with the objectives outlined in the ODCM and Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR Part 50, Appendix I, Section IV.B.1.

5.6.4 Not Used 5.6.5 CORE OPERATING LIMITS REPORT (COLR)

a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:
1. Technical Specification 2.1, Safety Limits (SL);
2. Technical Specification 3.1.1, SHUTDOWN MARGIN (SDM);
3. Technical Specification 3.1.3, Moderator Temperature Coefficient (MTC);
4. Technical Specification 3.1.5, Shutdown Bank Insertion Limits;
5. Technical Specification 3.1.6, Control Bank Insertion Limits;
6. Technical Specification 3.2.1, Heat Flux Hot Channel Factor (F Q (Z));
7. Technical Specification 3.2.2, Nuclear Enthalpy Rise Hot Channel Factor; INDIAN POINT 2 5.6-2 Amendment No. 292

High Radiation Area 5.7 5.0 ADMINISTRATIVE CONTROLS 5.7 High Radiation Area As provided in paragraph 20.1601(c) of 10 CFR Part 20, the following controls shall be applied to high radiation areas in place of the controls required by paragraph 20.1601(a) and (b) of 10 CFR Part 20:

5.7.1 High Radiation Areas with Dose Rates Not Exceeding 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surface Penetrated by the Radiation

a. Each entryway to such an area shall be barricaded and conspicuously posted as a high radiation area. Such barricades may be opened as necessary to permit entry or exit of personnel or equipment.
b. Access to, and activities in, each such area shall be controlled by means of Radiation Work Permit (RWP) or equivalent that includes specification of radiation dose rates in the immediate work area(s) and other appropriate radiation protection equipment and measures.
c. Individuals qualified in radiation protection procedures and personnel continuously escorted by such individuals may be exempted from the requirement for an RWP or equivalent while performing their assigned duties provided that they are otherwise following facility radiation protection procedures for entry to, exit from, and work in such areas.
d. Each individual or group entering such an area shall possess:
1. A radiation monitoring device that continuously displays radiation dose rates in the area; or
2. A radiation monitoring device that continuously integrates the radiation dose rates in the area and alarms when the device's dose alarm setpoint is reached, with an appropriate alarm setpoint, or
3. A radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area, or INDIAN POINT 2 5.7-1 Amendment No. 292

High Radiation Area 5.7 5.7 High Radiation Area 5.7.2 High Radiation Areas with Dose Rates Greater than 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surface Penetrated by the Radiation, but less than 500 rads/hour at 1 Meter from the Radiation Source or from any Surface Penetrated by the Radiation (continued)

b. Access to, and activities in, each such area shall be controlled by means of an RWP or equivalent that includes specification of radiation dose rates in the immediate work area(s) and other appropriate radiation protection equipment and measures.
c. Individuals qualified in radiation protection procedures may be exempted from the requirement for an RWP or equivalent while performing radiation surveys in such areas provided that they are otherwise following facility radiation protection procedures for entry to, exit from, and work in such areas.
d. Each individual or group entering such an area shall possess:
1. A radiation monitoring device that continuously integrates the radiation rates in the area and alarms when the device's dose alarm setpoint is reached, with an appropriate alarm setpoint, or
2. A radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area with the means to communicate with and control every individual in the area, or
3. A self-reading dosimeter (e.g., pocket ionization chamber or electronic dosimeter) and, (i) Be under the surveillance, as specified in the RWP or equivalent, while in the area, of an individual qualified in radiation protection procedures, equipped with a radiation monitoring device that continuously displays radiation dose rates in the area; who is responsible for controlling personnel exposure within the area, or (ii) Be under the surveillance as specified in the RWP or equivalent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area, and with the means to communicate with and control every individual in the area.

INDIAN POINT 2 5.7-3 Amendment No. 292

ENTERGY NUCLEAR INDIAN POINT 3, LLC ENTERGY NUCLEAR OPERATIONS, INC.

DOCKET NO. 50-286 INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 267 License No. DPR-64

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Entergy Nuclear Operations, Inc. (the licensee) dated April 15, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 2

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR-64 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A, B, and C, as revised through Amendment No. 267, are hereby incorporated in the renewed license. ENO shall operate the facility in accordance with the Technical Specifications.

3. This license amendment will be effective upon the licensees submittal of the certifications required by 10 CFR 50.82(a)(1)(i) and (ii), and shall be implemented within 90 days of the effective date of the amendment, but will not exceed December 31, 2021.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

James G. Danna, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: April 10, 2020

ATTACHMENT TO LICENSE AMENDMENT NO. 267 INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 RENEWED FACILITY OPERATING LICENSE NO. DPR-64 DOCKET NO. 50-286 Replace the following page of the license with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Page Insert Page 3 3 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages iv iv 1.1-1 1.1-1 1.1-5 1.1-5 4.0-1 4.0-1 5.0-1 5.0-1 5.0-2 5.0-2 5.0-3 5.0-3 5.0-4 5.0-4 5.0-5 5.0-5 5.0-6 5.0-6 5.0-8 5.0-8 5.0-32 5.0-32 5.0-33 5.0-33 5.0-37 5.0-37 5.0-39 5.0-39

(4) ENO pursuant to the Act and 10 CFR Parts 30, 40 and 70, Amdt. 203 to receive, possess, and use in amounts as required any 11/27/00 byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration; or associated with radioactive apparatus or components.

(5) ENO pursuant to the Act and 10 CFR Parts 30 and 70, to Amdt. 203 possess, but not separate, such byproduct and special 11/27/00 nuclear materials as may be produced by the operation of the facility.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below:

(1) Maximum Power Level ENO is authorized to operate the facility at steady state reactor core power levels not in excess of 3216 megawatts thermal (100% of rated power).

(2) Technical Specifications The Technical Specifications contained in Appendices A, B, and C, as revised through Amendment No. 267, are hereby incorporated in the renewed license. ENO shall operate the facility in accordance with the Technical Specifications.

(3) (DELETED) Amdt. 205 2-27-01 (4) (DELETED) Amdt. 205 2-27-01 D. (DELETED) Amdt. 46 2-16-83 E. (DELETED) Amdt. 37 5-14-81 F. This renewed license is also subject to appropriate conditions by the New York State Department of Environmental Conservation in its letter granting a Section 401 certification under the Federal Water Pollution Control Act Amendments of 1972.

Amendment No. 267

Facility Operating License No. DPR-64 Appendix A - Technical Specifications TABLE OF CONTENTS 4.0 DESIGN FEATURES 4.1 Site Location 4.2 Deleted 4.3 Fuel Storage 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.2 Organization 5.3 Facility Staff Qualifications 5.4 Procedures 5.5 Programs and Manuals 5.5.1 Offsite Dose Calculation Manual (ODCM) 5.5.2 Primary Coolant Sources Outside Containment 5.5.3 NOT USED 5.5.4 Radioactive Effluent Controls Program 5.5.5 Component Cyclic or Transient Limit 5.5.6 Reactor Coolant Pump Flywheel Inspection Program 5.5.7 Inservice Testing Program 5.5.8 Steam Generator (SG) Program 5.5.9 Secondary Water Chemistry Program 5.5.10 Ventilation Filter Testing Program (VFTP) 5.5.11 Explosive Gas and Storage Tank Radioactivity Monitoring Program 5.5.12 Diesel Fuel Oil Testing Program 5.5.13 Technical Specification (TS) Bases Control Program 5.5.14 Safety Function Determination Program (SFDP) 5.5.15 Containment Leakage Rate Testing Program 5.5.16 Control Room Envelope Habitability Program 5.6 Reporting Requirements 5.6.1 NOT USED 5.6.2 Annual Radiological Environmental Operating Report 5.6.3 Radioactive Effluent Release Report 5.6.4 NOT USED 5.6.5 CORE OPERATING LIMITS REPORT (COLR) 5.6.6 NOT USED 5.6.7 Post Accident Monitoring Instrumentation (PAM) Report 5.6.8 Steam Generator Tube Inspection Report 5.7 High Radiation Area INDIAN POINT 3 iv Amendment No. 267

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions


NOTE---------------------------------------------------

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

ACTUATION LOGIC TEST An ACTUATION LOGIC TEST shall be the application of various simulated or actual input combinations in conjunction with each possible interlock logic state and the verification of the required logic output. The ACTUATION LOGIC TEST, as a minimum, shall include a continuity check of output devices.

AXIAL FLUX DIFFERENCE AFD shall be the difference in normalized flux (AFD) signals between the top and bottom halves of a two section excore neutron detector.

CERTIFIED FUEL HANDLER A CERTIFIED FUEL HANDLER is an individual who (CFH) complies with the provisions of the CERTIFIED FUEL HANDLER Training and Retraining Program required by TS 5.3.2.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel so that it responds within the required range and accuracy to known input. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, interlock, display, and trip functions. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel.

Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION shall include an inplace cross calibration that compares the other sensing elements with the (continued)

INDIAN POINT 3 1.1-1 Amendment No. 267

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions MODE (continued) vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

NON-CERTIFIED OPERATOR A NON-CERTIFIED OPERATOR is a non-licensed operator who complies with the qualification requirements of Specification 5.3.1, but is not a CERTIFIED FUEL HANDLER.

OPERABLE-OPERABILITY A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

PHYSICS TESTS PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation. These tests are:

a. Described in FSAR Chapter 13, Initial Tests and Operations;
b. Authorized under the provisions of 10 CFR 50.59; or
c. Otherwise approved by the Nuclear Regulatory Commission.

QUADRANT POWER TILT QPTR shall be the ratio of the maximum upper RATIO (QPTR) excore detector calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater.

RATED THERMAL POWER RTP shall be a total reactor core heat transfer (RTP) rate to the reactor coolant of 3216 MWt.

(continued)

INDIAN POINT 3 1.1-5 Amendment No. 267

Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site Location Indian Point 3 is located on the east bank of the Hudson River at Indian Point, Village of Buchanan, in upper Westchester County, New York. The site is approximately 24 miles north of the New York City boundary line. The nearest city is Peekskill which is 2.5 miles northeast of Indian Point.

The minimum distance from the reactor center line to the boundary of the site exclusion area and the outer boundary of the low population zone as defined in 10 CFR 100.3 is 350 meters and 1100 meters, respectively.

4.2 Deleted (continued)

INDIAN POINT 3 4.0-1 Amendment No. 267

Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.1.1 The plant manager shall be responsible for overall facility operation and shall delegate in writing the succession to this responsibility during his absence.

The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment or modification to systems or equipment that affect nuclear safety.

5.1.2 The shift manager (SM) shall be responsible for the shift command function.

INDIAN POINT 3 5.0-1 Amendment No. 267

Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established for facility staff and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear fuel.

a. Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all decommissioning organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation.

These requirements, including the facility specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications, shall be documented in the FSAR and Quality Assurance Plan, as appropriate;

b. The plant manager shall be responsible for overall safe maintenance of the facility and shall have control over those onsite activities necessary for safe storage and maintenance of nuclear fuel;
c. The corporate officer with direct responsibility for IP3 shall have corporate responsibility for the safe storage and handling of nuclear fuel and shall take any measures needed to ensure acceptable performance of the staff in maintaining and providing technical support to the facility to ensure safe management of nuclear fuel; and
d. The individuals who train the CERTIFIED FUEL HANDLERS, carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their ability to perform their assigned functions.

(continued)

INDIAN POINT 3 5.0-2 Amendment No. 267

Organization 5.2 5.2 Organization 5.2.2 Facility Staff The facility staff organization shall include the following:

a. Each duty shift shall be composed of at least one shift manager and one NON-CERTIFIED OPERATOR. The NON-CERTIFIED OPERATOR position may be filled by a CERTIFIED FUEL HANDLER.

At least one person qualified to stand watch in the control room (NON-CERTIFIED OPERATOR or CERTIFIED FUEL HANDLER) shall be present in the control room when nuclear fuel is stored in the spent fuel pool.

b. Shift crew composition may be less than the minimum requirement of 5.2.2.a for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements and all of the following conditions are met:
1) No fuel movements are in progress;
2) No movement of loads over fuel are in progress; and
3) No unmanned shift positions during shift turnover shall be permitted while the shift crew is less than the minimum.
c. An individual qualified in radiation protection procedures shall be on site during fuel handling operations and during movement of heavy loads over the fuel storage racks. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.
d. Not Used.

(continued)

INDIAN POINT 3 5.0-3 Amendment No. 267

Organization 5.2 5.2 Organization 5.2.2 Facility Staff (continued)

e. The shift manager shall be a CERTIFIED FUEL HANDLER.
f. Deleted.

INDIAN POINT 3 5.0-4 Amendment No. 267

Facility Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Facility Staff Qualifications 5.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 for comparable positions with exceptions specified in the IPEC Quality Assurance Program Manual (QAPM).

5.3.2 An NRC approved training and retraining program for CERTIFIED FUEL HANDLER shall be maintained.

INDIAN POINT 3 5.0-5 Amendment No. 267

Procedures 5.4 5.0 ADMINISTRATIVE CONTROLS 5.4 Procedures 5.4.1 Written procedures shall be established, implemented, and maintained covering the following activities:

a. The procedures applicable to the safe storage of nuclear fuel recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978 except as provided in the quality assurance program described or referenced in the Updated FSAR.
b. Deleted
c. Quality assurance for effluent and environmental monitoring;
d. Fire Protection Program implementation; and
e. All programs specified in Specification 5.5.

INDIAN POINT 3 5.0-6 Amendment No. 267

Reporting Requirements 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements 5.5.1 Offsite Dose Calculation Manual (ODCM) (continued) in which any change in the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.

5.5.2 Primary Coolant Sources Outside Containment Deleted (continued)

INDIAN POINT 3 5.0-8 Amendment No. 267

Reporting Requirements 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.

5.6.1 Not Used 5.6.2 Annual Radiological Environmental Operating Report


NOTE----------------------------------------

A single submittal may be made for a multiple unit/facility station. The submittal should combine sections common to all units/facilities at the station.

The Annual Radiological Environmental Operating Report covering the operation of the unit/facility during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the radiological environmental monitoring program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

(continued)

INDIAN POINT 3 5.0-32 Amendment No. 267

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.2 Annual Radiological Environmental Operating Report (continued)

A full listing of the information to be contained in the Annual Radiological Environmental Operating Report is provided in the ODCM.

5.6.3 Radioactive Effluent Release Report


NOTE---------------------------------------

A single submittal may be made for a multiple unit/facility station. The submittal shall combine sections common to all units/facilities at the station; however, for units/facilities with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit/facility.

The Radioactive Effluent Release Report covering the operation of the unit/facility in the previous year shall be submitted prior to May 1 of each year in accordance with 10 CFR 50.36a.

The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit/facility. The material provided shall be consistent with the objectives outlined in the ODCM and Process Control Program and in conformance with 10 CFR Part 50.36a and 10 CFR 50, Appendix I, Section IV.B.1.

5.6.4 Not Used 5.6.5 CORE OPERATING LIMITS REPORT (COLR)

a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

(continued)

INDIAN POINT 3 5.0-33 Amendment No. 267

High Radiation Area 5.7 5.0 ADMINISTRATIVE CONTROLS 5.7 High Radiation Area As provided in paragraph 20.1601(c) of 10 CFR Part 20, the following controls shall be applied to high radiation areas in place of the controls required by paragraph 20.1601(a) and (b) of 10 CFR Part 20:

5.7.1 High Radiation Areas with Dose Rates Not Exceeding 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surface Penetrated by the Radiation

a. Each entryway to such an area shall be barricaded and conspicuously posted as a high radiation area. Such barricades may be opened as necessary to permit entry or exit of personnel or equipment.
b. Access to, and activities in, each such area shall be controlled by means of Radiation Work Permit (RWP) or equivalent that includes specification of radiation dose rates in the immediate work area(s) and other appropriate radiation protection equipment and measures.
c. Individuals qualified in radiation protection procedures and personnel continuously escorted by such individuals may be exempted from the requirement for an RWP or equivalent while performing their assigned duties provided that they are otherwise following facility radiation protection procedures for entry to, exit from, and work in such areas.
d. Each individual or group entering such an area shall possess:
1. A radiation monitoring device that continuously displays radiation dose rates in the area; or
2. A radiation monitoring device that continuously integrates the radiation dose rates in the area and alarms when the device's dose alarm setpoint is reached, with an appropriate alarm setpoint, or
3. A radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area, or (continued)

INDIAN POINT 3 5.0-37 Amendment No. 267

High Radiation Area 5.7 5.0 ADMINISTRATIVE CONTROLS 5.7 High Radiation Area 5.7.2 High Radiation Areas with Dose Rates Greater than 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surface Penetrated by the Radiation, but less than 500 rads/hour at 1 Meter from the Radiation Source or from any Surface Penetrated by the Radiation

a. Each entryway to such an area shall be conspicuously posted as a high radiation area and shall be provided with a locked or continuously guarded door or gate that prevents unauthorized entry, and, in addition:
1. All such door and gate keys shall be maintained under the administrative control of the shift supervisor, radiation protection manager, or his or her designee.
2. Doors and gates shall remain locked except during periods of personnel or equipment entry or exit.
b. Access to, and activities in, each such area shall be controlled by means of an RWP or equivalent that includes specification of radiation dose rates in the immediate work area(s) and other appropriate radiation protection equipment and measures.
c. Individuals qualified in radiation protection procedures may be exempted from the requirement for an RWP or equivalent while performing radiation surveys in such areas provided that they are otherwise following facility radiation protection procedures for entry to, exit from, and work in such areas.
d. Each individual or group entering such an area shall possess:
1. A radiation monitoring device that continuously integrates the radiation rates in the area and alarms when the device's dose alarm setpoint is reached, with an appropriate alarm setpoint, or
2. A radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area with the means to communicate with and control every individual in the area, or (continued)

INDIAN POINT 3 5.0-39 Amendment No. 267

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 292 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-26 AND AMENDMENT NO. 267 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-64 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 DOCKET NOS. 50-247 AND 50-286

1.0 INTRODUCTION

By letter dated February 8, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17044A004), Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted a Notification of Permanent Cessation of Power Operations for Indian Point Nuclear Generating Unit Nos. 2 and 3 (Indian Point 2 and 3). In its letter, Entergy provided notification to the U.S. Nuclear Regulatory Commission (NRC or the Commission) of its intent to permanently cease power operations no later than April 30, 2020, and April 30, 2021, for Indian Point 2 and 3, respectively.

After certifications of permanent cessation of power operations and permanent removal of fuel from the reactor vessel for Indian Point 2 and 3 are submitted in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 licenses will no longer authorize reactor operation or the emplacement or retention of fuel into the reactor vessel.

By letter dated April 15, 2019 (ADAMS Accession No. ML19105B236), Entergy submitted a request for changes to the Indian Point 2 and 3 Technical Specifications (TSs). The proposed changes would revise certain organization, staffing, and training requirements contained in TS Section 1.1, Definitions; Section 4.0, Design Features; and Section 5.0, Administrative Controls, that will no longer be applicable once the respective Indian Point unit is shut down and permanently defueled.

By letter December 18, 2019 (ADAMS Accession No. ML19333B868), the NRC approved the certified fuel handler (CFH) training and retraining program for Indian Point 2 and 3.

Enclosure 3

2.0 REGULATORY EVALUATION

The regulatory requirements and guidance that the NRC staff considered in its review of the license amendment request are:

The regulation in 10 CFR 50.120, Training and qualification of nuclear power plant personnel, which requires the use of a systems approach to training (SAT) for certain personnel positions, including CFHs.

The regulation in 10 CFR 50.36, Technical specifications, paragraph (c)(5), which, in part, identifies that an administrative controls section shall be included in the TSs and shall include provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. Paragraph (c)(6), Decommissioning, to 10 CFR 50.36, applies to a facility that has submitted certifications required by 10 CFR 50.82(a)(1) and states, in part, that TSs involving administrative controls will be developed on a case-by-case basis.

The regulation in 10 CFR 50.54, Conditions of licenses, which, in part, discusses the conditions in every nuclear power reactor operating license issued under 10 CFR Part 50. Section 50.54(m) to 10 CFR discusses reactor operators and senior reactor operators (SROs) licensed under 10 CFR Part 55.

NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Chapter 13, Conduct of Operations, Section 13.2.2, Revision 4, Non-Licensed Plant Staff Training, dated August 2016 (ADAMS Accession No. ML15006A129), which provides guidance for the review of training programs for non-licensed plant staff.

NUREG-1431, Standard Technical Specifications Westinghouse Plants, Revision 4.0, Volume 1, Specifications, dated April 2012 (ADAMS Accession No. ML12100A222), are the Standard Technical Specifications for Westinghouse plants that provide consistency in the usage of applicable words.

NUREG-1625, Proposed Standard Technical Specifications for Permanently Defueled Westinghouse Plants, Draft Report for Comment, dated March 1998 (ADAMS Accession No. ML082330233), provides examples of TSs that the NRC staff found acceptable during previous TS reviews for permanently shutdown and defueled reactors.

The regulations in 10 CFR 50.82(a)(1) require that when a licensee has determined to permanently cease operations, the licensee shall, within 30 days, submit a written certification to the NRC, consistent with the requirements of 10 CFR 50.4(b)(8), and once fuel has been permanently removed from the reactor vessel, the licensee shall submit a written certification to the NRC that meets the requirements of 10 CFR 50.4(b)(9).

The regulations in 10 CFR 50.82(a)(2) state:

Upon docketing of the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel, or when a final legally effective order to permanently cease operations has come into effect, the 10 CFR part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel.

3.0 TECHNICAL EVALUATION

The NRC staffs review of the changes is discussed in the following sections:

(1) TS Section 1.1, Definitions (2) TS Section 4.0, Design Features (3) TS Section 5.1, Responsibility (4) TS Section 5.2, Organization (5) TS Section 5.3, Unit Staff Qualifications (6) TS Section 5.4, Procedures (7) TS Section 5.5, Program and Manuals (8) TS Section 5.6, Reporting Requirements (9) TS Section 5.7, High Radiation Area 3.1 TS 1.1 Definitions The licensee proposes to add the following two definitions to TS 1.1:

1.1 Definitions CERTIFIED FUEL HANDLER A CERTIFIED FUEL HANDLER is an individual who complies with the provisions of the CERTIFIED FUEL HANDLER Training and Retraining Program required by TS 5.3.2.

NON-CERTIFIED OPERATOR A NON-CERTIFIED OPERATOR is a non-licensed operator who complies with the qualification requirements of Specification 5.3.1, but is not a CERTIFIED FUEL HANDLER.

NRC Staff Evaluation of Proposed Changes to TS Section 1.1 TS Section 1.1 provides the definitions used within the TSs. The licensee proposes to modify this section by adding definitions for a CFH and a non-certified operator. In the letter dated April 15, 2019, Entergy submitted its CFH training and retraining program for Indian Point 2 and 3 for NRC approval. In the letter dated December 18, 2019, the NRC approved this request. The proposed definitions are added to incorporate the changes from the approval of the CFH training and retraining program and to be used throughout the rest of the proposed TSs for consistency.

Proposed TS 5.3.2 (see Section 3.5 of this safety evaluation) states that an NRC-approved

training and retraining program for CFHs shall be maintained. The NRC staff reviewed the proposed definition for a CFH and finds it acceptable.

The terminology non-certified operator is used in proposed renamed TS 5.2.2, Facility Staff (see Section 3.4 of this SE). Also, proposed renamed TS 5.3, Facility Staff Qualifications, Section 5.3.1, defines qualification requirements that are applicable to all members of the facility staff, and therefore, extend to the non-certified operator. The NRC staff reviewed the proposed definition for a non-certified operator and finds it acceptable.

NRC Staff Conclusion of Proposed Changes to TS Section 1.1 The NRC staff reviewed the proposed definitions for a CFH and non-certified operator in TS Section 1.1. The staff finds that these positions are consistently utilized throughout the TSs and align with the CFH training and retraining program as described in the licensees April 15, 2019, letter. Therefore, the staff finds the proposed changes to TS Section 1.1 acceptable.

3.2 TS Section 4.0, Design Features The licensee proposes the following changes to TS 4.2, Reactor Core, under TS Section 4.0:

4.0 DESIGN FEATURES 4.2.1 Deleted 4.2.2 Deleted NRC Staff Evaluation of Proposed Changes to TS Section 4.2 TS Section 4.2 contains design features that provide information and design requirements associated with plant systems. The licensee proposes the deletion of TS 4.2, Reactor Core, which contains the design features of the fuel assemblies and control rod assemblies. The licensee proposes to delete TS 4.2 because it will no longer apply in the permanently defueled condition. Once the certifications required by 10 CFR 50.82(a)(1)(i) and (ii) have been submitted to the NRC, fuel assemblies will no longer be authorized to be retained or emplaced in the respective Indian Point 2 and 3 reactor vessel pursuant to 10 CFR 50.82(a)(2).

NRC Staff Conclusion of Proposed Changes to TS Section 4.2 Once the certifications required by 10 CFR 50.82(a)(1)(i) and (ii) have been docketed for Indian Point 2, and subsequently Indian Point 3, fuel assemblies and control rod assemblies will not be required and will no longer be authorized to be retained or emplaced in the respective units reactor vessel, pursuant to 10 CFR 50.82(a)(2). Therefore, TS 4.2 will no longer be applicable after Entergy submits both certifications required by 10 CFR 50.82(a)(1) for the respective unit.

The NRC staff finds that the proposed deletion of TS 4.2 reflects the scope of the activities that would result from the permanent cessation of operations and permanent fuel removal, and therefore, is acceptable.

As part of the change discussed above, the licensee also proposes to delete the associated reference to Section 4.2, Reactor Core, in the table of contents. The NRC staff reviewed this

proposed change and finds it acceptable, as it does not involve any technical changes and is administrative in nature.

3.3 TS Section 5.1, Responsibility The licensee proposes the following changes to TS 5.1, Responsibility, under TS Section 5.0, Administrative Controls.

5.1 Responsibility 5.1.1 The plant manager shall be responsible for overall facility operation and shall delegate in writing the succession to this responsibility during his absence.

The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment or modification to systems or equipment that affect nuclear safety.

5.1.2 The Shift manager (SM) shall be responsible for the shift command function.

NRC Staff Evaluation of Proposed Changes to TS Section 5.1 TS Section 5.1 identifies the responsibilities for the control room command function associated with modes of plant operation and is based on personnel positions and qualifications for an operating plant. It identifies the need for a delegation of authority for command in an operating plant when the principal assignee leaves the control room.

In TS 5.1.1, Entergy proposed to change the term unit to facility. This is an administrative change to reflect that Indian Point 2, and subsequently Indian Point 3, will be permanently shut down and defueled after submitting to the NRC the certifications required by 10 CFR 50.82(a)(1)(i) and (ii) for the respective unit. The term unit implies an operating plant. The term facility more appropriately represents the permanently shutdown and defueled condition or for a site that is undergoing decommissioning. This administrative change is proposed throughout the license amendment request. In all cases this proposed change is made, but the overall Indian Point management and staff responsibilities and the description of the facility are unchanged.

Entergy proposed to change TS 5.1.2 to eliminate the mode dependency for this control room command function and personnel qualifications associated with an operating plant. The proposed change establishes the shift manager as having command of the shift. Delegation of command is unnecessary once the respective Indian Point unit is in the permanently defueled condition with fuel in the spent fuel pool (SFP). While the shift would continue to be staffed with qualified personnel consistent with proposed TS 5.2.2 (see Section 3.4 of this safety evaluation), continuous staffing of the control room by an individual with an active senior reactor operator license would not be necessary for a facility that is in a permanently shutdown and defueled condition. Any event involving loss of SFP cooling would evolve slowly enough such that no immediate response would be required to protect the health and safety of the public or facility personnel.

NRC Staff Conclusion of Proposed Changes to TS Section 5.1 The change of the term unit to facility is an administrative change. The term unit implies an operating plant. The term facility more appropriately represents a permanently shutdown and defueled condition. The change in the term to facility is consistent with NUREG-1625. Once the certifications required by 10 CFR 50.82(a)(1)(i) and (ii) have been submitted to the NRC for Indian Point 2 and 3, the 10 CFR Part 50 license for the respective unit will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel. Therefore, there will be no operational modes at Indian Point 2 and 3 after Entergy submits to the NRC both certifications required by 10 CFR 50.82(a)(1) for the respective unit. The staff finds that the delegation of control room command is unnecessary once the respective unit is in the permanently defueled condition with fuel in the SFP, since any potential event involving loss of SFP cooling is expected to evolve slowly. The overall management responsibilities are unchanged, and there remains sufficient management oversight to maintain the facility in a safe manner. The NRC staff finds that the proposed changes to TS 5.1 reflect the scope of activities that would result from the permanent cessation of operations and permanent fuel removal, and therefore, are acceptable.

3.4 TS Section 5.2, Organization The licensee proposes the following changes to TS 5.2, Organization, under TS Section 5.0, Administrative Controls.

5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established for facility staff and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear fuel.

a. Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all decommissioning organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements including the facility-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications shall be documented in the UFSAR [Updated Final Safety Analysis Report] [FSAR and Quality Assurance Plan, as appropriate, for IP3];
b. The plant manager shall be responsible for overall safe maintenance of the facility and shall have control over those onsite activities necessary for safe storage and maintenance of nuclear fuel;
c. The corporate officer with direct responsibility for IP2 [or IP3] shall have corporate responsibility for the safe storage and handling of

nuclear fuel and shall take any measures needed to ensure acceptable performance of the staff in maintaining and providing technical support to the facility to ensure safe management of nuclear fuel, and

d. The individuals who train the CERTIFIED FUEL HANDLERS, carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their ability to perform their assigned functions.

5.2.2 Facility Staff The facility staff organization shall include the following:

a. Each duty shift shall be composed of at least one shift manager and one NON-CERTIFIED OPERATOR. The NON-CERTIFIED OPERATOR position may be filled by a CERTIFIED FUEL HANDLER.

At least one person qualified to stand watch in the control room (NON-CERTIFIED OPERATOR or CERTIFIED FUEL HANDLER) shall be present in the control room when nuclear fuel is stored in the spent fuel pool.

b. Shift crew composition may be less than the minimum requirement of 5.2.2.a for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements and all of the following conditions are met:
1) No fuel movements are in progress;
2) No movement of loads over fuel are in progress; and
3) No unmanned shift positions during shift turnover shall be permitted while the shift crew is less than the minimum.
c. An individual qualified in radiation protection procedures shall be on site during fuel handling operations and during movement of heavy loads over the fuel storage racks. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.
d. Not Used.
e. The shift manager shall be a CERTIFIED FUEL HANDLER.
f. Deleted.

NRC Staff Evaluation of Proposed Changes to TS Section 5.2 In TS 5.2.1, Entergy proposes to change (1) the safety of the nuclear power plant to the safety of the nuclear fuel, (2) safe operation and maintenance of the plant to safe storage and maintenance of nuclear fuel, and (3) overall plant nuclear safety to the safe storage and handling of nuclear fuel. Once Entergy submits to the NRC the certifications required in 10 CFR 50.82(a)(1(i) and (ii) for Indian Point 2 and 3, the 10 CFR Part 50 license for the respective unit will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel. Entergy will still be responsible for the safety of the spent fuel in the SFP and/or the dry casks, as well as any handling of the spent fuel.

In TS 5.2.1, Entergy proposes to change the term unit operation to facility staff and the term plant to facility or IP2 (or IP3, as applicable); these are administrative changes. As discussed above, these administrative changes reflect that Indian Point 2 and 3 will be permanently shut down and defueled after submitting to the NRC the certifications in 10 CFR 50.82(a)(1)(i) and (ii) for the respective unit. The terms unit operation and plant imply an operating plant. The terms facility staff or facility more appropriately represent a site that is undergoing decommissioning that is permanently shut down and in a defueled condition.

TS 5.2.1.a identifies the lines of authority, responsibility, and communication. The licensee proposes to change the term operating organization to decommissioning organization and the term plant-specific to facility-specific. These are administrative changes to reflect a facility that will be in a permanently defueled condition and undergoing decommissioning.

TS 5.2.1.b identifies the organizational position responsible for the safe operation of the facility and for control of activities necessary for the safe storage and maintenance of the spent fuel.

To reflect the permanently defueled condition, the responsibility for control of activities necessary for the safe operation and maintenance of the facility is changed to the responsibility for safe storage and maintenance of the nuclear fuel. The change from the term plant to facility is administrative, as discussed above.

TS 5.2.1.c identifies the organizational position responsible for overall facility safety. Entergy proposes to change the responsibility from for overall plant nuclear safety to the safe storage and handling of nuclear fuel, and the responsibility for providing technical support to the plant to ensure nuclear safety is changed to the facility to ensure safe management of nuclear fuel.

Also, the term operating was removed, as the facility would not be in operation once permanently defueled. This appropriately reflects that Indian Point 2, and subsequently Indian Point 3, will be permanently shut down and defueled after submitting to the NRC the certifications required by 10 CFR 50.82(a)(1)(i) and (ii).

TS 5.2.1.d addresses the requirement for organizational independence of the personnel who train the operations staff, health physics personnel, and quality assurance personnel from operating pressures. Entergy proposes to replace operating staff with CERTIFIED FUEL HANDLERS and to replace their independence from operating pressures to their ability to perform their assigned functions. These changes reflect the changed function of the previous operating staff to a focus on safe handling and storage of nuclear fuel and that Indian Point 2, and subsequently Indian Point 3, will be permanently shut down and defueled after submitting to the NRC the certifications required by 10 CFR 50.82(a)(1) (i) and (ii).

In TS 5.2.2, Entergy proposes to change the term unit to facility; this is an administrative change. As discussed above, this administrative change reflects that Indian Point 2 and 3 will be permanently shut down and defueled after submitting to the NRC the certifications in 10 CFR 50.82(a)(1)(i) and (ii) for the respective unit. The term unit implies an operating plant.

The term facility more appropriately represents a permanently shutdown and defueled condition.

Current TS 5.2.2.a stipulates when non-licensed operators must be onsite or assigned to the operating shift based on the status of fuel in the reactor or operational mode. Since Indian Point 2 and 3 will no longer be authorized to operate the reactor or emplace or retain fuel in the reactor vessel once the respective units certifications in 10 CFR 50.82(a)(1) are submitted to the NRC, there will no longer be operational modes for Indian Point 2, and subsequently Indian Point 3. Entergy proposes to change the minimum requirement to a minimum crew complement of one shift supervisor and one non-certified operator.

This reflects the reduced number of systems compared to an operating reactor required to provide and support SFP cooling and monitor SFP parameters, such as SFP level and temperature, while still maintaining the ability to ensure spent fuel handling operations are carried out in a safe manner. The spectrum of credible accidents and operational events and the quantity and complexity of activities required for safety will be greatly reduced from that at an operating plant. The shift supervisor will be qualified as a CFH in accordance with proposed TS 5.2.2.e. In this position, the individual will retain command and control responsibility for operational decisions and will be responsible for the functions required for event reporting and emergency response.

Indian Point 2, and subsequently Indian Point 3, will not be required to have operators licensed pursuant to 10 CFR Part 55 once the certifications of 10 CFR 50.82(a)(1)(i) and (ii) have been submitted for the respective unit to the NRC. Entergy also proposes to change TS 5.2.2.a to reflect the requirement for having one qualified watch stander (either a non-certified operator or CFH) in the control room when fuel is stored in the SFP. This reflects the reduced requirement for control room personnel training and qualification for a facility that is no longer authorized to operate the reactor or emplacement or retention of fuel in the reactor vessel once the certifications of 10 CFR 50.82(a)(1)(i) and (ii) have been submitted to the NRC.

The training and qualification for the non-certified operator will be determined in accordance with the SAT as defined in 10 CFR 55.4. This process ensures that the non-certified operator will be qualified to perform the functions necessary to monitor and ensure safe storage of fuel.

The SAT process requires (1) systematic analysis of the jobs to be performed, (2) learning objectives to be derived from the analysis that describe desired performance after training, (3) training design and implementation to be based on the learning objectives, (4) evaluation of trainee mastery of the objectives during training, and (5) evaluation and revision of the training based on the performance of trained personnel in the job setting.

On page 8 of Enclosure 1 to the license amendment request, Entergy stated that there will be a sufficient number of individuals qualified as CFHs to staff the facility 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 7 days a week. Entergy described that additional on-shift staffing will be provided to satisfy applicable security, fire protection, and emergency preparedness requirements. The licensee stated the control room will remain the physical center of the command function; however, since control of activities may be performed either remotely from the control room or locally in the facility, the

location of the command center is functionally where the shift supervisor is located in accordance with proposed TS 5.1.2. Entergy stated that activities that could be performed from the control room that have the potential to affect forced cooling of spent nuclear fuel include starting and stopping cooling water pumps, as well as changing the electrical power distribution system alignment.

Entergy also stated in its license amendment request that all spent fuel handling activities are performed locally at the SFP. Indications and/or alarms are also received in the control room that would be indicative of SFP abnormalities. The shift supervisor is responsible for directing the response to those abnormalities from either the control room or local to the SFP in accordance with applicable facility response procedures. For any conditions, incidents, or events that occur when the non-certified operator is in the control room alone and are not within the scope of qualifications that are possessed by the non-certified operator, the shift supervisor will be immediately contacted for direction by phone, radio, and/or facility page system.

TS 5.2.2.b addresses the conditions under which the minimum shift complement may be reduced. The conditions allow for shift crew composition to be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and TSs 5.2.2.a and 5.2.2.f for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members, provided immediate action is taken to restore the shift crew composition to within the minimum requirements. Entergy proposes to remove the reference to 10 CFR 50.54(m)(2)(i), because Indian Point 2 and 3 will not return to operation once the certifications in 10 CFR 50.82(a)(1)(i) and (ii) are submitted for the respective unit to the NRC, and the requirement for licensed operating personnel will no longer be required to protect public health and safety. Entergy proposes to remove the reference to TS 5.2.2.f, as it is proposed to be deleted as part of the overall change to TS 5.2.2.

TS 5.2.2.c establishes the requirement for a person qualified in radiation protection procedures to be onsite when fuel is in the reactor. This TS section also allows for the position to be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position. Entergy proposes to revise the condition of TS 5.2.2.c so that an individual qualified in radiation protection procedures is present onsite during the movement of fuel and during the movement of loads over fuel, because fuel will not be able to be emplaced or retained in the reactor vessel for Indian Point 2 and 3 once the certifications in 10 CFR 50.82(a)(1)(i) and (ii) are submitted for the respective unit to the NRC.

There are no changes proposed by the licensee for TS 5.2.2.d.

TS 5.2.2.e establishes the requirement for the operations manager or an assistant operations manager to hold an SRO license. Entergy proposes to revise TS 5.2.2.e to replace the requirement with a requirement that the shift manager be a CFH. Once the certifications in 10 CFR 50.82(a)(1)(i) and (ii) for Indian Point 2 and 3 have been submitted to the NRC, the requirements of 10 CFR 50.54(m) will no longer be applicable, because the 10 CFR Part 50 license for the respective unit will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel. These certifications also obviate the need for the operators licenses specified in 10 CFR Part 55. Therefore, there is no longer a need for operations management staff to hold an SRO license. Replacing this with a requirement that the control room shift supervisor be a CFH ensures that the senior individual on shift is

appropriately trained and qualified in accordance with the NRC-approved fuel handler training and retraining program to supervise shift activities. The Indian Point 2 and 3 management structure will not require positions above the control room shift supervisor to be a CFH or attend equivalent training. Entergy stated that once Indian Point 2, and subsequently Indian Point 3, are permanently shut down and defueled, the time available to mitigate credible events is expected to be greater than that for current design-basis events. As such, Entergy stated that Indian Point 2 and 3 management oversight of the facility can be performed by individuals meeting the applicable requirements of American National Standards Institute (ANSI)/American Nuclear Society (ANS) 3.1-1978 (as required by TS 5.3.1) and need not be qualified as CFHs.

TS 5.2.2.f establishes the requirements for a technical advisor position. Entergy proposes to delete TS 5.2.2.f because this position is only required for a plant authorized for power operations. Once the certifications required by 10 CFR 50.82(a)(1)(i) and (ii) have been submitted to the NRC for Indian Point 2 and 3, the requirements of TS 5.2.2.f will no longer be applicable, because the 10 CFR Part 50 license for the respective unit will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel.

NRC Staff Conclusion of Proposed Changes to TS Section 5.2 Once the certifications required by 10 CFR 50.82(a)(1)(i) and (ii) have been submitted to the NRC for Indian Point 2 and 3, the 10 CFR Part 50 license for the respective unit will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel. The proposed changes to the Indian Point 2 and 3 organization reflect the fact that the respective unit will be permanently defueled so the focus is changed from operating nuclear safety to the safe storage and handling of nuclear fuel. Once the respective Indian Point unit is permanently shut down and defueled, the time available to mitigate credible events is expected to be greater than that for current design-basis events.

In TS Section 5.2, administrative changes have been made to remove words associated with plant operation. These changes have been made to reflect the new function of the facility to safely store spent nuclear fuel. In addition, the operating staff are now considered CFHs in accordance with an approved CFR training and retraining program. Operators no longer have licenses, and CFHs are adequately trained to address all facility functions. The change also reflects the requirement for having a qualified watch stander who is either a non-certified operator or a CFH in the control room when fuel is stored in the SFP. This reflects the reduced requirement for control room personnel training and qualification for a plant authorized for storage of nuclear fuel only.

The NRC staff reviewed the proposed changes to TS 5.2 and finds that they reflect the scope of the activities that would result from the permanent cessation of operations and permanent fuel removal, and therefore, are acceptable.

3.5 TS Section 5.3, Unit Staff Qualifications The licensee proposes the following changes to TS 5.3 under TS Section 5.0, Administrative Controls:

5.3 Facility Staff Qualifications 5.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 for comparable positions with exceptions specified in the IPEC Quality Assurance Program Manual (QAPM).

5.3.2 An NRC approved training and retraining program for CERTIFIED FUEL HANDLERS shall be maintained.

NRC Staff Evaluation of the Proposed Changes to TS Section 5.3 The proposed change to TS 5.3 from unit to facility is an administrative change. As discussed above, this administrative change reflects that Indian Point 2 and 3 will be permanently shut down and defueled after submitting to the NRC the certifications in 10 CFR 50.82(a)(1)(i) and (ii) for the respective unit. The term unit implies an operating plant.

The term facility more appropriately represents a permanently shutdown and defueled condition or a site that is undergoing decommissioning.

In TS 5.3.1, Entergy proposes to revise the title of the Quality Assurance Program Manual (QAPM) by removing specific reference to the Entergy corporate QAPM. This change will allow Indian Point 2 and 3 to transition from the Entergy corporate QAPM to a site-specific QAPM during the decommissioning process. Entergy does not propose to change the qualification standards or exceptions to the standards. The proposed change is acceptable based on the licensee maintaining the requisite requirements to the minimum qualifications of staff, including any exceptions identified in the currently approved corporate QAPM in the facility site-specific QAPM to be used during the decommissioning process. Any changes to the QAPM will be required to be submitted to the NRC in accordance with the applicable provisions of 10 CFR 50.54(a).

TS 5.3.2 defines SROs and reactor operators as the individuals who perform the functions defined in the regulations in 10 CFR 50.54(m). Entergy proposes to delete this statement, because neither 10 CFR 50.54(m) nor the requirement for licensed operators per 10 CFR Part 55 apply following the submittal of the certifications in 10 CFR 50.82(a)(1).

Entergy proposes to add new language to TS 5.3.2 to require that an NRC-approved fuel handler training and retraining program for the CFHs be maintained. The CFH training and retraining program approved by the NRC ensures that the qualifications of CFHs are commensurate with the tasks to be performed and the conditions requiring response. The regulation in 10 CFR 50.120 requires training programs to be derived using a SAT as defined in 10 CFR 55.4. Although the requirements of 10 CFR 50.120 apply to holders of an operating license issued under 10 CFR Part 50, and the Indian Point 2 and 3 licenses will no longer authorize operation following submittal of the certifications required by 10 CFR 50.82(a)(1)(i) and (ii) for the respective unit, the CFH training and retraining program nonetheless aligns with those requirements. The CFH training and retraining program provides adequate confidence that appropriate SAT-based training of personnel who will perform the duties of a CFH is conducted to ensure the facility is maintained in a safe and stable condition.

NRC Staff Conclusion of the Proposed Changes to TS Section 5.3 Once the certifications required by 10 CFR 50.82(a)(1)(i) and (ii) have been submitted to the NRC for Indian Point 2 and 3, the 10 CFR Part 50 license for the respective unit will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel. The proposed changes to the Indian Point facility staff qualifications reflect the fact that Indian Point 2, and subsequently Indian Point 3, will be permanently defueled so the focus is changed from operating nuclear safety to the safe storage and handling of nuclear fuel. Once the respective Indian Point unit is permanently shut down and defueled, the time available to mitigate credible events is expected to be greater than that for current design-basis events. The NRC staff reviewed the proposed changes to TS 5.3 and finds that they reflect the scope of the activities that would result from the permanent cessation of operations and permanent fuel removal, and therefore, are acceptable.

3.6 TS Section 5.4, Procedures The licensee proposes the following changes to TS 5.4 under TS Section 5.0, Administrative Controls 5.4 Procedures 5.4.1 Written procedures shall be established, implemented, and maintained covering the following activities:

a. The procedures applicable to the safe storage of nuclear fuel recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978 except as provided in the quality assurance program described or referenced in the Updated FSAR;
b. Deleted NRC Staff Evaluation of the Proposed Changes to TS Section 5.4 TS 5.4 provides a description and requirements regarding administration of written procedures and will remain applicable with the reactor permanently defueled. As such, it is retained and revised to reflect a permanently defueled condition. Relevant procedures drawings and instructions will continue to be controlled per 10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, Criterion VI, Document Control. Activities involving security and emergency planning and preparedness will continue to be controlled by procedure.

In TS 5.4.1.a, Entergy proposes to revise the applicability for this TS to reflect the procedures applicable to the safe storage of nuclear fuel as recommended in Regulatory Guide 1.33, Revision 2, Appendix A, except as provided in the quality assurance program or in the Updated Final Safety Analysis Report. Since operating and refueling the reactor will both be prohibited by the 10 CFR Part 50 licenses once the certifications in 10 CFR 50.82(a)(1)(i) and (ii) have been submitted to the NRC for Indian Point 2 and 3, procedures associated with these activities will no longer need to be maintained for the respective unit. Procedures governing fuel handling operations will provide the guidance necessary to ensure safe handling of spent fuel in the SFP

and transfer from the SFP to dry fuel storage casks. Procedures governing responses to fuel handling accidents, personnel injuries, SFP events, and external events provide the necessary guidance to mitigate the consequences of such events. No change to Indian Point 2 and 3 actions in response to a fuel handling accident is proposed by the licensee.

TS 5.4.1.b requires emergency operating procedures that implement the requirements of NUREG-0737, Clarification of TMI [Three Mile Island] Action Plan Requirements, dated November 1980 (ADAMS Accession No. ML051400209), and NUREG-0737, Supplement 1, TMI Action Plan Requirements, Requirements for Emergency Response Capability, dated February 1989 (ADAMS Accession No. ML102560009), as stated in Generic Letter 82-33, Supplement 1 to NUREG-0737 - Requirements for Emergency Response Capability, dated December 17, 1982. This TS is proposed to be deleted, as Generic Letter 82-33 was only addressed to licensees of operating reactors, applicants for operating licenses, and holders of construction permits, none of which will apply to Indian Point 2 and 3 in the permanently defueled condition. Procedures governing the site response to accidents, events and injuries will provide the necessary guidance to mitigate the consequences of such events.

There are no changes proposed by the licensee for TS 5.4.1.c through f.

NRC Staff Conclusion of the Proposed Changes to TS 5.4 Once the certifications required by 10 CFR 50.82(a)(1)(i) and (ii) have been submitted to the NRC for Indian Point 2 and 3, the 10 CFR Part 50 license for the respective unit will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel. The proposed changes to the facility procedures reflect the fact that Indian Point 2 and 3 will be permanently defueled so the focus is changed from operating nuclear safety to the safe storage and handling of nuclear fuel. Once the respective Indian Point unit is permanently shut down and defueled, the time available to mitigate credible events is expected to be greater than that for current design-basis events. The NRC staff reviewed the proposed changes to TS 5.4 and finds that they reflect the scope of the activities that would result from the permanent cessation of operations and permanent fuel removal and, therefore, are acceptable.

3.7 TS Section 5.5, Programs and Manuals The licensee proposes the following changes to TS 5.5 under TS Section 5.0, Administrative Controls 5.5 Programs and Manuals 5.5.2 Primary Coolant Sources Outside Containment Deleted NRC Staff Evaluation of the Proposed Changes to TS Section 5.5 The NRC staff reviewed the proposed deletion of TS 5.5.2. This section provides a description and requirements regarding programs and manuals that are to be established, implemented, and maintained. TS 5.5 will remain applicable with the reactor permanently defueled. As such, it is retained and revised to reflect a permanently defueled condition. For TS 5.5.2, the Primary

Coolant Sources Outside Containment program was established to minimize leakage from portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident. Entergy proposes to delete this program, because these conditions can no longer exist for a permanently defueled facility.

NRC Staff Conclusion of the Proposed Change to TS Section 5.5 Once the certifications in 10 CFR 50.82(a)(1)(i) and (ii) have been submitted to the NRC for Indian Point 2 and 3, the 10 CFR Part 50 license for the respective unit will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel. The TS for the primary coolant sources outside containment program will be deleted because Indian Point 2, and subsequently Indian Point 3, will be permanently shut down and defueled. The safety focus is changed from operating nuclear safety to the safe storage and handling of nuclear fuel. Once the respective Indian Point unit is permanently shut down and defueled, the time available to mitigate credible events is expected to be greater than that for current design-basis events. The NRC staff reviewed the proposed changes to TS 5.5.2 and finds that they reflect the scope of the activities that would result from the permanent cessation of operations and permanent fuel removal, and therefore, are acceptable.

3.8 TS Section 5.6, Reporting Requirements The licensee proposes the following changes to TS 5.6 under TS Section 5.0, Administrative Controls:

5.6 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.

5.6.2 Annual Radiological Environmental Operating Report


NOTE ----------------------------------------------

A single submittal may be made for a multiple unit/facility station. The submittal should combine sections common to all units/facilities at the station.

The Annual Radiological Environmental Operating Report covering the operation of the unit/facility during the previous calendar year shall be submitted by May 15 of each year 5.6.3 Radioactive Effluent Release Report


NOTE ----------------------------------------

A single submittal may be made for a multiple unit/facility station. The submittal shall combine sections common to all units/facilities at the station; however, for units/facilities with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit/facility.

The Radioactive Effluent Release Report covering the operation of the unit/facility in the previous year shall be submitted prior to May 1 of each year in accordance with 10 CFR 50.36a. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit/facility NRC Staff Evaluation of the Proposed Changes to TS Section 5.6 The NRC staff reviewed the proposed changes to TS 5.6. In TSs 5.6.2 and 5.6.3, Entergy proposes to change the term unit to unit/facility and the term units to units/facilities, as applicable. As discussed above, this administrative change reflects that Indian Point 2 and 3 will be permanently shut down and defueled after submitting to the NRC the certifications in 10 CFR 50.82(a)(1)(i) and (ii) for the respective unit. The term unit implies an operating plant.

The term facility more appropriately represents a permanently shutdown and defueled condition. Additionally, the term unit/facility is proposed since Indian Point 2 will be shut down before Indian Point 3; therefore, one facility will be permanently defueled while the other unit will still be in operation.

NRC Staff Conclusion of the Proposed Changes to TS Section 5.6 The proposed changes to TSs 5.6.2 and 5.6.3 are administrative, and the NRC staff finds the proposed changes to TSs 5.6.2 and 5.6.3 acceptable since they involve no technical changes.

3.9 TS Section 5.7, Reporting Requirements The licensee proposes the following changes to TS 5.7 under TS Section 5.0, Administrative Controls:

5.7 High Radiation Area 5.7.1.c Individuals qualified in radiation protection procedures and personnel continuously escorted by such individuals may be exempted from the requirement for an RWP [radiation work permit] or equivalent while performing their assigned duties provided that they are otherwise following facility radiation protection procedures for entry to, exit from, and work in such areas.

5.7.2.c Individuals qualified in radiation protection procedures may be exempted from the requirement for an RWP or equivalent while performing radiation surveys in such areas provided that they are otherwise following facility radiation protection procedures for entry to, exit from, and work in such areas.

NRC Staff Evaluation of the Proposed Changes to TS 5.7 The NRC staff reviewed the proposed changes to TS 5.7. In TSs 5.7.1.c and 5.7.2.c, Entergy proposes to replace the term plant with the term facility. As discussed above, this administrative change reflects that Indian Point 2 and 3 will be permanently shut down and

defueled after submitting to the NRC the certifications in 10 CFR 50.82(a)(1)(i) and (ii) for the respective unit. The term plant implies an operating plant. The term facility more appropriately represents a permanently shutdown and defueled condition.

NRC Staff Conclusion of the Proposed Changes to TS 5.7 Once the certifications required by 10 CFR 50.82(a)(1)(i) and (ii) have been submitted to the NRC for Indian Point 2 and 3, the 10 CFR Part 50 license for the respective unit will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel. The NRC staff reviewed the proposed changes to TS 5.7 and finds that they reflect the scope of the activities that would result from the permanent cessation of operations and permanent fuel removal, and therefore, are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the New York State official was notified of the proposed issuance of the amendments on March 2, 2020. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on June 18, 2019 (84 FR 28343). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: M. Keefe-Forsyth A. Russell R. Guzman Date: April 10, 2020

ML20071Q717 *by e-mail OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DIRS/IRAB/BC* NRR/DSS/STSB/BC*

NAME RGuzman LRonewicz AMasters VCusumano DATE 03/20/2020 03/20/2020 08/06/2019 11/22/2019 OFFICE OGC - NLO* NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME AGhosh-Naber JDanna RGuzman DATE 04/01/2020 04/09/2020 04/10/2020