NL-05-065, Application for a Technical Specification Change to Add LCO 3.0.8 on the Inoperability of Snubbers Using the Consolidated Line Item Improvement Process (TSTF-372)

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Application for a Technical Specification Change to Add LCO 3.0.8 on the Inoperability of Snubbers Using the Consolidated Line Item Improvement Process (TSTF-372)
ML051660267
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 06/08/2005
From: Dacimo F
Entergy Nuclear Northeast
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-05-065
Download: ML051660267 (25)
v • d • e


Text

Enteray Nuclear Northeast Indian Point Energy Center 295 Broadway, Suite 1 P.O. Box 249 O. ,

isg Buchanan, NY 10511-0249 Fred Dacimo Site Vice President Tel 914 734 6700 June 8, 2005 Re: Indian Point Units 2 & 3 Docket Nos. 50-247 & 50-286 NL-05-065 Document Control Desk U.S. Nuclear Regulatory Commission Mail Stop O-PI-17 Washington, DC 20555-0001

Subject:

Application for a Technical Specification Change to Add LCO 3.0.8 on the Inoperability of Snubbers Using the Consolidated Line Item Improvement Process (TSTF-372)

Reference:

1) Technical Specification Task Force (TSTF) Improved Technical Specification Change Traveler, TSTF-372, "Addition of LCO 3.0.8, Inoperability of Snubbers," Revision 4.
2) Federal Register Notice 70 FR 23252, "Notice of Availability of Model Application Concerning Technical Specification Improvement to Modify Requirements Regarding the Addition of Limiting Condition for Operation 3.0.8 on the Inoperability of Snubbers Using the Consolidated Line Item Improvement Process," dated May 4, 2005.

Dear Sir:

Pursuant to I OCFR50.90, Entergy Nuclear Operations, Inc. (Entergy) is submitting a request for an amendment to the Technical Specifications (TS) for Indian Point Unit 2 (IP2) and Indian Point Unit 3 (IP3).

The proposed amendment would modify TS requirements for inoperable snubbers by adding LCO 3.0.8 . The changes are consistent with Revision 4 of NRC-approved Industry/Technical Specification Task Force (TSTF) Improved Technical Specification Change Traveler, TSTF-372, (Reference 1) and FederalRegister Notice 70 CFR 23252 (Reference 2). The availability of this TS improvement was announced in the FederalRegister on May 4, 2005 as part of the consolidated line item improvement process (Reference 2).

NL-05-065 Docket 50-247 & 50-286 Page 2 of 3 provides a description and assessment of the proposed change including a confirmation of applicability and plant-specific verifications and commitments. Attachment 2 provides the existing TS pages marked-up to show the proposed change. Attachment 3 provides revised (clean) TS pages. Attachment 4 provides a summary of the regulatory commitments made in this submittal. Attachment 5 provides the existing TS Bases pages marked up to show the proposed change (for information only).

Entergy requests approval of the proposed License Amendment by November 2005, with the amendment being implemented within 60 days.

In accordance with 10 CFR 50.91, a copy of this application, with attachments is being provided to the designated New York State official.

If you have any questions or require additional information, please contact Mr. Patric W. Conroy Manager, Licensing at (914) 734-6668.

I declare under penalty of perjury that the foregoing is true and correct. Executed on 06/08/2005.

Sir Fred R. Dacimo Site Vice President Indian Point Energy Center cc: next page

NL-05-065 Docket 50-247 & 50-286 Page 3 of 3 cc: Mr. John P. Boska, Sr. Project Manager Project Directorate I Division of Licensing Project Management U.S. Nuclear Regulatory Commission Mr. Samuel J. Collins Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission Resident Inspector's Office Indian Point Unit 2 U.S. Nuclear Regulatory Commission Resident Inspector's Office Indian Point Unit 3 U.S. Nuclear Regulatory Commission Mr. Peter R. Smith, President New York State Energy, Research and Development Authority Mr. Paul Eddy New York State Dept. of Public Service

ATTACHMENT 1 TO NL-05-065 DESCRIPTION AND ASSESSMENT APPLICATION FOR TECHNICAL SPECIFICATION CHANGE TO ADD LCO 3.0.8 FOR THE INOPERABILITY OF SNUBBERS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NO. 50-247 AND 50-286

Attachment 1 to NL-05-065 Docket 50-247 and 50-286 Page 1 of 2

1.0 DESCRIPTION

The proposed amendment would modify Technical Specification (TS) requirements for inoperable snubbers by adding LCO 3.0.8 for both Indian Point Unit 2 (IP2) and Indian Point Unit 3 (IP3).

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/

Technical Specification Task Force (TSTF) change TSTF-372, "Addition of LCO 3.0.8, Inoperability of Snubbers," Revision 4 and FederalRegister Notice 70 CFR 23252. The availability of this TS improvement was published in the FederalRegister on May 4, 2005 as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT 2.1 Applicabilitv of Published Safety Evaluation Entergy has reviewed the model safety evaluation published on May 4, 2005 (70 FR 23252) as part of the CLIIP. This review included a review of the NRC staffs evaluation, as well as the supporting information provided to support TSTF-372, Revision 4. Entergy has concluded that the justifications presented in the TSTF proposal and the model safety evaluation prepared by the NRC staff are applicable to IP2 and IP3 and justify this amendment for the incorporation of the changes to the respective plant Technical Specifications.

2.2 Optional Changes and Variations Entergy is not proposing any variations or deviations from the TS changes described in the TSTF-372, Revision 4 or the NRC staff's model safety evaluation published on May 4, 2005 (70 FR 23252).

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Entergy has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the FederalRegisteras part of the CLIIP. Entergy has concluded that the proposed NSHCD presented in the FederalRegisternotice is applicable to IP2 and IP3, and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Verification and Commitments As discussed in the notice of availability published in the FederalRegister on May 4, 2005 for this TS improvement, plant-specific verifications were performed as follows:

Attachment 1 to NL-05-065 Docket 50-247 and 50-286 Page 2 of 2 Entergy has established TS Bases for LCO 3.0.8 which provide guidance and details on how to implement the new requirements. LCO 3.0.8 requires that risk be managed and assessed. The Bases also state that while the Industry and NRC guidance on implementation of 10 CFR 50.65(a)(4), the Maintenance Rule, does not address seismic risk, LCO 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, but may be a qualitative assessment of vulnerability of systems and components when one or more snubbers are not able to perform their associated support function. provides the regulatory commitment made in this submittal.

4.0 ENVIRONMENTAL EVALUATION Entergy has reviewed the environmental evaluation included in the model safety evaluation published on May 4, 2005 (70 FR 23252) as part of the CLIIP. Entergy has concluded that the staff's findings presented in that evaluation are applicable to IP2 and IP3, and the evaluation is hereby incorporated by reference for this application.

ATTACHMENT 2 TO NL-05-065 PROPOSED TECHNICAL SPECIFICATION CHANGES APPLICATION FOR TECHNICAL SPECIFICATION CHANGE TO ADD LCO 3.0.8 FOR THE INOPERABILITY OF SNUBBERS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS Indian Point 2:

Page 3.0-1 Page 3.0-3 Indian Point 3:

Page 3.0-1 Page 3.0-3 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NO. 50-247 AND 50-286

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2,& LCO 3.0.7 LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:

a. MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />,
b. MODE 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, and
c. MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; INDIAN POINT 2 3.0 - 1 Amendment No. 238

LCO Applicability 3.0 3.0 LCO Applicability LCO 3.0.7 Test Exception LCO 3.1.8 allows specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.

-XJb R INDIAN POINT 2 3.0 - 3 Amendment No. 238

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 LCO 3.0.7.*¢ .4 L LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:

a. MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />;
b. MODE 4 within 13 hour1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />s: and
c. MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1. 2, 3. and 4.

(continued)

INDIAN POINT 3 3.0-1 Amendment 205

LCO Applicability 3.0 3.0 LCO APPLICABILITY (continued)

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.14. "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

LCO 3.0.7 Test Exception LCOs, such as 3.1.8, allow specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. When a Test Exception LCO isdesired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition inthe Applicability shall be made in accordance with the other applicable Specifications.

_IJSR I INDIAN POINT 3 3.0-3 Amendment 205

INSERT 1 (Applicable to Technical Specification Page 3.0-3 for IP2 and 1P3)

LCO 3.0.8 When one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:

a. the snubbers not able to perform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; or
b. the snubbers not able to perform their associated support function(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affected supported system LCO(s) shall be declared not met.

ATTACHMENT 3 TO NL-05-065 PROPOSED TECHNICAL SPECIFICATION PAGES APPLICATION FOR TECHNICAL SPECIFICATION CHANGE TO ADD LCO 3.0.8 FOR THE INOPERABILITY OF SNUBBERS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS Indian Point 2:

Page 3.0-1 Page 3.0-3 Indian Point 3:

Page 3.0-1 Page 3.0-3 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NO. 50-247 AND 50-286

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, and LCO 3.0.8.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:

a. MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />,
b. MODE 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, and
c. MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; INDIAN POINT 2 3.0 - 1 Amendment No. 238

LCO Applicability 3.0 3.0 LCO Applicability LCO 3.0.7 Test Exception LCO 3.1.8 allows specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.

LCO 3.0.8 When one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:

a. the snubbers not able to perform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; or
b. the snubbers not able to perform their associated support function(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affected supported system LCO(s) shall be declared not met.

INDIAN POINT 2 3.0- 3 Amendment No. 238

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7 and LCO 3.0.8.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified completion Time(s),

completion of the Required Action(s) is not required unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:

a. MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />;
b. MODE 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and
c. MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Exceptions to this specification are stated in the individual specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

(continued)

INDIAN POINT 3 3.0 - 1 Amendment 205

LCO Applicability 3.0 3.0 LCO APPLICABILITY (continued)

LCO 3.0.6 when a supported system LCO is not met solely due to a support system LCO not being met, the conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.14, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

when a support system's Required Action directs a supported system to be declared inoperable or directs entry into conditions and Required Actions for a supported system, the applicable conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

LCO 3.0.7 Test Exception LCOS, such as 3.1.8, allow specified Technical specification (TS) requirements to be changed to permit performance of special tests and operations.

unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. when a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable specifications.

LCO 3.0.8 when one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be declared not met so lely for this reason if risk is assessed and managed, and:

a. the snubbers not able to perform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; or
b. the snubbers not able to perform their associated support function(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affected supported system LCO(S) shall be declared not met.

INDIAN POINT 3 3.0 - 3 Amendment 205

ATTACHMENT 4 TO NL-05-065 LIST OF REGULATORY COMMITMENTS APPLICATION FOR TECHNICAL SPECIFICATION CHANGE TO ADD LCO 3.0.8 FOR THE INOPERABILITY OF SNUBBERS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NO. 50-247 AND 50-286

Attachment 4 to NL-05-065 Docket 50-247 and 50-286 Page 1 of 1 The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

Number Commitment Due Date NL-05-065-CO1 Entergy will establish the Technical 60 days following NRC (for IP2) Specification Bases for LCO 3.0.8 as approval of the License adopted with the applicable license Amendment Request COM-05-00014 amendment (for IP3) I

ATTACHMENT 5 TO NL-05-065 PROPOSED CHANGES TO TECHNICAL SPECIFICATION BASES PAGES APPLICATION FOR TECHNICAL SPECIFICATION CHANGE TO ADD LCO 3.0.8 FOR THE INOPERABILITY OF SNUBBERS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS Indian Point 2:

Page B 3.0-1 Page B 3.0-11 Indian Point 3:

Page B 3.0-1 Page B 3.0-9 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NO. 50-247 AND 50-286

LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES (0

LCOs LCO 3.0.1 through LCO 3.0= establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e.,

when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered. The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:

a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification and
b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.

INDIAN POINT 2 B 3.0 - 1 Revision 0

LCO Applicability B 3.0 BASES LCO 3.0.7 (continued)

The Applicability of a Test Exception LCO represents a condition not necessarily in compliance with the normal requirements of the TS.

Compliance with Test Exception LCOs is optional. A special operation may be performed either under the provisions of the appropriate Test Exception LCO or under the other applicable TS requirements. If it is desired to perform the special operation under the provisions of the Test Exception LCO, the requirements of the Test Exception LCO shall be followed.

\,~-

INDIAN POINT 2 B 3.0 - 1 1 Revision 0

LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES (C LCOs LCO 3.0.1 through LCO 3.06 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered. The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:

a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and
b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met.

This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.)

(continued)

INDIAN POINT 3 B 3.0 - I Revision 1

LCO Applicability B 3.0 BASES LCO 3.0.6 Cross train checks to identify a loss of safety function for (continued) those support systems that support multiple and redundant safety systems are required. The cross train check verifies that the supported systems of the redundant OPERABLE support system are OPERABLE, thereby ensuring safety function is retained. If this evaluation determines that a loss of safety function exists, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

LCO 3.0.7 There are certain special tests and operations required to be performed at various times over the life of the unit. These special tests and operations are necessary to demonstrate select unit performance characteristics, to perform special maintenance activities, and to perform special evolutions. Test Exception LCOs, such as LCO 3.1.8, allow specified Technical Specification (TS) requirements to be changed to permit performances of these special tests and operations, which otherwise could not be performed if required to comply with the requirements of these TS. Unless otherwise specified, all the other TS requirements remain unchanged.

This will ensure all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed to perform the special test or operation will remain in effect.

The Applicability of a Test Exception LCO represents a condition not necessarily in compliance with the normal requirements of the TS.

Compliance with Test Exception LCOs is optional. A special operation may be performed either under the provisions of the appropriate Test Exception LCO or under the other applicable TS requirements. If it is desired to perform the special operation under the provisions of the Test Exception LCO, the requirements of the Test Exception LCO shall be followed.

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-2<1 I INDIAN POINT 3 B 3.0 - 9 Revision 1

INSERT 1 (Applicable to Technical Specification Bases Pages 3.0-11 and B 3.0-9 for IP2 and 1P3 respectively)

LCO 3.0.8 LCO 3.0.8 establishes conditions under which systems are considered to remain capable of performing their intended safety function when associated snubbers are not capable of providing their associated support function(s). This LCO states that the supported system is not considered to be inoperable solely due to one or more snubbers not capable of performing their associated support function(s).

This is appropriate because a limited length of time is allowed for maintenance, testing, or repair of one or more snubbers not capable of performing their associated support function(s) and appropriate compensatory measures are specified in the snubber requirements, which are located outside of the Technical Specifications (TS) under licensee control. The snubber requirements do not meet the criteria in 10 CFR 50.36(c)(2)(ii), and, as such, are appropriate for control by the licensee.

Ifthe allowed time expires and the snubber(s) are unable to perform their associated support function(s), the affected supported system's LCO(s) must be declared not met and the Conditions and Required Actions entered in accordance with LCO 3.0.2.

LCO 3.0.8.a applies when one or more snubbers are not capable of providing their associated support function(s) to a single train or subsystem of a multiple train or subsystem supported system or to a single train or subsystem supported system. LCO 3.0.8.a allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function and due to the availability of the redundant train of the supported system.

LCO 3.0.8.b applies when one or more snubbers are not capable of providing their associated support function(s) to more than one train or subsystem of a multiple train or subsystem supported system. LCO 3.0.8.b allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function.

LCO 3.0.8 requires that risk be assessed and managed. Industry and NRC guidance on the implementation of 10 CFR 50.65(a)(4) (the Maintenance Rule) does not address seismic risk. However, use of LCO 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, but may be a qualitative awareness of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function.

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