NL-14-122, Indian Point, Unit 2 - Proposed License Amendment Regarding an Exigent Change to Technical Specification 3.8.6 Station Battery Surveillance

Indian Point, Unit 2 - Proposed License Amendment Regarding an Exigent Change to Technical Specification 3.8.6 Station Battery Surveillance

ML14259A329
Person / Time
Site:	Indian Point
Issue date:	09/15/2014
From:	Ventosa J A Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML14259A331	List: ML14259A328 ML14259A329 NL-14-122, Indian Point, Unit 2 - Proposed License Amendment Regarding an Exigent Change to Technical Specification 3.8.6 Station Battery Surveillance
References
NL-14-122
Download: ML14259A329 (14)

Text

i nEntera Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 John A Ventosa Site Vice President September 15, 2014 NL-14-122 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738

SUBJECT:

Proposed License Amendment Regarding An Exigent Change to Technical Specification 3.8.6 Station Battery Surveillance Indian Point Unit Number 2 Docket No. 50-247 License No. DPR-26

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc, (Entergy) hereby requests a License Amendment to Operating License DPR-26, Docket No. 50-247 for Indian Point Nuclear Generating Unit No. 2 (IP2). This exigent change is requested to revise the acceptance criteria for the Surveillance Requirement (SR) 3.8.6.6 for the 22 Battery. The 22 Battery met the SR 3.8.6.6 during its performance on March 7, 2014. However, questions were raised during a recent PI&R Sample Inspection about the continued operability of the Battery until the next surveillance test to be performed by March 7, 2015. If the 22 Battery no longer meets the SR 3.8.6.6, then SR 3.0.1 requires the battery to be declared inoperable even though it complies with applicable IEEE requirements until the next scheduled surveillance.

The questions are based on a concern that the 22 Battery will degrade and no longer meet SR 3.8.6.6 before the next scheduled test and therefore must be demonstrated to meet the criteria to ensure strict TS compliance.

The test cannot be done in Modes 1, 2, 3 or 4 and if the SR no longer meets SR 3.8.6.6, then SR 3.0.1 requires the battery to be declared inoperable.

Foreseeing that compliance with the SR is in question and there would be a need to revise the surveillance acceptance criteria or shut down the plant prior to the next scheduled surveillance could not reasonably have been foreseen or anticipated.

An evaluation performed by Entergy has concluded that the SR will be met until September 25, 2014. Therefore, Entergy requests approval of the proposed amendment on an exigent basis by September 24, 2014 in order to resolve this issue. Entergy believes this request meets the criteria of 10 CFR 50.91 (a)(6) where the proposed change involves no significant hazards considerations and that time does not permit the Commission to publish a Federal Register notice allowing 30 days for prior public comment.cLt -" "7..\ 4r_

NL-14-122 Docket No. 50-247 Page 2 of 2 Entergy has evaluated the proposed change in accordance with 10 CFR 50.91(a){5) using the criteria of 10 CFR 50.92 (c) and has determined that this proposed change involves no significant hazards considerations.

Attachment 1 includes this evaluation and describes the circumstances surrounding this request, including how this request satisfies the exigent change criteria, and that the situation could not have been avoided. The proposed Technical Specification and, for information, the planned Bases changes are provided in Attachments 2 and 3, respectively.

A copy of this application and the associated attachments are being submitted to the designated New York State official in accordance with 10 CFR 50.91. There are no new commitments being made in this submittal.

If you have any questions or require additional information, please contact Mr. Robert Walpole, Manager, Regulatory Affairs at (914) 254-6710.

I de are under penalty of perjury that the foregoing is true and correct. Executed on September

--1---' 2014. Sincerely, Attachments:

1. Analysis of Proposed Exigent Technical Specification Change Regarding Change to Surveillance Requirement 3.8.6.6 2. Markup of Technical Specification Change to Surveillance Requirement 3.8.6.6 3. Markup of TS Bases 3.8.4 and 3.8.6 Changes Associated with Surveillance Requirement 3.8.6.6 Revision Calculation IP-CALC-14-00028 -Station Battery System Calculation-Analysis Variation with an Battery Aged to 80% Capacity