Text

License Amendment Request - Application for Technical Specification Change (TSTF-427) to Add LCO 3.0.9 Regarding the Unavailability of Barriers Using the Consolidated Line Item Improvement Process
	ML13345B160
Person / Time
Site:	Palisades
Issue date:	12/11/2013
From:	Vitale A; Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	PNP 2013-076
	Download: ML13345B160 (25)
	v • d • e

..*:::>>Entergy Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 Tel 269 764 2000 Anthony J. Vitale Site Vice President PNP 2013-076 December 11 , 2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

License Amendment Request - Application for Technical Specification Change (TSTF-427) to Add LCO 3.0.9 Regarding the Unavailability of Barriers Using the Consolidated Line Item Improvement Process Palisades Nuclear Plant Docket 50-255 License No. DPR-20

Dear Sir or Madam:

In accordance with the provisions of 10 CFR 50.90, Entergy Nuclear Operations, Inc.

(ENO) is submitting a request for an amendment to the Technical Specifications (TS) for Palisades Nuclear Plant.

The proposed amendment would modify TS requirements for unavailable barriers by adding Limiting Condition for Operation (LCO) 3.0.9.

Attachment 1 provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. 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 existing TS Bases pages marked up to show the proposed change (for information only).

ENO requests approval of the proposed license amendment by December 1, 2014, with the amendment being implemented within 90 days.

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

This letter contains three new commitments related to establishing Technical Specifications Bases for LCO 3.0.9, which are also listed in Attachment 4.

PNP 2013-076 Page 2 If you should have any questions regarding this submittal, please contact Jim Miksa, Licensing Engineer, at 269 764 2945.

I declare under penalty of perjury that the foregoing is true and correct. Executed on December 11, 2013.

Sincerely, ajv/jpm Attachments: 1. Description and Assessment

2. Proposed Technical Specification Changes

3. Renewed Operating License Page Change Instructions and Revised Technical Specification Pages

4. Regulatory Commitments

5. Proposed Technical Specification Bases Changes (for information only) cc: Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC Technical Specifications Branch Chief, USNRC State of Michigan

ATTACHMENT 1 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed amendment would modify Palisades Nuclear Plant (PNP) Technical Specifications (TS) requirements for unavailable barriers by adding Limiting Condition for Operation (LCO) 3.0.9.

The changes are consistent with Nuclear Regulatory Commission (NRC) approved IndustrylTechnical Specification Task Force (TSTF) Standard Technical Specifications (STS) change TSTF-427, "Allowance for Non Technical Specification Barrier Degradation on Supported System OPERABILITY," Revision 2. The availability of this TS improvement was published in the Federal Register on October 3,2006 (71 FR 58444), as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Entergy Nuclear Operations, Inc. (ENO) has reviewed the safety evaluation (SE) published on October 3,2006 (71 FR 58444) as part of the CLlIP, "Notice of Availability of the Model Safety Evaluation." This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-427. ENO has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to PNP and justify this amendment for the incorporation of the changes to the PNP TS.

2.2 Optional Changes and Variations ENO is not propOSing any technical variations or deviations from the TS changes described in the TSTF-427, Revision 2, or the NRC staff's model safety evaluation dated September 25, 2006.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Entergy Nuclear Operations, Inc. (ENO) has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the consolidated line item improvement process (CLIIP). ENO has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Palisades Nuclear Plant (PNP) 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 Federal Register on September 25, 2006 for this TS improvement, plant-specific verifications were performed as follows:

Page 1 of 2

1. ENO commits to the guidance of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Section 11, which provides guidance and details on the assessment and management of risk during maintenance.

2. ENO will revise procedures to ensure that the risk assessment and management process described in NEI 04-08, "Allowance for Non-Technical Specification Barrier Degradation on Supported System OPERABILITY (TSTF-427) Industry Implementation Guidance, " March 2006, is used whenever a barrier is considered unavailable and the requirements of LCO 3.0.9 are applied, in accordance with an overall configuration risk management program (CRMP) to ensure that potentially risk-significant configurations resulting from maintenance and other operational activities are identified and avoided.

3. ENO will establish the Technical Specification Bases for LCO 3.0.9 as adopted with the applicable license amendment.

4.0 ENVIRONMENTAL EVALUATION ENO has reviewed the SE published on October 3,2006 (71 FR 58444) as part of the CLlIP, "Notice of Availability of the Model Safety Evaluation." ENO has concluded that the staffs findings presented in that evaluation are applicable to PNP and the evaluation is hereby incorporated by reference for this application.

5.0 REFERENCES

1. Federal Register Notice (71 FR 58444), dated October 3,2006, "Notice of Availability of Model Application Concerning Technical Specification Improvement To Modify Requirements Regarding the Addition of LCO 3.0.9 on the Unavailability of Barriers Using the Consolidated Line Item Improvement Process."

2. Technical Specification Task Force Improved Technical Specification Change Traveler, TSTF-427, "Allowance for Non Technical Specification Barrier Degradation on Supported System OPERABILITY," Revision 2 (ADAMS Accession No. ML061240055).

Page 2 of2

ATTACHMENT 2 Proposed Technical Specification Changes (showing proposed changes; additions are highlighted and deletions are strikethrough)

Five pages follow

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 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 plant 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 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the plant, as applicable, in:

a. MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ;

b. MODE 4 within 31 hours3.587963e-4 days 0.00861 hours 5.125661e-5 weeks 1.17955e-5 months ; and

c. MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

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; Palisades Nuclear Plant 3.0-1 Amendment No. 489, 9,251

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.7 Special Test Exception (STE) LCOs in each applicable LCO section allow specified Technical Specifications (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with STE LCOs is optional. When an STE LCO is desired to be met but is not met, the ACTIONS of the STE LCO shall be met. When an STE LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall only 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 LeO(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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

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.

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.9~_ _--...When one or more required barriers are unable to perform their relat upport function(s), any supported system LCO(s) are not required to b eclared not met solely for this reason for up to 30 days provided that a east one train or subsystem of the supported system is OPERABLE an upported by barriers capable of providing their related suppo 1....-_--;-....,

nction(s), and risk is assessed and managed. This specification ma~

ncurrently applied to more than one train or subsystem of a multi I in or subsystem supported system provided at least one train 0 ubsystem of the supported system is OPERABLE and the barrie upporting each of these trains or subsystems provide their relat u rt function s for different cat ories of initiatin even Palisades Nuclear Plant 3.0-3 Amendment No. 251

LCO Applicability 3.0 3.0 LCO APPLICABILITY Palisades Nuclear Plant Amendment No. 251

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the .performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per ... "

basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

Palisades Nuclear Plant Amendment No. 489, 210

SR Applicability 3.0 3.0 SR APPLICABILITY SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCD shall only be made when the LC~'s Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCD is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCD 3.0.4.

This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the plant.

Palisades Nuclear Plant Amendment No. 489, 219

ATTACHMENT 3 Renewed Operating License Page Change Instructions and Revised Technical Specification Pages Seven pages follow

Page Change Instructions ATTACHMENT TO LICENSE AMENDMENT NO. 2xx RENEWED FACILITY OPERATING LICENSE NO. DPR-20 DOCKET NO. 50-255 Remove the following page of Appendix A, Technical Specifications. and replace with the attached revised page. The revised page is identified by amendment number and contains a line in the margin indicating the area of change.

REMOVE INSERT Page 3.0-1 through 3.0-5 Page 3.0-1 through 3.0-6

LCD Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCD) APPLICABILITY LCD 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCD 3.0.2, LCD 3.0.7, LCD 3.0.8, and LCD 3.0.9.

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

If the LCD 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.

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

a. MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ;

b. MODE 4 within 31 hours3.587963e-4 days 0.00861 hours 5.125661e-5 weeks 1.17955e-5 months ; and

c. MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications.

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

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

LCD 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; Palisades Nuclear Plant 3.0-1 Amendment No. 2M, XXX

LCO Applicability 3.0 3.0 LCD APPLICABILITY LCD 3.0.4 (continued)

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications; or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the plant.

LCD 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCD 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCD 3.0.6 When a supported system LCD is not met solely due to a support system LCD not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCD ACTIONS are required to be entered. This is an exception to LCD 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.13, "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 LCD 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 LCD 3.0.2.

Palisades Nuclear Plant 3.0-2 Amendment No. 489, 219

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.7 Special Test Exception (STE) LCOs in each applicable LCO section allow specified Technical Specifications (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with STE LCOs is optional. When an STE LCO is desired to be met but is not met, the ACTIONS of the STE LCO shall be met. When an STE LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall only 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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

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 me~.

LCO 3.0.9 When one or more required barriers are unable to perform their related support function(s), any supported system LCO(s) are not required to be declared not met solely for this reason for up to 30 days provided that at least one train or subsystem of the supported system is OPERABLE and supported by barriers capable of providing their related support function(s), and risk is assessed and managed. This specification may be concurrently applied to more than one train or subsystem of a multiple train or subsystem supported system provided at least one train or subsystem of the supported system is OPERABLE and the barriers supporting each of these trains or subsystems provide their related support function(s) for different categories of initiating events Palisades Nuclear Plant 3.0-3 Amendment No. 2M, XXX

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.9 (continued)

If the required OPERABLE train or subsystem becomes inoperable while this specification is in use, it must be restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the provisions of this specification cannot be applied to the trains or subsystems supported by the barriers that cannot perform their related support function( s).

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

Palisades Nuclear Plant 3.0-4 Amendment No. XXX

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.