PNP 2014-042, License Amendment Request - Application to Revise Technical Specifications to Adopt TSTF-426, Revise or Add Actions to Preclude Into LCO 3.0.3 - RITSTF Initiatives 6b & 6c, Using the Consolidated Line Item Improvement Process

License Amendment Request - Application to Revise Technical Specifications to Adopt TSTF-426, Revise or Add Actions to Preclude Into LCO 3.0.3 - RITSTF Initiatives 6b & 6c, Using the Consolidated Line Item Improvement Process

ML14162A079
Person / Time
Site:	Palisades
Issue date:	06/11/2014
From:	Vitale A Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PNP 2014-042
Download: ML14162A079 (34)

Text

,.

~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 2014-042 June 11,2014 A TIN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

License Amendment Request - Application to Revise Technical Specifications to Adopt TSTF-426, "Revise or Add Actions to Preclude Entry into LCO 3.0.3 - RITSTF Initiatives 6b & 6c," Using the Consolidated Line Item Improvement Process Palisades Nuclear Plant Docket 50-255 License No. DPR-20

Dear Sir or Madam:

Pursuant to 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 to adopt the changes described in Technical Specification Task Force (TSTF)-426, Revision 5, "Revise or Add Actions to Preclude Entry into LCO 3.0.3 - RITSTF Initiatives 6b & 6c."

Attachment 1 provides a description and assessment of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed changes. Attachment 3 provides revised (clean) TS pages. Attachment 4 provides existing TS Bases pages marked up to show the proposed changes (for information only).

ENO requests approval of the proposed license amendment by June 30, 2015. Once approved, the amendment shall be 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 no new or revised commitments.

If you should have any questions regarding this submittal, please contact Jim Miksa, Regulatory Assurance Engineer, at 269 764 2945.

PNP 2014-042 Page 2 of 2 I declare under penalty of pe~ury that the foregoing is true and correct. Executed on June 11, 2014.

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

ATTACHMENT 1 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed change provides a short Completion Time to restore an inoperable system for conditions under which the existing Technical Specifications require a plant shutdown. The proposed amendment is consistent with Technical Specification Task Force (TSTF)-426, Revision 5, "Revise or Add Actions to Preclude Entry into LCO 3.0.3 - RITSTF Initiatives 6b &

6c (Reference 2)."

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Entergy Nuclear Operations, Inc. (ENO) has reviewed the model safety evaluation dated May 20, 2013 as part of the Federal Register Notice of Availability (Reference 1). This review included a review of the Nuclear Regulatory Commission (NRC) staff evaluation, as well as the information provided in TSTF-426, Revision 5, and the referenced Topical Report WCAP-16125-NP-A, Revision 2, "Justification for Risk-Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent plant Shutdown" (Reference 3). ENO has concluded that the justifications presented in the TSTF-426 proposal and the model safety evaluation prepared by the NRC staff are applicable to Palisades Nuclear Plant (PNP) and justify this amendment for the incorporation of the changes to the PNP Technical SpeCifications (TS).

2.2 Optional Changes and Variations ENO is not proposing any technical variations or deviations from the TS changes described in the TSTF-426, Revision 5, or the applicable parts of the NRC staffs model safety evaluation dated May 20, 2013. However, ENO is proposing the following administrative variations.

1. PNP TS 3.4.9, "Pressurizer," wording differs from Standard Technical Specifications (STS) TS 3.4.9, "Pressurizer," wording due to the site specific design of PNP's pressurizer heater groups. Additional detail was added to PNP TS 3.4.9 because PNP pressurizer heaters are deSigned with one heater group normally powered from an 1E emergency electrical supply, and the second group normally powered from a non-class 1E electrical supply with the capability of being powered from an emergency power supply. This difference is administrative and does not affect the applicability of TSTF-426 to the PNP TS.

2. PNP TS 3.4.11, "Pressurizer Power Operated Relief Valves (PORVs)," currently contain Required Actions for two PORVs inoperable. The Required Actions require closing associated block valves in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and restoration of one PORV to OPERABLE status in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Additionally, the TS contains a Required Action for two block valves inoperable which requires placing associated PORVs in manual control in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and restoration of one block valve to OPERABLE status in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Although the equivalent STS were approved in TSTF-426, Revision 5, ENO is not pursuing the change. Since each STS change was evaluated separately in WCAP-16125-NP-A, Revision 2, failure to adopt this change will not have an impact on the acceptability of adopting the remaining changes Page 1 of 5

which apply. Therefore the TSTF-426, Revision 5, changes for TS 3.4.11, "Pressurizer Power Operated Relief Valves (PORVs)," are not included.

3. The PNP plant specific design is consistent with STS 3.6.6B, "Containment Spray and Cooling Systems (Atmospheric and Dual) (Credit not taken for iodine removal by the Containment Spray System)." Therefore, the TSTF-426 changes to STS 3.6.6A, "Containment Spray and Cooling Systems (Atmospheric and Dual) (Credit taken for iodine removal by the Containment Spray System)," are not applicable. Since each STS change was evaluated separately in WCAP-16125-NP-A, Revision 2, failure to adopt these changes will not have an impact on the acceptability of adopting the remaining changes which apply.

4. The PNP design does not include a Shield Building Exhaust Air Cleanup System (SBEACS), Iodine Cleanup System (ICS), Emergency Core Cooling System (ECCS)

Pump Room Exhaust Air Cleanup System (PREACS), and a Penetration Room Exhaust Air Cleanup System (PREACS). Therefore, the following TSTF-426 changes for those systems are not included.

a. STS 3.6.8, "Shield Building Exhaust Air Cleanup System (SBEACS)"

b. STS 3.6.10, "Iodine Cleanup System (ICS)"

c. STS 3.7.13, "Emergency Core Cooling (ECCS) Pump Room Exhaust Air Cleanup System (PREACS)"

d. STS 3.7.15, "Penetration Room Exhaust Air Cleanup System (PREACS)

Since each STS change was evaluated separately in WCAP-16125-NP-A, Revision 2, failure to adopt these changes will not have an impact on the acceptability of adopting the remaining changes which apply.

5. Some PNP TS utilize different numbering and titles than the STS upon which TSTF-426 was based. The specific differences are shown in the table below.

PNP TS 3.7.10, "Control Room STS TS 3.7.11, "Control Room Ventilation (CRV) Filtration" Emergency Air Cleanup System (CREACS)"

Required Action C.2 Required Action C.2 LCO 3.4.16, "PCS Specific Activity" LCO 3. 4.16, "RCS Specific Activity" PNP TS 3.7.11, "Control Room STS TS 3.7.12, "Control Room Ventilation (CRV) Cooling" Emergency Air Temperature Control System (CREATCS)"

These differences are administrative and do not affect the applicability of TSTF-426 to the PNP TS.

Page 2 of 5

2.3 Licensee Verifications END confirms that PNP procedures can establish temporary alternate means of control room cooling, as assumed in the justification of the proposed change to the Control Room Ventilation (CRV) Cooling System.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Entergy Nuclear Operations, Inc. (END) requests adoption of Technical Specification Task Force (TSTF)-426, Revision 5, "Revise or Add Actions to Preclude Entry into LCD 3.0.3 -

RITSTF Initiatives 6b & 6c," which is an approved change to the Standard Technical Specifications (STS), into the Palisades Nuclear Plant Technical Specifications. The proposed change provides a short Completion Time to restore an inoperable system for conditions under which the existing Technical Specifications require a plant shutdown to begin within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in accordance with Limiting Condition for Operation (LCO) 3.0.3.

ENO has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change provides a short Completion Time to restore an inoperable system for conditions under which the existing Technical Specifications require a plant shutdown to begin within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in accordance with LCD 3.0.3. Entering into Technical Specification Actions is not an initiator of any accident previously evaluated. As a result, the probability of an accident previously evaluated is not significantly increased. The consequences of any accident previously evaluated that may occur during the proposed Completion Times are no different from the consequences of the same accident during the existing 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> allowance. As a result, the consequences of any accident previously evaluated are not significantly increased.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different type of accident from any accident previously evaluated?

Response: No.

No new or different accidents result from utilizing the proposed change. The changes do not involve a physical alteration of the plant (Le., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the changes do not impose any new or different requirements. The changes do not alter assumptions made in the safety analysis.

Page 3 of 5

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change increases the time the plant may operate without the ability to perform an assumed safety function. The analysis in WCAP-16125-NP-A, "Justification for Risk-Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent Plant Shutdown," Revision 2, August 2010, demonstrated that there is an acceptably small increase in risk due to a limited period of continued operation in these conditions and that the risk is balanced by avoiding the risks associated with a plant shutdown. As a result, the change to the margin of safety provided by requiring a plant shutdown within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is not significant.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, END concludes that the proposed change does not involve a significant hazards consideration under standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.0 ENVIRONMENTAL EVALUATION The proposed amendment would 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, or would change an inspection surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed license amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore pursuant to 10 CFR 51 .22(b), no environmental impact statement or environmental assessment need be prepared in conjunction with the proposed change.

5.0 REFERENCES

1. Federal Register Notice (78 FR 32476), dated May 30, 2013, "Models for Plant-Specific Adoption of TSTF-426, Revision 5, "Revise or Add Actions to Preclude Entry into LCO 3.0.3

- RITSTF Initiatives 6b & 6c," USing the Consolidated Line Item Improvement Process."

(ADAMS Accession No. ML13036A371)

2. Technical Specification Task Force Improved Technical Specification Change Traveler, TSTF-426, Revision 5, "Revise or Add Actions to Preclude Entry into LCO 3.0.3 - RITSTF Initiatives 6b & 6c," dated November 22, 2011. (ADAMS Accession No. ML113260461)

Page 4 of 5

3. Topical Report WCAP-16125-NP-A, Revision 2, "Justification for Risk-Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent plant Shutdown," dated August 2010. (ADAMS Accession No. 110070499)

Page 5 of 5

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

Seven pages follow

Pressurizer 3.4.9 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. < 375 kW pressurizer B.1 Restore required 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> heater capacity available pressurizer heaters to from electrical bus 1D, or OPERABLE status.

electrical bus 1E, Required pressurizer heater capacity from electrical bus 1E not capable of being powered from an emergency power supply.

c. -----NOTE------ =

C..:,..

.1:......-_-;Restore at leas 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Not applicable when the electrical bus 1D 0 remaining electrical bus 1 electrical bus 1 or electrical bus 1 required pressurizeli required pressurize heaters to OPERABL heaters intentionally' mad status inoperable i....-_ _ _ _""'t l< 375 kW pressurize~

heater capacity available from electrical bus 1D, an required pressurizer heateli capacity from electrical bu

~ E not capable of bein owered from a '----~

emergenc ower suQQ!y.

Palisades Nuclear Plant 3.4.9-2 Amendment No. 189

Pressurizer 3.4.9 CONDITION REQUIRED ACTION COMPLETION TIME GO. Required Action and G .1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition B or AND not met.

GO.2 Be in MODE 4. 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.9.1 -------------------------------NOTE---------------------------

Not required to be met until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after establishing a bubble in the pressurizer and the pressurizer water level has been lowered to within its normal operating band.

Verify pressurizer water level is < 62.8%. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SR 3.4.9.2 Verify the capacity of pressurizer heaters from 18 months electrical bus 1D, and electrical bus 1E is

~ 375 kW.

SR 3.4.9.3 Verify the required pressurizer heater capacity 18 months from electrical bus 1E is capable of being powered from an emergency power supply.

Palisades Nuclear Plant 3.4.9-3 Amendment No. 189

CRV Filtration 3.7.10 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

c. Initiate action to imQlemen miti ating actions Verify LCO 3.4.16, "PC SQecific Activity. " is met.

C.3 D. Required Action and 0.1 Place OPERABLE CRV Immediately associated Completion Filtration train in Time of Condition A not emergency mode.

met during CORE ALTERATIONS, during OR movement of irradiated fuel assemblies, or 0.2.1 Suspend CORE Immediately during movement of a ALTERATIONS.

fuel cask in or over the SFP. AND 0.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND 0.2.3 Suspend movement of a Immediately fuel cask in or over the SFP.

Palisades Nuclear Plant 3.7.10-2 Amendment No. 189,197,230

CRV Filtration 3.7.10 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. Two CRV Filtration E.1 Suspend CORE Immediately trains inoperable during AL TERATIONS.

CORE ALTERATIONS, during movement of AND irradiated fuel assemblies, or during E.2 Suspend movement of Immediately movement of a fuel cask irradiated fuel assemblies.

in or over the SFP.

AND OR E.3 Suspend movement of a Immediately One or more CRV fuel cask in or over the Filtration trains SFP.

inoperable due to an inoperable CRE boundary during CORE ALTERATIONS, during movement of irradiated fuel assemblies, or during movement of a fuel cask in or over the SFP.

F. +ws GRlJ FiltFatisA F.1 EAter LGO a.o.a Immediately tFaiAS iAS~eFa91e iA MODE 1,2,a, sr 4 far reaSSAS stl=ler tl=laA GSAditisA 8.

GR. Required Action and G .1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A Gf AND B or a not met in MODE 1,2,3, or4. G .2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Palisades Nuclear Plant 3.7.10-3 Amendment No. 189,197,230

CRVCooling 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Ventilation (CRV) Cooling LCO 3.7.11 Two CRV Cooling trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, 4, During CORE ALTERATIONS, During movement of irradiated fuel assemblies, During movement of a fuel cask in or over the Spent Fuel Pool (SFP).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CRV Cooling train A.1 Restore CRV Cooling 30 days inoperable. train to OPERABLE status.

B. -----NOTE---- ~ .1_ _....;R estore at least on~ 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ot applicable whe CRV Cooling train t second CRV Cooling trai OPERABLE status ntentionally' mad inoperable wo CRV Cooling trains

• noperable in MODE 1 2 30r4 Palisades Nuclear Plant 3.7.11-1 Amendment No. 189

CRVCooling 3.7.11 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 8 . Required Action and 8 .1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A or 8 AND not met in MODE 1, 2, 3, or4. 8 '.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> G . Required Action and G .1 Place OPERABLE CRY Immediately associated Completion Cooling train in Time of Condition A not operation met during CORE ALTERATIONS, during OR movement of irradiated fuel assemblies, or Go..2.1 Suspend CORE Immediately movement of a fuel cask in ALTERATIONS.

or over the SFP.

AND G .2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND G .2.3 Suspend movement of a Immediately fuel cask in or over the SFP.

Palisades Nuclear Plant 3.7.11-2 Amendment No. 189

CRV Cooling 3.7.11 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. Two CRV Cooling trains E.1 Enter LCO 3.0.3 Irnrnediately inoperable in MODE 1, 2, 3, or 4.

.g . Two CRV Cooling trains .g .1 Suspend CORE Immediately inoperable during CORE AL TERATIONS.

ALTERATIONS, during movement of irradiated AND fuel assemblies, or movement of a fuel cask in .g .2 Suspend movement of Immediately or over the SFP. irradiated fuel assemblies.

AND

.g .3 Suspend movement of a Immediately fuel cask in or over the SFP SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.11.1 Verify each CRV Cooling train has the capability to 18 months remove the assumed heat load.

Palisades Nuclear Plant 3.7.11-3 Amendment No. 189

ATTACHMENT 3 Renewed Operating license Page Change Instructions and Revised Technical Specification Pages Eight 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 pages of Appendix A, Technical Specifications, and replace with the attached revised pages. The revised pages are identified by amendment number and contain a line in the margin indicating the area of change.

REMOVE INSERT Page 3.4.9-2 through 3.4.9-3 Page 3.4.9-2 through 3.4.9-3 Page 3.7.10-2 through 3.7.10-3 Page 3.7.10-2 through 3.7.10-3 Page 3.7.11-1 through 3.7.11-3 Page 3.7.11-1 through 3.7.11-3

Pressurizer 3.4.9 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. < 375 kW pressurizer B.1 Restore required 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> heater capacity available pressurizer heaters to from electrical bus 1D, or OPERABLE status.

electrical bus 1E, OR Required pressurizer heater capacity from electrical bus 1E not capable of being powered from an emergency power supply.

C. ------------NOTE--------------- C.1 Restore at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Not applicable when the electrical bus 1D or remaining electrical bus 1D electrical bus 1E or electrical bus 1E required pressurizer required pressurizer heaters to OPERABLE heaters intentionally made status.

inoperable.

< 375 kW pressurizer heater capacity available from electrical bus 1D, and electrical bus 1E, OR

< 375 kW pressurizer heater capacity available from electrical bus 1D, and required pressurizer heater capacity from electrical bus 1E not capable of being powered from an emergency power supply.

Palisades Nuclear Plant 3.4.9-2 Amendment No. 489, XXX

Pressurizer 3.4.9 CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition B or C AND not met.

D.2 Be in MODE 4. 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.9.1 ----------------------N OTE-------------------

Not required to be met until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after establishing a bubble in the pressurizer and the pressurizer water level has been lowered to within its normal operating band.

Verify pressurizer water level is < 62.8%. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SR 3.4.9.2 Verify the capacity of pressurizer heaters from 18 months electrical bus 1D, and electrical bus 1E is

~ 375 kW.

SR 3.4.9.3 Verify the required pressurizer heater capacity 18 months from electrical bus 1E is capable of being powered from an emergency power supply.

Palisades Nuclear Plant 3.4.9-3 Amendment No. 489, XXX

CRV Filtration 3.7.10 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. ------------NOTE------------ C.1 Initiate action to implement Immediately Not applicable when mitigating actions.

second CRV Filtration train intentionally made AND inoperable.

---

C.2 Verify LCO 3.4.16, "PCS 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Specific Activity," is met.

Two CRV Filtration trains AND inoperable in MODE 1, 2,3, or 4 for reasons C.3 Restore at least one CRV 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> other than Condition B. Filtration train to OPERABLE status.

D. Required Action and D.1 Place OPERABLE CRV Immediately associated Completion Filtration train in Time of Condition A not emergency mode.

met during CORE AL TERATIONS, during OR movement of irradiated fuel assemblies, or D.2.1 Suspend CORE Immediately during movement of a AL TERATIONS.

fuel cask in or over the SFP. AND D.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND D.2.3 Suspend movement of a Immediately fuel cask in or over the SFP.

Palisades Nuclear Plant 3.7.10-2 Amendment No. 2J{), XXX

CRV Filtration 3.7.10 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. Two CRV Filtration E.1 Suspend CORE Immediately trains inoperable during ALTERATIONS.

CORE AL TERATIONS, during movement of AND irradiated fuel assemblies, or during E.2 Suspend movement of Immediately movement of a fuel cask irradiated fuel assemblies.

in or over the SFP.

AND OR E.3 Suspend movement of a Immediately One or more CRV fuel cask in or over the Filtration trains SFP.

inoperable due to an inoperable CRE boundary during CORE AL TERATIONS, during movement of irradiated fuel assemblies, or during movement of a fuel cask in or over the SFP.

F. Required Action and F.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A, B, AND or C not met in MODE 1, 2,3, or 4. F.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Palisades Nuclear Plant 3.7.10-3 Amendment No. ~,XXX

CRVCooling 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Ventilation (CRV) Cooling LCO 3.7.11 Two CRY Cooling trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, 4, During CORE ALTERATIONS, During movement of irradiated fuel assemblies, During movement of a fuel cask in or over the Spent Fuel Pool (SFP).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CRY Cooling train A.1 Restore CRY Cooling 30 days inoperable. train to OPERABLE status.

B. -------------NOTE-------------- B.1 Restore at least one 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Not applicable when CRY Cooling train to second CRY Cooling train OPERABLE status.

intentionally made inoperable.

Two CRY Cooling trains inoperable in MODE 1, 2, 3,or4.

Palisades Nuclear Plant 3.7.11-1 Amendment No. 489, XXX

CRVCooling 3.7.11 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or4. C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> D. Required Action and D.1 Place OPERABLE CRV Immediately associated Completion Cooling train in Time of Condition A not operation met during CORE ALTERATIONS, during OR movement of irradiated fuel assemblies, or D.2.1 Suspend CORE Immediately movement of a fuel cask in AL TERATIONS.

or over the SFP.

AND D.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND D.2.3 Suspend movement of a Immediately fuel cask in or over the SFP.

Palisades Nuclear Plant 3.7.11-2 Amendment No. 489, XXX

CRVCooling 3.7.11 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. Two CRV Cooling trains E.1 Suspend CORE Immediately inoperable during CORE AL TERATIONS.

ALTERATIONS, during movement of irradiated AND fuel assemblies, or movement of a fuel cask in E.2 Suspend movement of Immediately or over the SFP. irradiated fuel assemblies.

AND E.3 Suspend movement of a Immediately fuel cask in or over the SFP SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.11.1 Verify each CRV Cooling train has the capability to 18 months remove the assumed heat load.

Palisades Nuclear Plant 3.7.11-3 Amendment No. 489, XXX

ATTACHMENT 4 Proposed Technical Specification Bases Changes (for information only)

(showing proposed changes; additions are highlighted and deletions are strikethrough)

Nine pages follow

Pressurizer B 3.4.9 BASES ACTIONS B.1 (continued)

If < 375 kW of pressurizer heater capacity is available from either electrical bus 1D or electrical bus 1E, or the pressurizer heaters from electrical bus 1E are not capable of being powered from an emergency power supply, restoration is required within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is reasonable considering that a demand caused by loss of offsite power would be unlikely in this period. Pressure control may be maintained during this time using the remaining available pressurizer heaters.

If <375 kW of pressurizer heater capacity is available from electrica buses 10 and either < 375 kW of pressurizer heater capacity is available from electrical bus 1E or the pressurizer heaters from electrical bus 1 are not capable of being powered from an emergency power supply, then restoration is required within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The Condition is modified by' a Note stating it is not applicable if the second group of requir pressurized heaters is intentionally declared inoperable. The Conditio (joes not apply to voluntary removal of redundant systems or components from service. The Condition is only applicable if one group of require pressurized heaters is inoperable for any reason and the second grou of required pressurized heaters is discovered to be inoperable, or if bot groups of required pressurized heaters are discovered to be inop'erable at the same time. If both required groups of pressurizer heaters ali ........~~

inoperable, the pressurizer heaters may not be available to help maintai subcooling in the PCS loops during a natural circulation cooldow following a loss of offsite power. The inoperability of two groups 0 equired pressurizer heaters during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time has been shown to be acceptable based on the infrequent use of th Reguired Action and the small incremental effect on p-Iant risk R.....

e"o-f. "'=

3""".

Palisades Nuclear Plant B 3.4.9-5 Amendment No. 189

Pressurizer B 3.4.9 BASES ACTIONS GD.1 and G :.2 (continued)

If the required pressurizer heaters cannot be restored to an OPERABLE status within the allowed Completion Time of Required Action B.1 , the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 4 within 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonable, based on operating experience, to reach MODE 3 from full power in an orderly manner and without challenging safety systems.

Similarly, the Completion Time of 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> is reasonable, based on operating experience, to reach MODE 4 from full power in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.4.9.1 REQUIREMENTS This SR ensures that during steady state operation, pressurizer water level is maintained below the nominal upper limit to provide a minimum space for a steam bubble. The Surveillance is performed by observing the indicated level. SR 3.4.9.1 is modified by a Note which states that verification of the pressurizer water level is not required to be met until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after a bubble has been established in the pressurizer and the pressurizer water level has been lowered to its normal operating band.

The intent of this Note is to prevent an SR 3.0.4 conflict by delaying the performance of this SR until after the water level in the pressurizer is within its normal operating band following a plant heatup. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval has been shown by operating practice to be sufficient to regularly assess the level for any deviation and verify that operation is within safety analyses assumptions. Alarms are also available for early detection of abnormal level indications.

SR 3.4.9.2 The SR is satisfied when the power supplies are demonstrated to be capable of producing the minimum power and the capacity of the associated pressurizer heaters are verified to be ~ 375 kW. (This may be done by testing the power supply output and by performing an electrical check on heater element continuity and resistance.) The Frequency of 18 months is considered adequate to detect heater degradation and has been shown by operating experience to be acceptable.

Palisades Nuclear Plant B 3.4.9-6 Amendment No. 189

Pressurizer B 3.4.9 BASES SURVEILLANCE SR 3.4.9.3 REQUIREMENTS (continued) This SR only applies to the pressurizer heaters normally powered from electrical bus 1E since the pressurizer heaters powered from bus 10 are permanently connected to the engineered safeguards electrical system.

This SR confirms that the pressurizer heaters normally fed from electrical bus 1E are capable of being powered from electrical bus 1C by use of a jumper cable. It is not the intent of this SR to physically install the jumper cable, but to verify the necessary components are available for installation and to ensure the procedures and methods used to install the jumper cable are current. The Frequency of 18 months is based on engineering judgment and is considered acceptable when considering the design reliability of the equipment (the jumper cable is left permanently in place and dedicated to providing the emergency feed function only), and administrative control which govern configuration management and changes to plant procedures.

REFERENCES 1. FSAR, Chapter 14

2. FSAR, Section 4.3.7 B. WCAP-16125-NP-A, "Justification for Risk-Informed. Modification to Selected Technical Specifications for Conditions Leading to xigent Plant Shutdown" Revision 2 August 201 a Palisades Nuclear Plant B 3.4.9-71 Amendment No. 189

CRY Filtration B 3.7.10 BASES ACTIONS C.1. C.2. and C.3 (continued)

If both CRY Filtration trains are inoperable in MODE 1, 2, 3, or 4, fOIi reasons other than an inoperable control room boundary (i.e. Condition B), at least one CRY Filtration train must be returned to OPERABL status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The Condition is modified by a Note stating it is not applicable if the second CRY Filtration train is intentionally declare inoperable. The Condition does not apply to voluntary removal of redundant systems or components from service. The Condition is onl~

applicable if one train is inoperable for any reason and the second train is Ctiscovered to be inoperable, or if both trains are discovered to b inoperable at the same time. During the period that the CRY Filtrati0r;1 trains are inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from potential hazard lvhile both trains of CRY Filtration are inoperable. In the event of a DBA the mitigating actions will reduce the conseguences of radiologica eXQosures to the CRE occuQants Specification 3.4.16, "PCS Specific Activity," allows limited operation witH the primary coolant system (PCS) activity significantly greater than th LCO limit. This presents a risk to the plant operator during an accident when all CRY Filtration trains are inoperable. Therefore, it must b _'----_

erified within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> that LCO 3.4.16 is met. This Required Action does not require additional PCS samQling bey'ond that normally' reguired b LCO 3.4.16

~t least one CRY Filtration train must be returned to OPERABLE statu within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The Completion Time is based on Reference 3 whicH Ctemonstrated that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is acceptable based 0 the infrequent use of the Reguired Actions and the small incrementa effect on lant risk 0.1. 0.2.1. 0.2.2. and 0.2.3 During CORE ALTERATIONS, during movement of irradiated fuel assemblies, during movement of a fuel cask in or over the SFP, if Required Action A.1 cannot be completed within the required Completion Time, the OPERABLE CRY Filtration train must be immediately placed in the emergency mode of operation. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure will be readily detected.

Palisades Nuclear Plant B 3.7.10-6 Amendment 230

CRV Filtration B 3.7.10 BASES ACTIONS 0.1.0.2.1.02.2. and 0.2.3 (continued)

An alternative to Required Action 0.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the CRE. This places the plant in a condition that minimizes the accident risk. This does not preclude the movement of fuel assemblies or a fuel cask to a safe position.

E.1, E.2. and E.3 During CORE ALTERATIONS, during movement of irradiated fuel assemblies, or during movement of a fuel cask in or over the SFP, with two CRV Filtration trains inoperable or with one or more CRV Filtration trains inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that could result in a release of radioactivity that might enter the CRE. This places the plant in a condition that minimizes the accident risk. This does not preclude the movement of fuel assemblies or a fuel cask to a safe position.

If both CRV Filtration trains ar=e inoperable in MODE 1,2,3, or 4 for r=easons other than an inoperable CRE bOl:Jndary (Le., Condition B), the CRV Filtration may not be capable of performing the intended function and the plant is in a condition ol:Jtside the accident analysis. Ther=efore, LCO 3.0.3 ml:Jst be entered immediately.

(;B.1 and(; .2 In MODE 1,2,3, or 4, IIf #le a inoperable CRV Filtration train or the CRE boundary cannot be restored to OPERABLE status within the required Completion Time of Condition A or B n MODE 1 2 3 or ,the plant must be placed in a MODE that minimizes the accident risk. To achieve this status, the plant must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

Palisades Nuclear Plant B 3.7.10-7 Amendment 230

CRV Filtration B 3.7.10 BASES SURVEILLANCE SR 3.7.10.4 (Continued)

REQUIREMENTS Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref. 4) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 5). These compensatory measures may also be used as mitigating actions as required by Required Action B.2.

Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 6). Options for restoring the CRE boundary to OPERABLE status include changing the DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

REFERENCES 1. FSAR, Section 9.8

2. FSAR, Chapter 14

3. WCAP-16125-NP-A, "Justification for Risk-Informed Modification to Selected Technical Specifications for Conditions Leading to Exigent Plant Shutdown" Revision 2, August 2010 Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors"

4. NEI 99-03, "Control Room Habitability Assessment," June 2001.

~. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30,2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability." (ADAMS Accession No. ML040300694 ).

Palisades Nuclear Plant B 3.7.10-9 Amendment 230

CRVCooling B 3.7.11 BASES APPLICABILITY In MODES 1, 2, 3, and 4, the CRV Cooling must be OPERABLE to ensure that the control room temperature will not exceed equipment OPERABILITY requirements following isolation of the control room.

In MODES 5 and 6, the probability and consequences of a Design Basis Accident are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining CRV Cooling OPERABLE is not required in MODE 5 or 6, except for the following situations under which significant radioactive releases can be postulated:

a. During CORE ALTERATIONS;

b. During movement of irradiated fuel assemblies; and

c. During movement of a fuel cask in or over the SFP.

ACTIONS With one CRV Cooling train inoperable, action must be taken to restore OPERABLE status within 30 days. In this Condition, the remaining OPERABLE CRV Cooling train is adequate to maintain the control room temperature within limits. The 30 day Completion Time is reasonable, based on the low probability of an event occurring requiring control room isolation, consideration that the remaining train can provide the required capabilities.

B.1 If two CRV cooling trains are inoperable, at least one CRV cooling trai ust be returned to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The Condition i modified by a Note stating it is not applicable if the second CRV coolin train is intentionally declared inoperable. The Condition does not apply to woluntary removal of redundant systems or components from service. The Condition is only applicable if one train is inoperable for any reason an the second train is discovered to be inoperable, or if both trains al"i tfiscovered to be inoperable at the same time. The Completion Time is based on Reference 2 which demonstrated that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completio tnme is acceptable based on the infrequent use of the Reguired Action and the small incremental effect on Qlant risk Palisades Nuclear Plant B 3.7.11-3 Amendment No. 189

CRVCooling B3.7.11 BASES ACTIONS (continued)

In MODE 1, 2, 3, or 4, when Required Action A.1 cannot be completed within the required Completion Time, the plant must be placed in a MODE that minimizes the accident risk. To achieve this status, the plant must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

GO.1, G[).2.1, GlJ.2.2. and Gq .2.3 During CORE ALTERATIONS, during movement of irradiated fuel assemblies, or during movement of a fuel cask in or over the SFP, when Required Action A.1 cannot be completed within the required Completion Time, the OPERABLE CRV Cooling train must be placed in operation immediately. This action ensures that the remaining train is OPERABLE, and that any active failure will be readily detected.

An alternative to Required Action GO.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the control room. This places the plant in a condition that minimizes the accident risk. This does not preclude the movement of fuel assemblies or a fuel cask to a safe position.

Gi3.1. G8.2, and GS.3 During CORE ALTERATIONS, during movement of irradiated fuel assemblies, or during movement of a fuel cask in or over the SFP, with two CRV Cooling trains inoperable, action must be taken immediately to suspend activities that could result in a release of radioactivity that might require isolation of the control room. This places the plant in a Condition that minimizes the accident risk. This does not preclude the movement of fuel assemblies or a fuel cask to a safe position.

If both CRY Cooling tFains aFe inopeFable in MODE 1, 2, a, OF '1, the CRY Cooling may not be Gapable of peFfoFming the intended funGtion and the plant is in a Gondition outside the aGGident analysis. TheFefoFe, LCO a.o.a must be enteFed immediately.

Palisades Nuclear Plant B 3.7.11-4 Amendment No. 189

CRVCooling B 3.7.11 BASES SURVEILLANCE SR 3.7.11.1 REQUIREMENTS This SR verifies that the heat removal capability of the system is sufficient to meet design requirements. This SR consists of a combination of testing and calculations. An 18 month Frequency is appropriate, since significant degradation of the CRV Cooling is slow and is not expected over this time period.

REFERENCES 1. FSAR, Section 9.8

2. WCAP-16125-NP-A, "Justification for Risk-Informed Modificatio to Selected Technical Specifications for Conditions Leading t xigent Plant Shutdown ,i Revision 2 Au ust 2010 Palisades Nuclear Plant B 3.7.11-5 Amendment No. 189