Text

Report to NRC of Changes to Technical Specifications Bases
	ML14260A013
Person / Time
Site:	Palisades
Issue date:	09/15/2014
From:	Hardy J; Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	PNP 2014-088
	Download: ML14260A013 (31)
	v • d • e

Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, Ml 49043-9530 Tel 269 764 2000 JefferyA. Hardy Regulatory Assurance Manager PNP 201 4-088 September 15, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Report to NRC of Changes to Technical Specifications Bases Palisades Nuclear Plant Docket 50-255 License No. DPR-20

Dear Sir or Madam:

This report is submitted in accordance with Palisades Technical Specification 5.5.12.d, which requires that changes to the Technical Specifications Bases, implemented without prior Nuclear Regulatory Commission (NRC) approval, be provided to the NRC on a frequency consistent with 10 CFR 50.71 (e). Attachment 1 provides a listing of all bases changes since issuance of the previous report, dated November 9, 2012, and identifies the affected sections and describes the nature of the changes. Attachment 2 provides page change instructions, and copies of the revised Technical Specifications Bases Title Page, List of Effective Pages, and Technical Specifications Bases sections listed in Attachment 1.

Summary of Commitments This letter identifies no new commitments and no revisions to existing commitments.

Sincerely,

/1A jah/jse Attachments:

1. List of Technical Specifications Bases Changes

2. Revised Technical Specifications Bases cc:

Administrator, Region Ill, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC

~ Entergy PNP 2014-088 September 15, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 Tel 269 764 2000 Jeffery A. Hardy Regulatory Assurance Manager

SUBJECT:

Report to NRC of Changes to Technical Specifications Bases Palisades Nuclear Plant Docket 50-255 License No. DPR-20

Dear Sir or Madam:

This report is submitted in accordance with Palisades Technical Specification 5.5.12.d, which requires that changes to the Technical Specifications Bases, implemented without prior Nuclear Regulatory Commission (NRC) approval, be provided to the NRC on a frequency consistent with 10 CFR 50.71 (e). Attachment 1 provides a listing of all bases changes since issuance of the previous report, dated November 9, 2012, and identifies the affected sections and describes the nature of the changes. Attachment 2 provides page change instructions, and copies of the revised Technical Specifications Bases Title Page, List of Effective Pages, and Technical Specifications Bases sections listed in Attachment 1.

Summary of Commitments This letter identifies no new commitments and no revisions to existing commitments.

Sincerely, jah/jse Attachments: 1. List of Technical Specifications Bases Changes

2. Revised Technical Specifications Bases cc:

Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC

ATTACHMENT 1 LIST OF TECHNICAL SPECIFICATIONS BASES CHANGES Date Affected Bases Change Description June 13, 2013 Section B 3.0 Revised to implement license amendment number 251, which added Technical Specification LCD 3.0.8 concerning requirements for inoperable snubbers (NRC Safety Evaluation dated March 29, 2013, ADAMS Accession Number ML13064A140).

September 15, 2014 Section B 3.7.16 Revised to align with configuration of spent fuel pool following installation of new spent fuel pool racks per license amendment number 250 (NRC Safety Evaluation dated February 28, 2013, ADAMS Accession Number ML13056A514).

Page 1 of 1 ATTACHMENT 1 LIST OF TECHNICAL SPECIFICATIONS BASES CHANGES Affected Bases June 13,2013 Section B 3.0 September 15, 2014 Section B 3.7.16 Page 1 of 1 Revised to implement license amendment number 251, which added Technical Specification LCD 3.0.8 concerning requirements for inoperable snubbers (NRC Safety Evaluation dated March 29,2013, ADAMS Accession Number ML13064A140).

Revised to align with configuration of spent fuel pool following installation of new spent fuel pool racks per license amendment number 250 (NRC Safety Evaluation dated February 28, 2013, ADAMS Accession Number ML13056A514).

ATTACHMENT 2 REVISED TECHNICAL SPECIFICATIONS BASES Page Change Instructions Title Page List of Effective Pages Technical Specification Bases Section B 3.0 Section B 3.7.16 28 Pages Follow ATTACHMENT 2 REVISED TECHNICAL SPECIFICATIONS BASES Page Change Instructions Title Page List of Effective Pages Technical Specification Bases Section B 3.0 Section B 3.7.16 28 Pages Follow

PALISADES NUCLEAR PLANT Technical Specifications Bases September 15, 2014 Revise your copy of the Palisades Nuclear Plant Technical Specifications Bases by removing the pages identified below and inserting the revised pages. Vertical lines in the margin indicate the area of change.

LIST TECHNICAL SPECIFICATION BASES PAGES REMOVE INSERT

Technical Specification Bases

Technical Specification Bases Title Page Title Page Revised 11/08/2012 (1 page)

Revised 09/15/2014 (1 page)

Palisades Tech Spec Bases

Palisades Tech Spec Bases List of Effective Pages List of Effective Pages Revised 11/08/2012 (3 pages)

Revised 09/15/2014 (3 pages)

B 3.0-1 through B 3.0-16

B 3.0-1 through B 3.0-18 Revised 02/24/2005 (16 pages)

Revised 06/13/2013 (18 pages)

B 3.7.16-1 through B 3.7.16-5

B 3.7.16-1 through B 3.7.16-5 Amendment 246 (5 pages)

Amendment 250 (5 pages)

PALISADES NUCLEAR PLANT Technical Specifications Bases September 15, 2014 Revise your copy of the Palisades Nuclear Plant Technical Specifications Bases by removing the pages identified below and inserting the revised pages. Vertical lines in the margin indicate the area of change.

LIST TECHNICAL SPECIFICATION BASES PAGES REMOVE Technical Specification Bases Title Page Revised 11/08/2012 (1 page)

Palisades Tech Spec Bases List of Effective Pages Revised 11/08/2012 (3 pages)

B 3.0-1 through B 3.0-16 Revised 02/24/2005 (16 pages)

B 3.7.16-1 through B 3.7.16-5 Amendment 246 (5 pages)

INSERT Technical Specification Bases Title Page Revised 09/15/2014 (1 page)

Palisades Tech Spec Bases List of Effective Pages Revised 09/15/2014 (3 pages)

B 3.0-1 through B 3.0-18 Revised 06/13/2013 (18 pages)

B 3.7.16-1 through B 3.7.16-5 Amendment 250 (5 pages)

PALISADES PLANT FACILITY OPERATING LICENSE DPR-20 APPENDIX A TECHNICAL SPECIFICATIONS BASES Revised 09/15/2014 PALISADES PLANT FACILITY OPERATING LICENSE DPR-20 APPENDIX A TECHNICAL SPECIFICATIONS BASES Revised 09/15/2014

PALISADES TECHNICAL SPECIFICATIONS BASES LIST OF EFFECTIVE PAGES COVERSHEET Title Page 250

- Revised 09/15/14 TABLE OF CONTENTS Pages i and ii TECHNICAL SPECIFICATIONS BASES Bases2.0 Pages B2.1.1-1 -B2.1.1-4 Pages B 2.1.2-1

- B 2.1.2-4 Bases 3.0 Pages B 3.0-1

- B 3.0-18 Bases3.1 Pages B3.1.1-1 -B 3.1.1-5 Pages B 3.1.2-1

- B 3.1.2-6 Pages B 3.1.3-1

- B 3.1.3-4 Pages B3.1.4-1 -B3.1.4-13 Pages B 3.1.5-1 -B3.1.5-7 Pages B3.1.6-1 -B3.1.6-9 Pages B 3.1.7-1

- B 3.1.7-6 Bases3.2 Pages B3.2.1-1 -B3.2.1-11 Pages B 3.2.2-1

- B 3.2.2-3 Pages B 3.2.3-1

- B 3.2.3-3 Pages B 3.2.4-1

- B 3.2.4-3 Bases 3.3 Pages B 3.3.1-1

- B 3.3.1-35 Pages B 3.3.2-1

- B 3.3.2-10 Pages B 3.3.3-1

- B 3.3.3-24 Pages B 3.3.4-1

- B 3.3.4-12 Pages B 3.3.5-1

- B 3.3.5-6 Pages B 3.3.6-1

- B 3.3.6-6 Pages B 3.3.7-1

- B 3.3.7-12 Pages B 3.3.8-1

- B 3.3.8-6 Pages B 3.3.9-1

- B 3.3.9-5 Pages B3.3.10-1 -B3.3.10-4 Bases 3.4 Pages B 3.4.1-1

- B 3.4.1-4 Pages B 3.4.2-1

- B 3.4.2-2 Pages B 3.4.3-1

- B 3.4.3-7 Pages B 3.4.4-1

- B 3.4.4-4 Pages B 3.4.5-1

- B 3.4.5-5 Pages B 3.4.6-1

- B 3.4.6-6 Pages B 3.4.7-1

- B 3.4.7-7 Pages B 3.4.8-1

- B 3.4.8-5 Pages B 3.4.9-1

- B 3.4.9-6 Pages B 3.4.10-1 -B3.4.10-4 Pages B 3.4.11-1

- B 3.4.11-7 Revised 02/19/09 Revised 04/14/11 189 251

- Revised 06/13/13 189 Revised 09/09/03 189 Revised 07/18/07 Revised 07/02/04 Revised 07/30/03 Revised 05/15/07 Revised 08/06/04 Revised 09/28/01 Revised 09/28/01 189

- Revised 08/09/00 Revised 08/30/2011 189

- Revised 02/12/01 Revised 03/20/08 Revised 09/09/03 Revised 11/08/2012 189

- Revised 02/12/01 Revised 11/08/2012 Revised 02/24/05 189

- Revised 08/09/00 189 Revised 08/24/04 189 Revised 02/17/12 Revised 09/21/06 Revised 09/21/06 Revised 07/31/07 Revised 07/31/07 Revised 07/31/07 189 189 Revised 02/24/05 Revised 09/15/2014 PALISADES TECHNICAL SPECIFICATIONS BASES LIST OF EFFECTIVE PAGES COVERSHEET Title Page 250 - Revised 09/15/14 TABLE OF CONTENTS Pages i and ii Revised 02/19/09 TECHNICAL SPECIFICATIONS BASES Bases 2.0 Pages B 2.1.1 B 2.1.1-4 Revised 04/14/11 Pages B 2.1.2 B 2.1.2-4 189 Bases 3.0 Pages B 3.0 B 3.0-18 251 - Revised 06/13/13 Bases 3.1 Pages B 3.1.1 B 3.1.1-5 189 Pages B 3.1.2 B 3.1.2-6 Revised 09/09/03 Pages B 3.1.3 B 3.1.3-4 189 Pages B 3.1.4 B 3.1.4-13 Revised 07/18/07 Pages B 3.1.5 B 3.1.5-7 Revised 07102/04 Pages B 3.1.6 B 3.1.6-9 Revised 07/30103 Pages B 3.1.7 B 3.1.7-6 Revised 05/15/07 Bases 3.2 Pages B 3.2.1 B 3.2.1-11 Revised 08/06/04 Pages B 3.2.2 B 3.2.2-3 Revised 09/28/01 Pages B 3.2.3 B 3.2.3-3 Revised 09/28/01 Pages B 3.2.4 B 3.2.4-3 189 - Revised 08/09/00 Bases 3.3 Pages B 3.3.1 B 3.3.1-35 Revised 08/30/2011 Pages B 3.3.2 B 3.3.2-10 189 - Revised 02/12/01 Pages B 3.3.3 B 3.3.3-24 Revised 03/20108 Pages B 3.3.4 B 3.3.4-12 Revised 09/09/03 Pages B 3.3.5 B 3.3.5-6 Revised 11/08/2012 Pages B 3.3.6 B 3.3.6-6 189 - Revised 02/12/01 Pages B 3.3.7 B 3.3.7-12 Revised 11/08/2012 Pages B 3.3.8 B 3.3.8-6 Revised 02/24/05 Pages B 3.3.9 B 3.3.9-5 189 - Revised 08/09/00 Pages B 3.3.10 B 3.3.10-4 189 Bases 3.4 Pages B 3.4.1 B 3.4.1-4 Revised 08/24/04 Pages B 3.4.2 B 3.4.2-2 189 Pages B 3.4.3 B 3.4.3-7 Revised 02/17/12 Pages B 3.4.4 B 3.4.4-4 Revised 09/21/06 Pages B 3.4.5 B 3.4.5-5 Revised 09/21/06 Pages B 3.4.6 B 3.4.6-6 Revised 07/31/07 Pages B 3.4.7 B 3.4.7-7 Revised 07/31/07 Pages B 3.4.8 B 3.4.8-5 Revised 07/31/07 Pages B 3.4.9 B 3.4.9-6 189 Pages B 3.4.10 B 3.4.10-4 189 Pages B 3.4.11 B 3.4.11-7 Revised 02/24/05 1

Revised 09/15/2014

PALISADES TECHNICAL SPECIFICATIONS BASES 2

LIST OF EFFECTIVE PAGES Bases 3.4 Pages B 3.4.12-1

- B 3.4.12-13 Revised 02/17/12 (Continues)

Pages B 3.4.13-1

- B 3.4.13-7 Revised 03/20/08 Pages B 3.4.14-1

- B 3.4.14-8 189

- Revised 08/09/00 Pages B 3.4.15-1

- B 3.4.15-6 Revised 02/24/05 Pages B 3.4.16-1

- B 3.4.16-5 Revised 02/24/05 Pages B 3.4.17-1

- B 3.4.17-7 223 Bases3.5 Pages B 3.5.1-1 -B3.5.1-5 189 Page B 3.5.1-6 191 Page B 3.5.1-7 189 Page B 3.5.1-8 191 Pages B 3.5.2-1

- B 3.5.2-12 228 Pages B 3.5.3-1

- B 3.5.3-4 Revised 07/22/02 Pages B 3.5.4-1

- B 3.5.4-7 227 Pages B 3.5.5-1

- B 3.5.5-5 227 Bases 3.6 Pages B 3.6.1-1

- B 3.6.1-4 Revised 03/15/12 Pages B 3.6.2-1

- B 3.6.2-8 Revised 03/15/12 Pages B 3.6.3-1

- B 3.6.3-12 Revised 04/14/11 Pages B 3.6.4-1

- B 3.6.4-3 Revised 03/15/12 Pages B 3.6.5-1

- B 3.6.5-3 Revised 03/15/12 Pages B 3.6.6-1

- B 3.6.6-13 Revised 03/15/12 Bases 3.7 Pages B 3.7.1-1

- B 3.7.1-4 Revised 08/06/04 Pages B 3.7.2-1

- B 3.7.2-6 Revised 12/02/02 Pages B 3.7.3-1

- B 3.7.3-5 Revised 12/02/02 Pages B 3.7.4-1

- B 3.7.4-4 Revised 07/16/08 Pages B 3.7.5-1

- B 3.7.5-9 Revised 02/24/05 Pages B 3.7.6-1

- B 3.7.6-4 Revised 04/14/11 Pages B 3.7.7-1

- B 3.7.7-9 Revised 06/07/05 Pages B 3.7.8-1

- B 3.7.8-8 Revised 10/29/09 Pages B 3.7.9-1

- B 3.7.9-3 Revised 04/14/1 1 Pages B 3.7.10-1

- B 3.7.10-8 230 Pages B3.7.11-1 -B3.7.11-5 189 Pages B 3.7.12-1

- B 3.7.12-7 Revised 07/16/03 Pages B 3.7.13-1

- B 3.7.13-3 189

- Revised 08/09/00 Pages B 3.7.14-1

- B 3.7.14-3 Revised 09/09/03 Pages B 3.7.15-1

- B 3.7.15-2 236 Pages B 3.7.16-1

- B 3.7.16-5 250

- Revised 09/15/14 Pages B 3.7.17-1

- B 3.7.17-3 Revised 04/14/11 Revised 09/15/2014 PALISADES TECHNICAL SPECIFICATIONS BASES 2

LIST OF EFFECTIVE PAGES Bases 3.4 Pages B 3.4.12 B 3.4.12-13 Revised 02/17/12 (Continues)

Pages B 3.4.13 B 3.4.13-7 Revised 03/20/08 Pages B 3.4.14 B 3.4.14-8 189 - Revised 08/09/00 Pages B 3.4.15 B 3.4.15-6 Revised 02/24/05 Pages B 3.4.16 B 3.4.16-5 Revised 02/24/05 Pages B 3.4.17 B 3.4.17-7 223 Bases 3.5 Pages B 3.5.1 B 3.5.1-5 189 Page B 3.5.1-6 191 Page B 3.5.1-7 189 Page B 3.5.1-8 191 Pages B 3.5.2 B 3.5.2-12 228 Pages B 3.5.3 B 3.5.3-4 Revised 07/22/02 Pages 83.5.4 B 3.5.4-7 227 Pages B 3.5.5 B 3.5.5-5 227 Bases 3.6 Pages B 3.6.1 B 3.6.1-4 Revised 03/15/12 Pages B 3.6.2 B 3.6.2-8 Revised 03/15/12 Pages B 3.6.3 B 3.6.3-12 Revised 04/14/11 Pages B 3.6.4 83.6.4-3 Revised 03/15/12 Pages B 3.6.5 B 3.6.5-3 Revised 03/15/12 Pages B 3.6.6 B 3.6.6-13 Revised 03/15/12 Bases 3.7 Pages B 3.7.1 B 3.7.1-4 Revised 08/06/04 Pages B 3.7.2 B 3.7.2-6 Revised 12/02/02 Pages 83.7.3 83.7.3-5 Revised 12102/02 Pages B 3.7.4 B 3.7.4-4 Revised 07/16/08 Pages B 3.7.5 B 3.7.5-9 Revised 02/24/05 Pages B 3.7.6 B 3.7.6-4 Revised 04/14/11 Pages B 3.7.7 B 3.7.7-9 Revised 06/07/05 Pages B 3.7.8 B 3.7.8-8 Revised 10/29/09 Pages B 3.7.9 B 3.7.9-3 Revised 04/14/11 Pages B 3.7.10 B 3.7.10-8 230 Pages B 3.7.11 B 3.7.11-5 189 Pages B 3.7.12 B 3.7.12-7 Revised 07/16/03 Pages B 3.7.13 8 3.7.13-3 189 - Revised 08/09/00 Pages B 3.7.14 B 3.7.14-3 Revised 09/09/03 Pages B 3.7.15 B 3.7.15-2 236 Pages 83.7.16 B 3.7.16-5 250 - Revised 09/15/14 Pages B 3.7.17 B 3.7.17-3 Revised 04/14/11 Revised 09/15/2014

PALISADES TECHNICAL SPECIFICATIONS BASES LIST OF EFFECTIVE PAGES 3

Pages Pages Pages Pages Pages Pages Pages Pages Pages Pages B 3.8.1-1

- B 3.8.1-24 B 3.8.2-1

- B 3.8.2-4 B 3.8.3-1

- B 3.8.3-7 B 3.8.4-1

- B 3.8.4-9 B 3.8.5-1

- B 3.8.5-3 B 3.8.6-1

- B 3.8.6-6 B 3.8.7-1

- B 3.8.7-3 B 3.8.8-1

- B 3.8.8-3 B 3.8.9-1

- B 3.8.9-7 B 3.8.10-1

- B 3.8.10-3 Revised 11/08/12 Revised 11/06/01 Revised 09/16/1 1 Revised 07/13/06 Revised 11/06/01 189

- Revised 08/09/00 189 Bases 3.8 Bases 3.9 Revised Revised Revised 11/06/01 11/06/01 11/06/01 Pages Pages Pages Pages Pages Pages B 3.9.1-1 B 3.9.2-1 B 3.9.3-1 B 3.9.4-1 B 3.9.5-1 B 3.9.6-1

- B 3.9.1-4

- B 3.9.2-3

- B 3.9.3-6

- B 3.9.4-4

- B 3.9.5-4

- B 3.9.6-3 189

- Revised 08/09/00 189

- Revised 02/12/01 189

- Revised 08/09/00 Revised 07/31/07 Revised 07/31/07 189

- Revised 02/27/01 Revised 09/15/2014 PALISADES TECHNICAL SPECIFICATIONS BASES 3

LIST OF EFFECTIVE PAGES Bases 3.8 Pages B 3.8.1 B 3.8.1-24 Revised 11/08/12 Pages B 3.8.2 B 3.8.2-4 Revised 11/06/01 Pages B 3.8.3 B 3.8.3-7 Revised 09/16/11 Pages B 3.8.4 B 3.8.4-9 Revised 07/13/06 Pages B 3.8.5 B 3.8.5-3 Revised 11/06/01 Pages B 3.8.6 B 3.8.6-6 189 - Revised 08/09/00 Pages B 3.8.7 B 3.8.7-3 189 Pages B 3.8.8 B 3.8.8-3 Revised 11/06/01 Pages B 3.8.9 B 3.8.9-7 Revised 11/06/01 Pages B 3.8.10 B 3.8.10-3 Revised 11/06/01 Bases 3.9 Pages B 3.9.1 B 3.9.1-4 189 - Revised 08/09/00 Pages B 3.9.2 B 3.9.2-3 189 - Revised 02/12/01 Pages B 3.9.3 B 3.9.3-6 189 - Revised 08/09/00 Pages B 3.9.4 B 3.9.4-4 Revised 07/31/07 Pages B 3.9.5 B 3.9.5-4 Revised 07/31/07 Pages B 3.9.6 B 3.9.6-3 189 - Revised 02/27/01 Revised 09/15/2014

LCD Applicability B3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCD LCD 3.0.1 through LCD 3.0.8 establish the general requirements applicable to all Specifications and apply at all times unless otherwise stated.

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

LCD 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 LCD 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 LCD 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 plant 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.)

Palisades Nuclear Plant B 3.0-1 Revised 06/13/2013 LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCO LCO 3.0.1 LCO 3.0.2 LCO 3.0.1 through LCO 3.0.8 establish the general requirements applicable to all Specifications and apply at all times unless otherwise stated.

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

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 plant 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.)

Palisades Nuclear Plant B 3.0-1 Revised 06/13/2013

LCO Applicability B 3.0 BASES LCO 3.0.2 The second type of Required Action specifies the remedial measures that (continued) permit continued operation of the plant 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.

Completing the Required Actions is not required when an LCO is met or is no longer applicable, unless otherwise stated in the individual Specifications.

The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no longer exist. The individual LCOs ACTIONS specify the Required Actions where this is the case. An example of this is in LCO 3.4.3, PCS Pressure and Temperature (PIT) Limits.

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems.

Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience. Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/trains of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered. Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing.

In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.

When a change in MODE or other specified condition is required to comply with Required Actions, the plant may enter a MODE or other specified condition in which another Specification becomes applicable.

In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable and the ACTIONS Condition(s) are entered.

Palisades Nuclear Plant B 3.0-2 Revised 06/13/2013 BASES LCO 3.0.2

( continued)

LCO Applicability B 3.0 The second type of Required Action specifies the remedial measures that permit continued operation of the plant 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.

Completing the Required Actions is not required when an LCO is met or is no longer applicable, unless otherwise stated in the individual Specifications.

The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no longer exist. The individual LCO's ACTIONS specify the Required Actions where this is the case. An example of this is in LCO 3.4.3, "PCS Pressure and Temperature (PfT) Limits."

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems.

Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience. Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/trains of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered. Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.

When a change in MODE or other specified condition is required to comply with Required Actions, the plant may enter a MODE or other specified condition in which another Specification becomes applicable.

In this case, the Completion Times of the associated Required Actions would apply from the pOint in time that the new Specification becomes applicable and the ACTIONS Condition(s) are entered.

Palisades Nuclear Plant B 3.0-2 Revised 06/13/2013

LCO Applicability B 3.0 BASES LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:

a.

An associated Required Action and Completion Time is not met and no other Condition applies; or b.

The condition of the plant is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the plant. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

This Specification delineates the time limits for placing the plant in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS.

It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to prepare for an orderly shutdown before initiating a change in plant operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to reach lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the plant, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Primary Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.

Palisades Nuclear Plant B 3.0-3 Revised 06/13/2013 BASES LCO 3.0.3 LCO Applicability B 3.0 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:

a.

An associated Required Action and Completion Time is not met and no other Condition applies; or

b.

The condition of the plant is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the plant. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

This Specification delineates the time limits for placing the plant in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to prepare for an orderly shutdown before initiating a change in plant operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to reach lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the plant, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Primary Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.

Palisades Nuclear Plant B 3.0-3 Revised 06/13/2013

LCO Applicability B 3.0 BASES LCO 3.0.3 A plant shutdown required in accordance with LCO 3.0.3 may be (continued) terminated and LCO 3.0.3 exited if any of the following occurs:

a.

The LCO is now met.

b.

A Condition exists for which the Required Actions have now been performed.

c.

ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.

The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the plant to be in MODE 5 when a shutdown is required during MODE 1 operation.

If the plant is in a lower MODE of operation when a shutdown is required, the time limit for reaching the next lower MODE applies.

If a lower MODE is reached in less time than allowed, however, the total allowable time to reach MODE 5, or other applicable MODE, is not reduced. For example, if MODE 3 is reached in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , then the time allowed for reaching MODE 4 is the next 29 hours3.356481e-4 days 0.00806 hours 4.794974e-5 weeks 1.10345e-5 months , because the total time for reaching MODE 4 is not reduced from the allowable limit of 31 hours3.587963e-4 days 0.00861 hours 5.125661e-5 weeks 1.17955e-5 months . Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to reach a lower MODE of operation in less than the total time allowed.

In MODES 1, 2, 3, and 4, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 5 and 6 because the plant is already in the most restrictive Condition required by LCO 3.0.3.

The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, 3, or 4) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken. Exceptions to LCO 3.0.3 are provided in instances where requiring a plant shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the plant.

An example of this is in LCO 3.7.14, Spent Fuel Pool Water Level.

Palisades Nuclear Plant B 3.0-4 Revised 06/13/2013 BASES LCO 3.0.3 (continued)

LCO Applicability B 3.0 A plant shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:

a.

The LCO is now met.

b.

A Condition exists for which the Required Actions have now been performed.

c.

ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.

The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the plant to be in MODE 5 when a shutdown is required during MODE 1 operation. If the plant is in a lower MODE of operation when a shutdown is required, the time limit for reaching the next lower MODE applies. If a lower MODE is reached in less time than allowed, however, the total allowable time to reach MODE 5, or other applicable MODE, is not reduced. For example, if MODE 3 is reached in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , then the time allowed for reaching MODE 4 is the next 29 hours3.356481e-4 days 0.00806 hours 4.794974e-5 weeks 1.10345e-5 months , because the total time for reaching MODE 4 is not reduced from the allowable limit of 31 hours3.587963e-4 days 0.00861 hours 5.125661e-5 weeks 1.17955e-5 months . Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to reach a lower MODE of operation in less than the total time allowed.

In MODES 1, 2, 3, and 4, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 5 and 6 because the plant is already in the most restrictive Condition required by LCO 3.0.3.

The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, 3, or 4) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken. Exceptions to LCO 3.0.3 are provided in instances where requiring a plant shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the plant.

An example of this is in LCO 3.7.14, "Spent Fuel Pool Water LeveL" Palisades Nuclear Plant B 3.0-4 Revised 06/13/2013

LCD Applicability B3.0 BASES LCD 3.0.3 LCD 3.7.14 has an Applicability of During movement of irradiated fuel (continued) assemblies in the spent fuel pool. Therefore, this LCO can be applicable in any or all MODES.

If the LCD and the Required Actions of LCO 3.7.14 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the plant in a shutdown condition. The Required Action of LCO 3.7.14 of Suspend movement of irradiated fuel assemblies in spent fuel pool is the appropriate Required Action to complete in lieu of the actions of LCD 3.0.3. These exceptions are addressed in the individual Specifications.

LCO 3.0.4 LCD 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met.

It allows placing the plant in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when plant conditions are such that the requirements of the LCD would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCD 3.0.4.c.

LCD 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met 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. Compliance with Required Actions that permit continued operation of the plant for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the plant before or after the MODE change.

Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions.

LCD 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCD not met 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.

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR5O.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope.

Palisades Nuclear Plant B 3.0-5 Revised 06/13/2013 BASES LCO 3.0.3

( continued)

LCO 3.0.4 LCO Applicability B 3.0 LCO 3.7.14 has an Applicability of IIDu ring movement of irradiated fuel assemblies in the spent fuel pool.lI Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.14 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the plant in a shutdown condition. The Required Action of LCO 3.7.14 of "Suspend movement of irradiated fuel assemblies in spent fuel pooll! is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.

LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the plant in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when plant conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met 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. Compliance with Required Actions that permit continued operation of the plant for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the plant before or after the MODE change.

Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions.

LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met 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.

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope.

Palisades Nuclear Plant B 3.0-5 Revised 06/13/2013

LCO Applicability B 3.0 BASES LCO 3.0.4 The risk assessments will be conducted using the procedures and (continued) guidance endorsed by Regulatory Guide 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.

Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented.

The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these system and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable.

Palisades Nuclear Plant B 3.0-6 Revised 06/13/2013 BASES LCO 3.0.4 (continued)

LCO Applicability B 3.0 The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants."

Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented.

The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these system and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable.

Palisades Nuclear Plant B 3.0-6 Revised 06/13/2013

LCO Applicability B 3.0 BASES LCO 3.0.4 LCO 3.0.4.c allows entry into a MODE or other specified condition in the (continued)

Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications which describe values and parameters (e.g., primary coolant system specific activity), and may be applied to other Specifications based on NRC plant-specific approval.

The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS.

In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any plant shutdown. In this context, a plant shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.

Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the plant is not within the Applicability of the Technical Specification.

Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SR5 must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

Palisades Nuclear Plant B 3.0-7 Revised 06/13/2013 BASES LCO 3.0.4

( continued)

LCO Applicability B 3.0 LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications which describe values and parameters (e.g., primary coolant system specific activity), and may be applied to other Specifications based on NRC plant-specific approval.

The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any plant shutdown. In this context, a plant shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.

Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the plant is not within the Applicability of the Technical Specification.

Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

Palisades Nuclear Plant B 3.0-7 Revised 06/13/2013

LCO Applicability B 3.0 BASES LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate:

a.

The OPERABILITY of the equipment being returned to service; or b.

The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance.

An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the required testing.

An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system.

LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for supported systems that have a support system LCO specified in the Technical Specifications (TS). This exception is provided because LCO 3.0.2 would require that the Conditions and Required Actions of the associated inoperable supported system LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the plant is maintained in a safe condition are specified in the support system LCOs Required Actions. These Required Actions may include entering the supported systems Conditions and Required Actions or may specify other Required Actions.

Palisades Nuclear Plant B 3.0-8 Revised 06/13/2013 BASES LCO 3.0.5 LCO 3.0.6 LCO Applicability B 3.0 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate:

a.

The OPERABILITY of the equipment being returned to service; or

b.

The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance.

An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the required testing.

An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system.

LCO 3.0.6 establishes an exception to LCO 3.0.2 for supported systems that have a support system LCO specified in the Technical Specifications (TS). This exception is provided because LCO 3.0.2 would require that the Conditions and Required Actions of the associated inoperable supported system LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the plant is maintained in a safe condition are specified in the support system LCO's Required Actions. These Required Actions may include entering the supported system's Conditions and Required Actions or may specify other Required Actions.

Palisades Nuclear Plant B 3.0-8 Revised 06/13/2013

LCO Applicability B 3.0 BASES LCO 3.0.6 When a support system is inoperable and there is an LCO specified for it (continued) in the TS, the supported system(s) are required to be declared inoperable if determined to be inoperable as a result of the support system inoperability. However, it is not necessary to enter into the supported systems Conditions and Required Actions unless directed to do so by the support systems Required Actions. The potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems LCOs Conditions and Required Actions are eliminated by providing all the actions that are necessary to ensure the plant is maintained in a safe condition in the support systems Required Actions.

However, there are instances where a support systems Required Action may either direct a supported system to be declared inoperable or direct entry into Conditions and Required Actions for the supported system.

This may occur immediately or after some specified delay to perform some other Required Action. Regardless of whether it is immediate or after some delay, when a support systems 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.

Specification 5.5.13, Safety Functions Determination Program (SFDP),

ensures loss of safety function is detected and appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other limitations, remedial actions, or compensatory actions may be identified as a result of the support system inoperability and corresponding exception to entering supported system Conditions and Required Actions. The SFDP implements the requirements of LCO 3.0.6.

Cross train checks to identify a loss of safety function for 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.

Palisades Nuclear Plant B 3.0-9 Revised 06/13/2013 BASES LCO 3.0.6 (continued)

LCO Applicability B 3.0 When a support system is inoperable and there is an LCO specified for it in the TS, the supported system(s) are required to be declared inoperable if determined to be inoperable as a result of the support system inoperability. However, it is not necessary to enter into the supported systems l Conditions and Required Actions unless directed to do so by the support system's Required Actions. The potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems l LCO's Conditions and Required Actions are eliminated by providing all the actions that are necessary to ensure the plant is maintained in a safe condition in the support system's Required Actions.

However, there are instances where a support system's Required Action may either direct a supported system to be declared inoperable or direct entry into Conditions and Required Actions for the supported system.

This may occur immediately or after some specified delay to perform some other Required Action. Regardless of whether it is immediate or after some delay, 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.

Specification 5.5.13, IISafety Functions Determination Program (SFDP),II ensures loss of safety function is detected and appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other limitations, remedial actions, or compensatory actions may be identified as a result of the support system inoperability and corresponding exception to entering supported system Conditions and Required Actions. The SFDP implements the requirements of LCO 3.0.6.

Cross train checks to identify a loss of safety function for 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.

Palisades Nuclear Plant B 3.0-9 Revised 06/13/2013

SR Applicability B 3.0 BASES LCO 3.0.7 Special tests and operations are required at various times over the plants life to demonstrate performance characteristics, to perform maintenance activities, and to perform special evaluations. Because TS normally preclude these tests and operations, Special Test Exceptions (STEs) allow specified requirements to be changed or suspended under controlled conditions. STEs are included in applicable sections of the Specifications. Unless otherwise specified, all other TS requirements remain unchanged and in effect as applicable. This will ensure that all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed or suspended to perform the special test or operation will remain in effect.

The Applicability of an STE LCO represents a condition not necessarily in compliance with the normal requirements of the TS. Compliance with STE LCO is optional.

A special test may be performed under either the provisions of the appropriate STE LCO or the other applicable TS requirements.

If it is desired to perform the special test under the provisions of the STE LCO, the requirements of the STE LCO shall be followed. This includes the SRs specified in the STE LCO.

Some of the STE LCO require that one or more of the LCO for normal operation be met (i.e., meeting the STE LCO requires meeting the specified normal LCO). The Applicability, ACTIONS, and SRs of the specified normal LCO, however, are not required to be met in order to meet the STE LCO when it is in effect. This means that, upon failure to meet a specified normal LCO, the associated ACTIONS of the STE LCO apply, in lieu of the ACTIONS of the normal LCO. Exceptions to the above do exist. There are instances when the Applicability of the specified normal LCO must be met, where its ACTIONS must be taken, where certain of its Surveillances must be performed, or where all of these requirements must be met concurrently with the requirements of the STE LCO.

Unless the SRs of the specified normal LCO are suspended or changed by the special test, those SRs that are necessary to meet the specified normal LCO must be met prior to performing the special test. During the conduct of the special test, those Surveillances need not be performed unless specified by the ACTIONS or SRs of the STE LCO.

ACTIONS for STE LCO provide appropriate remedial measures upon failure to meet the STE LCO. Upon failure to meet these ACTIONS, suspend the performance of the special test and enter the ACTIONS for all LCOs that are then not met. Entry into LCO 3.0.3 may possibly be required, but this determination should not be made by considering only the failure to meet the ACTIONS of the STE LCO.

Palisades Nuclear Plant B 3.0-10 Revised 06/13/2013 BASES LCO 3.0.7 S R Applicability B3.0 Special tests and operations are required at various times over the plant's life to demonstrate performance characteristics, to perform maintenance activities, and to perform special evaluations. Because TS normally preclude these tests and operations, Special Test Exceptions (STEs) allow specified requirements to be changed or suspended under controlled conditions. STEs are included in applicable sections of the Specifications. Unless otherwise specified, all other TS requirements remain unchanged and in effect as applicable. This will ensure that all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed or suspended to perform the special test or operation will remain in effect.

The Applicability of an STE LCO represents a condition not necessarily in compliance with the normal requirements of the TS. Compliance with STE LCO is optional.

A special test may be performed under either the provisions of the appropriate STE LCO or the other applicable TS requirements. If it is desired to perform the special test under the provisions of the STE LCO, the requirements of the STE LCO shall be followed. This includes the SRs specified in the STE LCO.

Some of the STE LCO require that one or more of the LCO for normal operation be met (Le., meeting the STE LCO requires meeting the specified normal LCO). The Applicability, ACTIONS, and SRs of the specified normal LCO, however, are not required to be met in order to meet the STE LCO when it is in effect. This means that, upon failure to meet a specified normal LCO, the associated ACTIONS of the STE LCO apply, in lieu of the ACTIONS of the normal LCO. Exceptions to the above do exist. There are instances when the Applicability of the specified normal LCO must be met, where its ACTIONS must be taken, where certain of its Surveillances must be performed, or where all of these requirements must be met concurrently with the requirements of the STE LCO.

Unless the SRs of the specified normal LCO are suspended or changed by the special test, those SRs that are necessary to meet the specified normal LCO must be met prior to performing the special test. During the conduct of the special test, those Surveillances need not be performed unless specified by the ACTIONS or SRs of the STE LCO.

ACTIONS for STE LCO provide appropriate remedial measures upon failure to meet the STE LCO. Upon failure to meet these ACTIONS, suspend the performance of the special test and enter the ACTIONS for all LCOs that are then not met. Entry into LCO 3.0.3 may possibly be required, but this determination should not be made by considering only the failure to meet the ACTIONS of the STE LCO.

Palisades Nuclear Plant B 3.0-10 Revised 06/13/2013

SR Applicability B 3.0 BASES 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 LCQ 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). The snubber requirements do not meet the criteria in 10 CFR 50.36(c)(2)(ii), and, as such, are appropriate for administrative control.

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

Every time that the provisions of LCO 3.0.8 are applied it is required to confirm that at least one train (or subsystem) of systems supported by the inoperable snubbers would remain capable of performing their required safety or support functions for postulated design loads other than seismic loads. LCO 3.0.8 does not apply to non-seismic snubbers (i.e., seismic vs non-seismic), implementation of this restriction, and the associated plant configuration shall be available on a recoverable basis for NRC staff inspection. SEP-SNB-PLP-001, Snubber Examination and Testing Program, may be used as a reference for application of LCO 3.0.8 to site specific snubbers.

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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the snubber(s) before declaring the supported system inoperable. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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.

When applying LCO 3.0.8.a at least one AFW train (including a minimum set of supporting equipment required for its successful operation), or some alternative means of core cooling, not associated with the inoperable snubber(s), must be available. Implementation of this restriction and the associated plant configuration shall be available on a recoverable basis for NRC staff inspection.

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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to restore the snubber(s) before declaring the supported system inoperable. The 12 Palisades Nuclear Plant B 3.0-1 1 Revised 06/13/2013 BASES LCO 3.0.8 S R Applicability B 3.0 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). The snubber requirements do not meet the criteria in 10 CFR 50.36(c)(2)(ii), and, as such, are appropriate for administrative control.

If the 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.

Every time that the provisions of LCO 3.0.8 are applied it is required to confirm that at least one train (or subsystem) of systems supported by the inoperable snubbers would remain capable of performing their required safety or support functions for postulated design loads other than seismic loads. LCO 3.0.8 does not apply to non-seismic snubbers (Le., seismic vs non-seismic), implementation of this restriction, and the associated plant configuration shall be available on a recoverable basis for NRC staff inspection. SEP-SNB-PLP-001, "Snubber Examination and Testing Program," may be used as a reference for application of LCO 3.0.8 to site specific snubbers.

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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the snubber(s) before declaring the supported system inoperable. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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.

When applying LCO 3.0.8.a at least one AFW train (including a minimum set of supporting equipment required for its successful operation), or some alternative means of core cooling, not associated with the inoperable snubber(s), must be available. Implementation of this restriction and the associated plant configuration shall be available on a recoverable basis for NRC staff inspection.

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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to restore the snubber(s) before declaring the supported system inoperable. The 12 Palisades Nuclear Plant B 3.0-11 Revised 06/13/2013

SR Applicability B 3.0 hour0 days 0 hours 0 weeks 0 months 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.

When applying LCO 3.0.8.b at least one AFW train (including a minimum set of supporting equipment required for its successful operation) not associated with the inoperable snubber(s), or some alternative means of core cooling (e.g., F&B, fire water system or aggressive secondary cooldown using the steam generators) must be available. Implementation of this restriction and the associated plant configuration shall be available on a recoverable basis for NRC staff inspection.

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.

Palisades Nuclear Plant B 3.0-12 Revised 06/13/2013 SR Applicability B 3.0 hour0 days 0 hours 0 weeks 0 months 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.

When applying LCO 3.0.8.b at least one AFW train (including a minimum set of supporting equipment required for its successful operation) not associated with the inoperable snubber(s), or some alternative means of core cooling (e.g., F&B, fire water system or "aggressive secondary cooldown" using the steam generators) must be available. Implementation of this restriction and the associated plant configuration shall be available on a recoverable basis for NRC staff inspection.

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.

Palisades Nuclear Plant B 3.0-12 Revised 06/13/2013

SR Applicability B 3.0 B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY BASES SRs SR 3.0.1 through SR 3.0.4 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

SR 3.0.1 SR 3.0.1 establishes the requirement that SRs must be met during the MODES or other specified conditions in the Applicability for which the requirements of the LCO apply, unless otherwise specified in the individual SRs. This Specification is to ensure that Surveillances are performed to verify the OPERABILITY of systems and components, and that variables are within specified limits. Failure to meet a Surveillance within the specified Frequency, in accordance with SR 3.0.2, constitutes a failure to meet an LCO. Surveillances may be performed by means of any series of sequential, overlapping, or total steps provided the entire Surveillance is performed within the specified Frequency. Additionally, the definitions related to instrument testing (e.g., CHANNEL CALIBRATION) specify that these tests are performed by means of any series of sequential, overlapping, or total steps.

Systems and components are assumed to be OPERABLE when the associated SRs have been met. Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when:

a.

The systems or components are known to be inoperable, although still meeting the SRs; or b.

The requirements of the Surveillance(s) are known to be not met between required Surveillance performances.

Surveillances do not have to be performed when the plant is in a MODE or other specified condition for which the requirements of the associated LCO are not applicable, unless otherwise specified. The SRs associated with a Special Test Exception (STE) are only applicable when the STE is used as an allowable exception to the requirements of a Specification.

Unplanned events may satisfy the requirements (including applicable acceptance criteria) for a given SR.

In this case, the unplanned event may be credited as fulfilling the performance of the SR. This allowance includes those SRs whose performance is normally precluded in a given MODE or other specified condition.

Surveillances, including Surveillances invoked by Required Actions, do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply. Surveillances have to be met and performed in accordance with SR 3.0.2, prior to returning equipment to OPERABLE status.

Palisades Nuclear Plant B 3.0-13 Revised 06/13/2013 SR Applicability B 3.0 B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY BASES SRs SR 3.0.1 SR 3.0.1 through SR 3.0.4 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

SR 3.0.1 establishes the requirement that SRs must be met during the MODES or other specified conditions in the Applicability for which the requirements of the LCO apply, unless otherwise specified in the individual SRs. This Specification is to ensure that Surveillances are performed to verify the OPERABILITY of systems and components, and that variables are within specified limits. Failure to meet a Surveillance within the specified Frequency, in accordance with SR 3.0.2, constitutes a failure to meet an LCO. Surveillances may be performed by means of any series of sequential, overlapping, or total steps provided the entire Surveillance is performed within the specified Frequency. Additionally, the definitions related to instrument testing (e.g., CHANNEL CALIBRATION) specify that these tests are performed by means of any series of sequential, overlapping, or total steps.

Systems and components are assumed to be OPERABLE when the associated SRs have been met. Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when:

a.

The systems or components are known to be inoperable, although still meeting the SRs; or

b.

The requirements of the Surveillance(s) are known to be not met between required Surveillance performances.

Surveillances do not have to be performed when the plant is in a MODE or other specified condition for which the requirements of the associated LCO are not applicable, unless otherwise specified. The SRs associated with a Special Test Exception (STE) are only applicable when the STE is used as an allowable exception to the requirements of a Specification.

Unplanned events may satisfy the requirements (including applicable acceptance criteria) for a given SR. In this case, the unplanned event may be credited as fulfilling the performance of the SR. This allowance includes those SRs whose performance is normally precluded in a given MODE or other specified condition.

Surveillances, including Surveillances invoked by Required Actions, do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply. Surveillances have to be met and performed in accordance with SR 3.0.2, prior to returning equipment to OPERABLE status.

Palisades Nuclear Plant B 3.0-13 Revised 06/13/2013

SR Applicability B 3.0 BASES SR 3.0.1 Upon completion of maintenance, appropriate post maintenance testing (continued) is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 3.0.2. Post maintenance testing may not be possible in the current MODE or other specified conditions in the Applicability due to the necessary plant parameters not having been established.

In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a MODE or other specified condition where other necessary post maintenance tests can be completed.

An example of this process is:

a.

High Pressure Safety Injection (HPSI) maintenance during shutdown that requires system functional tests at a specified pressure. Provided other appropriate testing is satisfactorily completed, startup can proceed with HPSI considered OPERABLE.

This allows operation to reach the specified pressure to complete the necessary post maintenance testing.

SR 3.0.2 SR 3.0.2 establishes the requirements for meeting the specified Frequency for Surveillances and any Required Action with a Completion Time that requires the periodic performance of the Required Action on a once per.

. interval.

SR 3.0.2 permits a 25% extension of the interval specified in the Frequency. This extension facilitates Surveillance scheduling and considers plant operating conditions that may not be suitable for conducting the Surveillance (e.g., transient conditions or other ongoing Surveillance or maintenance activities).

The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply. These exceptions are stated in the individual Specifications. An example of where SR 3.0.2 does not apply is the Containment Leak Rate Testing Program.

Palisades Nuclear Plant B 3.0-14 Revised 06/13/2013 BASES SR 3.0.1

( continued)

SR 3.0.2 SR Applicability B 3.0 Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 3.0.2. Post maintenance testing may not be possible in the current MODE or other specified conditions in the Applicability due to the necessary plant parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a MODE or other specified condition where other necessary post maintenance tests can be completed.

An example of this process is:

a.

High Pressure Safety Injection (HPSI) maintenance during shutdown that requires system functional tests at a specified pressure. Provided other appropriate testing is satisfactorily completed, startup can proceed with HPSI considered OPERABLE.

This allows operation to reach the specified pressure to complete the necessary post maintenance testing.

SR 3.0.2 establishes the requirements for meeting the specified Frequency for Surveillances and any Required Action with a Completion Time that requires the periodic performance of the Required Action on a "once per...

II interval.

SR 3.0.2 permits a 25% extension of the interval specified in the Frequency. This extension facilitates Surveillance scheduling and considers plant operating conditions that may not be suitable for conducting the Surveillance (e.g., transient conditions or other ongoing Surveillance or maintenance activities).

The 25% extension does not Significantly degrade the reliability that results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply. These exceptions are stated in the individual Specifications. An example of where SR 3.0.2 does not apply is the Containment Leak Rate Testing Program.

Palisades Nuclear Plant B 3.0-14 Revised 06/13/2013

SR Applicability B 3.0 BASES SR 3.0.2 As stated in SR 3.0.2, the 25% extension allowed by SR 3.0.2 may be (continued) applied to Required Actions whose Completion Time is stated as once per..

. however, the 25% extension does not apply to the initial performance of a Required Action with a periodic Completion Time that requires performance on a once per.

. basis. The 25% extension applies to each performance of the Required Action after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed within the specified Frequency. A delay period of 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, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.

This delay period provides an adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance.

The basis for this delay period includes consideration of plant conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

Palisades Nuclear Plant B 3.0-15 Revised 06/13/2013 BASES SR 3.0.2 (continued)

SR 3.0.3 SR Applicability B 3.0 As stated in SR 3.0.2, the 25% extension allowed by SR 3.0.2 may be applied to Required Actions whose Completion Time is stated as "once per... " however, the 25% extension does not apply to the initial performance of a Required Action with a periodic Completion Time that requires performance on a "once per...

II basis. The 25% extension applies to each performance of the Required Action after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.

SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed within the specified Frequency. A delay period of 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, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.

This delay period provides an adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance.

The basis for this delay period includes consideration of plant conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

Palisades Nuclear Plant B 3.0-15 Revised 06/13/2013

SR Applicability B 3.0 BASES SR 3.0.3 When a Surveillance with a Frequency based not on time intervals, but (continued) upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals.

While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensees Corrective Action Program.

Palisades Nuclear Plant B 3.0-16 Revised 06/13/2013 BASES SR 3.0.3 (continued)

SR Applicability B 3.0 When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals.

While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensee's Corrective Action Program.

Palisades Nuclear Plant B 3.0-16 Revised 06/13/2013

SR Applicability B 3.0 BASES SR 3.0.3 If a Surveillance is not completed within the allowed delay period, then (continued) the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period.

If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1.

SR 3.0.4 SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified Condition in the Applicability.

This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the plant.

The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability. A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to Surveillance not being met in accordance with LCO 3.0.4.

However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states that surveillances do not have to be performed on inoperable equipment.

When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed.

Therefore, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes.

Palisades Nuclear Plant B 3.0-17 Revised 06/13/2013 BASES SR 3.0.3

( continued)

SR 3.0.4 SR Applicability B 3.0 If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1.

SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified Condition in the Applicability.

This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the plant.

The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability. A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to Surveillance not being met in accordance with LCO 3.0.4.

However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states that surveillances do not have to be performed on inoperable equipment.

When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed.

Therefore, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes.

Palisades Nuclear Plant B 3.0-17 Revised 06/13/2013

SR Applicability B 3.0 BASES SR 3.0.4 SR 3.0.4 does not restrict changing MODES or other specified conditions (continued) of the Applicability when a Surveillance has not been performed within the specified Frequency, providing the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3.

The provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any plant shutdown.

In this context, a plant shutdown is defined as a change in MODE or specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.

The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCOs Applicability, would have its Frequency specified such that it is not due until the specific conditions needed are met.

Alternately, the Surveillance may be stated in the form of a Note as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs annotation is found in Section 1.4, Frequency.

Palisades Nuclear Plant B 3.0-18 Revised 06/13/2013 BASES SR 3.0.4 (continued)

SR Applicability B 3.0 SR 3.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, providing the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3.

The provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any plant shutdown. In this context, a plant shutdown is defined as a change in MODE or specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.

The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCO's Applicability, would have its Frequency specified such that it is not "due" until the specific conditions needed are met.

Alternately, the Surveillance may be stated in the form of a Note as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

Palisades Nuclear Plant B 3.0-18 Revised 06/13/2013

Spent Fuel Pool Storage B 3.7.16 B 3.7 PLANT SYSTEMS B 3.7.16 Spent Fuel Pool Storage BASES BACKGROUND The fuel storage facility is designed to store either new (nonirradiated) nuclear fuel assemblies, or used (irradiated) fuel assemblies in a vertical configuration underwater. The storage pool is sized to store 892 fuel assemblies, which includes storage for failed fuel canisters.

The fuel storage racks are grouped into two regions, Region I and Region II per Figure B 3.7.16-1. The racks are designed as a Seismic Category I structure able to withstand seismic events.

Region I contains Metamic equipped racks in the spent fuel pool having a 10.25 inch center-to-center spacing and a single Carborundum equipped rack in the north tilt pit having an 11.25 inch by 10.69 inch center-to-center spacing. The Region I Carborundum equipped rack has restrictive loading patterns to address degradation of neutron absorbing material in the rack. The loading patterns accommodate some face-adjacent fuel assemblies with consideration of burnup credit in Sub-Regions 1 D and 1 E. The Region 1 Metamic equipped racks are only restricted by maximum planar U 235 enrichment. The Region I

Carborundum equipped rack also has provisions for storing non-fissile bearing components.

Region II contains racks in both the spent fuel pool and the north tilt pit having a 9.17 inch center-to-center spacing. Because of the smaller spacing and an analyzed solid poison concentration of zero (Boraflex),

Region II also has limitations for fuel storage. Further information on limitations can be found in Section 4.0, Design Features. These limitations (e.g., enrichment, burnup, loading patterns) are sufficient to maintain a keff of 0.95 when flooded with borated water and keff < 1.0 when flooded with unborated water.

APPLICABLE The fuel storage facility was originally designed for noncriticality by use SAFETY ANALYSES of adequate spacing, and flux trap construction, whereby the fuel assemblies are inserted into neutron absorbing stainless steel cans.

The current criticality calculations also take credit for soluble boron to prevent criticality.

The spent fuel pool storage meets the requirements specified in Guidance on the Regulatory Requirements for Criticality Analysis of Fuel Storage at Light-Water Reactor Power Plants, Laurence I. Kopp, U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Reactor Systems Branch, February 1998. This document Palisades Nuclear Plant B 3.7.16-1 Amendment No. 2G, 236, 246, 250 Spent Fuel Pool Storage B 3.7.16 B 3.7 PLANT SYSTEMS B 3.7.16 Spent Fuel Pool Storage BASES BACKGROUND APPLICABLE SAFETY ANALYSES Palisades Nuclear Plant The fuel storage facility is designed to store either new (nonirradiated) nuclear fuel assemblies, or used (irradiated) fuel assemblies in a vertical configuration underwater. The storage pool is sized to store 892 fuel assemblies, which includes storage for failed fuel canisters.

The fuel storage racks are grouped into two regions, Region I and Region II per Figure B 3.7.16-1. The racks are designed as a Seismic Category I structure able to withstand seismic events.

Region I contains Metamic equipped racks in the spent fuel pool having a 10.25 inch center-to-center spacing and a single Carborundum equipped rack in the north tilt pit having an 11.25 inch by 10.69 inch center-to-center spacing. The Region I Carborundum equipped rack has restrictive loading patterns to address degradation of neutron absorbing material in the rack. The loading patterns accommodate some face-adjacent fuel assemblies with consideration of burnup credit in Sub-Regions 1 D and 1 E. The Region 1 Metamic equipped racks are only restricted by maximum planar U235 enrichment. The Region I Carborundum equipped rack also has provisions for storing non-fissile bearing components.

Region II contains racks in both the spent fuel pool and the north tilt pit having a 9.17 inch center-to-center spacing. Because of the smaller spacing and an analyzed solid poison concentration of zero (Boraflex),

Region II also has limitations for fuel storage. Further information on limitations can be found in Section 4.0, "Design Features." These limitations (e.g., enrichment, burnup, loading patterns) are sufficient to maintain a keff of S 0.95 when flooded with borated water and keff < 1.0 when flooded with unborated water.

The fuel storage facility was originally designed for noncriticality by use of adequate spacing, and "flux trap" construction, whereby the fuel assemblies are inserted into neutron absorbing stainless steel cans.

The current criticality calculations also take credit for soluble boron to prevent criticality.

The spent fuel pool storage meets the requirements specified in "Guidance on the Regulatory Requirements for Criticality Analysis of Fuel Storage at Light-Water Reactor Power Plants", Laurence I. Kopp, U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Reactor Systems Branch, February 1998. This document B 3.7.16-1 Amendment No. 2Q7, 23e, 249, 250

Spent Fuel Pool Storage B 3.7.16 APPLICABLE established the requirements for use of soluble boron to maintain SAFETY ANALYSES keff 0.95.

(continued)

The spent fuel pool storage satisfies Criterion 2 of 10 CFR 50.36(c)(2).

LCO The restrictions for the Region I Carborundum equipped storage rack in Specification 4.3.1.1 on fuel assembly enrichment and the storage pool loading patterns, and on the placement of non-fissile bearing components, ensure that the keff of the spent fuel pool will always remain 0.95, assuming the pool to be flooded with water borated to 850 ppm, and < 1.0 if fully flooded with unborated water. Non-fissile bearing components shall be stored in accordance with Specification 4.3.1.lm. The restrictions are consistent with the criticality safety analyses performed for the spent fuel pool.

The restrictions for the Region I Metamic equipped storage racks in Specification 4.3.1.2 on fuel assembly enrichment ensure that the ke of the spent fuel pool will always remain 0.95, assuming the pool to be flooded with water borated to 850 ppm, and < 1.0 if fully flooded with unborated water.

The restrictions for Region II in Table 3.7.16-1, in the accompanying LCO, on fuel assembly enrichment and minimum burnup combinations, ensure that the keff of the spent fuel pool will always remain 0.95, assuming the pool to be flooded with water borated to 850 ppm, and

<1.0 if fully flooded with unborated water. The restrictions are consistent with the criticality safety analyses performed for the spent fuel pool according to Table 3.7.16-1, in the accompanying LCO. Fuel assemblies not meeting the criteria of Table 3.7.16-1 shall be stored in accordance with Specification 4.3.1.1 or 4.3.1.2.

Specification 4.3.1.1 describes U-235 enrichment restrictions for fuel assemblies stored in the Region I Carborundum equipped storage rack based on maximum nominal planar average U-235 enrichment. The term nominal describes the design enrichment specified for an assembly. The criticality calculations that support the Region I storage requirements include a manufacturers fuel enrichment tolerance of

+/-0.05 weight percent U-235. Specification 4.3.1.1 does not include the manufacturers fuel enrichment tolerance.

The term maximum refers to an assemblys limiting nominal planar average U-235 enrichment. Palisades fuel assembly design may have several distinct axial planar regions, and each region may have a different nominal planar average U-235 enrichment. Additionally, fuel Palisades Nuclear Plant B 3.7.16-2 Amendment No. 2.O, 2, 24, 250 BASES BASES APPLICABLE SAFETY ANALYSES

( continued)

LCD Palisades Nuclear Plant Spent Fuel Pool Storage B 3.7.16 established the requirements for use of soluble boron to maintain keff ~0.95.

The spent fuel pool storage satisfies Criterion 2 of 10 CFR 50.36(c)(2).

The restrictions for the Region I Carborundum equipped storage rack in Specification 4.3.1.1 on fuel assembly enrichment and the storage pool loading patterns, and on the placement of non-fissile bearing components, ensure that the keff of the spent fuel pool will always remain S 0.95, assuming the pool to be flooded with water borated to 850 ppm, and < 1.0 if fully flooded with unborated water. Non-fissile bearing components shall be stored in accordance with Specification 4.3.1.1 m. The restrictions are consistent with the criticality safety analyses performed for the spent fuel pool.

The restrictions for the Region I Metamic equipped storage racks in Specification 4.3.1.2 on fuel assembly enrichment ensure that the keff of the spent fuel pool will always remain s 0.95, assuming the pool to be flooded with water borated to 850 ppm, and < 1.0 if fully flooded with unborated water.

The restrictions for Region II in Table 3.7.16-1, in the accompanying LCD, on fuel assembly enrichment and minimum burnup combinations, ensure that the keff of the spent fuel pool will always remain ~ 0.95, assuming the pool to be flooded with water borated to 850 ppm, and

< 1.0 if fully flooded with unborated water. The restrictions are consistent with the criticality safety analyses performed for the spent fuel pool according to Table 3.7.16-1, in the accompanying LCD. Fuel assemblies not meeting the criteria of Table 3.7.16-1 shall be stored in accordance with Specification 4.3.1.1 or 4.3.1.2.

Specification 4.3.1.1 describes U-235 enrichment restrictions for fuel assemblies stored in the Region I Carborundum equipped storage rack based on maximum nominal planar average U-235 enrichment. The term "nominal" describes the deSign enrichment specified for an assembly. The criticality calculations that support the Region I storage requirements include a manufacturer's fuel enrichment tolerance of

+/-0.05 weight percent U-235. Specification 4.3.1.1 does not include the manufacturer's fuel enrichment tolerance.

The term "maximum" refers to an assembly's limiting nominal planar average U-235 enrichment. Palisades' fuel assembly design may have several distinct axial planar regions, and each region may have a different nominal planar average U-235 enrichment. Additionally, fuel B 3.7.16-2 Amendment No. 2Q7, 23&, 246, 250

Spent Fuel Pool Storage B 3.7.16 BASES LCO assembly enrichments may vary from pin to pin within a given axial (continued) planar region. The criticality analysis conservatively assumes each pin is loaded with the nominal enrichment for that planar region. The highest nominal planar average enrichment of the distinct axial planar regions is considered to be the maximum nominal planar average enrichment for that assembly. This value is used to verify that storage requirements have been met. The manufacturers fuel enrichment tolerance of +/-0.05 weight percent is excluded from this value.

Sub-Regions 1 D & 1 E in Region 1 can be distributed in any manner providing that any 2-by-2 grouping of cells and the assemblies in them meet the requirements of 4.3.1.lj or 4.3.1.1k for the number of cells occupied. For example, for a 4-by-4 group of cells, all of the following 2-by-2 configurations must be examined against the above requirements:

HHHHHH HHHHHHH H1HHHH APPLICABILITY This LCO applies whenever any fuel assembly or non-fissile bearing component is stored in the spent fuel pool or the north tilt pit.

Palisades Nuclear Plant B 3.7.16-3 Amendment No. 2O, 236, 246 250 BASES LCO

( continued)

APPLICABILITY Palisades Nuclear Plant Spent Fuel Pool Storage B 3.7.16 assembly enrichments may vary from pin to pin within a given axial planar region. The criticality analysis conservatively assumes each pin is loaded with the nominal enrichment for that planar region. The highest nominal planar average enrichment of the distinct axial planar regions is considered to be the maximum nominal planar average enrichment for that assembly. This value is used to verify that storage requirements have been met. The manufacturer's fuel enrichment tolerance of +/-0.05 weight percent is excluded from this value.

Sub-Regions 1 D & 1 E in Region 1 can be distributed in any manner providing that any 2-by-2 grouping of cells and the assemblies in them meet the requirements of 4.3.1.1j or 4.3.1.1 k for the number of cells occupied. For example, for a 4-by-4 group of cells, all of the following 2-by-2 configurations must be examined against the above requirements:

This LCO applies whenever any fuel assembly or non-fissile bearing component is stored in the spent fuel pool or the north tilt pit.

B 3.7.16-3 Amendment No. 2Q7, 2de, 246, 250

Spent Fuel Pool Storage B 3.7.16 BASES ACTIONS The ACTIONS are modified by a Note indicating that LCO 3.0.3 does not apply.

If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action.

If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operation. Therefore, in either case, inability to move fuel assemblies is not sufficient reason to require a reactor shutdown.

When the configuration of fuel assemblies or non-fissile bearing components stored in the spent fuel pool is not in accordance with the storage requirements, immediate action must be taken to make the necessary movement(s) to bring the configuration into compliance with the requirements.

SURVEILLANCE SR 3.7.16.1 REQUI REMENTS This SR verifies by administrative means that the combination of fuel assembly maximum nominal planar average enrichment and proposed fuel assembly placement is in accordance with Specification 4.3.1.1 prior to placing the assembly in a Region I Carborundum equipped storage location. This SR also verifies by administrative means that non-fissile bearing component storage will be in accordance with Specification 4.3.1.lm prior to placing the component in a Region I Carborundum storage location.

This SR also verifies by administrative means that the nominal planar average enrichment is in accordance with Specification 4.3.1.2 prior to placing the assembly in a Region I Metamic equipped storage location.

This SR also verifies by administrative means that the combination of maximum nominal planar average U-235 enrichment, burnup and decay time of the fuel assembly is in accordance with Tables 3.7.16-1 through 3.7.16-5, as appropriate, in the accompanying LCO prior to placing the fuel assembly in a storage location in the Region I Carborundum equipped rack or the Region II racks.

REFERENCES None Palisades Nuclear Plant B 3.7.16-4 Amendment No. 2O, 236, 246, 250 8ASES ACTIONS Spent Fuel Pool Storage 83.7.16 The ACTIONS are modified by a Note indicating that LCO 3.0.3 does not apply.

If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operation. Therefore, in either case, inability to move fuel assemblies is not sufficient reason to require a reactor shutdown.

When the configuration of fuel assemblies or non-fissile bearing components stored in the spent fuel pool is not in accordance with the storage requirements, immediate action must be taken to make the necessary movement(s) to bring the configuration into compliance with the requirements.

SURVEILLANCE SR 3.7.16.1 REQUIREMENTS This SR verifies by administrative means that the combination of fuel assembly maximum nominal planar average enrichment and proposed fuel assembly placement is in accordance with Specification 4.3.1.1 prior to placing the assembly in a Region I Carborundum equipped storage location. This SR also verifies by administrative means that non-fissile bearing component storage will be in accordance with Specification 4.3.1.1 m prior to placing the component in a Region I Carborundum storage location.

This SR also verifies by administrative means that the nominal planar average enrichment is in accordance with Specification 4.3.1.2 prior to placing the assembly in a Region I Metamic equipped storage location.

This SR also verifies by administrative means that the combination of maximum nominal planar average U-235 enrichment, burnup and decay time of the fuel assembly is in accordance with Tables 3.7.16-1 through 3.7.16-5, as appropriate, in the accompanying LCO prior to placing the fuel assembly in a storage location in the Region I Carborundum equipped rack or the Region II racks.

REFERENCES None Palisades Nuclear Plant 83.7.16-4 Amendment No. 2Q7, 239, a4S, 250

Figure B 3.7.16-1 (page 1 of 1)

Spent Fuel Pool Arrangement Spent Fuel Pool Storage B 3.7.16 BASES N

465.00 Ref.

178.00 Ref.

MlN POOL Nor-tb Tilt Pit 252.00 Ref.

Region I of the north tilt pit is comprised of Sub-Regions 1 D and 1 E. These Sub-Regions are defined in Specification 4.3.1.1 and are not related to the rack.

Palisades Nuclear Plant B 3.7.16-5 Amendment No. 2-7, 6, 246, 250 BASES N

' l

~

I' 465.00 1 Ref.

I r

I RegIon II I ReglOn II I

I I

11 x 11 11 x 11 176.00" I

IV-l W-2 Ref.

I I.--

I RegIon II RegIon II I

7 x 11 7 x 11 I

\\01-4 I

\\01-3 I

I 60.00" RegIon II RegIon II G x 7 G x G Ref.

W-5 W-6

~~==~~~~==~

L North TIlt Plt I

252.00 1 Ref. --J Figure B 3.7.16-1 (page 1 of 1)

Spent Fuel Pool Arrangement Spent Fuel Pool Storage B 3.7.16

'1 MAIN POOL Region I of the north tilt pit is comprised of Sub-Regions 1 D and 1 E. These Sub-Regions are defined in Specification 4.3.1.1 and are not related to the rack.

Palisades Nuclear Plant B 3.7.16-5 Amendment No. 207, 239, a4e, 250

PNP 2014-088, Report to NRC of Changes to Technical Specifications Bases

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