Text

Proposed Tech Specs Markups of Previously Submitted Pages & Revised ITS Submittal Pages
	ML18066A302
Person / Time
Site:	Palisades
Issue date:	09/14/1998
From:	; CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	;
Shared Package
ML18066A301	List: ML18066A300; ML18066A302;
References
	RTR-NUREG-1432 NUDOCS 9809300335
	Download: ML18066A302 (247)
	v • d • e

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ATTACHMENT 1 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO* NRC QUESTIONS

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9809300335 980914 PDR ADOCK 05000255

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CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3.8.1-01 JFD 10 STS 3. 8. 1 Required Action A. 2 ITS 3. 8. 1 Condition A With one offsite circuit inoperable, STS 3.8.1 Required Action A.2 specifies to declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable. This requirement has not been adopted in the Required Actions for Condition A in corresponding ITS 3. 8. 1. JFD 1O states that the Palisades design and requirements for operable offsite circuits ensures that each ESF bus will be energized if at least one circuit is operable.

Comment: JFD 10 does not explain how each ESF bus would be energized if only one offsite circuit is operable, or how long it would take to accomplish. No requirement has been proposed to verify that each ESF bus is energized following the loss of an offsite circuit. Additionally, Required Action A.2 applies to required features with no offsite power available. If offsite power is available to a required feature, no action is required.

Revise the submittal to adopt Required Action A. 2, or provide appropriate technical

justification for the difference.

Consumers Energy Response:

JFD 10 has been revised to provide additional clarification relative to the operability requirements between the offsite transmission network and the onsite class 1E electrical power distribution system for the Palisades plant, and to explain why ISTS 3.8.1 Required Action A.2 is not applicable in the Palisades ITS.

Affected Submittal Pages:

JFD 3.8.1 pg 2 of 3 1

ATTACHMENT 6 JUSTIFICATIONS FOR DEVIATIONS SPECIFICATION 3.8.1, AC SOURCES - OPERATING Discussion

6. The option to specifically list automatic load sequencers as a third type of AC Source, and provide a separate Action, is not adopted. Sequencers are not a separate source of "A.

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1'&.\0..

AC power; rather they are a support component for the DG function. As such they are implicitly required to be Operable by the requirement for DG Operability (as detailed in the ITS Bases). Similarly, when discovered inoperable, the Actions for an inoperable DG apply without having to state so explicitly.

NUREG-1432 Bases support this. The Reviewer's Note in the Bases for Required Action F .1 indicates that the specific condition related to the sequencer may be deleted

- if the unit design is such that any sequencer failure mode will only affect the ability of the associated DG to. power its respective safety loads under any conditions." t_ ~

7. The maximum time allowed to fail to meet the LCO is revised from 6 days to 10 days.

The accepted NUREG-1432 practice for limiting successive alternating inoperabilities with this type of maximum time Completion Time, is to allow one full Complete Time for each of the associated component types. In this case, with the proposed Completion Times of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for an offsite circuit and 7 days for a DG, the maximum time is appropriately specified as 10 days.

8. The Palisades DG design does not incorporate "gradual acceleration" on a DG start.

NUREG-1432 presentation of SR 3.8.1.2 Notes 1and3, and SR 3.8.1.7, are addressing this design feature. The proposed modifications to eliminate these Notes and the SR provides the appropriate presentation for the Palisades DG design.

9. The Palisades DG design does not incorporate "gradual acceleration" on a DG start.

Similarly, NUREG-1432 SR 3.8.1.3 Note 1 states an allowance for "gradual loading ...

However, since there is no stated prohibition to gradual loading, and the surveillance itself does not impose and loading-rate criteria, this Note is infonnational only, and should be removed as a Technical Specification requirement.

10. ISTS 3.8.1 Required Action A.2 is not retained; consistent with CTS. The PalisadesllA.I design and requirements for operable offsite circuits ensures that each ESF bus will be 3. ~. \- 0 l energized if at least one circuit is operable. If any bus can not be energized, then both required offsite circuits would be declared inoperable .

Palisades Nuclear Plant Page 2 of 3

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3.8.1-01 JFD 10 The qualified offsite circuits required by ITS LCO 3.8.1 are Safeguards Transformer 1-1 and Startup Transformer 1-2. For an offsite circuit to be considered operable, it must be capable of supplying electrical power to both class lE electrical trains. Inclusive in the requirement for operability is that the associated cables, instruments and breakers, necessary to provide a complete circuit from the switchyard to the onsite safety-related AC distribution system, are capable of performing their intended function. The normal lineup at Palisades, both during plant operation and shutdown, has both safety related 2400 volt AC buses supplied from Safeguards Transformer 1-1. If protective relay actuation occurs for the Safeguards Transformer, both buses are automatically transferred to the alternate required offsite source, Startup Transformer 1-2.

As part of the Palisades plant design, with one offsite circuit inoperable, electrical power is still available to both class 1E electrical trains since either the Safeguard Transformer 1-1, or the Startup Transformer 1-2 can be aligned to both safety-related 2400 V buses. Therefore, for either safety related 2400 volt bus to have "no offsite power available" as discussed under ISTS 3.8.1 Required Action A.2, both offsite circuits would have to be inoperable.

The condition of both offsite circuits being inoperable is covered under ISTS and ITS 3.8.1 Condition C, which includes the subject Required Action C.1, but with a reduced Completion Time. As such, Required Action A.2 of ISTS 3.8.1, which only applies when one electrical train cannot be powered from an offsite source, is not applicable to the Palisades ITS .

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CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3.8.1-02 DOCM.1 JFD 7 STS 3.8.1 Completion Time for Required Action A.3 ITS 3. 8. 1 Completion Time for Required Action A. 2 Bases for ITS 3.8.1 Required Action A.2, CTS Bases markup page B 3. 7. 1-5, insert The Completion Time for Required Action A.3 for STS 3.8.1 is 6 days from discovery of failure to meet the LCO. The Completion Time for Required Action A.2 for ITS 3.8.1 is 10 days from discovery of failure to meet the LCO. JFD 7 considers successive inoperabilities of an offsite circuit and a diesel generator.

Comment: JFD 7 did not consider successive inoperabilities of the offsite circuits.

Revise the submittal to conform to the STS, or provide appropriate technical justification for the difference.

Consumers Energy Response:

In ITS 3.8.1, application of a Completion Time modifier to successive inoperabilities of the offsite circuits does not apply. As such, consideration of this event was not discussed in JFD 7. Completion Times modified by the phases "from discovery to meet the LCO" impose a limit on the amount of time (Completion Time cap) operations are allowed to continue without meeting an LCO. The intent of this Completion Time modifier is to preserve the usage rule for "Condition based Completion Time tracking" and to prevent an indefinite failure to meet the LCO by alternating between multiple Conditions. As discussed in JFD 7, the Completion Time "cap" is selected such that it allows one full Completion Time for each of the associated Conditions. In this case, Condition A provides a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time for one inoperable offsite circuit, and Condition B provides a Completion Time of 7 days for one inoperable diesel generator.

The Completion Time "cap" is the sum of these two Completion Times (i.e. 10 days).

For successive inoperabilities of the offsite circuits, Completion Time tracking begins with the first occurrence of the inoperability, and continues to apply to all subsequent inoperabilities until compliance with the LCO is restored or the plant is removed from the mode of applicability. Therefore, the change described by JFD 7 provides conformity to the usage rules for the ISTS.

Affected Submittal Pages:

None 2

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS

RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION NRC REQUEST:

3.8.1-03 DOC L.1 -

RESPONSE TO NRC QUESTIONS JFDS STS 3. 8. 1 Completion Time for Required Action B. 4 ITS 3. 8. 1 Completion Time for Required Action B.4 Bases for ITS 3. 8. 1 Required Action B.4, CTS Bases markup page B 3. 7. 1. 7 insert CTS 3. 7.1 Action B.4 With one diesel generator inoperable, CTS 3. 7. 1 Action B.4 provides 7 days (total for both DGs) in any calendar month to restore the diesel generator(s) to operable status.

The Completion Time for Required Action B. 4 for co"esponding STS 3. 8. 1 is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

The Completion Time that has been proposed for Required Action B. 4 for co"esponding ITS 3. 8. 1 is 7 days. DOC L. 1 states that this proposed change is not a significant impact on safety.

Comment: No technical justification has been provided to support the proposed change. Additionally, DOC L. 1 does not explain why this proposed change is not a significant impact on safety. Revise the submittal to provide the appropriate technical justification, and to explain why the proposed change is not a significant impact on safety, or conform to the STS.

Consumers Energy Response:

DOC L.1 has been revised to provide a technical justification for the elimination of the cumulative outage time specified in CTS 3:7.1.B.4 and to explain why the proposed change does not result in a significant impact on safety.

Affected Submittal Pages:

DOC 3.8.1pg4of4 3

ATTACHMENT 3 DISCUSSION OF CHAi"\T S SPECIFICATION 3.8.1, AC SOURCES - OPE L.1 CTS Action .. l.B.4 requires restoration of an inoperable DG wit cumulative time 1 ny calendar month. ITS limits the restoratia time of any

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'2.

inoperability to 7 da (except as further restricted by the Co pletion Time added in 3 .~ /-OJ accordance with Discus

n of Change M. l), without era ng cumulative time. This change imposes both more ~trictive possibilities as l as less restrictive. CTS actions have the potential to a ow a 14-day contin us DG outage in the event the inoperability begins with 7 days ~maining in a alendar month; allowing those 7 day follo.wed by the first 7 days in the Il\xt cale ar ~onth. !~~ le~s restrictive aspect is the allowance to have two or more sep r DG moperab1lmes m any one calendar month that cumulatively could exceed ys. Since multiple DG inoperabilities in any one calendar month is expected to a rar ccurrence, and in the event it were to occur. it is reasonable to allow period of ti to effect repairs without imposing a forced reactor shutdown. th' change is not a sig 'ficant impact on safety. Elimination of tracking outage time a inst a cumulative limit 1 consistent with NUREG-1432 .

Palisades Nuclear Plant Page 4 of 4 01120/98

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3.8.1-03 DOC L.1 CTS Action 3.7.1.B.4 requires restoration of an inoperable DG within 7 day;;;

cumulative time in any calendar month. ITS Required Action B.4 limits the restoration time of any inoperability to 7 days (except as further restricted by the Completion Time added in accordance with Discussion of Change M.1 ), without tracking cumulative time. This change imposes both more restrictive possibilities as well as less restrictive. CTS actions have the potential to allow a 14-day continuous DG outage in the event the inoperability begins with 7 days remaining in a calendar month; allowing those 7 days followed by the first 7 days in the next calendar month.

Eliminating this allowance *in the ITS is considered more restrictive. The less restrictive aspect of the ITS is the allowance to have two or more separate DG inoperabilities in any one calendar month that cumulatively could exceed 7 days which is not allowed by the CTS.

Tracking cumulative outage time is not included in the ISTS since it is not a function of Operability. Instead, tracking cumulative outage time is a function of "availability."

Early custom technical specifications attempted to limit the time diesel generators were unavailable by specifying cumulative outage time in the specifications.

Conversely, a literal application of standard technical specifications would allow extended periods of diesel generator unavailability by an iterative process of declaring an inoperable diesel "Operable" followed by another period of inoperability.

Subsequent to the issuance of standard technical specifications, the NRC promulgated two rules (10 CFR 50.63, "Loss of all Alternating Current Power" and 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants") which mandated (in part) that controls be instituted to limit the time diesel generators are unavailable. In response to 10 CFR 50.63, the Palisades plant established an Emergency Diesel Generator Reliability Program to ensure diesel reliability is monitored and maintained above a reliability target level of 0.95.

This value is also used as a performance goal for diesel generator reliability under the requirements of 10 CFR 50.65. The elements of Emergency Diesel Generator Reliability Program are consistent with the guidance of Regulatory Guide 1.155, "Station Blackout" and NUMARC 87-00, "Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors."

The 7 day cumulative time in any calendar month requirement in the CTS would permit a maximum diesel generator unavailability of approximately 0.77. However, due to the commitments associated with the requirements of 10 CFR 50.63 and 10 CFR 50.65 to maintain a diesel generator reliability target level of 0.95, the overall availability of the Palisades plant diesel generators is significantly greater than 0.77 (the current availability for the emergency diesel generators is 99.0% for one diesel, and 99.1 % for the other). Since the requirements of the CFRs mandate higher levels of diesel generator availability than the CTS, excluding cumulative outage time in the ITS can be made without a significant impact on the health and safety of the public.

Elimination of tracking outage time against a cumulative limit is consistent with NUREG-1432.

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CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3.8.1-04 JFD 7 STS 3. 8. 1. 1 Completion Time for Required Action B. 4 ITS 3. 8. 1. 1 Completion Time for Required Action B. 4 Bases for ITS 3. 8. 1. 1 Required Action B. 4, CTS Bases markup page B 3. 7. 1. 7 insert STS 3.8.1.1 Required Action B.4 has a Completion Time that limits the amount of time that the LCO is not met from the time of discovery to 6 days. ITS 3. 8. 1. 1 Required Action B.4 has a Completion Time that limits the amount of time that the LCO is not met to 10 days. JFD 7 states that the 10 day Completion Time is based in part on the 7 day Completion Time to restore the DG to operable status.

Comment: The 7 day Completion Time to restore the DG to operable status requires additional justification (see comment 3.8.1-03 above). If the 7 day Completion Time is not approved by the NRC, revise the Completion Time that limits the amount of time that the LCO is not met to conform to the STS.

Consumers Energy Response:

As discussed in the response to RAI comment 3.8.1-03, additional justification has been provided to support the 7 day Completion Time for an inoperable diesel generator. As such, the final disposition of this comment is pending the NRC staff review of RAI comment 3.8.1-03.

Affected Submittal Pages:

None 4

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3.8.1-05 DOCLA.1 JFD6 STS 3. 8. 1 Condition F and Required Action F. 1 CTS 3. 7. 1 Action F .

CTS 3. 7. 1 Action F addresses one or both load sequencers inoperable. This requirement has not been retained in Co"esponding ITS 3. 8. 1. STS 3. 8. 1 Condition F and Required Action F. 1 address one load sequencer inoperable. This requirement has

.not been adopted in conesponding ITS 3. 8. 1.

Comment: The Note with STS 3. 8. 1 Condition F states that the Condition need not be adopted if a sequencer failure only affects the ability of the associated DG to power its safety loads. Neither DOC LA. 1 nor JFD 6 explain if the sequencers are shared by the diesels and the offsite circuits. If the sequencers are shared, revise the submittal to confonn to the STS. If the sequencers are not shared, provide appropriate technical justification for the difference.

Consumers Energy Response:

JFD 6 has been revised to clarify why an explicit Condition, Required Action, and Completion Time are not required for an inoperable automatic load sequencer in the Palisades ITS.

Affected Submittal Pages:

JFD 3.8.1 pg 2 of 3 5

ATTACHMENT 6 JUSTIFICATIONS FOR DE VIA TIO NS SPECIFICATION 3.8.1, AC SOURCES* OPERA TING Cban~e Disc_ussjon

6. The option to specifically list automatic load sequencers as a third type of AC Source.

and provide a separate Action. is not adopted. Sequencers are not a separate source of x

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AC power: rather they are a support component for the DG function. As such they are implicitly required to be Operable by the requirement for DG Operability (as detailed in the ITS Bases). Similarly, when discovered inoperable, the Actions for an inoperable DG apply without having to state so explicitly.

NUREG-1432 Bases support this. The Reviewer's Note in the Bases for Required Action F. l indicates that the specific condition related to the sequencer may be deleted

.. if the unit design is such that any sequencer failure mode will only affect the ability of the associated DG to power its respective safety loads under any conditions." t_ ~

7. The maximum time allowed to fail to meet the LCO is revised from 6 days to 10 days.

The accepted NUREG-1432 practice for limiting successive alternating inoperabilities with this type of maximum rime Completion Time, is ro allow one full Complete Time for each of the associated component types. In this case, with the proposed Completion Times of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for an offsire circuit and 7 days for a DG, the maximum rime is appropriately specified as 10 days.

8. The Palisades DG design does not incorporate "gradual acceleration" on a DG start.

NUREG-1432 presentation of SR 3.8.1.2 Notes 1and3, and SR 3.8.1.7, are addressing this design feature. The proposed modifications to eliminate these Notes and the SR provides the appropriate presentation for the Palisades DG design.

9. The Palisades DG design does not incorporate "gradual acceleration" on a DG start.

Similarly, NUREG-1432 SR 3.8.1.3 Note 1 states an allowance for "gradual loading."

However, since there is no stated prohibition to gradual loading, and the surveillance itself does not impose and loading-rate criteria, this Note is infonnational only, and should be removed as a Technical Specification requirement.

10. ISTS 3.8.1 Required Action A.2 is not retained; consistent with CTS. The Palisades It.A. I design and requirements for operable offsite circuits ensures that each ESF bus will be 3_ <?. \- 0 I energized if at least .one circuit is operable. If any bus can not be energized, then both required offsite circuits would be declared inoperable.

Palisades Nuclear Plant Page 2 of 3 01120/98

3.8.1-05 JFD 6 In the design of the Palisades plant, failure of an automatic load sequencer does not result in the inability to start all or part of the safety loads from the offsite power circuits when required, or result in overloading the offsite power circuits to a safety bus during an event.

The automatic load sequencers are not shared with the offsite power circuits, nor are they required to support the loading of the 2400 V Class lE buses when those buses are being supplied by offsite power. Therefore, inclusion of an explicit Condition, Required Action, and Completion Time for an inoperable automatic load sequencer is not required in the Palisades ITS.

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CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3.8.1-06 JFD 6 STS LCO 3. 8. 1 item c STS LCO 3.8.1 c addresses automatic load sequencers. This portion of the LCO has not been adopted in corresponding ITS 3. 8. 1.

Comment: If the response to comment 3. 8. 1-05 is to propose a Condition and Required Action that address the sequencers, then revise the submittal to have ITS LCO 3.8.1 adopt STS LCO 3.8.1.c.

Consumers Energy Response:

In response to comment 3.8.1-05, JFD 6 was revised to clarify why specific Actions are not required for an inoperable automatic load sequencer. As such, it is not necessary to specifically identify the automatic load sequencers as a third type of AC electrical power source in the LCO for proposed specification 3.8.1.

Affected Submittal Pages:

None 6

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS

RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION NRC REQUEST:

RESPONSE TO NRC QUESTIONS 3.8.1-07 JFD5 STS SR 3.8.1.5 STS SR 3. 8. 1. 5 specifies checking for and removing accumulated water from each day tank. This requirement has not been adopted in corresponding ITS 3. 8. 1.

Comment: A similar requirement has been retained from the CTS for the fuel oil storage tank as ITS SR 3. 8. 3. 5. Provide the technical justification for not adopting STS SR 3. 8. 1. 5, or conform to the STS.

Consumers Energy Response:

A new JFD (JFD 13) has been provided to clarify why ISTS SR 3.8.1.5 was not adopted in the ITS.

Affected Submittal Pages:

NUREG pg 3.8-7 JFD 3.8.1 pg 3 of 3 7

AC Sources-Operat; ng

3. 8. l SURVEILLANCE RE UIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.3 Momentary transients outside the load range do not invalidate this test.

This Survetl~ance shall be conducted on only one DG at 1 time.

This SR shall be preceded by and irmiediately follow without shutdown a successful performance of SR 3.8.1.Z e, *R l i 1 7

~. FN ~ I!) ff\ir.IA~

toa.~d ~ ~re.11.\.u' fuo.'fo\ 0('~14.~ Iv ptak

~cc..i d..A""-~ lo ~J., ~"J. Tiilh ~.8.1 1

b. ~ ~ ('.!.,M,aj(j~

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+tSa t" SR 3. 8. l. 4 Verify each day tank *(a~~ 1R91Re Me~~~ed- 31 days

~contains ~ of fuel oil.

(i) \\c-U x

1 fuel oil tran fer system [92] days to (automatic ly] transfer fu oil f storage tank ] to the day ta

[and ng1ne mounted nk].

(continued)

CEOG STS 3.8-7 Rev 1, 04/07/95

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ATTACHMENT 6 JUSTIFICATIONS FOR DEVIATIONS SPECIFICATION 3.8.1, AC SOURCES - OPERA TING Cbao"e Discussion

11. ISTS SR 3. 8.1.6 relates to surveilling the DG fuel oil transfer pumps. Palisades provides the appropriate plant specific fuel oil transfer pump surveillance in ITS 3. 8. 3.

SR 3. 8. 3. 6. This presentation preference is dictated by the plant specific current licensing basis allowing specified allowed Completion Times to repair inoperable transfer pumps prior to declaring a DG inoperable.

12. TSTF-8, Rev. 2 deleted the 3.8 SR Notes "However credit may be taken ... " and addressed that issue globally in the 3.0 Bases. This presentation is consistent with NUREG-1432.

I.Pr l ~.&./-of' x IY .

Palisades Nuclear Plant Page 3 of 3 01/20/98 7-b

3 .8. 1-07 JFD 13 This change reflects the current licensing basis/technical specifications. The surveillance requirement for checking and removing accumulated water from each diesel generator fuel oil day tank was not adopted in the ITS (or the CTS) due to the design of these tanks. The tanks are constructed with flat bottoms and do not provide a sump for water collection or removal. Historic performance has shown that water accumulation in these tanks has not been a problem. A similar surveillance requirement for the Diesel Fuel Oil Storage Tanlc was incorporated in the CTS following replacement of the original storage tank with a new storage tank. The new Diesel Fuel Oil Storage Tank contains an integral sump for water collection and removal. Thus, the surveillance requirement to check and remove accumulative water was retained in the ITS for the Diesel Fuel Oil Storage Tank only.

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CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3.8.1-08 JFDS ITS SR 3.8.1.5 STS SR 3.8.1.9 Note 1 Bases for STS SR 3. 8. 1. 9 Note 1 to STS SR 3. 8. 1. 9 specifies that the Surveillance not be performed in Mode 1 or

2. This Note has not been adopted in corresponding ITS SR 3. 8. 1. 5. The Bases for STS SR 3.8.1.9 states that the reason for the Note is that during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems.

Comment: JFD 5 did not address these issues. Revise the submittal to provide the technical justification for not adopting the Note or conform to the STS.

Consumers Energy Response:

A new JFD (JFD 14) has been provided to clarify why Note 1 to ISTS SR 3.8.1.9 was not adopted in the ITS.

Affected Submittal Pages:

NUREG pg 3.8-9 JFD 3.8.1pg3 of3 8

AC Sources-Operat 1 ng 3.8.l

SURVEILLANCE RE UIREMENTS SR 3.8.(§5 continued SURVEILLANCE

- - - - OTES******* .......*.--:1 FREQUENCY

l. his Surveil net shill n be performed i MOOE 1 or 2 However, credit ma be taKen for nplinned events t t Sitisfy th's SR.

If pe ormed with t OG synchro with offsite power it shill be per ormed it i po r fictor s Verify eich DG rejects a loid greiter thin ~18 months,(_

or equil to its associated single lirgest 1' post-iccident loid, ind:

i. Following loid rejection, the frequency is s ~ Hz; c,g

b. Within ~3ksecon s following load rejection, the voltage Is ~ ~~ V ands~; ind ~

2.44

c. Wtthtn I3 seconds following loid rejectt'On, tht frequency Is

~ .

'f'1, S' Hz ind s Go(, S"z) l.

1*

Hz.

pa rnonths,k_

x (continued)

CEOG STS 3.8-9 Rev 1, 04/07/95

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ATTACHMENT 6 JUSTIFICATIONS FOR DEVIATIONS SPECIFICATION 3.8.1, AC SOURCES- OPERATI~G D'ISGUSSIOQ

11. ISTS SR 3.8.1.6 relates co surveilling the DG fuel oil transfer pumps. Palisades provides the appropriate plane specific fuel oil transfer pump surveillance in ITS 3. 8. 3.

SR 3. 8. 3. 6. This presentation preference is dictated by the plant specific current licensing basis allowing specified allowed Completion Times to repair inoperable transfer pumps prior co declaring a DG inoperable.

12. TSTF-8, Rev. 2 deleted the 3.8 SR Notes "However credit may be taken ... " and addressed that issue globally in the 3. 0 Bases. This presentation is consistent with NUREG-1432.

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!Y.

Palisades Nuclear Plant Page 3 of 3 01/20/98

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3. 8. 1-08 JFD 14 This change reflects the current licensing basis/technical specifications. On April 29, 1998 the NRC issued Amendment 180 td the Palisades Plant operating license. The amendment revised the Technical Specification requirements and associated bases regarding the electrical power systems to closely emulate the Standard Technical Specifications for Combustion Engineering Plants, NUREG-1432, Revision 1. As part of this revision, new diesel generator surveillance tests were adopted including the tests which verify each diesel generator is capable of a load reject greater than or equal to its associated single largest post-accident load (ISTS SR 3.8.1. 9), and that each diesel generator is capable of a full load reject (ISTS SR 3.8.1.10). These new surveillance requirements (CTS 4.7.l.7 and CTS 4.7.1.8) were issued without the Note which states that the surveillance "shall not be performed in Mode 1 or 2. Omission of this note was found acceptable by the NRC staff in their Safety Evaluation related to Amendment 180 which concluded that "performance of these SRs (4.7.1.7, 4.7.1.8, and 4.7.1.10) at power would not cause any undue transients on the Class lE distribution system." As such, Note 1 in ISTS SR 3.8.1.9 and ISTS SR

3. 1. 8 .10 was not incorporated in the Palisades ITS .

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS

RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION NRC REQUEST:

RESPONSE TO NRC QUESTIONS 3.8.1-09 JFD5 ITS SR 3.8.1.6 STS SR 3.8.1.10 Note 1 Bases for Note 1 to STS SR 3. 8. 1. 10 specifies that the Surveillance not be performed in Mode 1 or 2. This Note has not been adopted in corresponding ITS SR 3. 8. 1. 6. The Bases for STS SR 3. 8. 1. 10 states that the reason for the Note is that during operation with the reactor critical, performance of this SR could cause perturbations to.the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems.

Comment: JFD 5 did not address these issues. Revise the submittal to provide the technical justification for not adopting the Note or conform to the STS.

Consumers Energy Response:

A new JFD (JFD 14) has been provided to clarify why Note 1 to ISTS SR 3.8.1.10 was

not adopted in the ITS.

Affected Submittal Pages:

NUREG pg 3.8.9 JFD 3.8.1 pg 3 of 3 9

AC Sources-Operat 1 ng

3. 8. l SURVEILLANCE RE UIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.ft)~ ----------- OTES------- -----------=-1 CTS ? his Surveil nee shall n be l{,7,1.7 performed i MOOE l or 2 However, credit ma be taken for nplanned events t t satisfy th's SR.

If pe ormed with t OG synchro with offsite power it shall be per ormed at a po r factor s Verify each DG rejects a 1oad greater than i£ 18 months,(_

or equal to its associated single largest f' post-accident load, and:

a. Following load rejection, the frequency is s ~ Hz; c,g

b. Within ~3ksecon s following load rejection, the voltage is ~ ~~ V ands~; and ~

U.'1

c. Within !3 seconds following load rejectt'On, the frequency is

~ . Hz and s

,-9.~

G6l. %)

(,1. S'"

Hz.

---NOTE--- ------------

Th* Survei 11 ce shall t be perfo d

HOOE l or . Howeve , credit may e akin for planned e nts that sa sfy this SR.

x (continued)

CEOG STS 3.8-9 Rev 1, 04/07/95

Chan Ile Discussjoo ATTACHMENT 6 JUSTIFICATIONS FOR DEVIATIONS SPECIFICATION 3.8.1, AC SOURCES- OPERATING

11. ISTS SR 3. 8.1.6 relates to surveilling the DG fuel oil transfer pumps. Palisades provides the appropriate plant specific fuel oil transfer pump surveillance in ITS 3 .8 .3.

SR 3.8.3.6. This presentation preference is dictated by the plant specific current licensing basis allowing specified allowed Completion Times to repair inoperable transfer pumps prior to declaring a DG inoperable.

12. TSTF-8, Rev. 2 deleted the 3.8 SR Notes "However credit may be taken ... " and addressed that issue globally in the 3.0 Bases. This presentation is consistent with NUREG-1432.

~Prt ~.&./-or x

Palisades Nuclear Plant Page 3 of 3 01120/98

3.8.1-09 JFD 14 This change reflects the current licensing basis/technical specifications. On April 29, 1998 the NRC issued Amendment 180 to the Palisades Plant operating license. The amendment revised the Technical Specification requirements and associated bases regarding the electrical power systems to closely emulate the Standard Technical Specifications for Combustion Engineering Plants, NUREG-1432, Revision 1. As part of this revision, new diesel generator surveillance tests were adopted including the tests which verify each diesel generator is capable of a load reject greater than or equal to its associated single largest post-accident load (ISTS SR 3.8.1.9), and that each diesel generator is capable of a full load reject (ISTS SR 3.8.1.10). These new surveillance requirements (CTS 4.7.1.7 and CTS

4. 7. 1. 8) were issued without the note which states that the surveillance "shall not be performed in Mode 1 or 2. Omission of this note was found acceptable by the NRC staff in their Safety Evaluation related to Amendment 180 which concluded that "performance of these SRs (4.7.1.7, 4.7.1.8, and 4.7.1.10) at power would not cause any undue transients on the Class lE distribution system." As such, Note 1 in ISTS SR 3.8.1.9 and ISTS SR

3. 1. 8. 10 was not incorporated in the Palisades ITS .

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3.8.1-10 ITS SR 3.8.1.8 STS SR 3.8.1.14 Note 1 CTS 4. 7.1.10 Note 1 to STS SR 3. 8. 1. 14 states that momentary transients outside the load and power factor ranges do not invalidate this test. This Note has been adopted in corresponding ITS SR 3.8.1.8.

Comment: The CTS markup does not show this proposed change, and no justification has been provided for the proposed change. Revise the submittal to correct the CTS markup, and to provide the appropriate justification.

Consumers Energy Response:

The markup of CTS 4. 7 .1.10 (Attachment 3, page 4 of 5) has been revised to indicate that the corresponding surveillance requirement in the ITS (SR 3.8.1.8) is preceded by a Note. The information contained in this Note was previously presented in CTS 4.7.1

(Attachment 3, page 3 of 5) as discussed in DOC A.2.

Affected Submittal Pages:

CTS 3.8.1 pg 4 of 5 10

3. g .1 ELECTRICAL POWER SYSTEMS TESTS ~

AC Power Sources - Operating (continued)

S'f3.3.I. 4.7.1.8 Verify that each DG, operating at a power factors 0.9, does not trip, and voltage is maintained s 4000 V during and following a load rejection of ~ 2300 and s 2500 kW; each 18 months.

~R3.g,1,7 4.7.1.9* Veri_~y; each 18 months; on an actual or simulated loss of offsite power:

a. De-energization of emergency buses;

b. Load shedding from emergency buses;

c. OG auto-starts from standby condition and:

1. Energizes permanently connected loads ins 10 seconds,

2. Energizes auto-connected shutdown loads through the automatic load sequencer,

3. Maintains steady state voltage ~ 2280 and s 2520 V,

4. Maintains steady state frequency~ 59.5 ands 61.2 Hz,

'IN~RT Nor!>s. Supplies permanently connected loads for ~ 5 minutes.

\4 4.7.1.10 Verify, each 18 months, that each DG operates at a power factor s 0.9 for ~ 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s:

a. For ~ 100 minutes loaded above its peak accident loading, and

b. For the remainder of the test loaded ~ 2300 and s 2500 kW .

.SR.'3.8.\,Cf 4.7.1.11* Verify; each 18 months; that each DG:

a. Can be synchronized with offsite power while supplying its associated 2400 volt bus upon a simulated restoration of offsite power;

b. Can transfer loads to an offsite power source; and

c. Can be returned to ready-to-load operation.

4.7.1.12* Verify the time of each sequenced load is within t 0.3 seconds of the design timing for each automatic load sequencer; each 18 months.

These tests must be performed in COLD SHUTDOWN or REFUELING SHUTDOWN.

4-43 Amendment No. ii, +i, ~. Hi,

/()-cµ

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS

RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION NRC REQUEST:

RESPONSE TO NRC QUESTIONS 3.8.1-11 Bases JFD 7 Bases for ITS SR 3. 8. 1.2, CTS Bases markup page B 3. 7. 1-12 Bases for CTS 4. 7.1.2 The Bases for CTS 4. 7. 1.2 states that standby conditions for a DG mean the diesel engine is not running and its coolant and oil temperatures are being maintained consistent with the manufacturer's recommendations. This has been retained in the Bases for corresponding ITS SR 3.8.1.2 which also contains the stipulation that

~ 20 minutes have elapsed since the last DG air roll. Bases JFD 7 states that this is an existing procedural limitation.

Comment: No technical justification has been provided to support the proposed change. Revise the submittal to provide the appropriate justification.

Consumers Energy Response:

JFD 7 (Bases) has been revised to provide the appropriate justification for modification of the Bases for ITS SR 3.8.1.2 (CTS 4.7.1.2).

Affected Submittal Pages:

JFD 3.8 Bases pg 2 of 3 11

ATTACHMENT 8 JUSTIFICATIONS FOR DEVIATIONS SECTION 3.8, ELECTRICAL POWER SYSTEMS - BASES Chanae Discussion

5. These changes are made to* reflect Palisades licensing basis, including any associated changes proposed in this submittal (which are justified by DOCs and NSHCs elsewhere), as presented in the associated ITS Specifications. Additional changes are also proposed to establish conformance with NUREG-1432 Bases. Rewording, reformatting, and revised numbering is made to incorporate these changes consistent with Writer's Guide conventions.

6. The B 3.8.1 and B 3.8.4 Bases for those Surveillances that are associated with restrictions on which operational Modes they are allowed to be performed in, already address the issue that "credit may be taken for unplanned events that satisfy a surveillance requirement." In addition, the "credit may be taken ... " concept applies to all surveillances, and is also addressed in the ITS Bases for SR 3 .0.1. Therefore elimination of this discussion above all 3. 8 .1 Surveillance Bases is administrative only, with no technical change or change in intent. This presentation is consistent with NUREG-1432 and TSTF-8, Rev. 2.

7. The B 3. 8 .1 Bases discussion of "standby conditions" for the DGs is enhanced to include the existing procedural limitations regarding time after air roll.If' tt-J.S ar

..-1,eAl ~-8'.o \

11

8. CTS requirements and Actions (and associated Bases) for DG fuel transfer pumps and DG starting air, are presented in the AC Sources-Operating Specification. ITS

~nistratively relocates these requirements and Actions to a separate Specification

.3 (3.8.~: Diesel Fuel, Lube Oil, and Starting Air. This relocation is appropriate for those support system with a justified r~storation time that is allowed prior to applying the restoration time for an inoperable DG.

9. TSTF-38 adds clarifying statements to the Bases of the battery inspection surveillance, which are adopted in the Palisades ITS Bases. Since this change only clarifies the existing intent, the change is acceptable.

10. This CTS Bases statement is in conflict with the CTS (and proposed ITS) requirements.

The statement was mistakenly included with the recent amendment. Elimination of the statement corrects an obvious error.

11. Clarification added to indicate the source of information relating resistance to voltage drop.

Palisades Nuclear Plant Page 2 of 3 01120/98

//

3.8.1-11 Bases JFD 7 The intent of this statement is to establish a minimum time at which a diesel generator is at rest prior to commencing the surveillance test. ITS SR 3 .8.1.2 provides assurance that a diesel generator would start and be ready for loading in the time period assumed in the safety analysis. Prior to starting a diesel generator for SR 3.8.1.2, a cylinder leakage test is performed by briefly (minimum of 5 seconds) cranking the diesel engine and observing the test cocks for the expulsion of water or oil. To avoid invalidating the test results of SR 3.8.1.2 by "preconditioning" a diesel engine, an elapse time of 20 minutes has been specified since the diesel engine was last air rolled. The specified time is based on engineering judgement considering vendor recommendations. Although this information is presently contained in plant procedures and imposes an additional restriction on the performance of the test, inclusion of this information in the Bases of SR 3.8.1.2 is appropriate since it preserves the original intent of the surveillance test.

I I-b

CONVERSION TO .IMPROVED TECHNICAL SPECIFICATIONS

RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION NRC REQUEST:

RESPONSE TO NRC QUESTIONS 3.8.2, AC Sources - Shutdown 3.8.2-01 JFD2 Bases Applicability for ITS 3.8.2, CTS Bases markup page B 3. 7.2-2 Bases Applicability for STS 3.8.2 The Bases Applicability for S TS 3. 8. 2 refers to monitoring and maintaining the plant in a cold shutdown or refueling condition. The Bases Applicability for ITS 3.8.2 refers to monitoring and maintaining the plant in a shutdown condition. JFD 2 states that differences have been made for clarity, grammatical preference, or to establish consistency within the Improved Technical Specifications.

Comment: This is not a justifiable plant specific difference. Revise the submittal to conform to the STS.

Consumers Energy Response:

The terminology used to describe the plant condition in item "d" of the ITS Applicability has been revised to conform with the terminology used in the ISTS. Conforming changes have also been made to CTS Bases markup page B 3.7.2-2.

Affected Submittal Pages:

ITS pg B 3.8.2-2 CTS pg B 3.7.2-2 12

AC Sources - Shutdown B 3.8.2 BASES*

LCO An OPERABLE DG, associated with a distribution subsystem (continued) required to be OPERABLE by LCO 3.8.10, ensures a diverse power source is available to provide electrical power support, assuming a loss of the offsite circuit.

Together, OPtRABILITY of the required offsite circuit and DG ensures the availability of sufficient AC sources to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents and loss of shutdown cooling).

The DG must be capable of starting, accelerating to rated speed and voltage, connecting to its respective 2400 V bus on detection of bus undervoltage, and accepting required loads. Proper "Normal Shutdown" loading sequence, and tripping of nonessential loads, is a required function for DG OPERABILITY. A Service Water Pump must be started soon after-the DG to assure continued DG operability. The OBA loading sequence is not required to be OPERABLE since the Safety Injection Signal is disabled during MODES 5 and 6 .

APPLICABILITY The AC sources required to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies provide assurance that equipment and instrumentation is available to:

a. Provide coolant inventory makeup,

b. Mitigate a fuel handling accident, ~I\ I

~.~.).*Of

c. Mitigate shutdown events that can lead to core damage, and Cold Shu~" C.Ond 1tv.t\ or \/

A._

d. Monitor and maintain the plant in aAs.A~temm r"~ue.\.,'r.°o condition.

This LCO is applicable during movement of irradiated fuel assemblies even if the plant is in a condition other than MODES 5 and 6. This LCO provides the necessary ACTIONS if the AC electrical power sources required by this LCO become unavailable during movement of irradiated fuel assemblies.

The AC source requirements for MODES 1, 2, 3, and 4 are addressed in LCO 3.8.1, "AC Sources - Operating."

Palisades Nuclear Plant 8 3.8.2-2

/di-~

01/20/98

AC Sources - Shutdown B 3.7.2 and 4.7.2 BASES g

An OPERABLE OG, associated with a distribution subsystem required to be OPERABLE by LCO 3 . . 10, ensures a diverse power source is available to provide electrical power support, assuming a loss of the offsite circuit.

Together, OPERABILITY of the required offsite circuit and OG ensures the availability of sufficient AC sources to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g.,

fuel handling accidents and loss of shutdown cooling).

The OG must be capable .of starting, accelerating to rated speed and voltage, connecting to its respective 2400 volt bus on detection of bus undervoltage, and accepting required loads. Proper "Normal Shutdown" loading sequence, and tripping of nonessential loads, is a required function for OG OPERABILITY. A Service Water Pump must be started soon after the DG to assure continued OG operability. The OBA loading sequence is not required to be OPERABLE since the Safety Injection Signal is disabled during APPLICABILITY ~ODE'S 5 ta.If\; t,J The AC sources required to be OPERABLE in to LO SHbT0014!~, ~EFtjElfNS SllUT88'11P'°'

and during movement of irradiated fuel assemblies provide assurance that*

equipment and instrumentation is available to:

a. Provide coolant inventory makeup, ~

b. Mitigate a fuel handling accident, ~ ~ oiJ

c. Mitigate shutdown events that can lead to~~ ~,, C,,i.h'""

d. ~~ an~ ~aintain@ the plant in~ _ * ~iJ.ttv"'

) cond 1t1 on. e- /

MOOE ~ or- '-" cl This LCO is applicable during mov.ement of irradiated fuel assemblies even i (<..~,.

the plant is in a condition other than -8LB SllUT9QllN er R!:rldELHl6 SllUT88'i\~. u'6*\~

This LCO provides the necessary ACTIONS if the AC electrical power sources required by this LCO become unavailable during movement of irradiated fuel ass emb l i es. ""' 1 i 3

_. 4 I rtO 0 E$ I ' I (l.""°' (i)

The AC source requirements for ~~~~r-5-~~~ are addressed in LCO 3.t:"l, "AC Sources - Operating" .

PALISADES J d. - b B 3.7.2-2 Amendment No.

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS

RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION NRC REQUEST:

RESPONSE TO NRC QUESTIONS

3. 8. 3, Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3-01 CTS LCO 3.7.3 ITS LCO 3.8.3 CTS LCO 3. 7. 3 states, "The stored DG fuel oil and DG lube oil shall be within limits."

Corresponding ITS LCO 3.8.3 states, "The stored diesel fuel oil, lube oil, fuel oil transfer system, and starting air subsystem shall be within limits for each required Diesel Generator (DG)". This proposed change was not noted on the CTS markup, and no justification has been provided for this proposed change.

Comment: Revise the submittal to note this proposed change on the CTS markup and provide the appropriate justification.

Consumers Energy Response:

The markup of CTS 3.7.3 (Attachment 3, page 2 of 4) has been revised to include the

"fuel oil transfer system" and the "starting air subsystem." Justification for this change is provided in (new) DOC A.3.

Affected Submittal Pages:

CTS 3.8.3 pg 2 of 4 DOC 3.8.3 pg 1 of 1 13

3.~.3 3.i ~ ELECTRICAL POWER SYSTEMS

3'-8. 3 Lc..o

~. 7 . !' OG Fuel Qi l and Lube Oil Specificat i ans The stored DG fuel oil and DG lube oi~. shall be within lim,i1t s . ? @

CD *~L 01L i~S'4S~r.. ' - ~ . 3 Sfo.l"+q*JO..... 0.1 r- ~ ~S'l l +t. IWI '1 4-o Applicability LC.. o- RP.'

o. ~. )-o I Specification 3.7.3 applies when any DG is required to be OPERABLE. 3*

3.7.3.A Action 900 knoN5 /Jo~) @

With stored fuel oil inventory< 23,700 and~ 20,110 gallons:

1. Restore stored fuel o;] inventory to within limits; within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . ~OO /{J()

3.7.3.8 With stored lube oil inventory <@and ~gallons: § Ml J iJ *a.3

1. Restore the lube oil inventory to within limits; within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

3.7.3.C With stored fuel oil viscosity, or water and sediment not within limits:

1. Declare both DGs inoperable, immediately.

3.7.3.D With stored fuel oil properties other than viscosity, and water and sediment not within limits:

Co"li (i 3.7.3.E

1. Restore stored fuel oil properties to within limits; within 30 days.

If any action required by 3.7.3.A through 3.7.3.D is not met and the associated completion time has expired, or if Specification 3.7.3 is not met for reasons other than those addressed in 3.7.3.A, through 3.7.3.0:

1. Declare both OGs inoperable; irrmediately.

\

3-44 Amendment No.

13-o..,., z. (){ 1

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.8.3, DIESEL FUEL OIL, LUBE OIL, Ai'lD STARTING AIR ADMINISTRATIVE CHANGES (A)

A.1 All reformatting and renumbering are in accordance with NUREG-1432. As a result, the Technical Specifications (TS) should be more readily readable, and therefore understandable by plant operators as well as other users. The reformatting, renumbering, and rewording process involves no technical changes to existing Technical Specifications.

Editorial rewording (either adding or deleting) is made consistent with NUREG-1432.

During Improved Technical Specification (ITS) development certain wording preferences or English language conventions were adopted which resulted in no technical changes (either actual or implied) to the TS. Additional information has also been added to more fully describe each subsection. This wording is consistent with NUREG-1432. Since the design is already approved by the NRC, adding more details does not result in a technical change.

A.2 A Note is added to ITS 3.8.3 Actions allowing separate entry for each DG. This provides explicit instructions for proper application of the Actions for Technical Specifications compliance. In conjunction with proposed Specification 1.3, "Completion Times," the Note provides direction consistent with the intent of CTS.

j A. These changes are presentation preferences consistent with the NUREG-1432.

herefor~ an administrative change with no impact on safety. /-A I '.l .O. ~ _,£)

TECHNICAL CHANGES - MORE RESTRICTIVE (M) I '1. i."J* o'J ff):°i were no ;z_:;trictive* changes associated with this specificationRP\ \ i~.'J-6 ~

LESS RESTRICTIVE CHANGES- REMOVAL OF DETAILS TO LICENSEE CONTROLLED DOCUMENTS (LA)

There were no "Removal of Detail" changes associated with this specification.

LESS RESTRICTIVE CHANGES (L)

There were no "Less Restrictive" changes associated with this specification.

Palisades Nuclear Plant Page 1of1 01/20/98

/3-b

3.8.3-01 DOC A.3 CTS 3.7.3 has been modified to include the "fuel oil transfer system" and "starting air subsystem" in the text of the "Specification". This change has been made to establish a format consistent with the ISTS by specifying, in the LCO, the functional capability of DG support systems required for the safe operation of the facility. This change does not add or delete any requirement to the CTS, but simply adopts a standard convention for specifying limiting conditions for operations. Therefore, this change is considered administrative in nature .

I 3-c_

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3.8.3-02 ITS LCO 3.8.3 ITS 3. 8. 3 Conditions C, D, and E ITS SR 3.8.3.6 Bases Applicability for ITS 3.8.3, CTS Bases markup page B 3. 7.3-2 ITS LCO 3.8.3 and the associated Bases Applicability refer to the fuel oil transfer system being within limits. ITS 3.8.3 Conditions C, D, and E, and ITS SR 3.8.3.6 refer to the operability of the fuel oil transfer system, they do not refer to any limits.

Comment: The LCO and the Bases Applicability should refer to the operability of the fuel transfer system. Revise the submittal to have the LCO and the Bases Applicability refer to the operability of the fuel oil transfer system.

Consumers Energy Response:

ITS LCO 3.8.3 has been revised to explicitly require both fuel oil transfer systems to be Operable. Conforming changes have also been made to the Applicability discussion in the associated Bases. In addition, ITS Condition F was revised to remove reference to Conditions C, D and E since the appropriate default action for the fuel oil transfer system is contained in the first part of Condition G which states "Required Action and associated Completion Time not met." Deleting the reference to Conditions C, D, and E eliminates the inappropriate association of the fuel transfer system being within limits.

Affected Submittal Pages:

ITS pg 3.8.3-1 ITS pg 3.8.3-2 ITS pg B 3.8.3-2 ITS pg B 3.8.3-4 NUREG pg 3.8.22 NUREG pg 3.8-23 CTS pg B 3.7.3-2 CTS pg B 3.7.3-3 14

Diesel Fuel, Lube Oil, and Starting Air 3.8.3

3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel, Lube Oil, and Starting Air

[

f FoR~\\ 'th,S<l {;><Ml'<.lrct' (Db)'.

o... 1\<.S~Gl~'vc.\.011.,lu*,011.,~,.J)l'Q.rf,1

~,r S..-.S-ys~ SI-oil t\. w 1"11\"' ~ ***+s q,,.. d

b. &ott1G1~ ~vc.LoiL..~~!~S"l'+'-~

s~11 I." ot'!P.il!jc.,,

LCO 3.8.3 he stored. ~i~Tfuerorl,'lli"be~il~~l oi~ransf~ ~A\ .o'J system, and s rting air subsystem sh 1 be within limits 3.t3 ~

'cf.or each re 'red Diesel Gen rator ( ) .

APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS

NOTE-------------------------------------

Separate Condition entry is allowed for each DG.

CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel oi 1 inventory A. l Restore fuel oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months

< 23,700 gallons and inventory to within

> 20,110 gallons in limits.

storage tank.

B. Stored 1ube oi 1 B.l Restore stored lube 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months i .nventory oil inventory to

< 200 gallons and within limits.

> 160 gallons.

c. Fuel transfer system C.l Restore fuel transfer 15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months (P-18A) inoperable. system to OPERABLE status.

D. Fuel transfer system 0.1 Restore fuel transfer 7 days (P-188) inoperable. system to OPERABLE status .

Palisades Nuclear Plant 3.8.3-1 Amendment No. 01/20/98

Diesel Fuel, Lube Oil, and Starting Air 3.8.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. Both fuel transfe-r E. l Restore one fuel 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months systems inoperable. transfer system to OPERABLE status.

F. Fuel oil properties F.l Restore stored fuel 30 days other than viscosity, oil properties to and water and within limits.

sediment, not within limits.

G. Required Action and G. l Declare associated Immediately associated Completion DG(s) inoperable.

Time not met.

QE Stored diesel fuel oil , lube oil, or starting air subsystem not within limits for reasons other th~

Condition A, B, C D, fZJ or F.. RI\\

1?.3*

Palisades Nuclear Plant 3.8.3-2 Amendment No. 01/20/98 J'-/- b

Diesel Fuel, Lube Oil, and Starting Air B 3.8.3 S1M ... d1c.11.L ~~"'l.1 i~ 01L, O.r"ld .o~~'A() C.1.- S1..1~l'IJ~f'N ,'\Al i'.lvprot"+ ~h<.. oPc.ta.-hl>/'I o~ 1~ ,o+a,,,d~ ~(_ fot..x..- ~r,es, '1'"-~f 3.~.3-05 BASES r ':'

APPLICABLE A description of the Safety Analyses applicable in MODES l, SAFETY ANALYSE 2, 3~ and 4 is provided in the Bases for LCO 3.8.1, "AC Sourc-es - Operating"; during MODES 5 and 6, in the Bases for LCO 3.8.2, ' AC Sources - Shutdown." 1 LCO Stored diesel fuel oil is required to have sufficient supply for 7 days of full accident load operation. It is also required to meet specific standards for quality. The specified 7 day requirement and the 6 day quantity listed in Condition A are taken from the Engineering Analysis associated with Event Report E-PAL-93-0268. Additionally, the ability to transfer fuel oil from the storage tank to each dax ank is required from each of the two transfer pumps. T em is req o av. a inimum apacity with m gin for a DG start att pt withou echa ing the air st t receivers.

Additionally, sufficient lube oil supply must be available to ensure the capability to operate at full accident load for 7 days. This requirement is in addition to the lube oil contained in the engine sump. The specified 7 day requirement and the 6 day quantity listed in Condition Bare based on an assumed lube oil consumption of 0.8 to 1.0% of fuel oil consumption.

ITK Dkrl.n~ <1." ~ rThe foeTOil trans fer ystem which includes rans er ~~ \ .o-'1 SvW'IJ-kN'\ M~S+ proviJ-<. pump P SA can be po red by offsite power, either DG . .,c-6"l J Howev , the fuel o* transfer system whic includes fuel 1 w dnl)v~ -fht. 0.1 d o~ .i..IX t ran fer pump P-1 can only be powered b offs i te power, o~,

rt ~tLL C.O'"r'Pf<.S.Sor 1 -.: .b.:(,.,y.;::.::.G--=-1-.. ::1.. :. .---1-----------r-----------J 5iM1c.1efl1 a.1r s-1a.rt These requirements, in conjunction with an ability to obtain Ca.~ c..;f Y ,

1nclud1n~ rra.~111, replacement supplies within 7 days, support the availability

~ a.t:'JJurt S~M of the DGs. DG day tank fuel requirements are addressed in

~di fy ~,.. I +5 LCOs 3.8.1 and 3.8.2.

~ s~ <<..1Q, ~d c b.

--~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~-

APPLICABILITY DG OPERABILITY is required by LCOs 3.8.l and 3.8.2 to ensure the availability of the required AC power to shut down the reactor and maintain it in a safe shutdown condition following a loss of off-site power. Since diesel fuel, lube ~Al oil, and starting air suppo:~-3.8.l and 3.8.2, stored 3~d*O.i:..

di es el fu e 1 oi l , 1ube oi 1 , <f~ and st a rt i ng a i r are required to be within limits when either DG is required to be OPERABLE. GnJ ,.,. , ~v~ "tro~ s;ys~ 1 ~ r~vi"'4 1' k ~)jl,

Palisades Nuclear Plant B 3.8.3-2 01/20/98

Diesel Fuel, Lube Oil, and Starting Air B 3.8.3

BASES ACTIONS (continued)

~

With the stored fuel oil properties, other than viscosity, and water and sediment, defined in the Fuel Oil Testing Program not within the required limits, but acceptable for short term DG operation, a period of 30 days is allowed for restoring the stored fuel oil properties. The most likely cause of stored fuel oil becoming out of limits is the addition of new fuel oil with properties that do not meet all of the limits. This 30 day period provides sufficient time to determine if new fuel oil, when mixed with stored fuel oil, will produce an acceptable mixture, or if other methods to restore the stored fuel oil properties are required. This restoration may involve feed and bleed procedures, filtering, or combinations of these procedures.

Even if a DG start and load was required during this time interval and the fuel oil properties were outside limits, there is a high likelihood that the DG would still be capable of performing its intended function.

J 0 ( Sta.M1n~ a.i'r stkS~-k./Y\.

Ll With a Required Action and associatelr~mpletion Time not met , or wi th di es el fu e1 oi ~(Qr) l ube"'~ not wi th i n l i mi ts for reasons other than addressed by Conditions A)[~ F, the associated DG may be incapable of performing its~&, or intended function and must be immediately declared inoperable.

In the event that diesel fuel oil with viscosity, or water and sediment is out of limits, this would be unacceptable for even short term DG operation. Viscosity is important primarily because of its effect on the handling of the fuel by the pump and injector system; water and sediment provides an indication of fuel contamination. When the fuel oil stored in the Fuel Oil Storage Tank is determined to be out of viscosity, or water and sediment limits, the DGs must be declared inoperable, immediately *

Palisades Nuclear Plant B 3.8.3-4

4-d 01/20/98

Diesel Fuel@* Lube Oil, and Starting Air 3.8.3 x

ACTIONS

NOTE-------------------------------------

Sepiritt Condition entry is allowed for each OG.

CONDITION REQUIRED ACTION COMPLETION TIME CT) 3.7,J. A A. Restore fuel oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months s to within limits.

c15 C)

B.

I YI V .t../J f?x\(

Restore ~

inventory to within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 3.13~ limits.

G

c. c.1 Ci.5 3,7,1.G 1

~

D. FiAd ~~*'tf4 (), I ~S~<f. ~/ ~Sf41 (continued)

Cl5 3 ,1,\ .~ (P-1t8) ,-,..,~.JJ"-.. ~yd"M to oPff2Jt13 l£ 7 d.o. '15 s~ws, l TS f, 8~ -fu.ai~~ E.1 ~c.s~~~ ~ g V\o~

3.-,.1.r ~ ste~ i~opu-~~Le., ~~s ~ .sy~i'e.W\.

CEOG STS 3.8- +o ot'Ell~LE Rev 1, 04/07/95 sfl::\.-tv l .

I~ -e_

Die)til Fuel Oil, Lube Oil, and Starting Air 3.3.3 ACTIONS continued CONDITION REQUIRED ACTION COMPLETION T!ME r;::\n.."" One ~-"'e'~ BSs with Restore stored fuel 30 days

~* ~.A"uel 011 oil properties to f'f\ pro pert i es ~n.:.::0:-::t_w:..1:....:*t:..:..:h~i:. :. n-+---.....:w:_i:_:t:h~in:...,:l,.:i: :,m1.:. :t:.* ;s:.. :. -:----+--:":-~

V 1 lmi ts* oW.w ~ vi sc.osi 1 °""'"cl wa.-k.r ~d. s.Ld, !Ytll"l Ont or mo DGs with ting air startin air receiver receiver ressure to e < [ZZS] psi psig.

[125J. psig.

@Y* Required Action and associated Completion Declare associated DG inoperable.

Irm1ediately CTS TiRM not met.

3', 7. 3. c.

3,7,'J.E One or*inore DGs with

diesel fuel oil, lube oil, or starting air subsyste* not within limits for reasons other than Condition A, 8,~

~F.

SURVEIL IREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.l tank conh ins (continued)

CEOG STS 3.8-23 Rev l, 04/07/95

1¥-.J

Diesel

BASES LCO .:IAJS~R-T .L Stored diesel fuei oil is required to have sufficient supply for 7 days of full accident load operation. It is also required to meet specific standards for quality. The specified 7 day requirement and the 6 day quantity 1 isted in Condition~A are taken from the Engineering Analysis associated with Event Report E-PAL-93-026B.Additionally, sufficient lube oil supply must be available to ensure the capability to operate at full accident load for 7 days. This requirement is in addition to the lube oil contained in the engine sump. The specified 7 day requirement and the 6 day quantity 1 isted in Condition S.Pf:ii\8 are based on an assumed lube oil consumption of1 o

@ ~ (rAJsEe.-r 2 J ~g °"o 1.0 % cF ~w..e \ .,,1 ~_,,s .......... p*h°O""t.,.

These requirements, in conjunction with an ability to obtain replacement supplies within 7 days, support the availability of the OGs. OG day tank fuel

@ requirementsra11d fuel t1a11!feF 6ii~ 2 bility From tbi ii'"ora3i t;u;ik *:i tbi diy iiPki, are addressed in LCOs 3&1 ~and 3@2.

APPLICABILITY fi) (i)

DG OPERABILITY is required by LCOs 3~1 and 3~ to ensure the availability of the required AC power to shut down the reactor and maintain it in a saf~

~

shutdown condition following a loss of off-site power. Since diesel fuel * >

~lube oil support LCOs 3 . . and 3.~.2. stored diesel fuel oil/~lube o are required to be within limit either OG is required to be OPERABLE.

'1 ACTIONS a..-id file. 1-vd. r4'r Sy~ i'1

~ ..,,fr.d "h "' oP, I In this Condition, the available DG fuel oil supply is less than the required 7 day supply, but enough for at least 6 days. This condition allows sufficient time to obtain additional fuel and to perform the sampling and analyses required prior- to addition of fuel oil to the tank. A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered ~ufficient to complete restoration of the required inventory prior to declaring the DGs inoperable.

f,*~=>~4;]

Jb@B.l In this Condition, the available DG lube oil supplyJi~less than the required 7 day supply, but enough for at least 6 days. This condition allows sufficient time to obtain additional lube oil. A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration of the required inventory prior to declaring the DGs inoperable.

PALISADES B 3.7.3-2 Amendment No .

Diesel Fuel and Lube Oil B 3.7.3 and 4.7.3 BASES

!.7.3.C;-t" Diesel fuel oil with viscosity, or water and sediment~out of l imit,&;k unacceptable for even short term DG operation. Viscosity is impor~t primarily because of its effect on the handling of the fuel by the pu~p and injector system; water and sediment provides an indication of fuel contamination. \./hen the fuel oil stored in the Fuel Oil Storage Tank is INSERT determined to be out of viscosity, or water and sediment limits, the FR.Orf\ e de rable imm,~e~d~i~a~t~el.u.i.__----~~~~~""-~~~~~~----

3, ~.I ;;,7,J 0 *@ <,::J)

( Pj q) With the stored fuel oil properties, other than viscosity~ater and sediment, defined in the Fuel Jil Testing Program not within the required CD limits, but acceptable for short term DG operation, a period of 30 days is allowed for restoring the stored fuel oil properties. The most likely cause of stored fuel oil becoming out of limits is the addition of new fuel oil with properties that do not meet all of the limits. This 30 day period provides sufficient time to determine if new fuel oil, when mixed with stored fuel oil, will produce an acceptable mixture, or if other methods to restore the stored fuel oil properties are required. This restoration may involve feed and bleed procedures, filtering, or combinations of these procedures. Even if a DG start and load was required during this time interval and the fuel oil properties were outside limits, there is a high likelihood that the DG would still be capable of performing its intended function.

3.7.3.~.l ~

n and associated Completion Time not met, or with diesel ot within limits for reasons other than addressed by

, the associated DG may be incapable of perfor~ing its

,5.!J.~.i-o-....i....._...u.1.u....:~~~,i._~immediately declared inoperable.

SU~LANCE REQUIREMENTS 3.!

SR 3.1 (P"wel eil qaa11tlty d1eei() L This SR provides verification that there is an adequate inventory of fuel oil in the storage tank to support either DG's operation for 7 days at full post-accident load. The 7 day period is sufficient time to place the plant in a safe shutdown condition and to bring in replenishment fuel from an offsite location.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is specified to ensure that a sufficient supply of fuel oil is available, since the Fuel Oil Storage Tank is the fuel oil supply for the diesel fire pumps, heating boilers, and rad waste evaporators, in addition to the DGs.

PALISADES B 3.7.3-3 Amendment No .

i~-A

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3.8.3-03 JFD 1 CTS 3. 7.3 Action B ITS 3.8.3 Condition B CTS 3. 7. 3 Action B refers to stored oil inventory < 175 and 2 150 gallons.

Corresponding ITS 3.8.3 Condition B refers to stored lube oil inventory< 200 gallons and > 160 gallons. JFD 1 states that the brackets have been removed and the proper plant specific information or value has been provided. No proposed change has been noted on the CTS markup. No specific justification has been provided for this proposed change.

Comment: Revise the submittal to note the proposed change on the CTS markup and provide the appropriate justification for the proposed change.

Consumers Energy Response:

The markup of CTS 3.7.3.B (Attachment 3, page 2 of 4) has been revised to include the proposed change to the stored lube oil inventory. Justification for this change is provided in (new) DOC M.1.

Affected Submittal Pages:

CTS 3.8.3 pg 2 of 4 DOC 3.8.3 pg 1 of 1 15

3.~.3

3. <g -;-;r ELECTRICAL POWER SYSTEMS

3'.g,3 --;1,7,,.

Lc.o QG Fu el 0 i l and Lube 0 i 1 Soecjfications The stored DG fuel oil and DG lube oil. shall be within lim,i,ts.? ~

CD . fvc_L oil i~ St~"'-YI- * -1 ~

Acpl iqbil ity St04'+*NO....

If o.1r si...tis'IU"'"' ** .fo

({;i.I LC-O

Spec1fication 3.7.3 appl1es when any DG 1s requ1red to be OPERABLE. 1. 'i'- )-o I Action <)oo ,4v noN .:5 !JoTE""") @

3.7.3.A With stored fuel oil inventory< 23,700 and~ 20,110 gallons:

l. Restore stored fuel oil inventory to within limits; within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

2.0o !~o 3.7.3.8 With stored lube oil inventory <@and~gallons: c§AAI J ~J *Qj

l. Res tore the 1ube oil inventory to within limits; within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

3.7.3.C With stored fuel oil viscosity, or water and sediment not within limits:

1. Declare both DGs inoperable, i11VT1ediately.

3.7.3.D With stored fuel oil properties other than viscosity, and water and sediment not within limits:

Cof'ld Gi 3.7.3.E

l. Restore stored fuel oil properties to within limits; within 30 days.

If any action required by 3.7.3.A through 3.7.3.D is not met and the associated completion time has expired, or if Specification 3.7.3 is not met for reasons other than those addressed in 3.7.3.A, through 3.7.3.D:

l. Declare both DGs inoperable; irrrnediately.

3-44 Amendment No .

2.. c{ 1

ATT ACITh'lENT 3 DISCUSSION OF CHAL~GES SPECIFICATION 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR ADMINISTRATIVE C~GES (A)

A.1 All reformatting and renumbering are in accordance with NUREG-1432. As a result, the Technical Specifications (TS) should be more readily readable, and therefore understandable by plant operators as well as other users. The reformatting, renumbering, and rewording process involves no technical changes to existing Technical Specifications.

Editorial rewording (either adding or deleting) is made consistent with NUREG-1432.

During Improved Technical Specification (ITS) development certain wording preferences or English language conventions were adopted which resulted in no technical changes (either actual or implied) to the TS. Additional information has also been added to more fully describe each subsection. This wording is consistent with NUREG-1432. Since the design is already approved by the NRC, adding more details does not result in a technical change.

A.2 A Note is added to ITS 3.8.3 Actions allowing separate entry for each DG. This provides explicit instructions for proper application of the Actions for Technical Specifications compliance. In conjunction with proposed Specification 1.3, "Completion Times," the Note provides direction consistent with the intent of CTS.

j A.

These changes are presentation preferences consistent with the NUREG-1432.

herefor~ an administrative change with no impact on safety. /.-A l '.3 ./). ; r() ~

TECHNICAL CHANGES - MORE RESTRICTIVE (M). 11 <>.1.l ... o

\ ~ :J .o*

1 fn~e were no ~Wstrictive" changes associated with this specificationAh \ ~~.'J,6 ~

LESS RESTRICTIVE CHANGES - REMOVAL OF DETAILS TO LICENSEE CONTROLLED DOCUMENTS (LA)

There were no "Removal of Detail" changes associated with this specification.

LESS RESTRICTIVE CHANGES (L)

There were no "Less Restrictive" changes associated with this specification.

Palisades Nuclear Plant Page 1of1 01/20/98

!5-.b

3.8.3-03/3.8.3-04 DOC M. l CTS 4.7.3.2 verifies the inventory of stored lube oil is~ 175 gallons each 31 days. CTS

3. 7. 3. B requires that actions be taken when the inventory of stored lube oil is < 175 and

=

: 150 gallons. Proposed_ITS SR 3.8.3.2 verifies the inventory of stored lube oil is~ 200 gallons. Proposed ITS 3.8.3 Condition B requires that actions be taken when the inventory of stored lube oil is < 200 and > 160 gallons. The quantity of stored lube oil in the ITS has been revised from the quantity requited in the CTS as a result of data recently obtained related to diesel generator lube oil consumption. The inventory of stored lube oil is based on amount of lube oil necessary to support full load diesel generator operation for at least 7 days. The CTS value of 175 gallons was based on an estimated consumption rate of 1 gallon per hour which is representative of large type diesel engines. Empirical data derived during a recent test of a Palisades plant diesel engine test concluded that the actual lube oil consumption rate was approximately 0.833. Values between 0.83 and 1.03 have been confirmed to be acceptable by the engine vendor. As a result of this test, and to ensure an adequate inventory of lube oil is available to support diesel engine operations, the quantity of stored lube oil required in the ITS has been increased to 200 gallons. A stored inventory of 200 gallons, together with the lube oil in the engine sump, will ensure an adequate amount of lube oil will be available to support full load diesel generator operation for at least 7 days in the event of an accident. This change has been characterized as "more restrictive" and is considered acceptable since it continues to preserve the original basis for stored lube oil contained in the CTS .

15- ~

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3.8.3-04 JFD4 ITS SR 3. 7.3.2 CTS 4.7.3.1 Bases for ITS SR 3.8.3.2, CTS Bases markup page B 3. 7.3-4 CTS 4. 7. 3. 1 requires verifying the stored lube oil inventory is 2 175 gallons. ITS SR 3. 7.3.2 requires verifying the stored lube oil inventory is 2 200 gallons. JFD 4 states that changes have been made to reflect the facility analysis description. No proposed change has been noted on the CTS markup. No specific justification has been provided for this proposed change.

Comment: Revise the submittal to note the proposed change on the CTS markup and provide the appropriate justification for the proposed change.

Consumers Energy Response:

The markup of CTS 4.7.3.2 (Attachment 3, page 4 of 4) has been revised to include the

proposed change to the stored lube oil inventory. Justification for this change is provided in (new) DOC M.1.

Affected Submittal Pages:

CTS 3.8.3 pg 4 of 4 DOC 3.8.3 pg 1 of 1 CTS pg B 3.7.3-4 16

(3.8A 3.1.3 1-cev ELECTRICAL pry~ER SYSTEMS TESTS 1

@J

. 7. 2 4.7.2.1 Ver. fy each AC power source requir by Specification 3.7.2 is the following surveillance. C edit may hat-satisfy a surveillance req rement.

4.7.1.1, 4.7.1.2, DG starting

4. 7 .1. 4 I OG 4.7.1.5, 4.7.1.6, PG Fuel Oil and Lube Oil Verify that the fuel oil and lube oil for each required OG is adequate by the following surveillance:

4. 7. 3. l ~

Verify that the Fuel Oil Storage Tank contains each 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . 2oo @

23,700 gallons of fuel; sr< '5. a:a:t 4. 7. 3. 2 Verify stored lube oil inventory is~ @gallons; each 31 days.

r~ 3.6' .'3.3 4. 7. 3. 3 Verify properties of new fuel oil and stored fuel oil are tested in accordance with, and maintained within the limits of, the rue1 Oil Testing Program, Specification 6.5.11.

4. 7. 3. 4 Check for and remove excess accumulated water from the Fuel Oil Storage Tank; each 92 days.

4-43b

I !..P - r;_,.

Amendment No .

ATT ACfLl\.fENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.8.3, DIESEL FVEL OIL, LCBE OIL, ~'ID STARTI~G AIR ADMINISTRATIVE C~GES (A)

A. l All reformatting and renumbering are in accordance with NUREG-1432. As a result, che Technical Specifications (TS) should be more readily readable, and therefore understandable by plant operacors as well as ocher users. The reformatting, renumbering, and rewording process involves no technical changes to existing Technical Specifications.

Editorial rewording (either adding or deleting) is made consistent with NUREG-1432.

During Improved Technical Specification (ITS) development certain wording preferences or English language conventions were adopted which resulted in no technical changes (either acrual or implied) to the TS. Additional information has also been added to more fully describe each subsection. This wording is consistent with NUREG-1432. Since che design is already approved by the NRC. adding more details does not result in a technical change.

A.2 A Note is added to ITS 3.8.3 Actions allowing separate entry for each DG. This provides explicit instructions for proper application of the Actions for Technical

A.

Specifications compliance. In conjunction with proposed Specification 1.3, "Completion Times," the Note provides direction consistent with the intent of CTS.

These changes are presentation preferences consistent with the NU.REG-1432.

here for~ an administrative change with no impact on safety. {A. l '.J .Q) ,.0 j

TECHNICAL CHANGES - MORE RESTRICTIVE (M) 11. ~ tJ.;J-D')

. fl~\ ~*O*

rn:e1 were no ~:~strictive" changes associated with this specific;o~ \, ".) .6*')'6~

LESS RESTRICTIVE CHANGES - REMOVAL OF DETAILS TO LICENSEE CONTROLLED DOCUMENTS (LA)

There were no "Removal of Detail" changes associated with this specification.

LESS RESTRICTIVE CHANGES (L)

There were no "Less Restrictive" changes associated with this specification.

Palisades Nuclear Plant Page 1of1 01/20/98 l&-h

3.8.3-03/3.8.3-04 DOC M.1 CTS 4.7.3.2 verifies the inventory of stored lube oil is;;::: 175 gallons each 31 days. CTS

3. 7. 3. B requires that actions be taken when the inventory of stored lube oil is < 175 and

150 gallons. Proposed ITS SR 3.8.3.2 verifies the inventory of stored lube oil is~ 200 gallons. Proposed ITS 3.8.3 Condition B requires that actions be taken when the inventory of stored lube oil is < 200 and > 160 gallons. The quantity of stored lube oil in the ITS has been revised from the quantity required in the CTS as a result of data recently obtained related to diesel generator lube oil consumption. The inventory of stored lube oil is based on amount of lube oil necessary to support full load diesel generator operation for at least 7 days. The CTS value of 175 gallons was based on an estimated consumption rate of 1 gallon per hour which is representative of large type diesel engines. Empirical data derived during a recent test of a Palisades plant diesel engine test concluded that the actual lube oil consumption rate was approximately 0.833. Values between 0.8% and 1.03 have been confirmed to be acceptable by the engine vendor. As a result of this test, and to ensure an adequate inventory of lube oil is available to support diesel engine operations, the quantity of stored lube oil required in the ITS has been increased to 200 gallons. A stored inventory of 200 gallons, together with the lube oil in the engine sump, will ensure an adequate amount of lube oil will be available to support full load diesel generator operation for at least 7 days in the event of an accident. This change has been characterized as "more restrictive" and is considered acceptable since it continues to preserve the original basis for stored lube oil

contained in the CTS .

l&-c

Diesel Fuel and Lu~e Oil B 3.7.3 and 4.7.3 BASES SR ~3. 2 (l~e_e ei l ~waRtiliy el!eek) Q. ~

This Surveillan~e ensures that sufficient l~inventory is available to s t t least 7 days of full accident load operation for one OG. The ns requirement i~ based on an estimated consum ti on of=...~.....................

O.~ +., l.OO'f0 of ~"4.\ 1,.\ c~s1,,1.*~~""*

A 31 day Frequency is adequate to ensure that a sufficient lube oil supply is onsite, since OG starts and run times are closely monitored by the plant sta~ ~.i SR .3.3 (f'1:1el eil ~walii;' *~**k)Q...

The tests listed below are a means of determining whether new fuel oil and stored fuel oil are of the appropriate grade and have not been contaminated with substances that would have an immediate, detrimental impact on diesel engine combustion.

Testing for viscosity, specific gravity, and water and sediment is completed for fuel oil delivered to the plant prior to its being added to the Fuel Oil Storage Tank. Fuel oil which fails the test, but has not been added to the Fuel Oil Storage Tank does not imply failure of this SR and requires no specific action. If results from these tests are within acceptable limits, the fuel oil may be added to the storage tank without concern for~

contaminating the entire volume of fuel oil in the storage tank. {[~z 32,)~

Fuel oil is tested for other of the parameters specified in ASTM 0975 \g l5* $".I~\

~.)_,....

accordance with the Fuel Oil Testing Program required by Specification 6.5.11 Fuel oil determined to have one or more measured parameters, other than viscosity or water and sediment, outside acceptable limits will be evaluated for its effect on OG operation. Fuel oil which is determined to be acceptable for short term OG operation, but outside limits will be restored to within limits in accordance with LCO ~3 Condition{[)

SR 3.i.3.lf I lJSC((.,T

~ 3,~*I GtlSt.S

( p~ 1"3)

PALISADES 8 3.7.3-4 Amendment No .

/&-d

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS

RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION NRC REQUEST:

3.8.3-05 RESPONSE TO NRC QUESTIONS Bases Applicable Safety Analysis discussion for ITS 3.8.3, CTS Bases markup page B 3. 7. 3-1 Bases Applicable Safety Analysis discussion for STS 3.8.3 The Bases Applicable Safety Analysis discussion for STS 3.8.3 includes reference to the criteria of 10 CFR 50. 36. This material has not been adopted in the Bases for corresponding ITS 3.8.3.

Comment: This is not a justifiable plant specific difference. Revise the Bases to conform to the STS.

Consumers Energy Response:

The Applicable Safety Analyses discussion in the Bases for ITS 3.8.3 has been revised to include the appropriate reference to 10 CFR 50.36.

Affected Submittal Pages:

ITS pg 8 3.8.3-2 CTS pg 8 3.7.3-1 17

Diesel Fuel, Lube Oi 1, and Starting Air B 3.8.3 S1"~~ ~1c.s~L *~\.1-c.L. 1 i.Jo.... 01L, ci..r.d .O+a..r+1A() a.1.- Sl,)bf'/J1<."""-J Ml C <JPPor+ "rl-1<. oP~-ttcr. o~ i"'° .o+~r-d~ ~C.. fot.ix.r ~re.es, +"~t 3.~.3-os BASES

~ ~

APPLICABLE A description of the Safety Analyses applicable in MODES l, SAFETY ANALYSE 2, 3, and 4 is provided in the Bases for LCO 3.8.l, AC 11 Sources - Operating during MODES 5 and 6, in the Bases for 11 LCO 3.8.2, AC Sources - Shutdown.

11 11 LCO Stored diesel fuel oil is required to have sufficient supply for 7 days of full accident load operation. It is also required to meet specific standards for quality. The specified 7 day requirement and the 6 day quantity listed in Condition A are taken from the Engineering Analysis associated with Event Report E-PAL-93-0268. Additionally, the ability to transfer fuel oil from the storage tank to each day ank is required from each of the two transfer pumps. T em 1s requ o av. a in1mum apacity with m gin for a DG start att pt withou echa ing the air st t receivers.

Addi~ionally, sufficient lube oil supply must be available to ensure the capability to operate at full accident load for 7 days. This requirement is in addition to the lube oil contained in the engine sump. The specified 7 day requirement and the 6 day quantity listed in Condition B are based on an assumed lube oil consumption of 0.8 to 1.0% of fuel oil consumption.

"Tht. D+a.ri'"'c a.1r ~ The-fuel oil transfer ystem which includes f e rans er Sl.lb.s'IJ+c.m Mws + prov1J.<. J pump P SA can be po red by offsite power, r by either 0 Howev , the fuel o transfer system whic includes fuel Cu 1*he>v~ fh~ a..1 d ot- ~"<. tran fer pump P-1 can only be powered b offsite power, o

~ ~l~L C.CJ'Y'Pf(.SSl)r i by G 1-1.

S'M1c.1c{'\1 a.it' ~'kl.rt These requirements, in conjunctiori with an ability to obtain Ct;.fr-A~j+y , 1nc.lud1n rro.~111,replacement supplies within 7 days, support the availability

~ a.rJJuR. S+a.rt 0 of the DGs. DG day tank fuel requirements are addressed in

~,11+'1 ~,.. 1+s LCOs 3.8.1 and 3.8.2.

q SS oc..1a.-k..d C b *

..___~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~---

APPLICABILITY DG OPERABILITY is required by LCOs 3.8.1 and 3.8.2 to ensure the availability of the required AC power to shut down the reactor and maintain it in a safe shutdown condition following a loss of off-site power. Since diesel fuel, lube ~A\

oil, and starting air suppo:~s 3.8.1 and 3.8.2, stored 3.~d*".2-diesel fuel oil, lube 011,(iij__ t(iniflt;>and starting air are required to be within limits when either DG is required

G,,.,J ,."' ~v~ tro~ tysJ,w... is r~ui"4 +. k ctil1't£ to be OPERABLE.

Palisades Nuclear Plant 8 3.8.3-2 01/20/98

/7 ELECTRICAL POWER SYSTEMS

~ 3.7.3 a J 4 1 ~Diesel BASES BACKGROUND The .liesel ~nerators (OGs) are provided with a storage tank having a required fuel oil inventory sufficient to operate one diesel for a period of 7 days, while the OG is supplying maximum post-accident loads. This onsite fuel oil capacity is sufficient to operate the DG for longer than the time to replenish the onsite supply from offsite sources.

Fuel oil is transferred from the Fuel Qi l Storage Tank to i her day tank by either of two Fuel Transfer !~h*0 .I>JSf..i 1 :~r. 1; For proper operation of the standby OGs, it is necessar to ensure the proper quality of the fuel oil. Regulatory Guide (RG) 1.137 a resses tne _ __

recommended fuel oil practices as supplemented by ANSI Nl95-l976r@:,t, z.\)

The DG lubrication system is designed to provide sufficient lubrication to permit proper operation of its associated DG under all loading conditions.

The system is required to circulate the lube oil to the diesel engine working surfaces and to remove excess heat generated by friction during operation.

The onsite storage in addition to the engine oil sump is sufficient to ensure 7 days of continuous operation. This supply is sufficient supply to allow the operator to replenish lube oil from offsite sources. Implicit in this LCO is the requirement to assure, though not necessarily by testing, the capability to transfer the lube oil from its storage location to the DG oil sump, while the DG is running. -[

.. --, _I,() 5e.-r 2)

APPLICABLE SAFETY ANALYSES ~: /t1 l()~c

.t1 ;; /

j z~

I 3, 0.~ u") 7J A description of the Safety Analyses applicable ~LQ S lH99"r;'s' provided in the Bases for LCO 3.f.l "AC Sources - Operating"; during~

-S+ll:HEleWff aild REFlilELitl* illUTQeWH".\ in the Bases for LCO 3J°'2 "AC Sources -

Shutdown". (!} W .

( 5.1nc." d1c:.~c.L ~L, Lkc. 01L, C4.Nl oiu.rh~o a.it- llJ,ay1~ /.)uP9dr-t- +ttt.

~ ~~rto..\-1of\ ot-1-r... ~+a.rd~j AC.. fow..,,. f"Jour<.~~ 1 f'ric.y ~o...+ts"+.j Ct<,4r16~ ~ o~ 10 CJ.fl. SoJ'°' (c."iC2..).

PALISADES B 3.7.3-1 Amendment No .

7-b

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3.8.3-06 Bases Background for ITS 3.8.3, CTS Bases markup page B 3. 7.3-1 Bases Background for ITS 3. 8. 3, ITS Bases page B 3. 8. 3-1 The second paragraph of the Bases Background for ITS 3.8.3, CTS Bases markup page B 3. 7. 3-1 is different than the second paragraph of the Bases Background for ITS 3.8.3, ITS Bases page B 3.8.3-1.

Comment: Revise the submittal to resolve this discrepancy. Provide the appropriate justification for all proposed changes.

Consumers Energy Response:

The discrepancy in the second paragraph of the Bases Background for ITS 3.8.3, and the CTS Bases markup, has been resolved. The discrepancy resulted from the misplacement of "Insert 1" to CTS Bases pages B 3.7.3-1 and B 3.7.3-2. Insert 1 has been corrected and conforming changes have been made to the proposed ITS Bases.

The justification for this change (JFD 8) presented in Attachment 8 of the submittal remains unchanged.

Affected Submittal Pages:

ITS pg B 3.8.3-1 ITS pg B 3.8.3-2 CTS B 3.7.3-2 Insert 18

Diesel Fuel, Lube Oil, and Starting Air B 3.8.3 3.8 ELECTRICAL POWER SYSTEMS B 3.8.3 Diesel Fuel, Lube Oil, and Starting Air BASES BACKGROUND The Diesel Generators (DGs) are provided with a storage tank having a required fuel oil inventory sufficient to operate one diesel for a period of 7 days, while the DG is supplying maximum post-accident loads. This onsite fuel oil capacity is sufficient to operate the OG for longer than the time to replenish the onsite supply from offsite sources.

For proper operation of the standby DGs, it is necessary to ensure the proper quality of the fuel oil. Regulatory Guide (RG) 1.137 (Ref. 1) addresses the reco1TUT1ended fuel oil practices as supplemented by ANSI N195-1976 (Ref. 2).

The DG lubrication system is designed to provide sufficient lubrication to permit proper operation of its associated DG under all loading conditions. The system is required to circulate the lube oil to the diesel engine working surfaces and to remove excess heat generated by friction during operation. The onsite storage in addition to the engine oil sump is sufficient to ensure 7 days of continuous operation.

This supply is sufficient supply to allow the operator to replenish lube oil from offsite sources. Implicit in this LCO is the requirement to assure, though not necessarily by testing, the capability to transfer the lube oil from its storage location to the DG oil sump, while the DG is running.

The startin air subsystem must pr v1 e, wit out the ai of the refill ompressor, sufficien air start capacity, including argin, to assure star capability for its associat DG.

-* Palisades Nuclear Plant B 3.8.3-1 16-a_

01/20/98

Diesel Fuel, Lube Oil, and Starting Air B 3.8.3

~ ~ic.hL ~v"l. 1 S11., ... i.Jrx. 01L 1 o.."d .O+a..No1A() a, 1,. Sv~f'IJ1'.-N Ml

).~ 3~ os

BASES APPLICABLE SAFETY ANALYSE 0 P'-"0,-Tlel\ o~ .+"" IJ+a.r-d" ~C.. foi.Jx.r !h.ir"e Sl 't""/

~

A description of the Safety Analyses applicable in MODES l, 2, 3, and 4 is provided in the Bases for LCO 3.8.1, "AC Sourc-es - Operating"; during MODES 5 and 6, in the Bases for LCO 3.8.2, ' AC Sources - Shutdown."

1 LCO Stored diesel fuel oil is required to have sufficient supply for 7 days of full accident load operation. It is also required to meet specific standards for quality. The specified 7 day requirement and the 6 day quantity listed in Condition A are taken from the Engineering Analysis associated with Event Report E-PAL-93-026B. Additionally, the ability to transfer fuel oil from the storage tank to each da~ank is required from each of the two transfer pu~ ry. g a1 r s em , s req o av a in1mum apacity with m gin for a OG start att pt withou echa ing the air st t receivers.

Additionally, sufficient lube oil supply must be available to ensure the capability to operate at full accident load for 7 days. This requirement is in addition to the lube oil contained in the engine sump. The specified 7 day requirement and the 6 day quantity listed in Condition Bare based on an assumed lube oil consumption of 0.8 to 1.0% of fuel oil consumption.

°7h~ D+a..r~,r'\~ a.1,.. ~ The.fuel oil transfer ystem which includes e rans er , p*' .o-i Sl.lbJ'/J-k.m M uS -t prw1~<. J pump P SA can be po red by offsite power, r by either DG_. *: "6*"l Howev , the fuel

transfer system whic includes fuel \

w11nov~ fh" a.id o~ -'rfi<.. tran fer pump P-1 can only be powered b offsi te power, or\

re. .5;1tl C.Cf'r'Pfr.SSor 1 by G 1-1.

S-M1c.1eri1 a.1r ~?a.N These requirements, in conjunction with an ability to obtain

~ f'i:J(.,j+y / /l)(../udlf'I~ Y'l"Q.~111, replacement supplies within 7 days, support the availability i'O GPJuR. S+o. rt of the OGs. DG day tank fuel requirements are addressed in

~i11+'1 ~r 1+s LCOs 3.8.1 and 3.8.2.

('SS OC:.1Q. ~c:J D b *

"--~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~___,.~~

APPLICABILITY DG OPERABILITY is required by LCOs 3.8.l and 3.8.2 to ensure the availability of the required AC power to shut down the reactor and maintain it in a safe shutdown condition following a loss of off-site power. Since diesel fuel, lube ~Al oil, and starting air suppo:~s J.8.1 and 3.8.2, stored 3~~*0.2..

diesel fuel oil, lube oil, <f~--~mi'fi?.;i and starting air are required to be within limits when either DG is required to be OPERABLE. C:.nd l"' + 11 ~ tro~ ~~$W.. is r~111f'4 +.~~ill.

Palisades Nuclear Plant B 3.8.3-2 01/20/98 18-b

SECTION 3.8

INSERT 1 Additionally, the ability to transfer fuel oil from the storage tank to each day tank is required from each of the two tr~fer pumps. j11iestaffingaiy'Systemisrequ1re to ave rum

~apacityf.vith m~rgin f9f a D~-s~~ -~ct-~mpt withou)lfecharging the air sta receivers.

- - - - - - - - - - ..... _ _ _ _L___ _ _ __

INSERT 2 The starting air subsystem must provide, without the aid of the refill compressor, sufficient air start capacity, including margin, to assure start capability for its associated DG.

B 3.7.3-2 18-c_

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3.8.3-07 Bases Background for ITS 3.8.3, CTS Bases markup page B 3. 7.3-1 Bases Background for ITS 3.8.3, ITS Bases page B 3.8.3-1

The fourth paragraph of the Bases Background for ITS 3. 8. 3, CTS Bases markup page B 3. 7. 3-1 is different than the fourth paragraph of the Bases Background for ITS 3. 8. 3, ITS Bases page B 3. 8. 3-1.

Comment: Revise the submittal to resolve this discrepancy. Provide the appropriate justification for all proposed changes.

Consumers Energv Response:

The discrepancy in the fourth paragraph of the Bases Background for ITS 3.8.3, and the CTS Bases markup, has been resolved. The discrepancy resulted from the misplacement of "Insert 2" to CTS Bases pages B 3.7.3-1 and B 3.7.3-2. Insert 2 has been corrected and conforming changes have been made to the proposed ITS Bases.

The justification for this change (JFD 8) presented in Attachment 8 of the submittal remains unchanged.

Affected Submittal Pages:

ITS pg B 3.8.3-1 ITS pg B 3.8.3-2 CTS pg B 3.7.3-1 Insert 19

Diesel Fuel, Lube Oil, and Starting Air B 3.8.3

-* 3.8 ELECTRICAL POWER SYSTEMS B 3.8.3 BASES Diesel Fuel, Lube Oil, and Starting Air BACKGROUND The Diesel Generators (DGs) are provided with a storage tanK having a required fuel oil inventory sufficient to operate one diesel for a period of 7 days, while the DG is supplying maximum post-accident loads. This onsite fuel oil capacity is sufficient to operate the DG for longer than the time to replenish the onsite supply from offsite sources.

~\ ( the ired to attempt For proper operation of the standby DGs, it is necessary to ensure the proper quality of the fuel oil. Regulatory Guide (RG) 1.137 (Ref. 1) addresses the recommended fuel oil practices as supplemented by ANSI Nl95-1976 (Ref. 2).

The DG lubrication system is designed to provide sufficient lubrication to permit proper operation of its associated DG under a 11 loading conditions. The system is required to circulate the lube oil to the diesel engine working surfaces and to remove excess heat generated by friction during operation. The onsite storage in addition to the engine oi 1 sump is sufficient to ensure 7 days of continuous operation.

This supply is sufficient supply to allow the operator to replenish lube oil from offsite sources. Implicit in this LCO is the requirement tci assure, though not necessarily by testing, the capability to transfer the lube oil from its storage location to the DG oil sump, while the OG is running.

The startin air subsystem must pr vi e, wit out the ai of the refill ompressor, sufficien air start capacity, including argin, to assure star capability for its associat OG .

- - Palisades Nuclear Plant B 3.8.3-1 01/20/98

SECTION 3.8

INSERT 1 The fuel oil transfer system which includes fuel transfer pump P-18.A. can be powered by offsite power, or by either DG. However, the fuel oil transfer system \vhich includes fuel transfer pump P-188 can only be powered }?y otTsite power, or by DG 1-1.

INSERT 2 D .

Each ~G is provided with an associated starting air subsystem to assure independent start capability. ~' /)~r-l1""t a.1r S(Si<,M 15 rc.~virt.d to hG1..ve. o.. /Y'r...A,/"f\v,...*

(c..fa.r..ifj u.idr- mo.rb1'(1 ~or 0. a& ~+c..M- at+c...-rt w1"tf..oe7f rtr.J.,cr61na

+he:. ail /,)iad* (C, C..<..1 V"<..('J I

B 3.7.3-1

q-b

Diesel Fuel , Lube Oil , and Starting Air 8 3.8.3 S'"""- ~\c.hL *~\,,"'L. 1 ii.k.. 01L 1 o..r.d .O+o..t'+1A() ~,.. Svbf'IJ'i<<N

/'<Al BASES i'.l1.19ror+ """'(. oPt."Q.-tl~ o~ ~"'- ~iO+il.r-d~ ~(.. fow.c..,. ~r"'Si ;"4.1 3.~3-05 APPLICABLE A description of the Safety Analyses applicable in MODES 1, SAFETY ANALYSE 2, 3, and 4 is provided in the Bases for LCO 3.8.1, "AC Sourc-es - Operating"; during MODES 5 and 6, in the Bases for LCO 3.8.2, "AC Sources - Shutdown."

LCO Stored diesel fuel oil is required to have sufficient supply for 7 days of full accident load operation. It is also required to meet specific standards for quality. The specified 7 day requirement and the 6 day quantity listed in Condition A are taken from the Engineering Analysis associated with Event Report E-PAL-93-026B. Additionally, the abi 1i ty to transfer fuel oil from the storage tank to each da~ank is required from each of the two transfer pumps._JTJ>' -g a1r s em 1s requ o av a inimum apacity with m gin for a DG start att pt withou echar. ing the air st t receivers.

Additionally, sufficient lube oil supply must be available to ensure the capabi 1i ty to operate at full accident 1oad for 7 days. This requirement is in addition to the lube oil contained in the engine sump. The specified 7 day requirement and the 6 day quantity listed in Condition Bare based on an assumed lube oil consumption of 0.8 to 1.0% of fuel oil consumption.

~<- D+a.r~,"~ a,,,.~ The.fuel oil transfer ystem which includes e rans er. f..~' .o"1 S1..1WYJ+<.N\ IY1 ws + prtiv1d<. J pump P SA can be po red by offsite power, r by either DG. *, ~*")

Howev , the fuel o transfer system whic includes fuel \

w1~hciv~*fh" a.id o~ ~r-r<.. tran fer pump P-1 c-0n only be powered b offsite power, o fC.~1LL C.Cf'r\Prc.ss~r 1 by G 1-1.

S'~1c.1en1 a.1r ~?a.rt These requirements, in conjunction with an ability to obtain C:C- fti e.,;f Y , /1X.,lud1n~ rra.~111, replacement supp 1 i es within 7 days, support the ava i 1abi1 i ty

-te ~urt S+a.M of the DGs. DG day tank fuel requirements are addressed in

~i11fi ~,.. 1+s LCOs 3.8.1 and 3.8.2.

<,SS o<..1c.i<.d Cb*

APP LI CAB I LI TY DG OPERABILITY is required by LCOs 3.8.1 and 3.8.2 to ensure the availability of the required AC power to shut down the reactor and maintain it in a safe shutdown condition following a loss of off-site power. Since diesel fuel, lube ~A\

oil, and starting air suppo~~s ~.8.1 and 3.8.2, stored 3~~*0.2.

diesel fuel oil, lube oil, <fu.~J._-t.6fo:ifi:Q and starting air are required to be within limits when either DG is required to be OPERABLE. G.,,J -f11c. +v~ tra~ ~vsJ,i.,. IS r~1J1N4 ~ ~ ~J.IE.

Palisades Nuclear Plant B 3.8.3-2 01/20/98

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS

RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION NRC REQUEST:

RESPONSE TO NRC QUESTIONS 3.8.3-08 ITS 3. 8. 3 Condition G Bases for ITS 3.8.3 Required Action G.1 ITS 3. 8. 3 Condition G addresses the starting air subsystem not within limits. The Bases for ITS 3.8.3 Required Action G.1 is silent regarding the starting air requirement.

Comment: Revise the submittal to expand the Bases for ITS 3.8.3 Required Action G.1 to address starting air.

Consumers Energy Response:

The Bases for ITS 3.8.3 Required Action G.1 has been revised to include the starting air subsystem.

Affected Submittal Pages:

ITS pg B 3.8.3-4 CTS pg B 3.7.3-3 20

Diesel Fuel, Lube Oil, and Starting Air B 3.8.3 ACTIONS Ll (continued)

With the stored fuel oil properties, other than viscosity, and water and sediment, defined in the Fuel Oil Testing Program not within the required limits, but acceptable for short term DG operation, a period of 30 days is al lowed for restoring the stored fuel oil properties. The most likely cause of stored fuel oil becoming out of limits is the addition of new fuel oil with properties that do not meet all of the limits. This 30 day period provides sufficient time to determine if new fuel oil, when mixed with stored fuel oil, wi 11 produce an acceptable mixture, or if other methods to restore the stored fuel oil properties are required. This restoration may involve feed and bleed procedures, filtering, or combinations of these procedures.

Even if a DG start and load was required during this time interval and the fuel oil properties were outside limits, there is a high likelihood that the DG would still be capable of performing its intended function.

Ll J 0f S1arnn6 Q.I*.- s~S~-kft\.

With a Required Action and associate}rnmpletion Time not met, or with diesel fuel oi~(]Ll lube . . ~not within limits for reasons other than addressed by Conditions A)[~ F, the associated DG may be incapable of performing its~e:,,or intended function and must be immediately declared inoperable.

In the event that diesel fuel oil with viscosity, or water and sediment is out of limits, this would be unacceptable for even short term DG operation. Viscosity is important primarily because of its effect on the handling of the fuel by the pump and injector system; water and sediment provides an indication of fuel contamination. When the fuel oil stored in the Fuel Oil Storage Tank is determined to be out of viscosity, or water and sediment limits, the DGs must be declared inoperable, immediately.

Palisades Nuclear Plant B 3.8.3-4 01/20/98

Diesel Fuel and Lube Oil 8 3.7.3 and 4.7 .3 BASES

7.7.3.C;T Diesel fuel oil with viscosity, or water and sediment*out of limit,£;"k unacceptable for even short term DG operation. Viscosity is impor~i primarily because of its effect on the handling of the fuel by the pu:np injector system; water and sediment provides an indication of fuel contamination. when the fuel oil stored in the Fuel Oil Storaje Tank is

/NS8<..T determined to be out of viscosity, or water and sediment limits, the DGs FR.orf\ e de rable im~~.e~~~:~a~t~e~l*L....----~~~~~--~~~~~~~~--

3, ~.I a.7 1 o 1@ <.;::J)

( Pj Cf J With the stored fuel oil properties, other than viscosity~ater and sediment, defined in the Fuel til Testing Program not within the rec;uire~

8 limits, but acceptaole for short term DG operation, a period of JO ca;s is allowed for restoring the stored fuel oil properties. The most likely cause of stored fuel oil becoming out of limits is the addition of new fuel 011 with properties that do not meet all of the limits. This JO day period provides sufficient time to determine if new fuel oil, wnen mixed with stored fuel oil, will produce an acceptaole mixture, or if other methods to restore the s~ored fuel oil properties are requ\red. This restoration may involve feed and oleed procedures, filtering, or comoinations of these procedures. Even if a OG start and load was required during this time interval and the f*,,el oil properties were outside limits, there is a high likelihood that the OG *..iould still be capable of performing its intended function.

~ /l'l I J.10-<58 3.7.3,\.l ~

R (P:wel ei l qaa11t I LJ eAeelt) Q...

This SR provides verification that there is an adequate inventory of fuel oil in the storage tank to support either DG's operation for 7 days at full post-accident load. The 7 day period is sufficient time to place the plant in a safe shutdown condition and to bring in replenishment fuel from an offsite location.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is specified to ensure that a sufficient supply of fuel oil is available, since the Fuel Oil Storage Tank is the fuel oil supply for the diesel fire pumps, heating boilers, and rad waste evaporators, in addition to the DGs.

PALISADES B 3.7.3-3 Amendment No .

aD-b

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3. 8. 4, DC Sources - Operating 3.8.4-01 DOC L.1 ITS 3. 8.4 Completion Time for Required Action C. 1 Bases for ITS 3.8.4 Action C.1, CTS Bases markup page B 3. 7. 4-3, insert ITS 3.8.4 Condition C addresses one DC electrical power source-inoperable for reasons other than Conditions A or B. The proposed Completion Time for associated Required Action C. 1 is 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . In the event of this occurrence, the CTS requires entry into a shutdown action. The Completion Time for Required Action A. 1 for corresponding STS 3. 8.4 is 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

Comment: No JFD has been provided to justify this proposed difference with the STS.

DOC L. 1 does not provide a technical justification to support the proposed change.

Revise the submittal to provide the technical justification for the proposed change, or confonn to the STS.

Consumers Energy Response:

JFD 5 for ISTS 3.8.4 has been expanded to include a discussion on the differences between ISTS Condition A and ITS Condition C. In addition, DOC L.1 has been revised to provide a technical justification for the changes made to CTS 3.7.4. The purpose for these changes is to preserve the operational flexibility of the CTS while maintaining a parallel structure that exists in the ISTS. The uniqueness of the Palisades plant design (reflected in the CTS) affords flexibility that is not contained in the ISTS. The structure of the ISTS provides a logical relationship between DC Sources (ISTS 3.8.4) and (DC)

Distribution Systems (ISTS 3.8.9) that is not contained in the CTS. The basis for the structure of the ISTS is the recognition that a DC electrical power system that is degraded due to an inoperable DC source presents no more risk than a DC electrical

. power system degraded due to an inoperable DC bus. As such, the Completion Times in the ISTS for an inoperable DC source and an inoperable DC distribution system are the same. Therefore to preserve the structure presented in the ISTS (and avoid perpetuating the illogical relationship between DC sources and DC power systems found in the CTS), and .to maintain the operational flexibility provided in the CTS, ISTS 3.8.4 has been modified accordingly.

Affected Submittal Pages:

JFD 3.8.4 pg 1 of 1 DOC 3.8.4 pg 2 of 3 21

Djseussion ATTACHMENT 6 JUSTIFICATION FOR DEVIATIONS SPECIFICATION 3.8.4, DC SOURCES - OPERATING NOTE: This attachment provides a brief discussion of the deviations from the Technical Specifications of NUREG-1432 that were made to support the development of the Palisades Nuclear Plant ITS. For Section 3. 8 ONLY, three additional attachment have been provided. Attachment 7 is a markup of the CTS Bases showing the difference between CTS and proposed ITS Bases. Attachment 8 provides an explanation of these differences. Attachment 9 provides a markup of NUREG-1432, Section 3.8 Bases.

The Change Numbers correspond to the respective deviation shown on the "NUREG MARKUPS." The first five justifications were used generically throughout the markup of the NUREG. Not all generic justifications are used in each Specification.

1. The brackets have been removed and the proper plant specific information or value has been provided .

2.

3.

Editorial change for clarity or for consistency with the Improved Technical Specifications (ITS) Writer's Guide.

The requirement/statement has been deleted since it is not applicable to this facility.

The following requirements have been renumbered, where applicable, to reflect this deletion.

4. Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect the facility specific nomenclature, number, reference, system description, or analysis description.

5. This change reflects the current licensing basis/technical specificatio~ L 1ruSu,1

6. TSTF-8, Rev. 2 deleted the 3.8 SR Notes "However credit may be taken ... " and addressed that issue globally in the 3.0 Bases. This presentation is consistent with NUREG-1432.

7. Incorporate TSTF-38 into SR 3. 8.4. 3 to specify the surveillance is to identify conditions which could degrade battery performance .

Palisades Nuclear Plant Page 1of1

<=21 01/20/98

3.8.4-01 JFD 5

... as modified by DOC L. l. ITS 3. 8 .4 has been developed to preserve the operational flexibility of the CTS while maintaining a parallel structure to the ISTS. The design of the Palisade plant DC electrical power system is such that each station battery has two associated battery chargers, one powered by the associated AC power distribution system (the directly connected charger), and one powered from the opposite AC power distribution system (the cross connected charger). CTS 3.7.4 provides the actions necessary to cope with a degraded DC electrical power system which results from an inoperable charger or an inoperable battery using the design features (i.e., cross connect capabilities) of the system. These same actions have been incorporated in ITS 3.8.4. However, in NUREG-1432, ISTS 3.8.4 is structured such that the restoration time for an inoperable DC electrical power subsystem (e.g. , charger, or battery, or charger and battery) is equivalent to the allowed outage time for an inoperable DC electrical power distribution system. The basis for this structure is the recognition that a degraded DC electrical power source presents no more risk than an inoperable DC bus. Thus, to maintain this same logical structure in the Palisade's ITS, Condition C has been added to address the concurrent inoperabilities of a charger and battery in the same electrical train (in the ISTS, this same configuration would be addressed by Condition A).

ct.I -b

ATTACHMENT 3 DISCUSSION OF CHAl'lGES SPECIFICATION 3.8.4, DC SOURCES - OPERA TING LESS RESTRICTIVE CHANGES - REMOVAL OF DETAILS TO LICENSEE CONTROLLED DOCUMENTS (LA)

LA. l CTS 3. 7 .4 and 4. 7 .4.6 detail the plant equipment designators for the DC electrical power trains. ITS 3.8.4 simply requires the operability of the DC electrical power trains, and relocates the details of what comprises the trains to the Bases and FSAR.

Since these details are not necessary to adequately describe the actual regulatory requirement, they can be moved to a licensee controlled document without a significant impact on safety. Placing these details in the Bases of ITS 3. 8 .4 and the FSAR provides adequate assurance that they will be maintained. The Bases are controlled by the Bases Control Process in Chapter 5 of the proposed Technical Specifications, and the FSAR is controlled by 10 CFR 50.59. This change is consistent with NUREG-1432.

LESS RESTRICTIVE CHANGES?

L.l

/(J~

3.7.4 Actions A.land B.l both have requirements for connection of b

/( Jl. IL I ry """/

0 charge "immediately." Additionally, there is no specific action for ain with both its ba fY and its charger inoperable, which therefore requires immediate shutdown co ence. These conditions are ones where DC po continues to remain available to the b albeit with inoperable sources. In the ent the entire DC bus is de-energized, CTS 3. .C.2 allows 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to restore required plant shutdown. herefore, the ITS action o connect additional battery charger(s) for degraded (but 'II powered) DC t ms, and for both the charger and battery inoperable (but still pow 'ng the D us), are being proposed with an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months allowed completion time. Without *s c nge, the CTS actions result in the plant being in a shutdown action immediate on discovery of an inoperable battery or charger (until the opposite trains e char is connected).

Therefore, this change allo lish connection of the opposite train spare charger, or storation to operable status t battery and/or charger, which may avoid a pote

ly unnecessary plant shutdown tran

nt. The time allowed is consistent wit at previously approved for the more degra d condition of the de-energize train. As such, this change will not result in a si 'ficant impact on safety .

Palisades Nuclear Plant Page 2 of 3 c21 - ('_

01120/98

3.8.4-01 DOC L.1 CTS 3.7.4 specifies the requirements for DC source when the plant is above Cold Shutdown.

CTS 3. 7.4 Actions A. l require the cross-connected charger( s) for the affected battery be placed in service immediately whenever one required charger is inoperable. CTS 3.7.4 Action B. l requires both chargers for the affected battery be placed in service immediately whenever one battery is inoperable. The CTS does not specify an Action when one charger and one battery in one train are inoperable concurrently: Thus, the provisions of LCO 3.0.3 are applied. In the ITS, the inoperability of a charger, a battery, and a charger and battery in one train concurrently, are addressed by Conditions A, B, and C, respectively. The Completion Times for Conditions A, B, and C are equally stated at 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months since these conditions are ones where DC power continues to remain available to the bus, albeit with inoperable sources. Selection of the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is consistent with that previously approved for the more degraded condition of one de-energized DC electrical distribution train allowed by CTS 3.7.9.c. With one DC electrical distribution train de-energized, the remaining DC electrical train is capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe condition. Since ITS 3.8.4 represents a configuration of the DC electrical system that is less severe and presents less risk for a loss of function than that allowed by CTS 3.7.9.c (proposed ITS 3.8.9), an extension of the Completion Times to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months can be made without a significant risk to public health and safety. An extension of the Completion Times for "DC Source-Operating" to match the Completion Times for (DC) "Distribution Systems-Operating" is consistent with the philosophy presented in NUREG-1432.

~/-d,

I I

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS

RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION NRC REQUEST:

3.8.4-02 RESPONSE TO NRC QUESTIONS Bases Applicable Safety Analysis discussion for ITS 3.8.4, CTS Bases markup page B 3. 7. 4-2 Bases Applicable Safety Analysis discussion for STS 3. 8. 4 The Bases Applicable Safety Analysis discussion for STS 3.8.4 includes reference to the criteria of 10 CFR 50.36. This material has not been adopted in the Bases for corresponding ITS 3. 8. 4.

Comment: This is not a justifiable plant specific difference. Revise the Bases to conform to the STS.

Consumers Energy Response:

The Applicable Safety Analyses discussion in the Bases for ITS 3.8.4 has been revised to include the appropriate reference to 10 CFR 50.36.

Affected Submittal Pages:

ITS pg B 3.8.4-2 CTS pg B 3.7.4-2

22

DC Sources - Operating B 3.8.4 BASES BACKGROUND The batteries for the DC power sources are sized to produce (continued) required capacity at 80% of nameplate rating, corresponding to warranted capacity at end of life cycles and the 100%

design demand. The voltage limit is 2.13 V per cell, which corresponds to a total minimum voltage output of 125.7 V per battery discussed in the FSAR, Chapter 8 (Ref. 2). The criteria for sizing large lead storage batteries are defined in IEEE-485 (Ref. 3).

Each DC electrical power source has ample power output capacity for the steady state operation of connected loads during normal operation, while at the same time maintaining its battery fully charged. Each battery charger also has sufficient capacity to restore the battery from the design minimum charge to its fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months while supplying normal steady state loads discussed in the FSAR, Chapter 8 (Ref. 2).

APPLICABLE A description cf the Safety Analyses applicable in MODES SAFETY ANALYSES 2, 3, and 4 is provided in the Bases for LCD 3.8.1, "AC Sources - Operating."

Trc. ~ rn.>n:t.S ~cxtr'i+f Cri+u-1"" ~ ,.p lo U:R ~o.~l<.)(Z.J.

LCO The DC power sources, each consisting of one battery, one directly connected battery charger and the corresponding control equipment and interconnecting cabling supplying power to the associated bus within the train are required to be OPERABLE to ensure the availability of DC control power and Preferred AC power to shut down the reactor and maintain it in a safe condition.

An OPERABLE DC electrical power source requires its battery to be OPERABLE and connected to the associated DC bus. In order for the battery to remain OPERABLE, one charger must be in service.

Palisades Nuclear Plant B 3.8.4-2 01/20/98

DC Sources - Operating B 3.7.4 and 4.7.4 BASES The batteries for the DC power sources are sized to produce required capacity at 80% of nameplate rating, corresponding to warranted capacity at end of life cycles and the 100% design demand. The voltage limit is 2.13 volts per cell, which corresponds to a total minimum voltage output of 125.7 volts per battery discussed in the FSAR, Chapter 8~(/jler{~ forGria~ large lead storag~

batteries are defined in IEEE-485,......,_ f.t

i (e.'°. n.)

Each DC electrical po~er source has ample power outpu capacity for the steady state operation of connected loads during normal operation, while at the same time maintaining its battery fully charged. Each battery charger also has sufficient capacity to restore the battery from the design minimum charge to its fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months while supplying normal steady state loads discussed in the FSAR, Chapter 8~

APPLICABLE SAFETY ANALYSES A description of the Safety Analyses applicable -~..-............,-~..,...,_is provided in the Bases for LCO 3~1 "AC Sources - Operating".

A.,,, ==c:::::::::: -rh1. tic. f'::x:IJ~s m+irfr C1rtV"<1l 3 o+ 10 CJ{ s6 .3(',. (c:i(zo..L LCO The DC power sources, each consisting of one battery, one directly connected battery charger and the corresponding control equipment and interconnecting cabling supplying power to the associated bus within the train are required to be OPERABLE to ensure the availability of DC control power and Preferred AC power to shut down the reactor and maintain it in a safe condition.

An OPERABLE DC electrical power source requires its battery to be OPERABLE and connected to the associated DC bus. In order for the battery to r ain OPERABLE, har er must be in service. fW 'let.~l.L

~,s ___cu ____,,..---

The LCO *

chargers ED-15 and ED-16 because those chargers are powered by the AC power distribution system and DG associated with the battery they supply. If only the cross connected chargers were , and a loss of off-site power should occur concurrently with the loss of one DG, both safeguards trains would eventually become disabled. One train would be disabled by the lack of AC motive power; the other would become disabled when the battery, whose only OPERABLE charger is fed by the failed OG, became depleted.

PALISADES B 3.7.4-2 Amendment No.

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3. 8. 5, DC Sources -Shutdown 3.8.5-01 JFD5 ITS SR 3.8.5.1 Bases for ITS SR 3. 8. 5. 1 STS SR 3.8.5.1 CTS 4.7.5.1 STS SR 3. 8. 5. 1 states that SRs 3. 8.4. 7 and 3. 8.4. 8 are applicable. These requirements have not been adopted in corresponding ITS SR 3. 8. 5. 1. JFD 5 states that this*

proposed difference reflects the current licensing basis/technical specifications.

Comment: The Notes to ITS SRs 3. 8.4. 7 and 3. 8.4. 8 state that the surveillances shall not be performed in Modes 1, 2, 3, or 4. These SRs are required to be performed in Modes 5 or 6. Provide the technical justification for not requiring these SRs to be applicable in Modes 5 and 6, or conform to the STS.

Consumers Energy Response:

JFD 5 has been revised to provide clarification for excluding the performance of ITS SR 3.8.4.7 and SR 3.8.4.8 in Modes 5 or 6. The discussion was extracted from the basis of CTS 4.7.5.1 which was recently approved by the NRC staff in the issuance of Amendment 180 to the Palisades Plant operating license.

Affected Submittal Pages:

JFD pg 3.8.5 pg 1 of 1 23

ATTACHMENT 6 JUSTIFICATION FOR DEVIATIONS SPECIFICATION 3.8.5, DC SOURCES - SHUTDOWN.

Cham~e Djscussiop NOTE: This attachment provides a brief discussion of the deviations from the Technical Specifications of NUREG-1432 that were made to support the development of the Palisades Nuclear Plant ITS. For Section 3. 8 ONLY, three additional attachment have been provided. Attachment 7 is a markup of the CTS Bases showing the difference between CTS and proposed ITS Bases. Attachment 8 provides an explanation of these differences. Attachment 9 provides a markup of NUREG-1432, Section 3.8 Bases.

The Change Numbers correspond to the respective deviation shown on the "NUREG MARKUPS." The first five justifications were used generically throughout the markup of the NUREG. Nor all generic justifications are used in each Specification.

1. The brackets have been removed and the proper plant specific information or value has been provided.

2. Editorial change for clarity or for consistency with the Improved Technical Specifications (ITS) Writer's Guide.

3. The requirement/statement has been deleted since it is not applicable to this facility.

The following requirements have been renumbered, where applicable, to reflect this deletion.

4. Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect the facility specific nomenclature, number, reference, system description, or analysis description.

!?A I

5. This change reflects the current licensing basis/technical specifications.~ ~-8-. .1- o I

Palisades Nuclear Plant Page 1of1 01120/98

3.8.5. JFD 5 Only those SRs from specification 3.8.4 which can be performed without affecting the Operability or reliability of the only required DC source are specified. Since the performance of SR 3. 8 .4~ 7 and SR 3. 8 .4. 8 would cause the only required battery to be inoperable during the test, these SRs have been excluded from SR 3. 8. 5 .1.

d.3-b

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3.8.5-02 Bases Applicable Safety Analysis discussion for ITS 3. 8. 5, CTS Bases markup page B 3. 7. 5-1 Bases Applicable Safety Analysis discussion for STS 3.8.4 The Bases Applicable Safety Analysis discussion for STS 3. 8. 5 includes reference to the criteria of 10 CFR 50. 36. This material has not been adopted in the Bases for corresponding ITS 3. 8. 5.

Comment: This is not a justifiable plant specific difference. Revise the Bases to conform to the STS.

Consumers Energy Response:

The Applicable Safety Analyses discussion in the Bases for ITS 3.8.5 has been revised to include the appropriate reference to 10 CFR 50.36.

Affected Submittal Pages:

ITS pg 8 3.8.5-1 CTS pg 8 3.7.5-1 24

DC Sources - Shutdown B 3.8.5 3.8 ELECTRICAL POWER SYSTEMS B 3.8.5 DC Sources - Shutdown BASES BACKGROUND A description of the DC sources is provided in the Bases for LCO 3.8.4, DC Sources - Operating."

11 APPLICABLE A description of the Safety Analyses applicable during SAFETY ANALYSES MODES 5 and 6 is provided in the Bases for LCO 3.8.2, AC 11 Sources - Shutdown." ~Al Th<. 'tx:. !Jw~ f'.Ja.-i-1S"+\./ Cr1hr~ .3 i:i+ ID C.R. SD.~ (cJ(z..'). 3.%,S*O~

LCO This LCO requires those, and only those, DC power sources which supply the DC distribution subsystems required by LCO 3.8.10, to be OPERABLE. Each DC source consists of one battery, one battery charger, and the corresponding control equipment and interconnecting cabling. This ensures the availability of sufficient DC power sources to maintain the plant in a safe manner and to mitigate the consequences of

APPLICABILITY postulated events during shutdown (e.g., fuel handling accidents and loss of shutdown cooling).

The DC power sources required to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies provide assurance that equipment and instrumentation is available to:

a. Provide coolant inventory makeup,

b. Mitigate a fuel handling accident,

c. Mitigate shutdown events that can lead to core damage, and /Al C.oid 1 ~. s-o 3

d. Monitoring and maintaining the plant in ~shutdown cond i ti on.£ or re tU<.L'" Oa6Nfiti'0t1 .

Palisades Nuclear Plant B 3.8.5-1

~LECTRICAL POWER SYSTEMS DC Sources - Shutdown B 5 -end 4. 1. 5

A:;~ alid 4.1. ! : DC Sources - Shutdown BACKGROUND ~

A description of the DC sources is provided in the Bases for LCO 3.~,

"DC Sources - Operating."

~**~: 'i:" "-::~

APPLICABLE SAFETY ANALYSES A description of the Safety Analyses applicable during : B -:fBB*=:

REl"tJELHl6 Sllt:JTBSWN is provided in the Bases for LCO 3)_...f. "AC Sources -

Shutdown". . \!1 £A.I

~t, tl.. rJb£.fW J)Q,~1S{) CA;{v1011 3 o.f 16 c:f?( So.3' (c.)(2.)' ) .s-.s LCO

. ~. 8 This LCO requires those, and only those, DC power sources which supply the DC distribution subsystems required by LCO 3 . . 10, to be OPERABLE. Each DC source consists of one battery, one battery charger, and the corresponding control equipment and interconnecting cabling. This ensures the availability of sufficient DC power sources to maintain the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents and loss of shutdown cooling).

APPLICABILITY r::: ~ = ~

The DC power sources required to be OPERABLE in ~~~7rnfuw~1Fll~C S-flt:JTeaw1t;-and during movement of irradiated fuel assemblies provide assurance that equipment and instrumentation is available to:

a. Provide coolant inventory makeup,

b. Mitigate a fuel handling accident,

c. Mitigate shutdown events that can lead to core

d. Monitoring and maintaining the plant in;.,Qbg SlollJTQQ\lN conditio",,t. or f'C.WinU C6t.d~tl41\t PALISADES B 3.7.5-1 Amendment No.

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3.8.5-03 JFD2 Bases Applicability for ITS 3.8.5, CTS Bases markup page B 3. 7.5-1 Bases Applicability for STS 3.8.5 The Bases Applicability for STS 3.8.5 refers to monitoring and maintaining the plant in a cold shutdown or refueling condition. The Bases Applicability for ITS 3. 8. 5 refers to monitoring and maintaining the plant in a shutdown condition. JFD 2 states that differences have been made for clarity, grammatical preference, or to establish consistency within the Improved Technical Specifications.

Comment: This is not a justifiable plant specific difference. Revise the submittal to conform to the STS.

Consumers Energy Response:

The terminology used to describe the plant condition in item "d" of the ITS Applicability has been revised to conform with the terminology used in the ISTS. Conforming changes have also been made to CTS Bases markup page B 3.7.5-1.

Affected Submittal Pages:

ITS pg B 3.8.5-1 CTS pg B 3.7.5-1 25

DC Sources - Shutdown B 3.8.5 3.8 ELECTRICAL POWER SYSTEMS B 3.8.5 DC Sources - Shutdown BASES BACKGROUND A description of the DC sources is provided in the Bases for LCO 3.8.4, "DC Sources - Operating."

APPLICABLE A description of the Safety Analyses applicable during SAFETY ANALYSES MODES 5 and 6 is provided in the Bases for LCO 3.8.2, "AC Sources - Shutdown. A'.-1 I Th< t:c. Dwrw 8a.*hs{\/ (}-,fu.1zJ1 .3 ci+ ID C.R SC>.~ (cJCz..'). 3.%.S*o~

- LCO This LCO requires those, and only those, DC power sources which supply the DC distribution subsystems required by LCO 3.~.10, to be OPERABLE. Each DC source consists of one battery, one battery charger, and the corresponding control equipment and interconnecting cabling. This ensures the availability of sufficient DC power sources to maintain the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents and loss of shutdown cooling).

APPL! CAB I LI TY The DC power sources required to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies provide assurance that equipment and instrumentation is available to:

a. Provide coolant inventory makeup,

b. Mitigate a fuel handling accident,

c. Mitigate shutdown events that can lead to core damage, and C..dd

d. Monitoring and maintaining the plant in a,...shutdown condition.£ or re. tU<.L'" O c6 nd'*hon .

Palisades Nuclear Plant B 3.8.5-1

DC Sources - Shutdown B ~5 ;rnd 4.7.5 ELECTRICAL POWER SYSTEMS B 3 .'H_ attd 4. 1. !!; DC Sources - Shutdown BASE~ -_

BACKGROUND (':i)

A description of the DC sources is provided in the Bases for LCO 3.~,

"DC Sources - Operating."

APPLICABLE SAFETY ANALYSES A description of the Safety Analyses applicable REFt:JEt!116 Slll:IT80fi!l is provided in the Bases for Shutdown.

LCO ~

This LCO requires those, and only those, DC power sources which supply the DC distribution subsyste!Tls required by LCO 3 . . 10, to be OPERABLE. Each DC source consists of one battery, one battery charger, and the corresponding control equipment and interconnecting cabling. This ensures the avai1a::i1lit; of sufficient DC power sources to maintain the plant in a safe manner ard to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents and loss of shutdown cooling).

~:SiitJTBe\llft;-and

l ~~A::~: :y during ::iovement of beirradiated fuelo~~i.$:ru sou cces cequ; cod to OPERABL [ ;

assemblies provide assurance

. ..; i,,~);

that equipment and instrumentation is available to:

a. Provide coolant inventory makeup,

b. Mitigate a fuel handling accident, c' Mitigate shutdown events that can lead to core damage,(d-..o)

d. Monitoring and maintaining the plant in ~..a--4.J'-C~~..t9~&ij>>T1-t' w..*~;lo':i_M~'~'"~~*:~~t"!2~F~;-<<i::l~*~:i-0-*--*~

SM'-+QQ!jN cond it i on,,t or r~WiliU C6t.d1tl6n. ~~~:::~ 'P'I ;_,J PALISADES B 3.7.5-1 Amendment No .

;<5-b*

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3. 8. 6, Battery Cell Parameters 3.8.6-01 Bases Applicable Safety Analysis discussion for ITS 3.8.6, CTS Bases markup page B 3. 7. 6-1 Bases Applicable Safety Analysis discussion for S TS 3. 8. 6 The Bases Applicable Safety Analysis discussion for STS 3. 8. 6 includes reference to the criteria of 10 CFR 50. 36. This material has not been adopted in the Bases Applicable Safety Analysis discussion for corresponding ITS 3. 8. 6.

Comment: This is not a justifiable plant specific difference. Revise the Bases to confonn to the STS.

Consumers Energy Response:

The Applicable Safety Analyses discussion in the Bases for ITS 3.8.6 has been revised to include the appropriate reference to 10 CFR 50.36.

Affected Submittal Pages:

ITS pg B 3.8.6-1 CTS pg B 3.7.6-1 26

Battery Cell Parameters B 3.8.6

3.8 ELECTRICAL POWER SYSTEMS B 3.8.6 Battery Cell Parameters BASES BACKGROUND This LCO delineates the limits on electrolyte temperature, level, float voltage, and specific gravity for the DC power source batteries. A discussion of these batteries is provided in the Bases for LCO 3.8.4, "DC Sources -

Operating."

APPLICABLE A description of the Safety Analyses applicable for SAFETY ANALYSES MODES 1, 2, 3, and*4 is provided in the Bases for LCO 3.8.1, "AC Sources - Operating"; during MODES 5 and 6, in the Bases ~A~, 0

for LCO 3.8.2, "AC Sources - Shutdown." ~*o*** 1 P.:n:tki"f ~ll. P"-~-hl'.! l'Jd1s-t1 ~1t<A-1~111 ) 0 {? /() C..FR. SOJ(,,Cc)Cz}. X LCO Battery cell parameters must remain within acceptable limits to ensure availability of the required DC power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated OBA.

Battery cell limits are conservatively established, allowing continued DC electrical system function even when Category A and B limits are not met.

The requirement to maintain the average temperature of representative cells above 70°F assures that the battery temperature is within the design band. Battery capacity is a function of battery temperature.

APPLICABILITY The battery cell parameters are required solely for the support of the associated DC power sources. Therefore, they are only required when the DC power source is required to be OPERABLE. Refer to the Applicability discussions in the Bases for LCO 3.8.4 and LCO 3.8.5, "DC Sources - Shutdown."

Palisades Nuclear Plant B 3.8.6-1 01/20/98

Battery Cell Para~eters

ELECTRICAL POWER SYSTEMS B 3.7.6 a"d BASES

~.7.~: Battery Cell Parameters B 3©6 a11d 4. 7 . &

BACKGROUND This LCO delineates the limits on electrolyte temperature, level, float voltage, and specific gravity for the DC power source batteries. A discussion of these batteries is provided in the Bases for LCO @4, "DC Sources -

Operating".

APPLICABLE SAFETY ANALYSES fol' MOOE' S I, 2, 5, a 11'\.d ~

&:d+*'"'f lt.LL e(i.{'c.f>lc.tt.rr ,Qo.f1ft)" .~ .. r.;.. ~ o.;. lb Cf.,,_ So.3' (c)Cz.").

LCO Battery cell parameters must remain within acceptable limits to ensure availability of the required DC power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated OBA. Battery cell limits are conservatively established, allowing continued DC electrical system function even when Category A and B limits are not met.

The requirement to maintain the average temperature of representative cells above 70'F assures that the battery temperature is within the design band.

Battery capacity is a function of battery temperature.

APPLICABILITY PALISADES B 3.7.6-1 Amendment No .

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3. 8. 7, Inverters - Operating 3.8. 7-01 Bases Applicable Safety Analysis discussion for ITS 3. 8. 7, CTS Bases markup page B 3. 7. 7-1 Bases Applicable Safety Analysis discussion for STS 3. 8. 7 The Bases Applicable Safety Analysis discussion for STS 3. 8. 7 includes reference to the criteria of 10 CFR 50. 36. This material has not been adopted in the Bases for con-esponding ITS 3. 8. 7.

Comment: This is not a justifiable plant specific difference. Revise the Bases to conform to the STS.

Consumers Energy Response:

The Applicable Safety Analyses discussion in the Bases for ITS 3.8.7 has been revised to include the appropriate reference to 10 CFR 50.36.

Affected Submittal Pages:

ITS pg B 3.8.7-1 CTS pg B 3.7.7-1 27

Inverters - Operating B 3.8.7 3.8 ELECTRICAL POWER SYSTEMS B 3.8.7 Inverters - Operating BASES BACKGROUND The inverters (ED-06, ED-07, ED-08, and ED-09) are the normal source of power for the Preferred AC buses. The function of the inverter is to provide continuous AC electrical power to the Preferred AC buses, even in the event of an interruption to the normal AC power distribution system. A Preferred AC bus can be powered from the AC power distribution system via the Bypass Regulator if its associated inverter is out of service. An interlock prevents supplying more than one Preferred AC bus from the bypass regulator at any time. The station battery provides an uninterruptable power source for the instrumentation and controls for the Reactor Protective System (RPS) and the Engineered Safety Features (ESF).

APPLICABLE A description of the Safety Analyses applicable in SAFETY ANALYSES MODES l, 2, 3, and 4 is provided in the Bases for LCO 3.8.l, 11 AC Sources - Operating. 11

.t.N\JU""\vs o.r< fat'+ of the. d1Str-1~"flor. SVJ+../"I"\ a.rr:J, 0..0 ~(.)<:.Ji 1 .()q,f,fy Cr1-l*r1"1 .3 o.f. 10 Cr:I. so.3~{c..Yz.),

LCO The inverters ensure the availability of Preferred AC power for the instrumentation required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated OBA.

Maintaining the inverters OPERABLE ensures that the redundancy incorporated into the RPS and ESF instrumentation and controls is maintained. The four inverters ensure an uninterruptable supply of AC electrical power to the Preferred AC buses even if the 2400 V safety related buses are de-energized.

An inverter is considered inoperable if it is not powering the associated Preferred AC bus, or if its output voltage or frequency is not within tolerances *

Palisades Nuclear Plant B .8.7-1 01/20/98

8© Inverters - Operating iiiR9 4 1 7 J ELECTRICAL POWER SYSTEMS B 3 *~ a~e 4. 7. 7-: Inverters - Operating

~ -_

BASE BACKGROUND (~o-o~, ~O-oi, eO*ot, ci""-'* Eo-oq)

The inverters~e the normal source of power for the Preferred AC buses. The function of the inverter is to provide continuous AC electrical power to the Preferred AC buses, even in the event of an interruption to the normal AC power distribution system. A Preferred AC bus can be powered from the ~C power distribution system via the Bypass Regulator if its associated ln~erter is out of service. An Interlock prevents supplying more than one Preferred AC bus from the bypass regulator at any time. The station battery provides an uninterruptable power source for the Instrumentation and controls for the Reactor Protective System (RPS) and the Engineered Safety Features (ESF).

APPLICABLE SAFETY ANALYSES A description of the Safety Analyses appl i cable~~~~""""'~~~;.,..

provided in the Bases for LCO 3.l.l "AC Sources - Operating".

1.- f41

"'=--[ !iiV<-l't.. rf a.re. c.. Pei.rt o~ ti\<. d1JH'16ul74'I /)ljotc.,,.,. q,td, G..o /J(.A,;..., 3 *~ 7ro I LCO !)ati1*~y Cri+tr,6;, ~ o+ 16 Ch(. so.J6C-c)Cz..).t. 't . f i I The inverters ensure the availability of Preferred AC power for the instrumentation required to shut down the reactor and main ain i in a sa e /

condition after an anticipated operational occurrence or a postulated OBA Maintaining the inverters OPERABLE ensures that the redundancy into the RPS and ESF instrumentation and controls is maintained. The four incorporat~d Ii inverters ensure an uninterruptable supply of AC electrical power to the ,

Preferred AC buses even if the 2400 volt safety related buses are I de-energized.

An inverter is considered inoperable if it is not powering the associated I Preferred AC bus, or if its output voltage or frequency is not within tolerances.

I PALISADES B 3.7.7-1 Amendment No .

a7-b

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3.8. 7-02 Bases for ITS SR 3.8. 7.1, CTS Bases markup page B 3. 7. 7-3 The first sentence of the Bases for ITS SR 3. 8. 7. 1 states, This Surveillance verifies that the inverters are functioning properly and Preferred AC buses energized from the inverter."

Comment: This sentence is very awkward. Revise utilizing parallel structure.

Consumers Energy Response:

The first sentence of the Bases for ITS SR 3.8. 7.1 has been revised to enhance its readability. A conforming change has also been made to CTS Bases markup page B 3.7.7-3.

Affected Submittal Pages:

ITS pg B 3.8.7-3 CTS pg B 3.7.7-3 28

Inverters - Operating B 3.8.7

BASES SURVEILLANCE SR -- 3. 8. 7. 1 e~1"b1n°'a -th~

REQUIREMENTS This Surveillance verifi~_)that the inverters are functioning properly and~eferred AC buses,e 0 ir~ized f1 e~

~~e iA¥eFti~. The verification of proper voltage and frequency output ensures that the required power is readily available for the instrumentation of the RPS and ESF connected to the Preferred AC buses. The 7 day Frequency takes into account indications available in the control room that alert the operator to inverter malfunctions.

REFERENCES None

Palisades Nuclear Plant B 3.8.7-3 01/20/98

Inverters - Operating B 3.7.7 and 4.7.7 BASES

~Al.

SU~CE REQUIREMENTS 1.a.1.oi....

3.a 0 SR . . 7 .1 (Inverter checks) ef'l!rr~J1frJ(,, -the 1 This Surveillance verifies that the inverters are functioning pr~erly and i?

Preferred AC buses eAer~ized F1 om Hie i11oer L!1. The verification of proper voltage and frequency output ensures that the required power is readily x available for the instrumentation of the RPS and ESF connected to the Preferred AC buses. The 7 day Frequency takes into account indications available in the control room that alert the operator to inverter malfunctions.

REFERENCES None PALISADES B 3.7.7-3 Amendment No.

d.8-b

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS

RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION NRC REQUEST:

RESPONSE TO NRC QUESTIONS

3. 8. 8, Inverters - Shutdown 3.8.8-01 Bases Applicable Safety Analysis discussion for ITS 3. 8. 8, CTS Bases markup page B 3. 7. 8-1 Bases Applicable Safety Analysis discussion for STS 3. 8. 8 The Bases Applicable Safety Analysis discussion for STS 3. 8. 8 includes reference to the criteria of 10 CFR 50. 36. This material has not been adopted in the Bases for corresponding ITS 3. 8. 8.

Comment: This is not a justifiable plant specific difference. Revise the Bases to conform to the STS.

Consumers Energy Response:

The Applicable Safety Analyses discussion in the Bases for ITS 3.8.8 has been revised to include the appropriate reference to 10 CFR 50.36.

Affected Submittal Paqes:

ITS pg 8 3.8.8-1 CTS pg 8 3.7.8-1 29

Inverters - Shutdown B 3.8.8 3.8 ELECTRICAL POWER SYSTEMS B 3.8.8 Inverters - Shutdown BASES BACKGROUND A description of the inverters is provided in the Bases for LCO 3.8.7, "Inverters - Operating. 11 APPLICABLE A description of the Safety Analyses applicable during SAFETY ANALYSES MODES 5 and 6 is provided in the Bases for LCO 3.8.2, 11 AC Sources - Shutdown. 11

!/il)(.r+<.rr <>r* PG:r-t of. th<.dt<sil'~vf-1111 P~~'fc."' a...J, ~ 011<.ff, ~c;.hsf/ C<.i+v11,., j O..f ;O Cff~ ~o ~&<<.n ).

LCO This LCO re)(i:_i res those, and only those, inverters necessary to support,.~Preferred AC buses required by LCO 3.8.10,

-,'Distribution Systems - Shutdown, to be OPERABLE. 11 This ensures the availability of sufficient Preferred AC electrical power to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents and loss of shutdown cool. i ng).

is not powering voltage or APPLICABILITY The inverters required to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies provide assurance that equipment and instrumentation is avai1able to:

a. Provide coolant inventory makeup,

b. Mitigate a fuel handling accident,

c. Mitigate shutdown events that can lead to core damage, ~J and J. r,1-a2-to/J

d. Monitoring and maintaining the plant in aAshutdown J conditiOnJ2 or rt~*i?o Cl~ifH/\. "

Palisades Nuclear Plant B 3.8.8-1 01/20/98

Inverters - Shutdown B ~B ' ' ' 4.7.8 ELECTRICAL POWER SYSTEMS B 3~8 aAe! 4. 7. 8: Inverters - Shutdown

~ -

BASE -

BACKGROUND (';'/

A description of the inverters is provided in the Bases for LCO 3~,

"Inverters - Operating".

APPLICABLE SAFETY ANALYSES ~: ~~

A description of the Safety Analyses applicable during

~H't:JEtfftt! Slil:IT881111 is provided in the Bases for LCO 32 "AC Sources -

~=~~ fr/

Shutdown". g 3.~J-.-0

!.r-vc.l'hrS o.r .. Pa."-t o +f).,... d l~f* '"'t'6" Spt<.m Q. nd, Q-4 g cJG / (Jo:fwt't (t_, tv 1 , " .J cf 1o c r-;.. so. 3i. cc)cc..), Y..

LCO This LCO requires those, and only those, inverters necessary to support to Preferred AC buses required by LCO 3~0, to be OPERABLE.

This ensures the availability of suftfcient Preferred AC electrical power to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents and loss of shutdown cooling).

An inverter is considered inoperable if it is not powering the associated Preferred AC bus, or it its voltage or frequency is not within tolerances.

~::L::::~~::: required t o be OPERABLE in mg 1 MEiri: 1 ~!~ ?1~11, .. ,

and during movement of irradiated fuel assemblies provide assurance that ~*

equipment and instrumentation is avail.able to:

a. Provide cool ant inventory makeup, L<:.a.v<- o. J t

b. Mitigate a fuel handling accident, ~ VfJe.. ,R"~c.ru~""

c. Mitigate shutdown events that can lead to core damage~ .Zit~~

d. Monitoring and maintaining the plant in a cote SlltHeewN cond i ti.on.

Slll1H/;; ~;;-~ ~I l - -:= -=-:=:!>" /~n l!

3.(:~ 02-PALISADES B 3.7.8-1 Amendment No .

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS

RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION NRC REQUEST:

RESPONSE TO NRC QUESTIONS 3.8.08-02 JFD 2 Bases Applicability for ITS 3. 8. 8, CTS Bases markup page B 3. 7. 8-1 Bases Applicability for STS 3. 8. 8 The Bases Applicability for STS 3. 8. 8 refers to monitoring and maintaining the plant in a cold shutdown or refueling condition. The Bases Applicability for ITS 3. 8. 8 refers to monitoring and maintaining the plant in a shutdown condition. JFD 2 states that differences have been made for clarity, grammatical preference, or to establish consistency within the Improved Technical Specifications Comment: This is not a justifiable plant specific difference. Revise the submittal to conform to the STS.

Consumers Energy Response:

The terminology used to describe the plant condition in item "d" of the ITS Applicability has been revised to conform with the terminology used in the ISTS. Conforming changes have also been made to CTS Bases markup page B 3.7.8-1.

Affected Submittal Pages:

ITS pg B 3.8.8-1 CTS pg B 3.7.8-1 30

Inverters - Shutdown B 3.8.8 3.8 ELECTRICAL POWER SYSTEMS B 3.8.8 Inverters - Shutdown BASES BACKGROUND A description of the inverters is provided in the Bases for LCO 3.8.7, "Inverters - Operating."

APPLICABLE A description of the Safety Analyses applicable during SAFETY ANALYSES MODES 5 and 6 is provided in the Bases for LCO 3.8.2, "AC Sources - Shutdown."

!;ivc.r;...rr <>r* PGl't of tN.. d1s-trllur111"1 p'1o~"' a.r.d, 0--0 Ov<.H, /Jq_ f-is~/ IJ.,t1..r,,,. j o~ ,o Gff~ .;o ~6(('C2,).

LCO This LCO re,9_i:_ires those, and only those. inverters necessary to suppor;~Preferred AC buses required by LCO 3.8.10, 11 Distribution Systems - Shutdown," to be OPERABLE.

This ensures the availability of sufficient Preferred AC electrical power to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents and loss of shutaown cooling).

An inverter is considered i noperab . ~ ~ i is not powering the as soc i ated Pref erred AC bus, r r it voltage or f\

frequency is not within tolerance . l~

APPLICABILITY The inverters required to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies provide assurance that equipment and instrumentation is avaiiable to:

a. Provide coolant inventory makeup,

b. Mitigate a fuel handling accident,

c. Mitigate shutdown events that can lead to core damage, /fi/

and J. t .;-o~

to/d

d. Monitoring and maintaining the plant in aAshutdown condition~ or re,~,;, c,~1f16f\.

0 '/..

Palisades Nuclear Plant B 3.8.8-1 01/20/98 3D-o..-

Inverters - Shutdown B ~8 ' ' ' 4.7.8 ELECTRICAL POWER SYSTEMS B 3~ at\\~I 4.~.8: Inverters - Shutdown BAsW -

BACKGROUND (";!)

A description of the inverters is provided in the Bases for LCO 3~,

"Inverters - Operating".

p:~:::~~:;::F~Yt::A~::::y REfit;ELir~ Slll::JT80\YN Analyses applicable during ~:::"~

is provided in the Bases for LCO 3;--~2 "AC Sources -

Shutdown".

l!J RPil 3 8'- 0 1 1nu~'4ctS a.r1. ~,., o~ ft!" d 'Ltti'lhlltl~n D J'l.:.ir. a.,J O.O O , ' 1 1 r 3 6 10 C~~ .SOJ' ( 2

LCO "D:s+-r*, \, ...~;-.. S"vchv.1.s - 5\.11..k.lo<-' "..1" This LCO requires those, and only those, inverters necessary to support to Preferred AC buses required by LCO 3~0, to be OPERABLE.

This ensures the availability of suf~ent Preferred AC electrical power to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents and loss of shutdown cooling).

An inverter is considered inoperable if it is not powering the associated Preferred AC bus, or it its voltage or frequency is not within tolerances.

~::L:::::~::: requ; red to be oPERABL E;n *ObQ ,Qifar,:,iii., ?1~11, and during movement of irradiated fuel assemblies provide assurance that equipment and instrumentation is available to:

a. Provide coolant inventory makeup,

b. Mitigate a fuel handling accident,

c. Mitigate shutdown events that can lead to core dama~e f~vJ.j

d. Monitoring and maintaining the plant in avtULD SHOT o?UIAorJf(FUEL~

Sllt!TB0'11H condition. ~~~()

PALISADES B 3.7.8-1 Amendment No .

3o-b

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3. 8. 9, Distribution Systems - Operating 3.8.9-01 JFD5 ITS 3.8.9 Condition A STS 3. 8. 9 Condition A CTS 3. 7.9 Action A Bases for ITS 3.8.9 Required Action A.1, CTS Bases markup page B

3. 7.9-3 Bases for STS 3. 8. 9 Required Action A. 1 STS 3.8.9 Condition A addresses one AC electrical power distribution subsystem inoperable. Condition A of corresponding ITS 3.8.9 addresses one or more AC electrical power distribution subsystems inoperable. JFD 5 states that this proposed difference reflects the current licensing basis/technical specifications. CTS 3. 7.9 Action A addresses one or more subsystems of one AC electrical power distribution train inoperable.

Comment: The Bases for ITS 3. 8. 9 Required Action A. 1 clearly explains the intent of ITS 3. 8. 9 Condition A, and is consistent with the Bases for corresponding STS 3. 8. 9 Required Action A. 1. The proposed change is not a justifiable plant specific difference.

Revise the submittal to conform to the STS.

Consumers Energy Response:

ITS 3.8.9 Condition A has been revised to state "one or more AC electrical power distribution subsystems in one train inoperable" consistent with CTS 3.7.9.A.

Affected Submittal Pages:

ITS pg 3.8.9-1 NUREG pg 3.8-39 31

Distribution Systems - Operating 3.8.9

3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 Left Train and Right Train AC, DC, and Preferred AC bus electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACT ION COMPLETION TIME

/~l,... ,.

A. One or more AC A.1 Restore AC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months j o ** -'I

.\.I electrical power power distribution distribution subsystem(s) to 8lill subsystems inoperable. OPERABLE status.

I\ 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from on~ f1n.;"

' ri discovery of failure to meet LCO B. One ~Preferred B.l Restore Preferred AC 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months AC bu inoperable. bus~ to OPERABLE status. 8lill 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO

c. One or more C.l Restore DC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months DC electrical power power distribution distribution subsystem(s) to 8NQ subsystems inoperable. OPERABLE status.

A 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from In OF"\t. i'ftl.1 "i discovery of failure to meet LCO

Palisades Nuclear Plant 3.8.9-1 Amendment No. 01/20/98 31-~

Distribution Systems-Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems-Operating

--@ aGim ~~

LCO 3.8.9 "-Train X and~ AC, DC, and AC:it.!Ubus electrical power distribution subsystems shall be OPERABLE.

c.i)

3. 7,'f APPLICABILITY: MODES 11 2, 3, and 4.

ACTIONS COHO IT ION REQUIRED ACTION COMPLETION TIME One AC electrical A. l Restore AC electrical a hours power distribution power distribution subsyst~erable. subsyste~PERABLE status. ~

I ri one. frb.1i\ 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO

Restore C ~

9--J~bl)Ste?I to OPERABLE status.

'i

@hours AHQ 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO O't" ('y'W'V.(...

. One DIC tlectr1c1l c.1 Restore DC electrical power d1str1but1on power distribution subsyst~~operable. subsyste~ OPERABLE status. ~

16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from 1n one. ~1" discovery of failure to meet LCO (continued)

CEOG STS 3.8-39 Rev l, 04/07/95

~1-b

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3.8.9-02 JFD5 ITS 3. 8. 9 Condition B STS 3. 8. 9 Condition B CTS 3. 7.9 Action B STS 3. 8. 9 Condition B addresses one AC vital bus inoperable. Condition B of con-esponding ITS 3. 8. 9 addresses one or more Prefen-ed AC buses inoperable.

JFD 5 states that this proposed difference reflects the cu"ent licensing basis/technical specifications. CTS 3. 7.9 Action B addresses one Prefen-ed AC bus inoperable.

Comment: The proposed difference seems not to reflect the cun-ent licensing basis/technical specifications. This is not a justifiable plant specific difference. Revise the submittal to conform to the STS.

Consumers Energy Response:

ITS 3.8.9 Condition B has been revised to state "one Preferred AC bus inoperable" consistent with CTS 3.7.9.B.

Affected Submittal Pages:

ITS pg 3.8.9-1 NUREG pg 3.8-39 32

Distribution Systems - Operating 3.8.9

3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 Left Train and Right Train AC, DC, and Preferred AC bus electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC A.1 Restore AC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months electrical power power distribution distribution subsystem(s) to ANQ subsystems inoperable. OPERABLE status.

'\ 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from If"\ <YI~ fro._;I'\ discovery of fa i l ure to meet LCO B. One ~Preferred B.1 Restore Preferred AC 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months AC bu inoperable. bus~ to OPERABLE status. ANQ 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO

c. One or more C.l Restore DC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months DC electrical power power distribution distribution subsystem(s) to ANQ subsystems inoperable. OPERABLE status.

.16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from I I'") Or'\t. 1!'0.1 l"j discovery of failure to meet LCO

-* Palisades Nuclear Plant 3.8.9-1 Amendment No. 01/20/98

Di stri but ion Sys tems-Operat; ng

3.8 3.8.9 ELECTRICAL

&0 PO~ER SYSTEMS Ofstribut1on Systems-Operating

~ ~~

3.8.9 LCO 3.8.9 .(,Train X and~AC, DC. and ACTit.l>"bus electrical po~er distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACT TONS CONDITION REQUIRED ACTION COMP LET !CN T:.~E Ont~AC electrical A.1 Restore AC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months powor d1str1but1on power distribution subsyst~erable. subsyste~PERABLE status. ~

If'\ otic. fn;a1f\ 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from d1scovery of failure to meet LCO

) <i Restore C ~ ~-"V"I@ hours r Nbsyste11 to OPERABLE j status. ~

16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months fro111 discovery of failure to meet

../ -

LCO crs OM IX tlectr1ul c.1 Restore DC electricil ours power d1str1~t1on power distribution 3,7, q,r_ subsyst~)operablt. subsyste~ OPERABLE status. ~

16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from 1n O('.(. -fr'a.1" discovery of failure to meet LCO (continued)

CEOG STS 3.8-39 Rev 1, 04/07/95

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3.8.9-03 JFD5 ITS 3.8.9 Condition C STS 3.8.9 Condition C CTS 3. 7. 9 Action C STS 3.8.9 Condition C addresses one DC electrical power distribution subsystem inoperable. Condition C of corresponding ITS 3. 8. 9 addresses one or more DC electrical power distribution subsystems inoperable. JFD 5 states that this proposed difference reflects the current licensing basis/technical specifications. CTS 3. 7.9 Action C addresses one or more subsystems of one DC electrical power distribution train inoperable.

Comment: This is not a justifiable plant specific difference. Revise the submittal to confonn to the STS.

Consumers Energy Response:

ITS 3.8.9 Condition Chas been revised to state "one or more DC electrical power distribution subsystems in one train inoperable" consistent with CTS 3.7.9.C.

Affected Submittal Pages:

ITS pg 3.8.9-1 NUREG pg 3.8-39 33

Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 Left Train and Right Train AC, DC, and Preferred AC bus electrical power distribution subsystems shall be OPERABLE.

APP LI CAB IL !TY: MODES l, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC A. 1 Restore AC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months electrical power power distribution distribution subsystem(s) to AliQ subsystems inoperable. OPERABLE status.

I\ 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from I l"I ()/'\ ~ fn:i_ ;" discovery of failure to meet LCO B. One~ Preferred B.l Restore Preferred AC 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months AC bu inoperable. bus~ to OPERABLE status. AliQ 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO

c. One or more C.l Restore DC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months DC electrical power power distribution distribution subsystem(s) to 8lil2 subsystems inoperable. OPERABLE status.

/\ 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from I('\ 01"\t. irt:i.11') discovery of failure to meet LCO

Palisades Nuclear Plant 3.8.9-1 Amendment No. 01/20/98 33-a...

Distribution Systems-Operating 3.8.9

3.8 ELECTRICAL POWER SYSTEMS 3.8.9 01stribut1on Systems-Operating li;efj) ~ ~~

LCO 3.8.9 .(.Train X and~AC, DC, and~;+:t;\;s electricil power distribution subsystems Shill be OPERABLE.

c:tS

3. 7,'f APPLICABILITY: MODES l, 2, 3, ind 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETrON TIME Ont~AC electricil A.l Restore AC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months r\Ai po~tr distribution power distribution Ji.<;.~

subsyst~erable. subsyste~PERABLE AtiQ status. (.S:)

I !'\ C>M ff't11 °r\ 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months fro111 X' discovery of.

h 11 ure to meet

.. LCO f td

<i' '1 / r-. '.

Restore c~ @hours j to OPERABLE AtiQ 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months fro111 discovery of hilure to meet LCO

"""~~ /?, rl I

~rs One DIC tlectr1c&l c. l Restore DC electricil ours po .. r d1str1~tion power distribution ~6 9-oj 3,7, q,e,.. subsyst~noperiblt. subsyste~ OPERABLE ANO s~ status. )

16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from 1n one 1fr:i1" discovery of K

failure to meet LCO (continued)

CEOG STS 3.8*39 Rev l, 04/07/95 33-b

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS

RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION NRC REQUEST:

RESPONSE TO NRC QUESTIONS 3.8.9-04 Bases for ITS 3.8.9 Required Action C.1, CTS Bases markup page B 3.7.9-4 Bases for ITS 3.8.9 Required Action C.1, STS Bases markup page B 3.7.9-7 The Bases for ITS 3. 8. 9 Required Action C. 1 refers to a DC bus in one train inoperable.

The Bases for ITS 3.8.9 Required Action C.1, STS Bases markup page B 3. 7.9-7 refers to a DC bus or buses in one train inoperable.

Comment: Revise the submittal to resolve this discrepancy.

Consumers Energy Response:

The Bases for ITS 3.8.9 Condition Chas been revised to state "with one or more DC buses in one train inoperable." This change corrects the discrepancy between the technical specification and the Bases.

Affected Submittal Pages:

ITS pg B 3.8.9-5 CTS pg B 3.7.9-4 34

Distribution Systems - Operating B 3.8.9

BASES ACTIONS (continued)

Ll O'le. or /7lOf1!.

With@' DC busi:lin one train inoperable, the remaining DC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is ~educed, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF functions not being supported. Therefore, the required DC buses must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months by powering the bus from the associated battery or charger.

This 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months limit is more conservative than Completion Times allowed for the vast majority of components which would be without power and is a feature of the original Palisades licensing basis.

The second Completion Time for Required Action C.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single continuous occurrence of failing to meet the LCO. If Condition C is entered while, for instance, an AC bus is inoperable and subsequently restored OPERABLE, the LCO may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This could lead to a total of 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months , since initial failure of the LCO, to restore the Preferred DC distribution system. At this time, a AC bus could again become inoperable, and Preferred AC distribution restored OPERABLE. This could continue indefinitely.

The Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

This will result in establishing the "time zero" at the time the LCO was initially not met, instead of the time Condition C was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely *

Palisades Nuclear Plant B 3.8.9-5 01/20/98

Distribution Systems - - Operating 8 3.7.9 and 4.7.9 BASES An

operable DC distribution subsys m can cause engineered safety ure s e inoperable. !f a redundant s fety feature in the other train ncurrently inoperable, a loss cf safety function could occur. Ac*.oN c. l equires compliance with Conditi . . 3.7.9.E to assure that the plar utdcwn if a safet* f~nction i lost.

,<ff j Q)~.

~ '6--"'V ;

With@~ ~u~or;-one train inoperable, the remaining DC electrical power x.

distribution subsyste~s are capable of supporting the minimum safety f~n:tion$

necessary to shut dc~n the reactor and ~aintain it in a safe shutdown condition, assuming no single failure. The overall reliability is re*j*~cec, however, because a sir;le failure in the remaining DC electrical power distribution subsyste~ could result in the minimum required ESF functions not being su~ported. Therefore, the required DC buses must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months by powering the bus from the associated battery or charger.

This 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months limit is more conservative than Completion Times allowed for the*

the original Palisades licensing :rasis. --fit-JS"C?Z---T I vast majority of components which would be without power and is a feature of

~Q.l and 0.2 If the inoperable distribution status Condition de radation in the electrical distribution system (?A I tha causes a requ~r2c '1 ;.

J -

1-.:"

safety fonction to be lost. Condition 1s enterej, and this results in the loss of a required function, e plant is in a cc~c1t1cn outside the acci~ent analysis. Therefore, no additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

PALISADES B 3.7.9-4 Amendment No

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3.8.9-05 Bases Applicability for ITS 3.8.9, CTS Bases markup page B 3. 7. 9-2 The Bases Applicability for ITS 3.8.9 states, "The AC source requirements for Modes 5 and 6 are addressed in LCO 3.8.2, AC Sources -Shutdown."

Comment: This statement seems out of context with the remainder of the Applicability discussion because these Bases address distribution systems and not AC sources.

Revise the submittal to remove this statement from the Bases.

Consumers Energy Response:

The Applicability for ITS 3.8.9 has been revised to delete the statement "the AC source requirement for Modes 5 and 6 are addressed in LCO 3.8.2, AC Sources - Shutdown.".

Affected Submittal Pages:

ITS pg B 3.8.9-3 CTS pg B 3.7.9-2 35

Distribution Systems - Operating B 3.8.9

BASES APPL! CAB IL !TY The_electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that AC, DC, and Preferred AC power is available to the redundant trains and channels of safeguards equipment 1 instrumentation and controls required to support engineered safeguards equipment in the event of an accident or transient.

Electrical power distribution subsystem requirements for MODES 5 and 6, and during movement of irradiated fuel assemblies are addressed in LCO 3.8.10, Distribution 11 Systems - Shutdown."

ACTIONS With one or more required AC buses, load centers, motor control centers, or distribution panels, except Preferred AC buses, in one train inoperable, the redundant AC electrical power distribution subsystem in the other train is capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because an additional failure in the power distribution systems could result in the minimum required ESF functions not being supported.

Therefore, the required AC buses, load centers, motor control centers, and distribution panels must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The second Completion Time for Required Action A.l establishes a limit on the maximum time allowed for any combinations of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition A is entered while, for instance, a DC bus is inoperable and subsequently restored OPERABLE, the LCO may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This could lead to a total of 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months , since initial failure of the LCO, to restore the AC distribution system. At this time, a DC circuit could again become inoperable, and AC distribution restored OPERABLE.

This could continue indefinitely *

Palisades Nuclear Plant B 3.8.9*3 01/20/98

Distribution Systems - ~rating B ~9 ,,; <.7.~

BASES Maintaining both trains of AC, DC, and Preferred AC bus electrical power distribution subsystems OPERABLE ensures that the redundancy incorporated into the plant design is not defeated. Therefore, a single failure within any electrical power distribution subsystem will not prevent safe shutdown of the reactor.

OPERABLE electrical power distribution subsystems require the buses, load motor control centers, and distribution panels listed in

.9-1 to be energized to their proper voltages. In addition, tie breakers between redundant safety related AC power distribution subsystems must be open when a 2400 volt source is OPERABLE for each train. This prevents any electrical malfunction in any power distribution subsystem from propagating to the redundant subsystem. If any tie breakers are closed, the affected redundant electrical power distribution subsystems are considered inoperable. This applies to the onsite, safety related redundant electrical power distribution subsystems. It does not, however, preclude redundant Class lE 2400 volt buses from being powered from the same offsite circuit or preclude cross connecting Class IE 480 volt subsystems when 2400 volt power is available for only one train.

This LCO does not address the power source for the Preferred AC buses. The Preferred AC buses are normally powered from the associated inverter. An alternate source, the Bypass Regulator, is available to supply one Preferred

bus at a time, to allow maintenance on an inverter. The proper alignment of the inverter output breakers is addres ed u er the inverter LCOs. Therefore a Preferred AC Bus may be considered operable when powered from either the associated inverter or the Bypass Regu a as long as the voltage and frequency of the supply is correct. ,*--(CAP~)

APPLICABILITY The electrical power distribution subsystems are required to be OPERABLE~~"""

~QbQ ~H~T89W~to ensure that AC, DC, and Preferred AC power is available to the redundant trains and channels of safeguards equipment, instrumentation and controls required to support engineered safe uards e ui ment

an accide * ~nt.

vent of fUt I

3. ';. 9-a_S are PALISADES B 3.7.9-2 Amendment No

c35-1

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS

RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION NRC REQUEST:

RESPONSE TO NRC QUESTIONS 3.8.9-06 CTS 3. 7.g Action E ITS 3. 8. 9 Condition E Bases for ITS 3.8.9 Required Action E.1, CTS Bases markup page B

3. 7.9-4 Bases for STS 3. 8. 9 Required Action E. 1 CTS 3. 8. 9 Condition E addresses two or more inoperable distribution subsystems that result in a loss of function. ITS 3. 8. 9 Condition E does not refer to other existing equipment failures, and the Bases for STS 3. 8. 9 Required Action E. 1 does not contain this reference either.

Comment: ITS 3. 8. 9 Condition Eis a proposed change relative to the CTS. This proposed change has not been noted on the CTS markup, and justification for the proposed change has not been provided. Revise the submittal to note this proposed change on the CTS markup, and provide the appropriate justification. Revise the associated Bases to support ITS 3.8.9 Condition E.

Consumers Energy Response:

The markup of CTS 3.7.9.E (Attachment 3, page 1 of 3) has been revised to be consistent with ITS 3.8.9 Condition E. Justification for this change is provided in (new)

DOC A.3. Conforming changes have also been made to the Bases.

Affected Submittal Pages:

ITS pg B 3.8.9-6 CTS 3.8.9 pg 1 of 3 DOC 3.8.9 pg 1 of 2 CTS pg B 3.7.9-4 36

Distribution Systems - Operat1~g B 3.8.9 BASES ACTIONS n. 1 and D.2 (continued)

If the inoperable distribution subsystem cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to an operating condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MOOE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SUR VE IL LANCE . SR 3.8.9.1 REQUIREMENTS This surveillance verifies that the required AC, DC, and Preferred AC bus electrical power distribution subsystems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained.

For those buses which have undervol tage a1anJ ; n the ')( ed control room, correct voltage may be verified"Oy the absence of an*undervoltage alann.

s For those buses which have~nly one possible power source ed and have undervoltage alarn8 in the control room, correct X breaker alignment by the absence of an undervoltage alann. )(

ma.~ \kJ'~ . . A~I ~~9-0"'t

Palisades Nuclear Plant B 3.8.9-6 01/20/98 3~-a_

3.~~ ELECTRICAL POW.ER SYSTEMS @

3.i ,q 3. T ,-, Distrjbytion Systems - Ocerating Specifications Applicability Specification 3.7.9 applies when the PCS is0o*e <e~ !i~IS;:A'PI~ ~

Action ft1ooc;s

~ t,- '2., ~. :4"'* :iJ ~

c~ A 3.7.9.A With one or more subsystems of one AC electrical power distribution train inoperable: ~

-'-o--....f.etlll!!~~~E-:--;o+~~~~,_,-(§

l-: Eerrt~ly with 3.7.3.E, if applicable, &iid G::rttrJ.. B 3 . 7. 9. B With one Preferred AC bus inopera e: ~

la 'i~~ly with 3 z 9 E. jf appljcahle an~ ~

Restore the DC electrical~~ distribution train to OPERAS~

2.

status; within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . ~~~'<-~ow"!) <5 3.7.9.D If the action required by 3.7.9.A, through 3.7.9.C is not met and the associated completion time has expired: ~ *

1. The reactor shall be placed in HOT SHUTDOWN; within ~~hours, a~:

'"~--M.1 I

-t::.~ ($' 2_ The reactor shall be placed in COLD SHUTDOWN: within ~rs. .

J""A> t?l~ ~ 3C. :

3.7.9.E @fejn~1noperable distribution subsystem that results in a oss of a sa e y unction:

1. Enter Specification 3.0.3; i11V11ediately.

(lr.sw-'" ~'1< aho~:

~

diSCd II~

~

/(., ll'fS ~

JI .(.;Iwrt. -fD tK2e f- LW 3-45f Amendment No .

I 31.o - b

ATTACHMENT 3 DISCUSSION OF CHAi'lGES SPECIFICATION 3.8.9, DISTRIBlJTION SYSTEM - OPERA TING ADMINISTRATIVE CHANGES (A)

A.1 All reformatting and renumbering are in accordance with NUREG-1432. As a result, the Technical Specifications (TS) should be more readily readable, and therefore understandable by plant operators as well as other users. The reformatting, renumbering, and rewording process involves no technical changes to existing Technical Specifications.

Editorial rewording (either adding or deleting) is made consistent with NUREG-1432.

During Improved Technical Specification (ITS) development certain wording preferences or English language conventions were adopted which resulted in no .

technical changes (either actual or implied) to the TS. Additional information has also been added to more fully describe each subsection. This wording is consistent with NUREG-1432. Since the design is already approved by the NRC, adding more details does not result in a technical change.

A.2 _CTS 3.7.9.A.l, B.1, and C.l specify an action that informs the operator to comply with other required actions is necessary. Since these other required actions are required to be met regardless of this statement, this statement does not provided specific action. It therefore serves solely as an informational note, which does not appear in ITS. As such, its removal is an administrative editorial presentation preference with no technical change or change in intent. This change is consistent_ with NUREG-1432.

A. *3 N<lc.., f/t1 J;J-.9-o~

TECHI\TICAL CHANGES - MORE RESTRICTIVE (M)

M .1 CTS 3. 7. 9. D requires that' if inoperable components are not restored to OPERABLE status then the reactor shall be placed in a hot shutdown condition within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and cold shutdown within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . In the proposed ITS, the requirement is to place the plant in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The CTS HOT SHUTDOWN is nominally equivalent to the proposed ITS MODE 3 as discussed in Section 1.1 and therefore, there is little effect in adopting the proposed ITS MODE 3 parameters. However, adopting the proposed ITS shutdown times is considered to be more restrictive, ~ut continues to allow sufficient time to shutdown the plant in a safe and controlled manner. This change is consistent with NUREG-1432 .

Palisades Nuclear Plant Page 1of2 01/20/98

3.8.9 DOC A.3 CTS 3. 7. 9. E requires immediate entry into specification 3 .0.3 "with any inoperable distribution subsystem that results in a loss of a safety function. " ITS 3. 8. 9 Condition E requires immediate entryTnto LCO 3.0.3 when "two or more inoperable subsystems result in a loss of function." The requirements of the CTS and ITS are essentially equivalent. That is, both specifications require a plant shutdown when a loss of safety function exists due to degradation of the electrical distribution system. The difference in language between CTS 3.7.9.E and ITS 3.8.9 Condition Eis due to the application of the technical specification usage rules and treatment for a loss of safety function. (See Chapter 3. 0 of the Palisades ITS conversion submittal for a discussion related to the inclusion of ITS LCO 3 .0.6) Since the proposed wording does not alter the original intent of the CTS, this change has been characterized as administrative in nature .

3& -cJ

Distribution Systems - - Operating 8 3.7.9 and 4.7.9 BASES An

operable DC distribution subsys m can cause engineered safety ures e inoperable. If a redundant s fety feature in the other train ncurrently inoperable, a loss of. safety function could occur. AC c. l equires compliance with Conditi 3.7.9.E to assure that the pla utdown if a safet function i lost.

0~

With@~ ~u~~one train inoperable, the rema1n1ng DC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and ~aintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF functions not being supported. Therefore, the required DC buses must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months by powering the bus from the associated battery or charger.

This 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months limit is more conservative than Completion Times allowed for the vast majority of components which would be without power and is a feature of the original Palisades licensing!asis. itt--JS-72---Tj

~D.l and D.2 If the inoperable status power Condition electrical distribution system tha causes a required safety function to Condition is entered, and this results in the loss of a required function, e plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

PALISADES B 3.7.9-4 Amendment No.

3t.o-e

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3.8.9-07 Bases for ITS SR 3.8.9.1, CTS Bases markup page B 3. 7.9-5, third paragraph The third paragraph of the Bases for ITS SR 3. 8. 9. 1 addresses buses which have only one possible power source.

Comment: There seems to be material missing from the sentence -the sentence is incomplete. Revise the submittal to add the missing material to the Bases.

Consumers Energy Response:

The Bases for ITS 3.8.9 SR 3.8.9.1 has been revised to incorporate missing material.

The phrase "may be verified" has been added to the sentence which now reads "

... correct breaker alignment may be verified by the absence of an undervoltage alarm."

Affected Submittal Pages:

ITS pg B 3.8.9-6 CTS pg B 3.7.9-5 37

Distribution Systems - Operat1r.g 8 3.8.9 BASES ACTIONS Q.l and 0.2 (continued)

If the inoperable distribution subsystem cannot be restored to OPERABLE status within the required Completion Time, tne plant must be brought to an operating condition in ~n1cn t~e LCO does ndt apply. To achieve this status, the plant must.

be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reacn tr.e required plant conditions from full power conditions 1n an orderly manner and without challenging plant systems.

SURVEILLANCE SB 3.8.9.l REQUIREMENTS This surveillance verifies that the required AC, DC, and Preferred AC bus electrical power distribution subsystems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained.

For those buses which have undervoltage alarrrJ in the 'X e.d control room, correct voltage may be verified~y the absence of an*undervoltage alarm.

s For those buses which have~nly one possible power source x e.d and have undervoltage ala~ in the control room, correct breaker alignment by the absence of an undervoltage alarm.

mo-~ v.t~ .

Palisades Nuclear Plant B 3.8.9-6

01/20/98 3 7-(L.

Distribution Systems - - Operating B 3.7.9 and 4.7.9 BASES S~LANCE ~~QUIREMENTS

~ (A6 Bij& alignment e"eek) ~

This surveillance verifies that the required AC, DC, and Preferred AC bus electrical power distribution subsystems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained.

For those buses which have undervoltage alarmed in the control room, correct voltage may be verified by the absence of an undervoltage alarm.

(1 {',\ D"i' For those buses which have only one possible power source and have undervoltage alarmed in the (Ontrol room, correct breaker alignmen~by the

~~*

absence of an undervol tage al arm. fl"O-i ~\Jt.c"'~c.J A Preferred AC Bus may be considered correctly aligned when powered from either the associated inverter or from the bypass regulator. A mechanical interlock prevents connecting two or more Preferred AC Buses to the Bypass Regulator. LCO~ . . 7 and SR ~.7.1 address the condition of supplying a Preferred AC Bu ram the bypas e ulator.

8 ~8 .

The 7 day Frequ cy takes into nt the redundant capability of the AC, DC, and Preferred AC bus electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions.

REFERENCES None CT5 Tlfet.E $. 7.C/-1 B~ES Tlh3lt d 3.'6. 9-1 PALISADES B 3.7.9-5 Amendment No.

~7-b

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3.8.9-08 Bases Applicable Safety Analysis discussion for ITS 3. 8. 9, CTS Bases markup page B 3. 7. 9-1 Bases Applicable Safety Analysis discussion for STS 3. 8. 9 The Bases Applicable Safety Analysis discussion for STS 3. 8. 9 includes reference to the criteria of 10 CFR 50. 36. This material has not been adopted in the Bases for corresponding ITS 3. 8. 9.

Comment: This is not a justifiable plant specific difference. Revise the Bases to conform to the STS.

Consumers Energy Response:

The Applicable Safety Analyses discussion in the Bases for ITS 3.8.9 has been revised to include the appropriate reference to 10 CFR 50.36.

Effected Submittal Pages:

ITS pg B 3.8.9-1 CTS pg B 3.7.9-1 38

Distribution Systems - Operating B 3.8.9 3.8 ELECTRICAL POWER SYSTEMS B 3.8.9 Distribution Systems - Operating BASES BACKGROUND The onsite Class lE AC, DC, and Preferred AC bus electrical power distribution systems are divided into two redundant and independent electrical power distribution trains. Each electrical power distribution train is made up of several subsystems which include the safety related buses, load centers, motor control centers, and distribution panels shown in Table B 3.8.9-1.

The Class lE 2400 V safety related buses, Bus lC and Bus lD, are normally powered from offsite, but can be powered from the DGs, as explained in the Background section of the Bases for LCO 3.8.1, AC Sources - Operating.

11 11 Eac 2400 V safety J related bus supplies one train of Class lE the 80 V ~e distribution system.

The 120 V Preferred AC buses are normally powered from the inverters. The alternate power supply for the buses is a constant voltage transformer, called the Bypass Regulator.

Use of the Bypass regulator is governed by LCO 3.8.7, 11 Inver'ters - Operating. The bypass regulator is powered 11 from the non-Class lE instrument AC bus, Y-01. The Instrument AC bus is normally powered through an automatic bus transfer switch, an instrument AC transformer, and isolation fuses. Its normal power source is MCC-1. Loss of power to MCC-1 will cause automatic transfer of the Instrument AC bus t6 MCC-2.

There are two independent 125 V DC electrical power distribution subsystems.

APPLICABLE A description of the Safety Analyses applicable in SAFETY ANALYSES MODES 1, 2, 3, and 4 is provided in the Bases for LCO 3.8.1.

1]\, d1s-fr~~101\sys4cms f)o.t1~fy C}.,.Jc.r,*";, o-f t 6 CF-fl S~.J' (c )(z).

Palisades Nuclear Plant B 3.8.9-1 01/20/98 38-o-

©""

Distribution Systems - O~erating 8 4.7.i ELECTRICAL POWER SYSTEMS B 3~.9 aRe 4.7 ...Q: Distribution Systems - Operating g -

BAS -

BACKGROUND The onsite Class IE AC, DC, and Preferred AC bus electrical power distribution systems are divided into two redundant and independent electrical power distribution trains. Each electrical power distribution train is made up of several subsystems which include the safety related buses, load centers, ~ator control centers, and distribution panels shown in ~~3&-;-1.

The Class lE 2400 volt safety related buses, Bus lC and Bus lD, are normally powered from offsite, but can be powered from the DGs, as explained in the Background section of the Bases for LCO 3~.I, "AC Sources - Operating". Each 2400 volt safety related bus supplies one in of Class IE the 480 volt distribution system. "$

The 120 volt Preferred AC buses are normally powered from the inverters. The alternate power supply for the buses is a constant voltage transformer, called the Bypass Regulator. Use of the Bypass regulator is governed by LCO 3 . . 7, "Inverters - Operating." The bypass regulator is powered from the non-Class lE instrument AC bus, Y-01. The Instrument AC bus is normally powered through an automatic bus transfer switch, an instrument AC transformer, and isolation fuses. Its normal power source is MCC-1. Loss of power to MCC-1 will cause automatic transfer of the Instrument AC bus to MCC-2.

There are two independent 125 volt DC electrical power distribution subsystems.

APPLICABLE SAFETY ANALYSES is 1fw.11 ~ 3 (J ~ Id Ct:lt. So.J( (c LCO The AC, DC, and Preferred AC bus electrical power distribution subsystems are required o be OPERABLE. The required power distribution subsystems listed in 3 .* 9-1 ensure the availability of AC, DC, and Preferred AC bus rical power for the systems required to shut down the reactor and

maintain it in a safe condition after an anticipated operational occurrence or a postulated OBA.

PALISADES B 3.7.9-1 Amendment No.

38-b

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3. 8. 10, Distribution Systems - Shutdown 3.8.10-01 ITS 3.8.1 Required Action A.2.5 CTS 3. 7.10 Action A.2.5 ITS 3. 8. 10 Required Action A. 2. 5 states, "Declare associated required shutdown cooling train inoperable and not in operation," which is consistent with the STS. CTS 3. 7. 1O Action A.2.5 states, "Declare affected required shutdown cooling trains inoperable."

Comment: This proposed change was not noted on the CTS markup. Revise the submittal to note the proposed change on the CTS markup, and provide the appropriate justification.

Consumers Energy Response:

The markup of CTS 3.7.1 O.A action 2.5 (Attachment 3 page 1 of 2 )has been revised to include the phrase "and not in operation." Justification for this change is provided in (new) DOC A.2.

Affected Submittal Pages:

CTS 3.8.10 pg 1 of 2 DOC 3.8.10 pg 1 of 1 39

3.1i-+:+- ELECTRICAL POWER SYSTEMS ~

j.'?.10 .... 7.1-6" Distribution Systems - Shutdown~

Specifications Llo 3. 'i* to The necessary portion of AC, OC, and Preferred AC electrical power distribution subsystems listed in Table 3.7.9-1 shall be OPERABLE to supPort equipment required to be OPERABLE. ~A.f Applicability (f;il = :;

Specification 3.7.10 applies when the plant is ~:~~*'T~;;: C.

REFl:lELING Slll:ITBewu wI tlr fuel i 11 the 1 eaehl" 1 and during movement of irradiated fuel assemblies.

Action 3.7.10.A With one or more required AC, DC, or Preferred AC electrical power distribution subsystems inoperable, immediately initiate action to:

l. Declare affected required features supplied by an inoperable distribution subsystem to be~~~~~~ .~

2. l. Suspend ~Fl:1ELI!H! 6PEAAHQtl5; ~

2.2. Suspend movement of irradiated fuel assemblies, and 2.3. Suspend operations involving positive reactivity additions, and 2.4. Restore the required AC, DC, and Preferred AC electrical power distribution subsystems to OPERABLE status, and 2.5. Declare affected required shutdown cooling trains inoperable.

RA\ ).6. lo... oJ_

/

f\?~

0-Nd No\-

>t I'(\

\ o~rG\-\ON 3-45h Amendment No .

~q I of

2-

-O-

ATTACHMENT 3 DISCUSSION OF CHAL"IGES SPECIFICATION 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN ADMINISTRATIVE CHANGES (A)

A.1 All reformatting and renumbering are in accordance with NUREG-1432. As a result, the Technical Specifications ('fS) should be more readily readable, and therefore understandable by plant operators as well as other users. The reformatting, renumbering, and rewording process involves no technical changes to existing Technical Specifications.

Editorial rewording (either adding or deleting) is made consistent with NUREG-1432.

During Improved Technical Specification (ITS) development certain wording preferences or English language conventions were adopted which resulted in no technical changes (either actual or implied) to the TS. Additional information has also been added to more fully describe each subsection. This wording is consistent with NUREG-1432. Since the design is already approved by the NRC, adding more details does not result in a technical change.

A.'J A.JevJ TECHNICAL CHANGES - MORE RESTRICTIVE (M)

There were no "More Restrictive" changes associated with this specification.

LESS RESTRICTIVE CHAL'\TGES - REMOVAL OF DETAILS TO LICENSEE CONTROLLED DOCUMENTS (LA)

There were no "Removal of Details" changes associated with this specification.

LESS RESTRICTIVE CHANGES (L)

There were no "Less Restrictive" changes associated with this specification .

Palisades Nuclear Plant Page 1of1 01/20/98

3.8.10 DOC A.2 CTS 3.7.10.A contains the actions to be taken when one or more required AC, DC, or Preferred AC electrical power distribution subsystems are inoperable. CTS 3.7.10.A action 2.5 states to "declare affected required shutdown cooling trains inoperable." In the ITS, the corresponding action is Required Action A.2.5 which states "declare associated required shutdown cooling train inoperable and not in operation." Required Action A.2.5 contains the phrase "and in operation" which is not in the CTS. The inclusion of this phrase assures the appropriate actions are taken in the event primary coolant circulation and heat removal functions are lost as a result of an electrical distribution system inoperability. In this instance, reliance on LCO 3.0.6 would be inappropriate. This change is considered administrative in nature since it does not alter an existing requirement in the CTS, but simply addresses each aspect (i.e., Operable, and in operation) related to a loss of the shutdown cooling function.

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3. 8. 10-02 Bases Applicable Safety Analysis discussion for ITS 3. 8. 10, CTS Bases markup page B 3. 7. 10-1 Bases Applicable Safety Analysis discussion for STS 3. 8. 10 The Bases Applicable Safety Analysis discussion for STS 3. 8. 10 includes reference to the criteria of 10 CFR 50.36. This material has not been adopted in the Bases for corresponding ITS 3. 8. 10.

Comment: This is not a justifiable plant specific difference. Revise the Bases to confonn to the STS.

Consumers Energy Response:

The Applicable Safety Analyses discussion in the Bases for ITS 3.8.10 has been revised to include the appropriate reference to 10 CFR 50.36.

Affected Submittal Pages:

ITS pg B 3.8.10-1 CTS pg B 3.7.10-1 40

Distribution Systems - Shutdown B 3.8.10

~ 3.8 ELECTRICAL POWER SYSTEMS B 3.8.10 Distribution Systems - Shutdown BASES BACKGROUND A description of the AC, DC, and Preferred AC bus electrical power distribution systems is provided in the Bases for LCO 3.8.9, 11 Distribution Systems - Operating. 11 APPLICABLE A description of the Safety Analyses applicable Rn/ ~

SAFETY ANALYSES during MODES 5 and 6 is provided in the Bases for LCO 3.8.2, 3J.10-0,;...

11 AC Sources - Shutdown. 11 Tu. d1mM1an S,ti'tr.ros Qc;Dsfy G1+/-v10*0 2J o-+/- )()CPft Sc .Jt,(L)cz.) X LCO This LCO requires those, and only those, AC, DC, and Preferred AC distribution subsystems to be OPERABLE which are necessary to support equipment required by other LCOs.

Maintaining these portions of the distribution system energized ensures the availability of sufficient power to operate the plant in a safe manner to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).

APPLICABILITY The electrical power distribution subsystems required to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies, provide assurance that equipment and instrumentation is available to:

a. Provide coolant inventory makeup,

b. Mitigate a fuel handling accident,

c. Mitigate shutdown events that can lead to core damage, ~A\

and C,bld 3.~/(j*

o.3

d. Monitoring and maintaining the plant in a~shutdown conditionA a.f'd f't.f~*"Q ~61'di*hV\. '{.

Palisades Nuclear Plant B 3.8.10-1 01/20/98

Distribution Systems - Shutdown al"\d 1.7.lZ BO ELECTRICAL POWER SYSTEMS B 3~0 *Ri_ 4,7 ~: Distribution Systems - Shutdown BAS~

BACKGROUND A description of the AC, DC, and Preferred AC bus electrical power distribution systems is provided in the Bases for Systems - Operating". LCO 3&1' "Distribution APPLICABLE SAFETY ANALYSES A description of the Safety Analyses applicable RE~OH!M !ill~T891W is provided in the Bases for Shutdown". -0.._.

LCO This LCO requires those, and only those, AC, DC, and Preferred AC distribution subsystems to be OPERABLE which are necessary to support equipment required by other LCOs.

Maintaining these portions of the distribution system energized ensures the availability of sufficient power to operate the plant in a safe manner to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).

APPLICABILITY c;;~Gi 1' d:;:J G.~

The electrical power distribution subsystems required to be OPERABLE i11 E9L0 Sl:ll ITQQl,m, REFWH I~~ Sb\1 ITQQW*, and during movement of irradiated fue 1 /?.A l assemblies, provide assurance that equipment and instrumentation is available 1. ,6*C~

to:

a. Provide coolant inventory makeup, Lta....,..... O.I;) ;r

b. Mitigate a fuel handling accident, C.10<- ,Rdwu* (o,..<V

c. Mitigate shutdown events that can lead to core damage, ~

d. ~3 i5~ ~ ~ ~~ t ~~~~ta i ni ng the plant i n a -1:rG~QLi:t9~Sofololol1r-'.ITM.0--,~~~""";~;=-l.jl(,.;;gu.i.i.tJ..~~jl.l.l....-

0 PALISADES B 3.7.10-1 Amendment No.

t/-o-b

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

3. 8. 10-03 JFD 2 Bases Applicability for ITS 3. 8. 10, CTS Bases markup page B 3. 7. 10-1 Bases Applicability for STS 3. 8. 10 The Bases Applicability for STS 3. 8. 10 refers to monitoring and maintaining the plant in a cold shutdown or refueling condition. The Bases Applicability for ITS 3. 8. 1O refers to monitoring and maintaining the plant in a shutdown condition. JFD 2 states that differences have been made for clarity, grammatical preference, or to establish consistency within the Improved Technical Specifications.

Comment: This is not a justifiable plant specific difference. Revise the submittal to conform to the STS.

Consumers Energv Response:

The terminology used to describe the plant condition in item "d" of the ITS Applicability has been revised to conform with the terminology used in the ISTS. Conforming changes have also been made to CTS Bases markup page B 3. 7 .10-1.

Affected Submittal Pages:

ITS pg B 3.8.10-1 CTS pg B 3.7.10-1 41

Distribution Systems - Shutdown B 3.8.10 3.8 ELECTRICAL POWER SYSTEMS B 3.8.10 Distribution Systems - Shutdown BASES BACKGROUND A description of the AC, DC, and Preferred AC bus electrical power distribution systems is provided in the Bases for LCO 3.8.9, "Distribution Systems - Operating."

APPLICABLE A description of the Safety Analyses applicable Rn/

SAFETY ANALYSES during MODES 5 and 6 is provided in the Bases for LCO 3.8.2, ).°d-IO'c.,._

"AC Sources - Shutdown."

Th d1mlhd1ao Sir+/-c.r0s Qg,Jufy G1+/-v10*0::, Qt ./OCeJt So .Jt,(L)cz..) X LCO This LCO requires those, and only those, AC, DC, and Preferred AC distribution subsystems to be OPERABLE which are necessary to support equipment required by other LCOs.

Maintaining these portions of the distribution system energized ensures the availability of sufficient power to

operate the plant in a safe manner to mitigate the consequences of postulated events during shutdown (e.g., fuel han.dling accidents).

The electrical power distribution subsystems required to be APPLICABILITY OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies, prov1de assurance that equipment and instrumentation is available to:

a. Provide coolant inventory makeup,

b. Mitigate a fuel handling accident,

c. Mitigate shutdown events that can lead to core damage, ~Al and CDld 3. ( /O *o.3

d. Monitoring and maintaining the plant in a~shutdown condition~ O.rd r't.f!.kU'(lo ~61'd1*hV\ * '{.

Palisades Nuclear Plant 8 3.8.10-1 01/20/98

B @o Distribution Systems - Shutdown al'le! 4.7.l~

~ ELECTRICAL POWER SYSTEMS B 3):::\0 -aRQ 4_.7.Hl: Distribution Systems - Shutdown BAsh'V -

BACKGROUND A description of the AC, DC, and Preferred AC bus electrical power distribution systems is provided in the Bases for LCO 3~c..9* "Distribution Systems - Operating". ~

APPLICABLE SAFETY ANALYSES A description of the Safety Analyses applicable REFtJHrnG 511l:JTBOWH* is provided in the Bases for Shutdown".

LCO This LCO requires those, and only those, AC, DC, and Preferred AC distribution subsystems to be OPERABLE which are necessary to support equipment required by other LCOs.

Maintaining these portions of the distribution system energized ensures the availability of sufficient power to operate the plant in a safe manner to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).

APPLICABILITY GD"i: !> 4;J (.,~

The electrical power distribution subsystems required to be OPERABLE i11 COLO

-Sl:l!ITQQ'.lll, RErn~UN~ Sl:l' 1TQQW*, and during movement of irradiated fuel assemblies, provide assurance that equipment and instrumentation is available to:

a. Provide coolant inventory makeup,

,/

b. Mitigate a fuel handling accident,

c. Mitigate shutdown events that can lead to co.___::;;.;i.:;::..&..

d. Monitoring and ma1ntain1ng the plant in

~O IOOW condition.

~11/ 3.~.10-0';

PALISADES B 3.7.10-1 Amendment No .

L// b

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

5. 5, Programs and Manuals 5.5-01 ITS 5.5.2 CTS 6.5.2 The CTS markup for the first paragraph in this section contains the term "shutdown cooling system". Although the ITS has this term in it, the STS markup does not include it.

Comment: Revise the submittal to include this term in the STS markup.

Consumers Energv Response:

ISTS 5.5.2 (Attachment 5 page 5.0-8) has been revised to include the phrase "the Shutdown Cooling System."

Effected Submittal Pages:

NUREG pg 5.0-8 42

Programs and Manuals 5.5 5.5 Progruis -.~d Manuals

~. s. \ 5. 5. l Offsite Dose Calcylation Manya] (QQCMl (continuP.d) th~ affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.

5.5.2 Primary Coolant Soyrces Oytsjde Containment as include

a. Preventive maintenance and periodic visual inspection requirements;~

b. Integrated leak test requirements for each system at refueling cycle intervals or less;

<. J:'" ~e.--+) I@

l. S'.3 5.5.3 This program provides controls that ensure the capability to rl' obtain and analyze reactor coolant, radioactive gases, and particulates in plant gaseous effluents and containment atmosphere samples under accident conditions. The program shall include the following:

a. Training of personnel;

b. Procedures for sampling and analysis; and

c. Provisions for maintenance of sampling and analysis equipment.

S.S.4 Rad1gact1ye Effluent Controls Program This program conforms to 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably (continued)

CEOG STS 5.0-8 Rev 1, 04/07/95

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

5.5-02 JFD 19 CTS 6.5.14 ITS 5.5.14 Information has been added or changed in the CTS for this section via "Insert 1" from the STS markup without any supporting DOCs.

Comment: Revise the submittal to address each change in CTS 6.5.14 as revised by "Insert 1" from the STS markup. Each of these changes or additions should be supported by an appropriate DOC.

Consumers Energy Response:

Consistent with TSTF-52, and as discussed in JFD 19, the acceptance criteria for local leakage tests of the containment have been placed in the Containment Leakage Rate Testing program in Chapter 5.0. For the Palisade's plant, the acceptance criteria of CTS 4.5.2 a.(1), CTS 4.5.2 a.(2), and CTS 4.5.2 b. have been include in proposed ITS 5.5.14. This change has been annotated in the CTS (Attachment 3, page 1 of 29, and 2 of 29) consistent with similar type changes which move requirements within the technical specifications as part of the conversion process. As such, the information contained in Insert 1 to the ISTS simply reflects the inclusion of the requirements specified in CTS 4.5.2.

Affected Submittal Pages:

None 43

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

5. 6, Reporting Requirements 5.6-01 CTS 6.6.1 ITS 5.6.1 The first paragraph of the CTS, ITS, and STS from this section has a bracketed item containing the term "describe maintenance". This term has not been edited to reflect plant specific maintenance items relating to the Occupational Radiation Exposure Report.

Comment: Revise the CTS, ITS, and STS markup bracketed item for this section to reflect plant specific maintenance items relating to the Occupational Radiation Exposure Report.

Consumers Energy Response:

The first paragraph of ITS 5.6.1 contains the words "describe maintenance" in brackets.

The purpose of this phrase is to ensure the details of any special maintenance activity are included in the Occupational Radiation Exposure Report. Since the nature of all special maintenance activities may not be known, the requirement of ITS 5.6.1 is met by describing the details related to each special maintenance activity performed during the reporting period. Parentheses were originally used to enclose this same phrase in NUREG-0212, "Standard Technical Specification Combustion Engineering Pressurized Water Reactors" however, brackets were adopted in NUREG-1432 since the material was already enclosed in parentheses. Therefore, for this occurrence in NUREG-1432, the bracketed information is not intended to be replaced with plant specific information.

Affected Submittal Pages:

None

44

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS

RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION NRC REQUEST:

5.6-02 DOC A.8 -

RESPONSE TO NRC QUESTIONS CTS 6.6.5 b.1 ITS 5.6.5 b.1 DOC A. 8 does not fully explain or support the removal of the term "LCO 3. 10. 1" from CTS 6.6.5 b.1.

Comment: Revise the CTS submittal DOC A. 8 to substantiate removal of the term "LCO 3.10.1" from CTS 6.6.5 b.1.

Consumers Enerqv Response:

DOC A.8 has been revised to substantiate removal of the term "LCO 3.10.1" from CTS 6.6.5.b.1.

Affected Submittal Pages:

DOC 5.0 pg 2of6 45

AITACHMENT 3 DISCUSSION OF CHA.J\TGES CHAPTER 5.0, ADMINISTRATIVE CONTROLS A.5 CTS 6.4.1 requires that written procedures shall be established, implemented, and maintained for the ac-tivities listed. In this list, the CTS contains item b., "Refueling operations, and item c., "Surveillance and test activities of safety-related activities."

These items are included in the procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978 which is referenced in CTS 6.4. la and included in the proposed ITS 5.4. la. Therefore, since these procedures are already required by the reference to Regulatory Guide 1. 33, Revision 2, February 1978, they are not included in the proposed ITS. This change is an administrative change since no requirements have changed. This change maintains consistency with NUREG-1432.

A.6 CTS 6.4. l requires that written procedures shall be established, implemented, and maintained for the activities listed. In this list, the CTS contains item f., "Site Security Plan implementation" and item g., "Site Emergency ~Ian implementation .. " These items were recommended to be removed from the Technical Specifications in NRC Generic Letter 93-07 since they are duplicative of regulations contained in the Code of Federal Regulations part 50 and 73. This change is considered to be an administrative change since these requirements must still be met as required by the Code of Federal Regulations. This change maintains consistency with NUREG-1432.

A.7 CTS 6.5.7 is entitled .. Inservice Inspection and Testing Program." In the proposed ITS 5.5.7, the title is changed to the "Inservice Testing Program." This change is considered to be an administrative change since the requirements of the program are unchanged. This change maintains consistency with NUREG-1432.

A.8 CTS 6.6.Sb. l lists, among referenced LCOs, "3 .10. l." That item is unnecessary and has been deleted. Neither CTS 3 .10.1, nor its ITS replacement reference the COLR .

Palisades Nuclear Plant Page 2 of 6 01/20/98

5.6-02 DOC A.8 CTS 6.6.5 a. lists the core operating limits that are established and documented in the COLR prior to each core reload. Specifically, these limits are: ASI Limits (CTS 3 .1.1), Regulating Group Insertions Limits {CTS 3.10.5), Linear Heat Rate Limits (CTS 3.23.1), and Radial Peaking Factor Limits (CTS 3.23.2). CTS 6.6.5 b. list the documents approved by the NRC that describe the analytical methods used to determine the core operating limits. As part of this listing, cross references are made to the LC Os pertaining to the affected limit (e.g. , ASI Limits, Regulating Group Insertion Limits, etc ... ). In error, CTS 6.6.5 b.1. lists CTS 3.10.1 (Shutdown Margin Requirements) as an LCO related to a document that describes analytical methods used to determine the core operating limits. Since Shutdown Margin is not a cycle dependent limit (the limit is contained in the technical specifications and not in the COLR), referencing CTS 3.10.1 in CTS 6.6.5 b.1 is inappropriate and has been deleted. This change has been characterized as administrative in nature since it does not alter any requirement of the CTS, but simply corrects an administrative oversight .

15-b

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS NRC REQUEST:

5.6-02 DOC A.10, LA.1 CTS 6.5.5, 6.6.8 (ref. 4.5.4, 4.5.5, 4.5.6)

ITS 5.5.5, 5.6.7 .

DOC A. 10 and LA. 1 are included in the Attachment 3 "Discussion of Change" portion of the CTS markup but are not referenced in the actual CTS markup. It appears that DOC A. 10 should be referenced in CTS 6. 6. 8 and that DOC LA. 1 should be referenced in CTS 6.5.5.

Comment: Revise the CTS submittal to reference DOC A. 10 and LA. 1.

Consumers Energy Response:

DOC A.10 is used to denote the change to CTS 4.5.6 on CTS page 4-21 c (Attachment 3, page 5 of 29),. LA.1 is used to denote the change to CTS 4.5.4 and CTS 4.5.5 on CTS pages 4-21a, 4-21b, and 4-21c (Attachment 3 pages 3, 4, and 5 of 29). In response to this comment, no change to the submittal is necessary.

Affected Submittal Pages:

None 46

ATTACHMENT 2

.. CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS EDITORIAL REVISIONS

AC Sources - Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources - Operating LCO 3.8.1 The following AC electrical sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the onsite Class,E AC Electrical Power Distribution System; and""t.

b. Two Diesel Generators (DGs) each capable of supplying one train of the onsite Class lE AC Electrical Power Distribution System.

APPLICABILITY: MODES l, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One offsite circuit A.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. (offsi te source check) for OPERABLE MQ offsite circuit.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months filill thereafter A.2 Restore offsite circuit to OPERABLE 1 status. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AiiQ 10 days from discovery of failure to meet LCO Palisades Nuclear Plant 3.8.1-1 Amendment No. 01/20/98 I o°' {0

AC Sources - Operating 3 .8 .1

ACTIONS B.

CONDITION One DG inoperable. B.1 REQUIRED ACTION Perform SR 3.8.1.1 COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (offsi te source check) for the Afil2 OPERABLE offsite ci rcuit(s). Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter Arm 8.2 Declare required feature(s) supported 1'4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from '(

by the inoperable DG inoperable when its discovery of Condition 8 eJ redundant required concurrent with feature(s) is i noperabil i ty of inoperable. redundant required Arm feature(s)

8. 3.1 Determine OPERABLE DG 1 is not inoperable due 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Y.

8.3.2 QR to common cause failure.

Perform SR 3.8.1.2 1 (start test) for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE OG.

filill 8.4 Restore DG to 1 OPERABLE status. 7 days AN.Q 10 days from discovery of failure to meet LCO

Palisades Nuclear Plant 3.8.1-2 cQ o-F JO Amendment No. 01/20/98

DC Sources - Operating 3.8.4

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.8 -------------------NOTE----~---------------

Thi s Surveillance shall not be performed in MODE 1, 2, 3, or 4.

60 months l Verify battery capacity is ~ 80% of the manufacturer's rating when subjected to a Aiiil performance discharge test or a modified performance discharge test. 12 months when battery shows degradation or has reached 85%

of the expected life with capacity

< 100% of manufacturer's rating 24 months when battery has reached 85% of the expected life with capacity

~ 100% of manufacturer's rating Palisades Nuclear Plant 3.8.4-4 Amendment No. 01/20/98 3 of J 0

AC Sources - Shutdown B 3.8.2 SURVEILLANCE SR 3.8.2.1 REQUIREMENTS (continued) SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in MODES 5 and q.

The SRs from LCO 3.8.1 w are required ar those which both support a feature eq_uired in MODES 5 an 6 and which _ _J i can be performed with ut .ffecting the OPERAS! ITY or ~

reliability of the re uir~sources.

"'f~ltL--i:i ...\(__..

With only one DG avai able, many tests ca ot be performed since their performanc would render t DG inoperable during the test. This l r tests which require DG loading: SRs 3.8.1.3, 3.8.1.5, 3.8.1.6, 3.8.1.7, 3.8.1.8, 3.8.1.9, 3.8.1.10, and 3.8.1.11.

REFERENCES None

Palisades Nuclear Plant B 3.8.2-4 01/20/98 1of!D

DC Sources - Operating B 3.8.4

BASES SURVEILLANCE SR --3.8.4.8 REQUIREMENTS (continued) A battery performance discharge test is a test of constant current capac.ity of a battery, normally done in the "as found" condition, after having been in service, to detect any change in the capacity determined by the acceptance test. The test is intended to determine overall battery degradation due to age and usage.

The modified performance discharge te simulated duty cycle consisting of just two rates* e one m ute rate published for the battery or th argest curre t load of the X I duty cycle, followed by the test rate e7loyed for the ~

performance test, both of which envelop the d ty cycle of the service test. Since the am ere-hours rem ed by a rated one minute discharge represents a very small portion of the battery capacity, the test rate an be ch ged to that for the performance test without comp - - g the results of the performance discharge test. The battery terminal voltage for the modified performance discharge test should remain above the minimum battery terminal voltage specified in the battery service test for the duration of time equal to that of the service test.

A modified performance discharge test is a test of the battery capacity and its ability to provide a high rate, short duration load (usually the highest rate of the duty cycle). This will often confirm the battery's ability to meet the critical pe.riod of the load duty cycle, in addition to determining its percentage of rated capacity. Initial conditions for the modified performance discharge test should be identical to those specified for a service test.

Either the battery performance discharge test or the modified performance discharge test is acceptable for satisfying SR 3.8.4.8; however, only the modified performance discharge test may be used to satisfy SR 3.8.4.8 while satisfying the requirements of SR 3.8.4.7 at the same time.

The acceptance criteria for this Surveillance are consistent wifh the recommendations of IEEE-450 (Ref. 4) and IEEE-485 (Ref. 3). These references recommend that the battery be replaced if its capacity is below 80% of the manufacturer rating. A capacity of 80% shows that the battery rate of deterioration is increasing, even if there is ample capacity to meet the load requirements .

Palisades Nuclear Plant B 3.8.4-10

&o-FID 01/20/98

DC Sources - Operating B 3.8.4

BASES SURVEILLANCE SR J.8.4.8 (continued)

REQUIREMENTS The Surveillance Frequency for this test is normally 60 months. If the battery shows degradation, or if the battery has reached 85% of its expected life and capacity is

< 100% of the manufacturer's rating, the Surveillance Frequency is reduced to 12 months. However, if the battery shows no degradation but has reached 85% of its expected life, the Surveillance Frequency is only reduced to 24 months for batteries that retain capacity ~ 100% of the manufacturer's rating. Degradation is indicated, according to IEEE-450 (Ref. 4), when the battery capacity drops by more than 10% relative to its capacity on the previous performance test or when it is ~ 10% below the manufacturer's rating. These Frequencies are consistent with the recommendations in IEEE-450 (Ref. 4).

The reason for the restriction that the plant be outside of MODES l, 2, 3, and 4 is that performing the Surveillance requires disconnecting the battery from the DC distribution buses and connecting it to a test load resistor bank. This fort*

action makes the battery inoperable and completely unavai !able X J y

REFERENCES 1. 10 CFPfJO, Appendix A, GDC 17

2. FSAR, Chapter 8

3. IEEE-485-1983, June 1983

4. IEEE-450-1995

5. Letter; Graham Walker, C&D Charter Power Systems, Inc to John Slinkard, Consumers Power Company, 12 July 1996

6. Regulatory Guide 1.32, February 1977

7. Regulatory Guide 1.129, December 1974 Palisades Nuclear Plant B 3.8.4-11 01/20/98

DC Sources - Shutdown B 3.8.5

BASES APPLICABILITY This LCO is applicable during movement of irradiated fuel (continued) assemblies even if the plant is in a condition other than MODE 5 or 6. This LCO provides the necessary ACTIONS if the DC electrical power sources required by this LCO become unavailable during movement o *rradiated fuel assemblies.

ACTIONS Since the required DC source is only required to support features required by other LCOs, the option to declare those required features with no DC power available to be inoperable, assures that appropriate ACTIONS will be implemented in accordance with the affected LCOs.

A.2.1. A.2.2. A.2.3. and A.2.4 Required Action A.1 may involve undesired and unnecessary administrative efforts, therefore, Required Actions A.2.1 through A.2.4 provide alternate, but sufficiently conservative, actions.

Required Actions A.2.1 through A.2.4 require suspension of CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions. The suspension of CORE ALTERATIONS and movement of irradiated fuel assemblies does not preclude actions to place a fuel assembly in a safe location; the suspension of positive reactivity additions does not preclude actions to maintain or increase reactor vessel inventory provided the required SHUTDOWN MARGIN is maintained.

These ACTIONS minimize the probability or the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC sources (and to continue this action until restoration is accomplished) in order to provide the necessary DC power to the plant safety systems.

Palisades Nuclear Plant B 3.8.5-2

/ o-F ID

DC Sources - Shutdown B 3.8.5 BASES ACTIONS A.Z.l. A.2.2. A.2.3. and A.2.4 (continued)

The Completion Time of "immediately is consistent with the 11 required times for actions requiring prompt attention. The restoration of the required DC power sources should be completed as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient control and Preferred AC power.

SURVEILLANCE SR 3.8.5.l REQUIREMENTS SR 3.8.5.l requires the s from LCO 3.8.4 hat are necessary for ensurin he OPERABILITY of t e AC sources in MODES 5 and 6.

~r-F~~.lt:--

The SRs from LCO 3. . 4 whi re re~uired re those which can be performed wi hout effecting ~he 0 RABILITY or reliability of the equired DC- source. With only one battery available, oading tests ca t be performed since their performance wo ld render t battery inoperable during the test. This

ase for SRs 3.8.4.7 and 3.8.4.8.

REFERENCES None

Palisades Nuclear Plant 8 3.8.5-3 8of/O

Distribution Systems - Shutdown B 3.8.10 BASES APPLICABILITY This LCO is applicable during movement of irradiated fuel (continued) ass~mblies even if the plant is in a condition other than MODE 5 or 6. This LCO provides the necessary ACTIONS if the electrical power distribution subsystems required by this LCO become unavailable during movement of irradiated fuel assemblies.

The electrical power distribution subsystem requirements for MODES 1, 2, 3, and 4 are addressed in LCO 3.8.9, 11 Distribution Systems - Operating. 11

./

ACTIONS Ll ../"'

Si nee the di stri buti on systems are onl requi re./~o suppo t features required by other LCOs, the ption _>o"declare ose affected required features to be in erabl~ assures t at appropriate ACTIONS will be impleme ted in accordan with the affected LCOs.

A.2.1. A.2.2. A.2.3. A.2.4. and A.2.5 Required Action A.l may involve undesired and unnecessary administrative efforts, therefore, Required Actions A.2.1 through A.2.5 provide alternate, but sufficiently conservative, actions.

Required Actions A.2.1, A.2.2, A.2.3, and A.2.5 require suspension of CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions, and declaration that affected shutdown cooling trains are inoperable. The suspension of CORE ALTERATIONS and movement of irradiated fuel assemblies does not preclude actions to place a fuel assembly in a safe location; the suspension of positive reactivity additions does not preclude actions to maintain or increase reactor vessel inventory provided the required SHUTDOWN MARGIN is maintained.

These ACTIONS minimize the probability or the occurrence of postulated events. It is further required (Required Action A.2.4) to immediately initiate action to restore the required distribution subsystems (and to continue this action until restoration is accomplished) in order to provide the necessary electrical power to the plant safety systems.

Palisades Nuclear Plant B 3.8.10-2 01/20/98 q of /{)

ATTACHMENT 8 JUSTIFICATIONS FOR DEVIATIONS SECTION 3.8, ELECTRICAL PO\VER SYSTEMS - BASES Discussion Note: The CTS Bases for Electrical Power Systems are unique in they have been upgraded co incorporate the format, and much of the content, of NUREG-1432.

These Bases have previously been reviewed and found acceptable by the NRC I151) in support of amendmen'r### to the Palisades Technical Specifications dated '/..

A ~ 1 \. d-Q \'lit {l(XXXX ##, ####}. To facilitate the review of the proposed Bases for ITS

' 1

\ ---section 3. 8, a markup of the CTS Electrical Power Systems Bases has been XA Cc)J provided which denotes only those differences between the previously approved CTS Bases and the proposed ITS Bases. In addition, a separate "red-line & strikeout" version of NUREG-1432, has been provided and will serve as a comparison between the CTS and NUREG-1432.

A brief discussion of the deviations from the CTS Bases is provided below.

The Change Numbers correspond to the respective deviation shown on the "CTS MARKUPS". The first five justifications were used generically throughout the markup of the CTS Bases .

1.

2.

The brackets have been removed and the proper plant specific information or value has been provided.

Deviations have been made for clarity, grammatical preference, or to establish consistency within the Improved Technical Specifications. These deviations are editorial in nature and do not involve technical changes or changes of intent.

3. The requirement/statement has been deleted since it is not applicable to this facility.

The following requirements have been renumbered, where applicable, to reflect this deletion.

4. Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect the facility specific nomenclature, number, reference, system description, or analysis description .

Palisades Nuclear Plant

/0 Page I of 3 of/()

01120/98

ATTACHMENT 3 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION REVISED PAGES FOR SECTION 3.8

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION REVISED PAGES FOR SECTION 3.8 Page Change Instructions Revise the Palisades submittal for conversion to Improved Technical Specifications by removing the pages identified below and inserting the attached pages. The revised pages are identified by date and contain vertical lines in the margin indicating the areas of change.

REMOVE PAGES INSERT PAGES REV DATE NRC COMMENT #

INTRODUCTION ATTACHMENT 1 TO ITS CONVERSION SUBMITTAL 3.8.1-1 3.8.1-1 09/04/98 N/A editorial 3.8.1-2 3.8.1-2 09/04/98 N/A editorial 3.8.3-1 3.8.3-1 09/04/98 RAI 3.8.3-02 3.8.3-2 3.8.3-2 09/04/98 RAI 3.8.3-02 3.8.4-4 3.8.4-4 09/04/98 NIA editorial 3.8.9-1 3.8.9-1 09/04/98 RAI 3.8.9-01 RAI 3.8.9-02 RAI 3.8.9-03 ATTACHMENT 2 TO ITS CONVERSION SUBMITTAL B 3.8.2-1 B 3.8.2-1 09/04/98 N/A editorial B 3.8.2-2 B 3.8.2-2 09/04/98 RAI 3.8.2-01 B 3.8.2-4 B 3.8.2-4 09/04/98 N/A editorial B 3.8.3-1 B 3.8.3-1 09/04/98 RAI 3.8.3-06 RAI 3.8.3-07 B 3.8.3-2 B 3.8.3-2 09/04/98 RAI 3.8.3-05 RAI 3.8.3-06 RAI 3.8.3-07 RAI 3.8.3-02 B 3.8.3-4 B 3.8.3-4 09/04/98 RAI 3.8.3-08 RAI 3.8.3-02 B 3.8.4-2 B 3.8.4-2 09/04/98 RAI 3.8.4-02 B 3.8.4-10 B 3.8.4-10 09/04/98 N/A editorial B 3.8.4-11 B 3.8.4-11 09/04/98 N/A editorial B 3.8.5-1 B 3.8.5-1 09/04/98 RAI 3.8.5-02 RAI 3.8.5-03 B 3.8.5-2 B 3.8.5-2 09/04/98 N/A editorial B 3.8.5-3 B 3.8.5-3 09/04/98 NIA editorial B 3.8.6-1 B 3.8.6-1 09/04/98 RAI 3.8.6-01 B 3.8.7-1 B 3.8.7-1 09/04/98 RAI 3.8.7-01 B 3.8.7-3 B 3.8.7-3 09/04/98 RAI 3.8.7-02 B 3.8.8-1 B 3.8.8-1 09/04/98 RAI 3.8.8-01 RAI 3.8.8-02 1

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ATTACHMENT 2 TO ITS CONVERSION SUBMITTAL (continued)

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AC Sources - Operating 3.8.1

3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources - Operating LCO 3.8.1 The following AC electrical sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the onsite Class lE AC Electrical Power Distribution System; and

b. Two Diesel Generators (DGs) each capable of supplying one train of the onsite Class lE AC Electrical Power Distribution System.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One offsite circuit A.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. (offsite source check) for OPERABLE AND offsite circuit.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months AND thereafter A.2 *Restore offsi te 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months circuit to OPERABLE status. AND 10 days from discovery of failure to meet LCO Palisades Nuclear Plant 3.8.1-1 Amendment No. 09/04/98

AC Sources - Operating 3.8.1

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. One DG inoperable. B.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (offsite source check) for the OPERABLE offsite circuit(s). Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND B.2 Declare required 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from feature(s) supported discovery of by the inoperable DG Condition B inoperable when its concurrent with redundant required inoperability of feature(s) is redundant inoperable. required feature(s)

B.3.1 Determine OPERABLE DG 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is not inoperable due to common cause failure.

OR B.3.2 Perform SR 3.8.1.2 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (start test) for OPERABLE DG.

AND B.4 Restore DG to 7 days OPERABLE status.

AND 10 days from discovery of failure to meet LCO

Palisades Nuclear Plant 3.8.1-2 Amendment No. 09/04/98

Diesel Fuel, Lube Oil, and Starting Air 3.8.3

3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel, Lube Oil, and Starting Air LCO 3.8.3 For each Diesel Generator (DG):

a. The stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits, and

b. Both diesel fuel oil transfer systems shall be OPERABLE.

APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS

NOTE-------------------------------------

Separate Condition entry is allowed for each DG.

CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel oil inventory A.1 Restore fuel oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months

< 23,700 gallons and inventory to within

> 20,110 gallons in limits.

storage tank.

B. Stored lube oil B.1 Restore stored lube 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months inventory oil inventory to

< 200 gallons and within limits.

> 160 gallons.

c. Fuel transfer system C.1 Restore fuel transfer 15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months (P-18A) inoperable. system to OPERABLE status.

D. Fuel transfer system D.1 Restore fuel transfer 7 days (P-188) inoperable. system to OPERABLE

-~tatus .

Palisades Nuclear Plant 3.8.3-1 Amendment No. 09/04/98

Diesel Fuel, Lube Oil, and Starting Air 3.8.3

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. Both fuel transfer E.1 Restore one fuel 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months systems inoperable. transfer system to OPERABLE status.

F. Fuel oil properties F.l Restore stored fuel 30 days other than viscosity, oil properties to and water and within 1i mits.

sediment, not within limits.

G. Required Action and G.1 Declare associated Immediately associated Completion DG(s) inoperable.

Time not met.

OR Stored diesel fuel oi 1, lube oil, or starting air subsystem not within limits for reasons other than Condition A, B, or F.

Palisades Nuclear Plant 3.8.3-2 Amendment No. 09/04/98

DC Sources - Operating 3.8.4

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.8 -------------------NOTE--------------------

Thi s Surveillance shall not be performed in MODE 1, 2, 3, or 4.

Verify battery capacity is ~ 80% of the 60 months manufacturer's rating when subjected to a performance discharge test or a modified performance discharge test.

12 months when battery shows degradation or has reached 85%

of the expected life with capacity

< 100% of manufacturer's rating

24 months when battery has reached 85% of the expected life with capacity

~ 100% of manufacturer's rating

Palisades Nuclear Plant 3.8.4-4 Amendment No. 09/04/98

Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 Left Train and Right Train AC, DC, and Preferred AC bus electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES l, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC A.1 Restore AC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months electrical power power distribution distribution subsystem(s) to AND subsystems in one OPERABLE status.

train inoperable. 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO B. One Preferred AC bus B.1 Restore Preferred AC 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable. . bus to OPERABLE status. AND 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO

c. One or more C.1 Restore DC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months DC electrical power power distribution distribution subsystem(s) to AND subsystems in one OPERABLE status.

train inoperable. 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO Palisades Nuclear Plant 3.8.9-1 Amendment No. 09/04/98

AC Sources - Shutdown B 3.8.2 BASES LCO An OPERABLE DG, associated with a distribution subsystem (continued) required to be OPERABLE by LCO 3.8.10, ensures a diverse power source is available to provide electrical power support, assuming a loss of the offsite circuit.

Together, OPERABILITY of the required offsite circuit and DG ensures the availability of sufficient AC sources to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents and loss of shutdown cooling).

The DG must be capable of starting, accelerating to rated speed and voltage, connecting to its respective 2400 V bus on detection of bus undervoltage, and accepting required loads. Proper Normal Shutdown" loading sequence, and tripping of nonessential loads, is a required function for DG OPERABILITY. A Service Water Pump must be started soon after the DG to assure continued DG operability. The OBA loading sequence is not required to be OPERABLE since the Safety Injection Signal is disabled during MODES 5 and 6.

APPLICABILITY The AC sources required to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies provide assurance that equipment and instrumentation is available to:

a. Provide coolant inventory makeup,

b. Mitigate a fuel handling accident,

c. Mitigate shutdown events that can lead to core damage, and

d. Monitor and maintain the plant in a cold shutdown condition or refueling condition.

This LCO is applicable during movement of irradiated fuel assemblies even if the plant is in a condition other than MODES 5 and 6. This LCO provides the necessary ACTIONS if the AC electrical power sources required by this LCO become unavailable during movement of irradiated fuel assemblies.

The AC source requirements for MODES 1, 2, 3, and 4 are addressed in LCO 3.8.1, "AC Sources - Operating."

Palisades Nuclear Plant B 3.8.2-2 09/04/98

AC Sources - Shutdown B 3.8.2 BASES SURVEILLANCE SR 3.8.2.1 REQUIREMENTS (continued) SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in MODES 5 and 6.

The SRs from LCO 3.8.1 which are required are those which both support a feature required in MODES 5 and 6 and which can be performed without affecting the OPERABILITY or reliability of the required sources.

With only one DG available, many tests cannot be performed since their performance would render that DG inoperable during the test. This is the case for tests which require DG loading: SRs 3.8.1.3, 3.8.1.5, 3.8.1.6, 3.8.1.7, 3.8.1.8, 3.8.1.9, 3.8.1.10, and 3.8.1.11.

REFERENCES None

Palisades Nuclear Plant B 3.8.2-4 09/04/98

Diesel Fuel, Lube Oil, and Starting Air B 3.8.3 3.8 ELECTRICAL POWER SYSTEMS B 3.8.3 Diesel Fuel, Lube Oil, and Starting Air BASES BACKGROUND The Diesel Generators (DGs) are provided with a storage tank having a required fuel oil inventory sufficient to operate one diesel for a period of 7 days, while the DG is supplying maximum post-accident loads. This onsite fuel oil capacity is sufficient to operate the DG for longer than the time to replenish the onsite supply from offsite sources.

Fuel oil is transferred from the Fuel Oil Storage Tank to either day tank by either of two Fuel Transfer Systems. The fuel oil transfer system which includes fuel transfer pump P-18A can be powered by offsite power, or by either DG.

However, the fuel oil transfer system which includes fuel transfer pump P-188 can only be powered by offsite power, or by DG 1-1.

For proper operation of the standby DGs, it is necessary to ensure the proper quality of the fuel oil. Regulatory Guide (RG) 1.137 (Ref. 1) addresses the recommended fuel oil practices as supplemented by ANSI N195-1976 (Ref. 2).

The DG lubrication system is designed to provide sufficient lubrication to permit proper operation of its associated DG under all loading conditions. The system is required to circulate the lube oil to the diesel engine working surfaces and to remove excess heat generated by friction during operation. The onsite storage in addition to the engine oil sump is sufficient to ensure 7 days of continuous operation.

This supply is sufficient supply to allow the operator to replenish lube oil from offsite sources. Implicit in this LCO is the requirement to assure, though not necessarily by testing, the capability to transfer the lube oil from its storage location to the DG oil sump, while the DG is running.

Each DG is provided with an associated starting air subsystem to assure independent start capability. The starting air system is required to have a minimum capacity with margin for a DG start attempt without recharging the air start receivers.

Palisades Nuclear Plant B 3.8.3-1 09/04/98

Diesel Fuel, Lube Oil, and Starting Air B 3.8.3

BASES APPLICABLE SAFETY ANALYSES A description of the Safety Analyses applicable in MODES l, 2, -3, and 4 is provided in the Bases for LCO 3.8.1, "AC Sources - Operating"; during MODES 5 and 6, in the Bases for LCO 3.8.2, "AC Sources - Shutdown." Since diesel fuel, lube oil, and starting air subsystems support the operation of the standby AC power sources, they satify Criterion 3 of 10 CFR 50.36(c)(2).

LCO Stored diesel fuel oil is required to have sufficient supply for 7 days of full accident load operation. It is also required to meet specific standards for quality. The specified 7 day requirement and the 6 day quantity listed in Condition A are taken from the Engineering Analysis associated with Event Report E-PAL-93-026B. Additionally, the ability to transfer fuel oil from the storage tank to each day tank is required from each of the two transfer pumps.

Additionally, sufficient lube oil supply must be available to ensure the capability to operate at full accident load for 7 days. This requirement is in addition to the lube oil contained in the engine sump. The specified 7 day requirement and the 6 day quantity listed in Condition Bare based on an assumed lube oil consumption of 0.8 to 1.0% of fuel oil consumption.

The starting air subsystem must provide, without the aid of the r~fill compressor, sufficient air start capacity, including margin, to assure start capability for its associated DG.

These requirements, in conjunction with an ability to obtain replacement supplies within 7 days, support the availability of the DGs. DG day tank fuel requirements are addressed in LCOs 3.8.1 and 3.8.2.

APPLICABILITY DG OPERABILITY is required by LCOs 3.8.1 and 3.8.2 to ensure the availability of the required AC power to shut down the reactor and maintain it in a safe shutdown condition following a loss of off-site power. Since diesel fuel, lube oil, and starting air support LCOs 3.8.1 and 3.8.2, stored diesel fuel oil, lube oil, and starting air are required to be within limits, and the fuel transfer system is required to be OPERABLE, when either DG is required to be OPERABLE .

Palisades Nuclear Plant B 3.8.3-2 09/04/98

Diesel Fuel, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS F.l (continued) --

With the stored fuel oil properties, other than viscosity, and water and sediment, defined in the Fuel Oil Testing Program not within the required limits, but acceptable for short term DG operation, a period of 30 days is allowed for restoring the stored fuel oil properties. The most likely cause of stored fuel oil becoming out of limits is the addition of new fuel oil with properties that do not meet all of the limits. This 30 day period provides sufficient time to determine if new fuel oil, when mixed with stored fuel oil, will produce an acceptable mixture, or if other methods to restore the stored fuel oil properties are required. This restoration may involve feed and bleed procedures, filtering, or combinations of these procedures.

Even if a DG start and load was required during this time interval and the fuel oil properties were outside limits, there is a high likelihood that the DG would still be capable of performing its intended function.

With a Required Action and associated Completion Time not met, or with diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than addressed by Conditions A, B, or F, the associated DG may be incapable of performing its intended function and must be immediately declared inoperable.

In the event that diesel fuel oil with viscosity, or water and sediment is out of limits, this would be unacceptable for even short term DG operation. Viscosity is important primarily because of its effect on the handling of the fuel by the pump and injector system; water and sediment provides an indication of fuel contamination. When the fuel oil stored in the Fuel Oil Storage Tank is determined to be out of viscosity, or water and sediment limits, the DGs must be declared inoperable, immediately.

Palisades Nuclear Plant B 3.8.3-4 09/04/98

DC Sources - Operating B 3.8.4

BASES BACKGROUND The- batteries for the DC power sources are sized to produce (conti~ued) required capacity at 80% of nameplate rating, corresponding to warranted capacity at end of life cycles and the 100%

design demand. The voltage limit is 2.13 V per cell, which corresponds to a total minimum voltage output of 125.7 V per battery discussed in the FSAR, Chapter 8 (Ref. 2). The criteria for sizing large lead storage batteries are defined in IEEE-485 (Ref. 3).

Each DC electrical power source has ample power output capacity for the steady state operation of connected loads during normal operation, while at the same time maintaining its battery fully charged. Each battery charger also has sufficient capacity to restore the battery from the design minimum charge to its fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months while supplying normal steady state loads discussed in the FSAR, Chapter 8 (Ref. 2).

APPLICABLE A description of the Safety Analyses applicable in MODES 1, SAFETY ANALYSES 2, 3, and 4 is provided in the Bases for LCO 3.8.1, "AC Sources - Operating."

The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2).

LCO The DC power sources, each consisting of one battery, one directly connected battery charger and the corresponding control equipment and interconnecting cabling supplying power to the associated bus within the train are required to be OPERABLE to ensure the availability of DC control power and Preferred AC power to shut down the reactor and maintain it in a safe condition.

An OPERABLE DC electrical power source requires its battery to be OPERABLE and connected to the associated DC bus. In order for the battery to remain OPERABLE, one charger must be in service *

Palisades Nuclear Plant B 3.8.4-2 09/04/98

DC Sources - Operating B 3.8.4

BASES SURVEILLANCE SR-_ 3.8.4.8 REQUIREMENTS (continued) A battery performance discharge test is a test of constant current capacity of a battery, normally done in the as 11 found" condition, after having been in service, to detect any change in the capacity determined by the acceptance test. The test is intended to determine overall battery degradation due to age and usage.

The modified performance discharge test is a simulated duty cycle consisting of just two rates; the one minute rate published for the battery or the largest current load of the duty cycle, followed by the test rate employed for the performance test, both of which envelop the duty cycle of the service test. Since the ampere-hours removed by a rated one minute discharge represents a very small portion of the battery capacity, the test rate can be changed to that for the performance test without compromising the results of the performance discharge test. The battery terminal voltage for the modified performance discharge test should remain above the minimum battery terminal voltage specified in the battery service test for the duration of time equal to that of the service test.

A modified performance discharge test is a test of the battery capacity and its ability to provide a high rate, short duration load (usually the highest rate of the duty cycle). This will often confirm the battery's ability to meet the critical period of the load duty cycle, in addition to determining its percentage of rated capacity. Initial conditions for the modified performance discharge test should be identical to those specified for a service test.

Either the battery performance discharge test or the modified performance discharge test is acceptable for satisfying SR 3.8.4.8; however, only the modified performance discharge test may be used to satisfy SR 3.8.4.8 while satisfying the requirements of SR 3.8.4.7 at the same time.

The acceptance criteria for this Surveillance are consistent with the recommendations of IEEE-450 (Ref. 4) and IEEE-485 (Ref. 3). These references recommend that the battery be replaced if its capacity is below 80% of the manufacturer rating. A capacity of 80% shows that the battery rate of deterioration is increasing, even if there is ample capacity to meet the load requirements.

Palisades Nuclear Plant B 3.8.4-10 09/04/98

DC Sources - Operating B 3.8.4 BASES SURVEILLANCE SR-- 3.8.4.8 (continued)

REQUIREMENTS The Surveillance Frequency for this test is normally 60 months. If the battery shows degradation, or if the battery has reached 85% of its expected life and capacity is

< 100% of the manufacturer's rating, the Surveillance Frequency is reduced to 12 months. However, if the battery shows no degradation but has reached 85% of its expected life, the Surveillance Frequency is only reduced to 24 months for batteries that retain capacity ~ 100% of the manufacturer's rating. Degradation is indicated, according to IEEE-450 (Ref. 4), when the battery capacity drops by more than 10% relative to its capacity on the previous performance test or when it is ~ 10% below the manufacturer's rating. These Frequencies are consistent with the recommendations in IEEE-450 (Ref. 4).

The reason for the restriction that the plant be outside of MODES 1, 2, 3, and 4 is that performing the Surveillance requires disconnecting the battery from the DC distribution

buses and connecting it to a test load resistor bank. This action makes the battery inoperable and completely unavailable for use.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 17

2. FSAR, Chapter 8

3. IEEE-485-1983, June 1983

4. IEEE-450-1995

5. Letter; Graham Walker, C&D Charter Power Systems, Inc to John Slinkard, Consumers Power Company, 12 July 1996

6. Regulatory Guide 1.32, February 1977 7* Regulatory Guide 1.129, December 1974

Palisades Nuclear Plant B 3.8.4-11 09/04/98

DC Sources - Shutdown B 3.8.5 3.8 ELECTRICAL POWER SYSTEMS B 3.8.5 DC Sources - Shutdown BASES BACKGROUND A description of the DC sources is provided in the Bases for LCO 3.8.4, "DC Sources - Operating."

APPLICABLE A description of the Safety Analyses applicable during SAFETY ANALYSES MODES 5 and 6 is provided in the Bases for LCO 3.8.2, "AC Sources - Shutdown."

The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2).

LCO This LCO requires those, and only those, DC power sources which supply the DC distribution subsystems required by LCO 3.8.10, to be OPERABLE. Each DC source consists of one battery, one battery charger, and the corresponding control

equipment and interconnecting cabling. This ensures the availability of sufficient DC power sources to maintain the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents and loss of shutdown cooling).

APPLICABILITY The DC power sources required to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies provide assurance that equipment and instrumentation is available to:

a. Provide coolant inventory makeup,

b. Mitigate a fuel handling accident,

c. Mitigate shutdown events that can lead to core damage, and

d. Monitoring and maint~i~ing_the plant in a cold II shutdown condition or refueling condition. I Palisades Nuclear Plant B 3.8.5-1 09/04/98

DC Sources - Shutdown B 3.8.5 BASES APPLICABILITY This LCO is applicable during movement of irradiated fuel (continued) assemblies even if the plant is in a condition other than MODE 5 or 6. This LCO provides the necessary ACTIONS if the DC electrical power sources required by this LCO become unavailable during movement of irradiated fuel assemblies.

The DC source requirements for MODES l, 2, 3, and 4 are addressed in LCO 3.8.4, DC Sources - Operating.

11 11 ACTIONS Since the required DC source is only required to support features required by other LCOs, the option to declare those required features with no DC power available to be inoperable, assures that appropriate ACTIONS will be implemented in accordance with the affected LCOs.

A.2.1, A.2.2, A.2.3, and A.2.4 Required Action A.1 may involve undesired and unnecessary administrative efforts, therefore, Required Actions A.2.1 through A.2.4 provide alternate, but sufficiently conservative, actions.

Required Actions A.2.1 through A.2.4 require suspension of CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions. The suspension of CORE ALTERATIONS and movement of irradiated fuel assemblies does not preclude actions to place a fuel assembly in a safe location; the suspension of positive reactivity additions does not preclude actions to maintain or increase reactor vessel inventory provided the required SHUTDOWN MARGIN is maintained.

These ACTIONS minimize the probability or the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC sources (and to continue this action until restoration is accomplished) in order to provide the necessary DC power to the plant safety systems .

Palisades Nuclear Plant B 3.8.5-2 09/04/98

DC Sources - Shutdown B 3.8.5

BASES ACTIONS A.2-.1. A.2.2. A.2.3. and A.2.4 (continued)

The Completi.on Time of immediately is consistent with the 11 11 required times for actions requiring prompt attention. The restoration of the required DC power sources should be completed as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient control and Preferred AC power.

SURVEILLANCE SR 3.8.5.1 REQUIREMENTS SR 3.8.5.1 requires the SRs from LCO 3.8.4 that are necessary for ensuring the OPERABILITY of the AC sources in MODES 5 and 6.

The SRs from LCO 3.8.4 which are required are those which can be performed without affecting the OPERABILITY or reliability of the required DC source. With only one battery available, loading tests cannot be performed since their performance would render that battery inoperable during the test. This is the case for SRs 3.8.4.7 and 3.8.4.8.

REFERENCES None

Palisades Nuclear Plant B 3.8.5-3 09/04/98

Battery Cell Parameters B 3.8.6

3.8 ELECTRICAL POWER SYSTEMS B 3.8.6 Battery Cell Parameters BASES BACKGROUND This LCO delineates the limits on electrolyte temperature.

level, float voltage, and specific gravity for the DC power source batteries. A discussion of these batteries is provided in the Bases for LCO 3.8.4, "DC Sources -

Operating."

APPLICABLE A description of the Safety Analyses applicable for SAFETY ANALYSES MODES 1 2, 3, and 4 is provided in the Bases for LCO 3.8.1, 1

"AC Sources - Operating"; during MODES 5 and 6 in the Bases 1

for LCO 3.8.2, "AC Sources - Shutdown."

Battery cell parameters satisfy Criterion 3 of 10 CFR 50.36(c)(2) .

LCO Battery cell parameters must remain within acceptable limits to ensure availability of the required DC power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA.

Battery cell limits are conservatively established, allowing continued DC electrical system function even when Category A and B limits are not met.

The requirement to maintain the average temperature of representative cells above 70°F assures that the battery temperature is within the design band. Battery capacity is a function of battery temperature.

APPLICABILITY The battery cell parameters are required solely for the support of the associated DC power sources. Therefore, they are only required when the DC power source is required to be OPERABLE. Refer to the Applicability discussions in the Bases for LCO 3.8.4 and LCO 3.8.5, "DC Sources - Shutdown."

Palisades Nuclear Plant B 3.8.6-1 09/04/98

Inverters - Operating B 3.8.7 3.8 ELECTRICAL POWER SYSTEMS B 3.8.7 Inverters - Operating BASES BACKGROUND The inverters (ED-06, ED-07, ED-08, and ED-09) are the normal source of power for the Preferred AC buses. The function of the inverter is to provide continuous AC electrical power to the Preferred AC buses, even in the event of an interruption to the normal AC power distribution system. A Preferred AC bus can be powered from the AC power distribution system via the Bypass Regulator if its associated inverter is out of service. An interlock prevents supplying more than one Preferred AC bus from the bypass regulator at any time. The station battery provides an uninterruptable power source for the instrumentation and controls for the Reactor Protective System (RPS) and the Engineered Safety Features (ESF).

APPLICABLE A description of the Safety Analyses applicable in SAFETY ANALYSES MODES l, 2, 3, and 4 is provided in the Bases for LCD 3.8.l, "AC Sources - Operating."

Inverters are part of the distribution system and, as such, satify Criterion 3 of 10 CFR 50.36(c)(2).

LCD The inverters ensure the availability of Preferred AC power for the instrumentation required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA.

Maintaining the inverters OPERABLE ensures that the redundancy incorporated into the RPS and ESF instrumentation and controls is maintained. The four inverters ensure an uninterruptable supply of AC electrical power to the Preferred AC buses even if the 2400 V safety related buses are de-energized.

An inverter is considered inoperable if it is not powering the associated Preferred AC bus, or if its output voltage or frequency is not within tolerances .

Palisades Nuclear Plant B 3.8.7-1 09/04/98

Inverters - Operating B 3.8.7

BASES SURVEILLANCE SR-3.8.7.1 REQUIREMENTS This Surveillance verifies that the inverters are functioning properly and energizing the Preferred AC buses.

The verification of proper voltage and frequency output ensures that the required power is readily available for the instrumentation of the RPS and ESF connected to the Preferred AC buses. The 7 day Frequency takes into account indications available in the control room that alert the operator to inverter malfunctions.

REFERENCES None

Palisades Nuclear Plant B 3.8.7-3 09/04/98

Inverters - Shutdown B 3.8.8

3.8 ELECTRICAL POWER SYSTEMS B 3.8.8 Inverters - Shutdown BASES BACKGROUND A description of the inverters is provided in the Bases .for LCO 3.8.7, "Inverters - Operating."

APPLICABLE A description of the Safety Analyses applicable during SAFETY ANALYSES MODES 5 and 6 is provided in the Bases for LCO 3.8.2, "AC Sources - Shutdown."

Inverters are part of the distribution system and, as such, satisfy Criterion 3 of 10 CFR 50.36(c)(2).

LCO This LCO requires those, and only those, inverters necessary to support the Preferred AC buses required by LCO 3.8.10, "Distribution Systems - Shutdown," to be OPERABLE.

This ensures the availability of sufficient Preferred AC electrical power to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents and loss of shutdown cooling).

An inverter is considered inoperable if it is not powering the associated Preferred AC bus, or if its voltage or frequency is not within tolerances.

APPLICABILITY The inverters required to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies provide assurance that equipment and instrumentation is available to:

a. Provide coolant inventory makeup,

b. Mitigate a fuel handling accident,

c. Mitigate shutdown events that can lead to core damage, and Monitoring and maintaining the plant in a cold d*

shutdown condition or refueling condition.

Palisades Nuclear Plant B 3.8.8-1 09/04/98

Distribution Systems - Operating B 3.8.9 3.8 ELECTRICAL POWER SYSTEMS B 3.8.9 Distribution Systems - Operating BASES BACKGROUND The onsite Class lE AC, DC, and Preferred AC bus electrical power distribution systems are divided into two redundant and independent electrical power distribution trains. Each electrical power distribution train is made up of several subsystems which include the safety related buses, load centers, motor control centers, and distribution panels shown in Table B 3.8.9-1.

The Class lE 2400 V safety related buses, Bus lC and Bus lD, are normally powered from offsite, but can be powered from the DGs, as explained in the Background section of the Bases for LCO 3.8.1, AC Sources - Operating. Each 2400 V safety 11 11 related bus supplies one train of the Class lE 480 V distribution system.

The 120 V Preferred AC buses are normally powered from the inverters. The alternate power supply for the buses is a constant voltage transformer, called the Bypass Regulator.

Use of the Bypass regulator is governed by LCO 3.8.7, "Inverters - Operating. The bypass regulator is powered 11 from the non-Class lE instrument AC bus, Y-01. The Instrument AC bus is normally powered through an automatic bus transfer switch, an instrument AC transformer, and isolation fuses. Its normal power source is MCC-1. Loss of power to MCC-1 will cause automatic transfer of the Instrument AC bus to MCC-2.

There are two independent 125 V DC electrical power distribution subsystems.

APPLICABLE A description of the Safety Analyses applicable in SAFETY ANALYSES MODES 1, 2, 3, and 4 is provided in the Bases for LCO 3.8.1.

The distribution systems satisfy Criterion 3 of 10 CFR 50.36(c)(2).

Palisades Nuclear Plant B 3.8.9-1 09/04/98

Distribution Systems - Operating B 3.8.9 BASES APPLICABILITY The electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that AC, DC, and Preferred AC power is available to the redundant trains and channels of safeguards equipment, instrumentation and controls required to support engineered safeguards equipment in the event of an accident or transient.

Electrical power distribution subsystem requirements for MODES 5 and 6, and during movement of irradiated fuel assemblies are addressed in LCO 3.8.10, "Distribution Systems - Shutdown."

ACTIONS With one or more required AC buses, load centers, motor control centers, or distribution panels, except Preferred AC buses, in one train inoperable, the redundant AC electrical power distribution subsystem in the other train is capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because an additional failure in the power distribution systems could result in the minimum required ESF functions not being supported.

Therefore, the required AC buses, load centers, motor control centers, and distribution panels must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The second Completion Time for Required Action A.1 establishes a limit on the maximum time allowed for any combinations of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition A is entered while, for instance, a DC bus is inoperable and subsequently restored OPERABLE, the LCO may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This could lead to a total of 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months , since initial failure of the LCO, to restore the AC distribution system. At this time, a DC circuit could again become inoperable, and AC distribution restored OPERABLE.

This could continue indefinitely .

Palisades Nuclear Plant B 3.8.9-3 09/04/98

Distribution Systems - Operating B 3.8.9 BASES ACTIONS C.l (continued)

With one or more DC bus in one train inoperable, the remaining DC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF functions not being supported. Therefore, the required DC buses must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months by powering the bus from the associated battery or charger.

This 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months limit is more conservative than Completion Times allowed for the vast majority of components which would be without power and is a feature of the original Palisades licensing basis.

The second Completion Time for Required Action C.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single continuous occurrence of failing to meet the LCD. If Condition C is entered while, for instance, an AC bus is inoperable and subsequently restored OPERABLE, the LCD may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This could lead to a total of 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months , since initial failure of the LCD, to restore the Preferred DC distribution system. At this time, a AC bus could again become inoperable, and Preferred AC distribution restored OPERABLE. This could continue indefinitely.

The Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

This will result in establishing the "time zero" at the time the LCO was initially not met, instead of the time Condition C was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely .

Palisades Nuclear Plant B 3.8.9-5 09/04/98

Distribution Systems - Operating B 3.8.9

BASES ACTIONS (continued)

D.1 and D.2 If the inoperable distribution subsystem cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to an operating condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

E.1 Condition E corresponds to a degradation in the electrical distribution system that causes a required safety function to be lost. When more than one Condition is entered, and this results in the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation .

SURVEILLANCE LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

SR 3.8.9.1 REQUIREMENTS This surveillance verifies that the required AC, DC, and Preferred AC bus electrical power distribution subsystems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained.

For those buses which have undervoltage alarms in the control room, correct voltage may be verified by the absence of an undervoltage alarm.

For those buses which have only one possible power source and have undervoltage alarms in the control room, correct breaker alignment may be verified by the absence of an undervoltage alarm *

Palisades Nuclear Plant B 3.8.9-6 09/04/98

Distribution Systems - Shutdown B 3.8.10

3.8 ELECTRICAL POWER SYSTEMS B 3.8.10 Distribution Systems - Shutdown BASES BACKGROUND A description of the AC, DC, and Preferred AC bus electrical power distribution systems is provided in the Bases for LCO 3.8.9, "Distribution Systems - Operating."

APPLICABLE A description of the Safety Analyses applicable SAFETY ANALYSES during MODES 5 and 6 is provided in the Bases for LCO 3.8.2, "AC Sources - Shutdown."

The distribution system satisfy Criterion 3 of 10 CFR 50.36(c)(2).

LCO This LCO requires those, and only those, AC, DC, and Preferred AC distribution subsystems to be OPERABLE which

are necessary to support equipment required by other LCOs.

Maintaining these portions of the distribution system energized ensures the availability of sufficient power to operate the plant in a safe manner to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).

APPLICABILITY The electrical power distribution subsystems required to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies, provide assurance that equipment and instrumentation is available to:

a. Provide coolant inventory makeup,

b. Mitigate a fuel handling accident,

c. Mitigate shutdown events that can lead to core damage, and

d. Monitoring and maintaining the plant in a cold shutdown condition and refueling condition .

Palisades Nuclear Plant B 3.8.10-1 09/04/98

Distribution Systems - Shutdown B 3.8.10 BASES APPLICABILITY Thls LCO is applicable during movement of irradiated fuel (continued) assemblies even if the plant is in a condition other than MODE 5 or 6. This LCO provides the necessary ACTIONS if the electrical power distribution subsystems required by this LCO become unavailable during movement of irradiated fuel assemblies.

The electrical power distribution subsystem requirements for MODES l, 2, 3, and 4 are addressed in LCO 3.8.9, "Distribution Systems - Operating. 11 ACTIONS Since the distribution systems are only required to support features required by other LCOs, the option to declare those affected required features to be inoperable assures that appropriate ACTIONS will be implemented in accordance with the affected LCOs.

A.2.1. A.2.2. A.2.3. A.2.4. and A.2.5 Required Action A.1 may involve undesired and unnecessary administrative efforts, therefore, Required Actions A.2.1 through A.2.5 provide alternate, but sufficiently conservative, actions.

Required Actions A.2~1, A.2.2, A.2.3, and A.2.5 require suspension of CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions, and declaration that affected shutdown cooling trains are inoperable. The suspension of CORE ALTERATIONS and movement of irradiated fuel assemblies does not preclude actions to place a fuel assembly in a safe location; the suspension of positive reactivity additions does not preclude actions to maintain or increase reactor vessel inventory provided the required SHUTDOWN MARGIN is maintained.

These ACTIONS minimize the probability or the occurrence of postulated events. It is further required (Required Action A.2.4) to immediately initiate action to restore the required distribution subsystems (and to continue this action until restoration is accomplished) in order to provide the necessary electrical power to the plant safety systems.

Palisades Nuclear Plant B J.8.10-2 09/04/98

3. 8 .J ELECTRICAL POWER SYSTEMS TESTS ~

AC Power Sources - Operating (continued)

Sf3.-Z.\, 4.7.l.8 Verify that each OG, operating at a power factors 0.9, does not trip, and voltage is maintained s 4000 V during and following a load rejection of~ 2300 and s 2500 kW; each 18 months.

~R3.8,l.7 4.7.l.9* Verify;- each 18 months; on an actual or simulated loss of offsite power:

a. De-energization of emergency buses;

b. Load shedding from emergency buses;

c. OG auto-starts from standby condition and:

1. Energizes permanently connected loads in s 10 seconds,

2. Energizes auto-connected shutdown loads through the automatic load sequencer,

3. Maintains steady state voltage ~ 2280 and s 2520 V,

4. Maintains steady state frequency~ 59.5 ands 61.2 Hz, and

@ ~~ NoTC) 5. Supplies permanently connected loads for~ 5 minutes.

SR 3.f,I .~ 4.7.1.10 Verify, e?ch 18 months, that each OG operates at a power factor s 0.9 for ~ 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s:

a. For ~ 100 minutes loaded above its peak accident loading, and

b. For the remainder of the test loaded ~ 2300 and s 2500 kW .

.S~"3.g,\,q 4.7.1.11* Verify; each 18 months; that each DG:

a. Can be synchronized with offsite power while supplying its associated 2400 volt bus upon a simulated restoration of offsite power;

b. Can transfer loads to an offsite power source; and

c. Can be returned to ready-to-load operation.

4.7.1.12* Verify the time of each sequenced load is within +/- 0.3 seconds of the design timing for each automatic load sequencer; each 18 months.

These tests must be performed in COLO SHUTDOWN or REFUELING SHUTDOWN .

4-43 Amendment No. 60, ~. m, H-i, REVISED 09114191

3.<;?.3 3.~ ~ ELECTRICAL POWER SYSTEMS 3'-8.3 -a. 7.3"' PG Fuel 011 and Lube Oil Specifications Lc..o The-stored PG fuel oil and DG lube oi~ shall be within lim,\ts.:?* ~

OD *~Lo1li~S~""' tlnJ ~

Aop l icabil i ty Stot+*l'J°a- 0.11' S~S'/S'h~** ~

LC..O, Specification 3.7.3 applies when any OG is required to be OPERABLE.

Action Qoo ~ noN~ /JDTF >----@

3.7.3.A With stored fuel oil inventory< 23,700 and~ 20,110 gallons:

I. Restore stored fuel oil inventory to within limits; within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . .:<..OO /~()

l.Of\~ B 3.7.3.8 ~ and ~gallons:

With stored lube oil inventory < \4L3I '~ r;:i7}

~

1. Restore the lube oil inventory to within limits; within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

G,,,ei( ~ 3.7.3.C With stored fuel oil viscosity, or water and sediment not within limits:

1. Declare both DGs inoperable, immediately.

3.7.3.0 With stored fuel oil properties other than viscosity, and water and sediment not within limits:

1. Restore stored fuel oil properties to within limits; within 30 days.

3.7.3.E If any action required by 3.7.3.A through 3.7.3.D is not met and the associated completion time has expired, or if Specification 3.7.3 is not met for reasons other than those addressed in 3.7.3.A, through 3.7.3.D:

1. Declare both OGs inoperable; immediately.

3-44 Amendment No.

REVISED 091114191

~

t- ELECTRICAL POWER SYSTEMS TESTS I .7.2 4.7.2.1 Ver. fy each AC power source requir by Specification 3.7.2 is the following surveillance. C edit may be hat satisfy a surveillance req rement.

4.7.1.1, 4.7.1.2, 4.7.1.4, 4.7.1.5, (see 3.K?-)

4.7.1.6, DG Fuel Oil and Lube Oil Verify that the fuel oil and lube oil for each required DG is adequate by the following surveillance:

451. 3.1. '3. \ 4. 7. 3. 1 Verify that the Fuel Oil Storage Tank contains~ 23,700 gallons of fuel; each 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . 2oO ~

SR'3*!:a.'2. 4.7.3.2 Verify stored lube oil inventory is ~~gallons; each 31 days.~

Si.. 3,2'.'3.3 4.7.3.3 Verify properties of new fuel oil and stored fuel oil are tested in accordance with, and maintained within the limits of, the Fuel Oil Testing Program, Specification 6.5.11.

Si 3. i.3 *5 4. 7. 3. 4 Check for and remove excess accumulated water from the Fuel Oil Storage Tank; each 92 days.

4-43b Amendment No.

REVISED 091'04191

3.~~ ELECTRICAL POWER SYSTEMS ~

3.~ ,q 3.7.9 Distribytion Systems - Operating Specifications The left and right trains of AC, DC, and Preferred AC power distribution

______/fii7' subsys~ems(i9stid iR Iabli 3 ' 9-l~hall be OPERABLE. !

Aoplicability ~ j

ication 3.7.9 applies when the PCS is~~~~~~ ~I c~ A 3.7.9.A With one or more subsystems of one AC electrical power distribution 1 train inoperable: ~ 1

1. 6e11119ly Hitn 3.7.9.E, if applieable, a111d ~~ I1 2.

3.7.9.B With one Preferred AC bus inopera e: R*Z L Ca11113ly w;th 3 7 9.E. jf appljqhle 1 an~

~J C 3.7.9.C

2.

status; within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . ~.u. 1 Restore the DC electrical ~stribution train to

~low!}-- '8 OPERAS~

~ !) 3.7.9.D If the action required by 3.7.9.A, through 3.7.9.C is not met and the associated completion time has expired: ~

1. The reactor shall be placed in HOT SHUTDOWN; within ~~hours, a~

~

S (lwo Of mot) 2.

1 The reactor shall be placed in COLD SHUTDOWN: within ~~rs.

'"~--M.1

~~ 3.7.9.E ~ino~erable distribution subsystem that results in a~s of a

~nct1on:

I. Enter Specification 3.0.3; immediately.

(!n~4 ~)<.a.ho~:

.:/- /~ tTvrs d;sCdvu1

§)

~

, I {8t.; I t.1 rt- ft> tn.lle-f LW 3-45f Amendment No .

I REVISED 09104191

3.~ ~ ELECTRICAL POWER SYSTEMS @ A.I

3. g, tV g.~.10 .... 7 .16 Distribution Systems - Shutdown Sgecifications The necessary portion of AC, DC, and Preferred AC electrical power distri~ution subsystems listed in Table 3.7.9-1 shall be OPERABLE to support equipment required to be OPERABLE.

Apglicability Specification 3.7.10 applies when the plant is-4.'~:et::~~~~.....Q.l"

-REFl:!ELINS Slll:HBeWN witlt real i11 Hie 1eaete12 1 and during movement of irradiated fuel assemblies.

Action 3.7.10.A With one or more required AC, DC, or Preferred AC electrical power distribution subsystems inoperable, immediately initiate action to:

1. Declare affected required features supplied by an inoperable distribution subsystem to b~~2~~N 0\

2 .1. Suspend REFtJELirH1 ePER;\+t-fl~IS;i -~ ~

2.2. Suspend movement of irradiated fuel assemblies, and 2.3. Suspend operations involving positive reactivity additions, and 2.4. Restore the required AC, DC, and Preferred AC electrical power distribution subsystems to OPERABLE status, and 2.5. Declare affected required shutdown cooling trains inoperable.~

I ADD~ A~ ll.b+ ~

<1N olt.ro.+ton I 3-45h Amendment No.

I of . 2-REVISED 09J04191

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.8.1, AC SOURCES - OPERATING LESS RESTRICTIVE CHANGES - REMOVAL OF DETAILS TO LICENSEE CONTROLLED DOCUMENTS (LA)

LA.1 CTS Action 3. 7 .1. F requires inoperable automatic DG load sequencers to immediately result in considering the associated DG inoperable. This statement of operability is not required to be explicitly within the ITS actions. Attributes of operability are relocated to the ITS LCO Bases for LCO 3.8.1. This detail of a support system required for DG operability can be adequately controlled within the Bases where revisions are governed by the Administrative Controls Section for Bases Control Program and 10 CFR 50.59. This level of detail remaining being located within the Bases in lieu of an explicit ITS Action is consistent with NUREG-1432.

LA.2 CTS 4. 7 .1 presents a Surveillance Note ("Credit may be taken for unplanned events ... ") that applies globally to AC power source tests. The CTS Note is specifically needed only for those Surveillance that have restrictions associated with the operations Modes in which they are allowed to be performed. Since CTS 4. 7 .2.1 contains no restrictions, the fundamental allowance is applicable without any necessity for an explicitly statement. This fundamental allowance is stated in the ITS Bases for SR 3.0.1. This detail for the method of application can be adequately controlled within the Bases where revisions are governed by the Administrative Controls Section for Bases Control Program and 10 CFR 50.59. This level of detail remaining being located within the Bases in lieu of an explicit ITS SR is consistent with NUREG-1432.

LESS RESTRICTIVE CHANGES (L)

L.1 CTS Action 3. 7. l .B.4 requires restoration of an inoperable DG within 7 days cumulative time in any calendar month. ITS Required Action B.4 limits the restoration time of any inoperability to 7 days (except as further restricted by the Completion Time added in accordance with Discussion of Change M. l), without tracking cumulative time. This change imposes both more restrictive possibilities as well as less restrictive. CTS actions have the potential to allow a 14-day continuous DG outage in the event the inoperability begins with 7 days remaining in a calendar month; allowing. those 7 days followed by the first 7 days in the next calendar month.

Eliminating this allowance in the ITS is considered more restrictive. The less restrictive aspect of the ITS is the allowance to have two or more separate DG inoperabilities in any one calendar month that cumulatively could exceed 7 days which is not allowed by the CTS.

Palisades Nuclear Plant Page 3 of 4 09/04/98

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.8.1, AC SOURCES - OPERATING LESS RESTRICTIVE CHANGES (L)

L.1 (continued)

Tracking cumulative outage time is not included in the ISTS since it is not a function of Operability. Instead, tracking cumulative outage time is a function of "availability." Early custom technical specifications attempted to limit the time diesel generators were unavailable by specifying cumulative outage time in the specifications. Conversely, a literal application of standard technical specifications would allow extended periods of diesel generator unavailability by an iterative process of declaring an inoperable diesel "Operable" followed by another period of inoperability. Subsequent to the issuance of standard technical specifications, the NRC promulgated two rules (10 CFR 50.63, "Loss of all Alternating Current Power" and 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants") which mandated (in part) that controls be instituted to limit the time diesel generators are unavailable. In response to 10 CFR 50.63, the Palisades plant established an Emergency Diesel Generator Reliability Program to

ensure diesel reliability is monitored and maintained above a reliability target level of 0.95. This value is also used as a performance goal for diesel generator reliability under the requirements of 10 CFR 50.65. The elements of Emergency Diesel Generator Reliability Program are consistent with the guidance of Regulatory Guide 1.155, "Station Blackout" and NUMARC 87-00, "Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors."

The 7 day cumulative time in any calendar month requirement in the CTS would permit a maximum diesel generator unavailability of approximately 0.77. However, due to the commitments associated with the requirements of 10 CFR 50. 63 and 10 CFR 50.65 to maintain a diesel generator reliability target level of 0.95, the overall availability of the Palisades plant diesel generators is significantly greater than 0.77 (the current availability for the emergency diesel generators is 99.03 for one diesel, and 99.1 % for the other). Since the requirements of the CFRs mandate higher levels of diesel generator availibility than the CTS, excluding cumulative outage time in the ITS can be made without a significant impact on the health and safety of the public. Elimination of tracking outage time against a cumulative limit is consistent with NUREG-1432.

Palisades Nuclear Plant Page 4 of 4 09/04798

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR ADMINISTRATIVE CHANGES (A)

A.1 All reformatting and renumbering are in accordance with NUREG-1432. As a result, the Technical Specifications (TS) should be more readily readable, and therefore understandable by plant operators as well as other users. The reformatting, renumbering, and rewording process involves no technical changes to existing Technical Specifications.

Editorial rewording (either adding or deleting) is made consistent with NUREG-1432.

During Improved Technical Specification (ITS) development certain wording preferences or English language conventions were adopted which resulted in no technical changes (either actual or implied) to the TS. Additional information has also been added to more fully describe each subsection. This wording is consistent with NUREG-1432. Since the design is already approved by the NRC, adding more details does not result in a technical change.

A.2 A Note is added to ITS 3.8.3 Actions allowing separate entry for each DG. This provides explicit instructions for proper application of the Actions for Technical Specifications compliance. In conjunction with proposed Specification 1. 3, "Completion Times," the Note provides direction consistent with the intent of CTS.

These changes are presentation preferences consistent with the NUREG-1432.

Therefore, this is an administrative change with no impact on safety.

A.3 CTS 3.7.3 has been modified to include the "fuel oil transfer system" and "starting air subsystem" in the text of the "Specification". This change has been made to establish a format consistent with the ISTS by specifying, in the LCO, the functional capability of DG support systems required for the safe operation of the facility. This change does not add or delete any requirement to the CTS, but simply adopts a standard convention for specifying limiting conditions for operations. Therefore, this change is considered administrative in nature .

Palisades Nuclear Plant Page 1of2 09/04798

ATTACHl\.fENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR TECHNICAL CHANGES - MORE RESTRICTIVE (M)

M.1 CTS 4.7.3.2 verifies the inventory of stored lube oil is ~ 175 gallons each 31 days.

CTS 3.7.3.B requires that actions be taken when the inventory of stored lube oil is< 175 and 2 150 gallons. Proposed ITS SR 3.8.3.2 verifies the inventory of stored lube oil is 2 200 gallons. Proposed ITS 3.8.3 Condition B requires that actions be taken when the inventory of stored lube oil is < 200 and > 160 gallons. The quantity of stored lube oil in the ITS has been revised from the quantity required in the CTS as a result of data recently obtained related to diesel generator lube oil consumption. The inventory of stored lube oil is based on amount of lube oil necessary to support full load diesel generator operation for at least 7 days. The CTS value of 175 gallons was based on an estimated consumption rate of 1 gallon per hour which is representative of large type diesel engines. Empirical data derived during a recent test of a Palisades plant diesel engine test concluded that the actual lube oil consumption rate was approximately 0.83%. Values between 0.8% and 1.0% have been confirmed to be acceptable by the engine vendor. As a result of this test, and to ensure an adequate inventory of lube oil is available to support diesel engine operations, the quantity of stored lube oil required in the ITS has been increased to 200 gallons. A stored inventory of200 gallons, together with the lube oil in the engine sump, will ensure an adequate amount of lube oil will be available to support full load diesel generator operation for at least 7 days in the event of an accident. This change has been characterized as "more restrictive" and is considered acceptable since it continues to preserve the original basis for stored lube oil contained in the CTS.

LESS RESTRICTIVE CHANGES - REMOVAL OF DETAILS TO LICENSEE CONTROLLED DOCUMENTS (LA)

There were no "Removal of Detail" changes associated with this specification.

LESS RESTRICTIVE CHANGES (L)

There were no "Less Restrictive" changes associated with this specification.

Palisades Nuclear Plant Page 2 of 2 09/04/98

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.8.4, DC SOURCES - OPERATING LESS RESTRICTIVE CHANGES - REMOVAL OF DETAILS TO LICENSEE CONTROLLED DOCUMENTS (LA)

LA.1 CTS 3. 7.4 and 4. 7.4. 6 detail the plant equipment designators for the DC electrical power trains. ITS 3.8.4 simply requires the operability of the DC electrical power trains, and relocates the details of what comprises the trains to the Bases and FSAR.

Since these details are not necessary to adequately describe the actual regulatory requirement, they can be moved to a licensee controlled document without a significant impact on safety. Placing these details in the Bases of ITS 3.8.4 and the FSAR provides adequate assurance that they will be maintained. The Bases are controlled by the Bases Control Process in Chapter 5 of the proposed Technical Specifications, and the FSAR is controlled by 10 CPR 50.59. This change is consistent with NUREG-1432.

LESS RESTRICTIVE CHANGES (L)

L.1 CTS 3. 7.4 specifies the requirements for DC source when the plant is above Cold Shutdown. CTS 3.7.4 Actions A.1 require the cross-connected charger(s) for the affected battery be placed in service immediately whenever one required charger is inoperable. CTS 3.7.4 Action B.l requires both chargers for the affected battery be placed in service immediately whenever one battery is inoperable. The CTS does not specify an Action when one charger and one battery in one train are inoperable concurrently. Thus, the provisions of LCO 3.0.3 are applied. In the ITS, the inoperability of a charger, a battery, and a charger and battery in one train concurrently, are addressed by Conditions A, B, and C, respectively. The Completion Times for Conditions A, B, and C are equally stated at 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months since these conditions are ones where DC power continues to remain available to the bus, albeit with inoperable sources. Selection of the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is consistent with that previously approved for the more degraded condition of one de-energized DC electrical distribution train allowed by CTS 3.7.9.c. With one DC electrical distribution train de-energized, the remaining DC electrical train is capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe condition. Since ITS 3.8.4 represents a configuration of the DC electrical system that is less severe and presents less risk for a loss of function than that allowed by CTS 3.7.9.c (proposed ITS 3.8.9), an extension of the Completion Times to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months can be made without a significant risk to public health and safety. An extension of the Completion Times for "DC Source-Operating" to match the Completion Times for (DC) "Distribution Systems-Operating'~ is consistent with the philosophy presented in NUREG-1432.

Palisades Nuclear Plant Page 2 of 3 09/04798

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.8.9, DISTRIBUTION SYSTEM - OPERATING ADMINISTRATIVE CHANGES (A)

A.l All reformatting and renumbering are in accordance with NUREG-1432. As a result, the Technical Specifications (TS) should be more readily readable, and therefore understandable by plant operators as well as other users. The reformatting, renumbering, and rewording process involves no technical changes to existing Technical Specifications.

Editorial rewording (either adding or deleting) is made consistent with NUREG-1432.

During Improved Technical Specification (ITS) development certain wording preferences or English language conventions were adopted which resulted in no technical changes (either actual or implied) to the TS. Additional information has also been added to more fully describe each subsection. This wording is consistent with NUREG-1432. Since the design is already approved by the NRC, adding more details does not result in a technical change.

A.2 CTS 3.7.9.A.1, B.1, and C.l specify an action that informs the operator to comply with other required actions is necessary. Since these other required actions are required to be met regardless of this statement, this statement does not provided specific action. It therefore serves solely as an informational note, which does not

appear in ITS. As such, its removal is an administrative editorial presentation preference with no technical change or change in intent. This change is consistent with NUREG-1432.

A.3 CTS 3.7.9.E requires immediate entry into specification 3.0.3 "with any inoperable distribution subsystem that results in a loss of a safety function. " ITS 3. 8. 9 Condition E requires immediate entry into LCO 3.0.3 when "two or more inoperable subsystems result in a loss of function." The requirements of the CTS and ITS are essentially equivalent. That is, both specifications require a plant shutdown when a loss of safety function exists due to degradation of the electrical distribution system.

The difference in language between CTS 3.7.9.E and ITS 3.8.9 Condition Eis due to the application of the technical specification usage rules and treatment for a loss of safety function. (See Chapter 3.0 of the Palisades ITS conversion submittal for a discussion related to the inclusion of ITS LCO 3.0.6) Since the proposed wording does not alter the original intent of the CTS, this change has been characterized as administrative in nature .

Palisades Nuclear Plant Page 1of2 09/04798

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.8.9, DISTRIBUTION SYSTEM - OPERATING TECHNICAL CHANGES - MORE RESTRICTIVE (M)

M .1 CTS 3. 7. 9. D requires that if inoperable components are not restored to OPERABLE status then the reactor shall be placed in a hot shutdown condition within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and cold shutdown within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . In the proposed ITS, the requirement is to place the plant in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The CTS HOT SHUTDOWN is nominally equivalent to the proposed ITS MODE 3 as discussed in Section 1.1 and therefore, there is little effect in adopting the proposed ITS MODE 3 parameters. However, adopting the proposed ITS shutdown times is considered to be more restrictive, but continues to allow sufficient time to shutdown the plant in a safe and controlled manner. This change is consistent with NUREG-1432.

M.2 CTS 3.7.9 Actions for restoration of an inoperable power distribution subsystems, do not impose limitations for overlapping combinations of inoperable AC, DC and Preferred AC subsystems. ITS Required Actions A.1, B.1 and C. l include a requirement for restoration of all subsystems to operable status within 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months of initial failure to meet the LCO requirement. These added Completion Times assure that alternating inoperabilities in AC, DC and/or Preferred AC subsystems will not continue indefinitely without complete restoration to compliance with the LCO. The 16-hour Completion Time is reasonable to assure timely restoration. This Completion Time is consistent with the NUREG-1432.

LESS RESTRICTIVE CHANGES - REMOVAL OF DETAILS TO LICENSEE CONTROLLED DOCUMENTS (LA)

LA.1 CTS 3.7.9, and Table 3.7.9-1, detail the plant equipment designators for the AC, DC and Preferred AC distribution subsystems. ITS 3.8.9 simply requires the operability of the subsystems, and relocates the details of the plant-specific designators to the Bases and FSAR. Since these details are not necessary to adequately describe the actual regulatory requirement, they can be moved to a licensee controlled document without a significant impact on safety. Placing these details in the Bases of ITS 3. 8. 9 and the FSAR provides adequate assurance that they will be maintained. The Bases are controlled by the Bases Control Process in Chapter 5 of the proposed Technical Specifications, and the FSAR is controlled by 10 CFR 50.59. This change is consistent with NUREG-1432.

LESS RESTRICTIVE CHANGES (L)

There were no "Less Restrictive" changes a~ociated with this specification .

Palisades Nuclear Plant Page 2 of 2 09/04/98

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN ADMINISTRATIVE CIJANGES (A)

A.1 All reformatting and renumbering are in accordance with NUREG-1432. As a result, the Technical Specifications (TS) should be more readily readable, and therefore understandable by plant operators as well as other users. The reformatting, renumbering, and rewording process involves no technical changes to existing Technical Specifications.

Editorial rewording (either adding or deleting) is made consistent with NUREG-1432.

During Improved Technical Specification (ITS) development certain wording preferences or English language conventions were adopted which resulted in no technical changes (either actual or implied) to the TS. Additional information has also been added to more fully describe each subsection. This wording is consistent with NUREG-1432. Since the design is already approved by the NRC, adding more details does not result in a technical change.

A.2 CTS 3.7.10.A contains the actions to be taken when one or more required AC, DC, or Preferred AC electrical power distribution subsystems are inoperable. CTS 3.7.10.A action 2.5 states to "declare affected required shutdown cooling trains inoperable." In the ITS, the corresponding action is Required Action A.2.5 which states "declare associated required shutdown cooling train inoperable and not in operation." Required Action A.2.5 contains the phrase "and in operation" which is not in the CTS. The inclusion of this phrase assures the appropriate actions are taken in the event primary coolant circulation and heat removal functions are lost as a result of an electrical distribution system inoperability. In this instance, reliance on LCO 3.0.6 would be inappropriate. This change is considered administrative in nature since it does not alter an existing requirement in the CTS, but simply addresses each aspect (i.e., Operable, and in operation) related to a loss of the shutdown cooling function.

TECHNICAL CHANGES - MORE RESTRICTIVE (M)

There were no "More Restrictive" changes associated with this specification.

Palisades Nuclear Plant Page 1of2 09/04/98

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN LESS RESTRICTIVE CHANGES - REMOVAL OF DETAILS TO LICENSEE CONTROLLED DOCUMENTS (LA)

There were no "Removal of Details". changes associated with this specification.

LESS RESTRICTIVE CHANGES (L)

There were no "Less Restrictive" changes associated with this specification .

Palisades Nuclear Plant Page 2 of 2 09/04/98

AC Sources-Operating

3. 8. l SURVEILLANCE RE UIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.l.3 Momentary transients outside the load range do not invalidate this test.

This Surveil~ance shall be conducted on only one OG at a time.

This SR shall be preceded by and i!Tlllediately follow without shutdown a successful performance of SR 3.8.1.Z 91' iR 3 a l 7, F""' ~ I :> ff\i f\ IA \<s

\oa~ed to ~reaw frtAv. "re~i.t.~ ~ ptak etcc:.i ~.w.\ lo"'~' 11 "~ Tiele 6.8.l 1 b, F;-r +N (.tMai() ~

o.(:~

+<.-s. t" SR 3 .8.1. 4 Verify each day tank.[aAa eRgiRe lfteijftted- 31 days

-t-eMt contains ~ of fuel oil.

CD \\o-U e fuel oil tran fer system (92] days to [automatic ly] transfer fu otl f storage tank ] to the day ta

[and ng1ne mounted nk].

(continued)

CEOG STS 3.8-7 Rev 1, 04/07/95

REVISED 09104191

AC Sources-Operating

3. 8. l

SURVEILLANCE RE UIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.ftj* ----- ----------- OTES------- ----------

1. his Surveil ance shall n be performed i MODE 1 or 2 However, credit ma be taken for nplanned events t t satisfy th"s SR.

If pe armed with t DG synchro with offsite power it .shall be per armed at a po r factor s Verify each DG rejects a load greater than ~18 months,(_

or equal to its associated single largest "-

post-accident load, and:

a. Following load rejection, the frequency is s ~ Hz; c,g

b. Within b(,3~secon s following load rejection, the voltage is ~ ~~ V ands~; and ~

2'14

c. Within~ seconds following load rejection, the frequency is

~~Hz and s~Hz.

~ ~

cr5 i.+.J.r.Z (continued)

CEOG STS 3.8-9 Rev 1, 04/07/95 REVISED 09J04J91

Diesel Fuel@, Lube Oil, and Starting Air 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel~ Lube Oil, and Starting Air LCO 3.8.3 1es 1 or each requ1re iesel enerator (OG el: x a.. 7h°' o+crid d1c.M~1.l.01t,JtJh,01l.. Q.,.cl S~fl~ (A.,,. SvMtlk.#'J Sha.II b'4, (.U ~II\ /1 rn I +J l Q, '(IJ {J lo.. ~o+il dn.M C111.L 01L +"'°""~'" 111r+c.t11J Si'lo.11 ~~ O~l.l.*

APPLICABILITY: ihen associated OG is required to be OPERABLE.

ACTIONS

~-------------------NOTE-------------------------------------

Separate Condition entry is allowed for each DG.

-~--------**************&*****************************************************

CONDITION REQUIRED ACTION COMPLETION TIME CT) 3.7,J.A A. Restore fuel oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months

.--rl!!'T to with i n limits.

B. ~~

1 ;T Restore u e 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months inventory to within limits.

G Ci5 c. c.1 3,7,1.C:,

cbi

\). FiAd ~/4!r S)sftf4 (), I Rt,~M ~l~s~ (continued) c-rs 3I1, \ I 14 (P-1t8)11t~IJJ'4.. s-yd*w. -fa oPffUce lE. 7do.y5 s+ca.-Ns.

l TS f. B~ .fu..ei~~ E.1 R~s~~~~ 8 ltloffS 3.r. I* I" ~ s+ou i.. oper~llle .. fr'O."'-.S ~ ~ys+e.M.

CEOG STS 3.8- +o ol'EllMLE

.stc-.-hl 1

REVISED 09i'04191

Die:.~l Fuel Oil, Lube Oil, and Starting Air 3.8.3 ACTIONS continued CONDITION REQUIRED ACTION COMPLETION TIME r;::\ n,/ ene

~* ~...ruel

~ 11101"~ 863 011 Ni t:h- ft? Restore stored fuel oil properties to 30 days f'i;\ properties ~n~o:7-t....;w~i....;;,t~hi7n:__..__ _. . . .:. w.:. .:t::h~i i :.:.n. . :l..:.i t~s..:..:---~:+---:-:--....._

.

.mi.: ..:*

V limits. otlt.w ~ vislDSi 'GIM.c( wa...+u- ~ ud,*~Y1 One or 110 OGs with ting air startin air rec1iver receiver ressure to e < [2ZS] psi psig.

[125} psig.

@Y* Required Action and associated Completion Declare associated OG inoperable.

Irrmediately C.TS Tille not met.

3,7, 3' c.

3 ,7, 3, E

One or more OGs with diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than Condition A, B,~

~F.

SURVEIL IR£MENTS SURVEILLANCE FREQUENCY C\.S SR 3.8.3.l

~.1.3.1 (continued)

CEOG STS 3.8-23 Rev 1, 04/07/95 REVISED 09/04191

Distribution Systems-Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 01s~ribut1on Systems-Operating

@ ~ ~~

LCO 3.8.9 .\Train X and~ AC, DC, and AC:it.l'ObUs electrical power distribution subsystems shall be OPERABLE.

CT) 3.7,'f APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Ona AC electrical A.I Restore AC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 1\A I power distribution power distribution J.11::- o I subsyst~o~erable. subsyste~PERABLE ANO status. (.1) l f'\ Of" frt..1i\ 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from )(

discovery of failure to meet LCO Pr.L~ru

(?41

'i 'J -~S'-O, Restore c~ (1) hours y 9- Jtilss) s tell to OPERABLE status. ANQ 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO

"""" ftll.H'.(,,, ,zAI c.1s

. One DC 11.ctr1ca1 power d1str1but1on C. l Restore DC electrical power distribution ours jJ.9-Q3 3.7.q.c.. subsyst~~operable. subsyst..~ OPERABLE ANQ status. )

16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from K In One. -ft'u.1n discovery of failure to meet LCO (continued)

CEOG STS 3.8-39 Rev 1, 04/07 /95 REVISED 09/04198

ATTACHMENT6 JUSTIFICATIONS FOR DEVIATIO NS SPECIFICATION 3.8.1, AC SOURCES - OPERATING Discussion NOTE: This attachment provides a brief discussion of the deviations from the Technical Specifications of NUREG-1432 that were made to support the development of the Palisades Nuclear Plant ITS. Due to the recent CTS amendment request, which proposed NUREG - like Bases for Section 3. 8, three additional attachment have been provided. Attachment 7 is a markup of the CTS Bases showing the difference between CTS and proposed ITS Bases.

Attachment 8 provides an explanation of these differences. Attachment 9 provides a markup of NUREG-1432, Section 3.8 Bases. Therefore, the JFDs are provided against changes to the CTS Bases, rather than as typically done against the NUREG Bases.

The Change Numbers correspond to the respective deviation shown on the "NUREG MARKUPS." The first five justifications were used generically throughout the markup of the NUREG. Not all generic justifications are used in each Specification.

1. The brackets have been removed and the proper plant specific information or value has been provided.

2. Editorial change for clarity or for consistency with the Improved Technical Specifications (ITS) Writer's Guide.

3. The requirement/ statement has been deleted since it is not applicable to this facility.

The following requirements have been renumbered, where applicable, to reflect this deletion.

4. Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect the facility specific nomenclature, number, reference, system description, or analysis description.

5. This change reflects the current licensing basis/technical specifications.

Palisades Nuclear Plant Page 1of4 09704798

ATTACHMENT6 JUSTIFICATIONS FOR DEVIATIONS SPECIFICATION 3.8.1, AC SOURCES-OPERATING Discussion

6. The option to specifically list automatic load sequencers as a third type of AC Source, and provide a separate Action, is not adopted. Sequencers are not a separate source of AC power; rather they are a support component for the DG function. As such they are implicitly required to be Operable by the requirement for DG Operability (as detailed in the ITS Bases). Similarly, when discovered inoperable, the Actions for an inoperable DG apply without having to state so explicitly.

NUREG-1432 Bases support this. The Reviewer's Note in the Bases for Required Action F .1 indicates that the specific condition related to the sequencer may be deleted "if the unit design is such that any sequencer failure mode will only affect the ability of the associated DG to power its respective safety loads under any conditions." In the design of the Palisades plant, failure of an automatic load sequencer does not result in the inability to start all or part of the safety loads from the offsite power circuits when required, or result in overloading the offsite power circuits to a safety bus during an event. The automatic load sequencers are not shared with the offsite power circuits, nor are they required to support the loading of the 2400 V Class lE buses when those buses are being supplied by offsite power.

Therefore, inclusion of an explicit Condition, Required Action, and Completion Time for an inoperable automatic load sequencer is not required in the Palisades ITS.

7. The maximum time allowed to fail to meet the LCO is revised from 6 days to 10 days. The accepted NUREG-1432 practice for limiting successive alternating inoperabilities with this type of maxiffium time Completion Time, is to allow one full Complete Time for each of the associated component types. In this case, with the proposed Completion Times of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for an offsite circuit and 7 days for a DG, the maximum time is appropriately specified as 10 days.

8. The Palisades DG design does not incorporate "gradual acceleration" on a DG start.

NUREG-1432 presentation of SR 3. 8 .1. 2 Notes 1 and 3, and SR 3. 8.1. 7, are addressing this design feature. The proposed modifications to eliminate these Notes and the SR provides the appropriate presentation for the Palisades DG design.

9. The Palisades DG design does not incorpo_rate "gradual acceleration" on a DG start.

Similarly, NUREG-1432 SR 3.8.1.3 Note 1 states an allowance for "gradual loading." However, since there is no stated prohibition to gradual loading, and the surveillance itself does not impose and loading-rate criteria, this Note is informational only, and should be removed as a Technical Specification requirement.

Palisades Nuclear Plant Page 2 of 4 09/04798

Chanee Discussion ATTACHMENT6 JUSTIFICATIONS FOR DEVIATIONS SPECIFICATION 3.8.1, AC SOURCES - OPERATING

10. ISTS 3.8.1 Required Action A.2 is not retained; consistent with CTS. The Palisades design and requirements for operable offsite circuits ensures that each ESP bus will be energized if at least one circuit is operable. If any bus can not be energized, then both required offsite circuits would be declared inoperable.

The qualified offsite circuits required by ITS LCO 3. 8. 1 are Safeguards Transformer 1-1 and Startup Transformer 1-2. For an offsite circuit to be considered operable, it must be capable of supplying electrical power to both class lE electrical trains.

Inclusive in the requirement for operability is that the associated cables, instruments and breakers, necessary to provide a complete circuit from the switchyard to the onsite safety-related AC distribution system, are capable of performing their intended function. The normal lineup at Palisades, both during plant operation and shutdown, has both safety related 2400 volt AC buses supplied from Safeguards Transformer 1-

1. If protective relay actuation occurs for the Safeguards Transformer, both buses are automatically transferred to the alternate required offsite source, Startup Transformer 1-2.

As part of the Palisades plant design, with one offsite circuit inoperable, electrical power is still available to both class lE electrical trains since either the Safeguard Transformer 1-1, or the Startup Transformer 1-2 can be aligned to both safety-related 2400 V buses. Therefore, for either safety related 2400 volt bus to have "no offsite power available" as discussed under ISTS 3.8. l Required Action A.2, both offsite circuits would have to be inoperable. The condition of both offsite circuits being inoperable is covered under ISTS and ITS 3.8.1 Condition C, which includes the subject Required Action C.l, but with a reduced Completion Time. As such, Required Action A.2 of ISTS 3.8.1, which only applies when one electrical train cannot be powered from an offsite source, is not applicable to the Palisades ITS.

11. ISTS SR 3. 8 .1. 6 relates to surveilling the DG fuel oil transfer pumps. Palisades provides the appropriate plant specific fuel oil transfer pump surveillance in ITS 3.8.3, SR 3.8.3.6. This presentation preference is dictated by the plant specific current licensing basis allowing specified allowed Completion Times to repair inoperable transfer pumps prior to declaring a DG inoperable.

12. TSTF-8, Rev. 2 deleted the 3.8 SR Notes "However credit may be taken ... " and addressed that issue globally in the 3. 0 Bases. This presentation is consistent with NUREG-1432 .

Palisades Nuclear Plant Page 3 of 4 09/04798

ATTACHMENT6 JUSTIFICATIONS FOR DEVIATIONS SPECIFICATION 3.8.1, AC SOURCES - OPERATING Discussion

13. This change reflects the current licensing basis/technical specifications. The surveillance requirement for checking and removing accumulated water from each diesel generator fuel oil day tank was not adopted in the ITS (or the CTS) due to the design of these tanks. The tanks are constructed with flat bottoms and do not provide a sump for water collection or removal. Historic performance has shown that water accumulation in these tanks has not been a problem. A similar surveillance requirement for the Diesel Fuel Oil Storage Tank was incorporated in the CTS following replacement of the original storage tank with a new storage tank. The new Diesel Fuel Oil Storage Tank contains an integral sump for water collection and removal. Thus, the surveillance requirement to check and remove accumulative water was retained in the ITS for the Diesel Fuel Oil Storage Tank only.

14. This change reflects the current licensing basis/technical specifications. On April 29, 1998 the NRC issued Amendment 180 to the Palisades Plant operating license. The amendment revised the Technical Specification requirements and associated bases regarding the electrical power systems to closely emulate the Standard Technical Specifications for Combustion Engineering Plants, NUREG-1432, Revision 1. As part of this revision, new diesel generator surveillance tests were adopted including the tests which verify each diesel generator is capable of a load reject greater than or equal to its associated single largest post-accident load (ISTS SR 3. 8 .1. 9), and that each diesel generator is capable of a full load reject (ISTS SR 3. 8 .1. 10). These new surveillance requirements (CTS 4.7.1.7 and CTS 4.7.1.8) were issued without the note which states that the surveillance "shall not be performed in Mode 1 or 2.

Omission of this note was found acceptable by the NRC staff in their Safety Evaluation related to Amendment 180 which concluded that "performance of these SRs (4.7.1.7, 4.7.1.8, and 4.7.1.10) at power would not cause any undue transients on the Class lE distribution system." As such, Note 1 in ISTS SR 3.8.1.9 and ISTS SR 3.1.8.10 was not incorporated in the Palisades ITS.

Palisades Nuclear Plant Page 4 of 4 09/04798

DiScussion ATTACHMENT 6 JUSTIFICATION FOR DEViATIONS SPECIFICATION 3.8.4, DC SOURCES - OPERATING NOTE: This attachment provides a brief discussion of the deviations from the Technical Specifications of NUREG-1432 that were made to support the development of the Palisades Nuclear Plant ITS. For Section 3.8 ONLY, three additional attachment have been provided. Attachment 7 is a markup of the CTS Bases showing the difference between CTS and proposed ITS Bases.

Attachment 8 provides an explanation of these differences. Attachment 9 provides a markup of NUREG-1432, Section 3.8 Bases.

The Change Numbers correspond to the respective deviation shown on the "NUREG MARKUPS." The first five justifications were used generically throughout the markup of the NUREG. Not all generic justifications are used in each Specification.

1. The brackets have been removed and the proper plant specific information or value has been provided .

2.

3.

Editorial change for clarity or for consistency with the Improved Technical Specifications (ITS) Writer's Guide.

The requirement/statement has been deleted since it is not applicable to this facility.

The following requirements have been renumbered, where applicable, to reflect this deletion.

4. Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect the facility specific nomenclature, number, reference, system description, or analysis description.

Palisades Nuclear Plant Page 1of2 09/04798

ATTACHMENT 6 JUSTIFICATION FOR DEVIATIONS SPECIFICATION 3.8.4, DC SOURCES - OPERATING

5. This change refle~ts the current licensing basis/technical specifications as modified by I I

DOC L. l. ITS 3.8.4 has been developed to preserve the operational flexibility of the I I

CTS while maintaining a parallel structure to the ISTS. The design of the Palisade I I

plant DC electrical power system is such that each station battery has two associated I I

battery chargers, one powered by the associated AC power distribution system (the I I

I directly connected charger), and one powered from the opposite AC power I I

distribution system (the cross connected charger). CTS 3. 7.4 provides the actions I I

necessary to cope with a degraded DC electrical power system which results from an I I

inoperable charger or an inoperable battery using the design features (i.e., cross I I

connect capabilities) of the system. These same actions have been incorporated in I ITS 3.8.4. However, in NUREG-1432, ISTS 3.8.4 is structured such that the I restoration time for an inoperable DC electrical power subsystem (e.g., charger, or battery, or charger and battery) is equivalent to the allowed outage time for an inoperable DC electrical power distribution system. The basis for this structure is the recognition that a degraded DC electrical power source presents no more risk than an inoperable DC bus. Thus, to maintain this same logical structure in the Palisade's ITS, Condition C has been added to address the concurrent inoperabilities of a charger and battery in the same electrical train (in the ISTS, this same configuration would be addressed by Condition A).

6. TSTF-8, Rev. 2 deleted the 3.8 SR Notes "However credit may be taken ... " and addressed that issue globally in the 3.0 Bases. This presentation is consistent with NUREG-1432.

7. Incorporate TSTF-38 into SR 3.8.4.3 ~o specify the surveillance is to identify conditions which could degrade battery performance.

Palisades Nuclear Plant Page 2 of 2 09/04/98

ATTACHMENT 6 JUSTIFICATION FOR-DEVIATIONS SPECIFICATION 3.8.5, DC SOURCES - SHUTDOWN Change Discussion NOTE: This attachment provides a brief discussion of the deviations from the Technical Specifications of NUREG-1432 that were made to support the development of the Palisades Nuclear Plant ITS. For Section 3.8 ONLY, three additional attachment have been provided. Attachment 7 is a markup of the CTS Bases showing the difference between CTS and proposed ITS Bases.

Attachment 8 provides an explanation of these differences. Attachment 9 provides a markup of NUREG-1432, Section 3.8 Bases.

The Change Numbers correspond to the respective deviation shown on the "NUREG MARKUPS." The first five justifications were used generically throughout the markup of the NUREG. Not all generic justifications are used in each Specification.

1. The brackets have been removed and the proper plant specific information or value has been provided.

2. Editorial change for clarity or for consistency with the Improved Technical Specifications (ITS) Writer's Guide.

3. The requirement/statement has been deleted since it is not applicable to this facility.

The following requirements have been renumbered, where applicable, to reflect this deletion.

4. Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect the facility specific nomenclature, number, reference, system description, or analysis description.

5. This change reflects the current licensing basis/technical specifications. Only those SRs from specification 3. 8 .4 which can be performed without affecting the Operability or reliability of the only required DC source are specified. Since the performance of SR 3.8.4.7 and SR 3.8.4.8 would cause the only required battery to be inoperable during the test, these SRs have been excluded from SR 3. 8. 5 .1 .

Palisades Nuclear Plant Page 1of1 09/04798

AC Sources - Shutdown B 3.7.2 and 4.7.2 BASES An OPERABLE DG, associated with a distribution subsystem required to be OPERABLE by LCO 3 . . 10, ensures a diverse power source is available to provide electrical power support, assuming a loss of the offsite circuit.

Together, OPERABILITY of the required offsite circuit and DG ensures the availability of sufficient AC sources to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g.,

fuel handling accidents and loss of shutdown cooling).

The. DG must be capable of starting, accelerating to rated speed and voltage, connecting to its respective 2400 volt bus on detection of bus undervoltage, and accepting required loads. Proper "Normal Shutdown" loading sequence, and tripping of nonessential loads, is a required function for DG OPERABILITY. A Service Water Pump must be started soon after the DG to assure continued DG operability. The OBA loading sequence is not required to be OPERABLE since the Safety Injection Signal is disabled during ES~~S"'"~~

APPLICABILITY The AC sources required to be OPERABLE in eotc SntJTCO'Rff' !lEfi'l::!ELINS SI ll:JT88'1JN-,

and during movement of irradiated fuel assemblies provide assurance that equipment and instrumentation is available to:

a. Provide coolant inventory makeup, ~

b. Mitigate a fuel handling accident, ~ ~ ~

c. Mi t ~gate shutdown. eve~ts that can lea~ to ;oUamae: ~ ,., C~b\.1)1'\

d. ~on1 r an~ ~arntarn@) the plant rn * - ___ _ * ~.J'~~

cond 1t10n. /'\A c .r::-

, *~doc;; -;i 1

o ... "" o' This LCO is applicable during movement of irradiated fuel assemblies even i r~~~

the plant is in a condition other than t0LB Slll:JT8QUM eF ~i,.'dELH16 Slll:JT89Wrt: (.btd*'"

This LCO provides the necessary ACTIONS if the AC electrical power sources required by this LCO become unavailable during movement of irradiated fuel assemblies. (M;;~~ ~ 31 ~3 (V The AC source requirements for ililliivlii ~~~ICowi'are addressed in LCO 3.p, "AC Sources - Operating".

PALISADES B 3.7.2-2 Amendment No.

REVISED 09/04191

ELECTRICAL POWER SYSTEMS B 3.7.3 a::J 4 '3:' Diesel BASES BACKGROUND The .diesel "'nerators (DGs) are provided with a storage tank having a required fuef oil inventory sufficient to operate one diesel. for a period of 7 days, while the DG is supplying maximum post-accident loads. This onsite fuel oil capacity is sufficient to operate the OG for longer than the time to replenish the onsite supply from offsite sources.

Fuel oil is transferred from the Fuel Oil Storage Tank to i her day tank by either of two Fuel Transfer ~h*~ ~IJSf.i .1 (ll.6f, I)

For proper operation of the standby OGs, it is necessar to ensure the proper quality of the fuel oil. Regulatory Guide (RG) 1.137 a resses t e recommended fuel oil practices as supplemented by ANSI Nl95-1976~

The DG lubrication system is designed to provide sufficient lubrication to permit proper operation of its associated DG under all loading conditions.

The system is required to circulate the lube oil to the diesel engine working surfaces and to remove excess heat generated by friction during operation.

The onsite storage in addition to the engine oil sump is sufficient to ensure 7 days of continuous operation. This supply is sufficient supply to allow the operator to replenish lube oil from offsite sources. Implicit in this LCO is the requirement to assure, though not necessarily by testing, the capability to transfer the lube oil from its storage location to the DG oil sump, while the DG is running. !~I~5~T

2)

APPLICABLE SAFETY ANALYSES G/)io~E"S /1 2, 31 o..-;_-ol_'__Q f A description of the Safety Analyses applicable a~bQ SMIJTl39 1J~ 1 provided in the Bases for LCO 3.'f<:l "AC Sources - Operating"; during~

-sHl:JTB6Wl4 and REFWELH" illWTl3BWf+, Ii n the Bases for LCO 3 J..:..2 "AC Sou:ces -

Shutdown". (!} W

~1nu. d1c.1t.L ~L, Ike. 01L, o..NJ t>ia.M1,; ll~1~ +;,..

(

0 a.1;. 1.Joppdr-+-

~ ~A:.tb)riof\ Qt -I-re. f.lf.a.rdl.j AC.. fOfp4..- f)our<.t,~ 1 ff\e.y /Jo.oft f+j CR1-k.ri6tJ ! o~ 10 CAA soJeo (c 1Ct}.

PALISADES B 3.7.3-1 Amendment No.

REVISED 09104J98

SECTION 3.8

- INSERT 1 The fuel oil transfer system which includes fuel transfer pump P-18A can be powered by offsite power, or by either DG. However, the fuel oil transfer system which includes fuel transfer pump P-18B can qnly be powered by offsite power, or by DG 1-1 .

. INSERT 2

~Al 3.83-61 Each DG is provided with an associated starting air subsystem to assure independent start capability. The starting air system is required to have a minimum capacity with margin for a DG start attemp without recharging the air start receivers .

B 3.7.3-1 REVISED 091'D4J91

Diesel BASES LCO .:rAJsell T .L Stored diesel fuel oil is required to have sufficient supply for 7 days of full accident load operation. It is also required to meet specific standards for quality. The specified 7 day requirement and the 6 day quantity listed in Condition~A are taken from the Engineering Analysis associated with Event Report E-PAL-93-0268.Additionally, sufficient lube oil supply must be available to ensure the capability to operate at full accident load for 7 days. This requirement is in addition to the lube oil contained in the engine sump. The specified 7 day requirement and the 6 day quantity listed in Condition ScPflim\B are based on an assumed lube oil consumption of1 o

~ (iAJsk?.I 2J 0.8-+'o1.0% of ~u.el ~,\ ~s ........ p+1*0"'-1..;

(!) These requirements, in conjunction with an ability to obtain replacement supplies within 7 days, support the availability of the OGs. OG day tank fuel

@ requi rementsr and fuel t1 a11Jfel" Sip a hi Ji ty from tRi &tQri9i tu1k +g ui diy

~are addressed in LCOs \J}l~ and 3@2.

APPLICABILITY ~ ~

DG OPERABILITY is required by LCOs 3+.l and 3~ to ensure the availability of the required AC power to shut down the reactor and maintain it in a safe shutdown condition following a loss of off-site power. Since diesel fuel~~

~lube oil support LCOs 3. . and 3.l.2, stored diesel fuel oil,~lub~

are required to be within limit either DG is required to be OPERABLE.

1

~u.8\ tl"'u..s.f er-, o..."'<l ~+-o..r"\-\~ a.Ir

a...id f1lc. tcu.t. fut.1'r Sy~ i'1 \

~ v 1"4 +, be. Pt/:4 o /, '!------

In this Condition, the available DG fuel oil supply is less than the required 7 day supply, but enough for at least 6 days. This condition allows sufficient time to obtain additional fuel and to perform the sampling and analyses required prior to addition of fuel oil to the tank. A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration of the required inventory prior to declaring the DGs inoperable.

~s~~;'J

@B.1 In this Condition, the available DG lube oil supplyJi?-less than the required 7 day supply, but enough for at least 6 days. This condition allows sufficient time to obtain additional lube oil. A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration of the required inventory prior to declaring the DGs inoperable.

PALISADES B 3.7.3-2 Amendment No .

REVISED 0911Mr.11

SECTION 3.8

INSERT 1 Additionally, the ability to transfer fuel oil from the storage tank to each day tank is required from each of the two tr~fer pumps.

INSERT 2 The starting air subsystem must provide, without the aid of the refill compressor, sufficient air start capacity, including margin, to assure start capability for its associated DG .

B 3.7.3-2 REVISED 091114J91

BASES 3.7.3.C.t Diesel Fuel and Lube Oil B 3.7.3 and 4.7.3 his wov Id be.

Diesel fuel oil with viscosity, or water and sediment*out of limit..!~

unacceptable for even short term OG operation. Viscosity is impor~t primarily because of its effect on the handling of the fuel by the pump and injector system; water and sediment provides an indication of fuel contamination. When the fuel oil stored in the Fuel Oil Storage Tank is JNSEl<..T determined to be out of viscosity, or water and sediment limits, the OGs mus pR..ort'\ e dee a

rab le i mmi.i,;e~dol.i~at:.!e;..!li...---------------

3.tl.I J, 7 3 0 i@ G:J)

( Pj Cf) With the stored fuel oil properties, other than viscosity~ater and

~

sediment, defined in the Fuel ,0'il Testing Program not within the required limits, but acceptable for short term DG operation, a period of 30 days is allowed for restoring the stored fuel oil properties. The most likely cause of stored fuel oil becoming out of limits is the addition of new fuel oil with properties that do not meet all of the limits. This 30 day period provides sufficient time to determine if new fuel oil, when mixed with stored fuel oil, will produce an acceptable mixture, or if other methods to restore the stored fuel oil properties are required. This restoration may involve feed and bleed procedures, filtering, or combinations of these procedures. Even if a DG start and load was required during this time interval and the fuel oil

,qq properties were outside limits, there is a high likelihood that the OG would still be capable of performing its intended function.

~

I J.:U*08 3.7.3:iul

~

Completion Time not met, or with diesel may be incapable of performing its declared inoperable.

SU~LANCE REQUIREMENTS 3.r SR 3 .1 ( Fwel e H qaan LI Ly e~eelt) ~

This SR provides verification that there is an adequate inventory of fuel oil in the storage tank to support either OG's operation for 7 days at full post-accident load. The 7 day period is sufficient time to place the plant in a safe shutdown condition and to bring in replenishment fuel from an offsite location.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is specified to ensure that a sufficient supply of fuel oil is available, since the Fuel Oil Storage Tank is the fuel oil supply for the diesel fire pumps, heating boilers, and rad waste evaporators, in addition to the DGs.

PALISADES B 3.7.3-3 Amendment No.

I.....

REVISED 09184J91

Diesel Fuel and Lube Oil B 3.7.3 and 4.7.3 BASES SR =+ffj3. 2 (l11ee _ell 'llURti t~* eAeek) Q. ~

This Surveillance- ensures that sufficient l\JbeOilinventory is to

,~port at least 7 days of full accident load operation for one,.;,.;;...;.,..,..,;..;.;,.;:_

~gallons requirement is based on an estimated consum tion of ~~;J..."'-l~

cw hcµrf'.) 0.~ +o l.0°70 of ~i..e\ o\\ C.nc\SV.l"lp-1';'7">\.

A 31 day Frequency is adequate to ensure that a suffitient lube oil supply is onsite, since OG starts and run times are closely monitored by the plant sta~ 3.i SR . . 3. 3 +rije1 e i1 'l1Ul Hy ~RQ~~) q_

The tests listed below are a means of determining whether new fuel oil and stored fuel oil are of the appropriate grade and have not been contaminated with substances that would have an immediate, detrimental impact on diesel engine combustion~

Testing for viscosity, specific gravity, and water and sediment is completed for fuel oil delivered to the plant prior to its being added to the Fuel Oil Storage Tank. Fuel oil which fails the test, but has not been added to the Fuel Oil Storage Tank does not imply failure of this SR and requires no specific action. If results from these tests are within acceptable limits, the fuel oil may be added to the storage tank without concern for~

3)@

.cff contaminating the entire volume of fuel oil in the storage tank. (Q~'*

. 5 S".11 Fuel oil is tested for other of the parameters specified in ASTM 0975 in

accordance with the Fuel Oil Testing Program required by Specification (6.S.11)

Fuel oil determined to have one or more measured parameters, other than viscosity or water and sediment, outside acceptable limits will be evaluated for its effect on DG operation. Fuel oil which is determined to be acceptable for short term DG operation, but outside limits will be restored to within limits in accordance with LCD ~3 Conditio~

5R 3.~.3.y I AJ5Ef2.,T

~ 3/C*I (3Q..St.S (p~ 1'3)

PALISADES B 3.7.3-4 Amendment No .

REVISED 09184191

BASES DC Sources - Operating B 3.7.4 and 4.7.4 The batteries for the DC power sources are sized to produce required capacity at 80% of nameplate rating, corresponding to warranted capacity at end of life cycles and the 100% design demand. The voltage limit is 2.13 volts per cell, which corresponds to a total minimum voltage output of 125.7 volts per battery discussed in the FSAR, Chapter 8~ *

for *

arge 1ead storage batteries are defined in IEEE-485 b

i (t.~. !).

Each DC electrical power source has ample power outpu capacity for the steady state operation of connected loads during normal operation, while at the same time maintaining its battery fully charged. Each battery charger also has sufficient capacity to restore the battery from the design minimum charge to its fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months while supplying normal steady state loads discussed in the FSAR, Chapter 8~

APPLICABLE SAFETY ANALYSES A description of the Safety Analyses applicable _.,,a CQ! C SW!!+QQIJ~~ is provided in the Bases for LCO 3,.1....l "AC Sources - Operating".

~ \!) fi'."°I CD m+1s-fY CRl'lC:"ttn 3 o+ 10 CB s6. !!cl (c1(z;)

1.g-:1.(-D~

............. "Th.. De. J)oor<t.S I LCO The DC power sources, each consisting of one battery, one directly connected battery charger and the corresponding control equipment and interconnecting cabling supplying power to the associated bus within the train are required to be OPERABLE to ensure the availability of DC control power and Preferred AC power to shut down the reactor and maintain it in a safe condition.

An OPERABLE DC electrical power source requires its battery to be OPERABLE and connected to the associated DC bus. In order for the battery to r ain w

OPERABLE, The LCO

- - *~~s har er must be in service.

supply. If only the cross connected chargers were off-site power should occur concurrently with the loss of one DG, both

__c:u

_(A,V

chargers ED-15 and ED-16 because those chargers are powered by the AC power distribution system and DG associated with the battery they "cr.blt.

, and a loss of safeguards trains would eventually become disabled. One train would be disabled by the lack of AC motive power; the other would become disabled when the battery, whose only OPERABLE charger is fed by the failed DG, became depleted.

i PALISADES .B 3.7.4-2 I I

Amendment No.

REVISED 09J04191 I

DC Sources - Shutdown B S imd 4.7.5 ELECTRICAL POWER SYSTEMS B 3.~ 'lfft'd ~.7.~ DC Sources - Shutdown BASE~

BACKGROUND A description of the DC sources is provided in the Bases for LCO "DC Sources - Operating."

/~{,

LCO ~

This LCO requires those, and only those, D er sources which supply the DC distribution subsystems required by LCO 3. , to be OPERABLE. Each DC source consists of one battery, one battery charger, and the corresponding control equipment and interconnecting cabling. This ensures the availability of sufficient DC power sources to maintain the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents and loss of shutdown cooling).

~::L:~A::~::Ysources S11l:JTf38~1f";-and required to be OPERABLE in ~~~i:fw:"ai, fJ, during movement of irradiated fuel assemblies provide assurance that equipment and instrumentation is available to:

a. Provide coolant inventory makeup,

b. Mitigate a fuel handling accident,

c. Mitigate shutdown events that can lead to core damage,(~..;!)

Monitoring and ma i nta i ni ng the plant i n ;--a."'"C:~O~b,QQ~~!;+o!ij~~"'QiP\o~r~:IJ1\:~r::t:iEFf'"!:~~opj!IUla!l'I Cod ~

d.

SM~iQQ~IN condition.). or f~Wan~ C?o.dltl6t\o ~~:d! " ~ "

PALISADES B 3.7.5-1 Amendment No.

REVISED 09J04191

ELECTRICAL POWER SYSTEMS B 3.7.6 and 4.7.S: Battery Cell Parameters Battery Cel 1 Parac.eters B 3©6 a11d 4.7.G BASES BACKGROUND This LCO delineates the limits on electrolyte temperature, level, float voltage, and specific gravity for the DC power source batteries. A discussion of these batteries is provided in the Bases for LCO 3;.k.4, "DC Sources -

Operating". ~ 8 APPLICABLE SAFETY ANALYSES

&,-H ...'"'f le.LL ~C..1'<<-lh'-tefS' 1:ia.f1r~7 Cr.t ..r* .. ~ a-t lb CF-A. So.36 (c)Cz.).

LCO Battery cell parameters must remain within acceptable limits to ensure availability of the required DC power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated OBA. Battery cell limits are conservatively established, allowing continued DC electrical system function even when Category A and B limits are not met.

The requirement to maintain the *average temperature of representative cells above 70'F assures that the battery temperature is within the design band.

Battery capacity is a function of battery temperature.

APPLICABILITY The battery cell parameters are required solely for the support of the associated DC power sources. Therefore, they are only required when the DC power source is required to be OPERABL Refer to the A li ability discussions in the Bases for LCO 3. ' and LCO 3~5, "DC Sources - Shutdown" .

.* ~

PALISADES B 3.7.6-1 Amendment No.

REVISED 09/04J9a

Inverters - Operating B ~7 **8 4.l l ELECTRICAL POWER SYSTEMS B3 *tiJ

'S ar1! 4. 7.1-: Inverters - Operating BASE BACKGROUND (ED-ot., ~C-oi, EO-ot l o.Nf Eo-oq)

The inverters~e the normal source of power for the Preferred AC buses. The function of the inverter is to provide continuous -AC electrical power to the Preferred AC buses, even in the event of an interruption to the normal AC power distribution system. A Preferred AC bus can be powered from the AC power distribution system via the Bypass Regulator if its associated inverter is out of service. An interlock prevents supplying more than one Preferred AC bus from the bypass regulator at any time. The station battery provides an uninterruptable power source for the instrumentation and controls for the Reactor Protective System (RPS) and the Engineered Safety Features (ESF).

APPLICABLE SAFETY ANALYSES is

~41

'3-~1-6 /

Leo ~o.+1~~y Cri+c.r10~ ~ o+ 16 CF7t. so.Jt,(c )cz.). K.

The inverters ensure the availability of Preferred AC power for the instrumentation required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated OBA.

Maintaining the inverters OPERABLE ensures that the redundancy incorporated into the RPS and ESF instrumentation and controls is maintained. The four inverters ensure an uninterruptable supply of AC electrical power to the Preferred AC buses even if the 2400 volt safety related buses are de-energized.

An inverter is considered inoperable if it is not powering the associated Preferred AC bus, or if its output voltage or frequency is not within tolerances.

PALISADES B 3.7.7-1 Amendment No.

REVISED D9J04l9I

BASES Inverters - Operating B 3.7.7 and 4.7.7 f<.l+I SU~CE ~EQUIREHENTS ~.~.1.oi....

3*8 SR . . 7.1 (Inverter checks) ef'I! r~?~t} /l\J(;. f he 1 This Surveillance verifies that the inverters are functioning properly and~

Preferred AC buses efl0P!jized f1 om the i liver te-r. The veri fi cation of proper voltage and frequency output ensures that the required power is readily available for the instrumentation of the RPS and ESF connected to the Preferred AC buses. The 7 day Frequency takes into account indications available in the control room that alert the operator to inverter malfunctions.

REFERENCES None PALISADES B 3.7.7-3

Amendment No .

ELECTRICAL POWER SYSTEMS B 3@8 3

&Ae 4.7.8:

Inverters - Shutdown Inverters - Shutdown B ~B ' ' ' 4.7.9 BASE BACKGROUND ~

A description of the inverters is provided in the Bases for LCO 3~,

"Inverters - Operating".

APPLICABLE SAFETY ANALYSES ~:::J~

A description of the Safety Analyses applicable during ~:~;.Y R:Efi't1ELifU! Sll~T88'11'PI is provided .in the Bases for LCO 3~2 "AC Sources - t-.'r I Shutdowri". . _ g 3-~~.-o

~vc.rhrS a.r .. ¥a.r-t 6 ++h-.. d1~fH1111f16" :yrtc.m Q11d, Q4 g uc / /)o.."'1sft (~.t""'I\ 3 cf 1 o cFt<.. ~o. :bl c1C2...), )l LCO This LCO requires those, and only those, inverters necessary to support to Preferred AC buses required by LCO 3~0, to be OPERABLE.

This ensures the availability of suf~ent Preferred AC electrical power to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents and loss of shutdown cooling).

An inverter is considered inoperable if it is not powering the associated Preferred AC bus, or it its voltage or frequency is not .within tolerances.

~::L:::::~::: required to be OPERABLE in mg ,£iii~r.:,;r.£~°'?1~11, and during movement of irradiated fuel assemblies provide assurance that equipment and instrumentation is available to: u

a. Provide coolant inventory makeup, (.r..o..vc.. o.J t

b. Mitigate a fuel handling accident, V/J1... .Rc~t..r u. <-

c. Mitigate shutdown events that can lead to core damage~ ~tf.j.,,...1

d. Monitoring an~ ~aintaining the plant in a COLB Sll~T/~; +~

SlltffBOWN cond1t10n. ( *--= -~ /<}'1 /

3.r.~ 02.-

PALISADES B 3.7.8-1 Amendment No.

ELECTRICAL POWER SYSTEMS Distribution Systems -

B 3~.9 aRa 4.7 ...Q.: Distribution Systems - Operating

~ -

O~~rating B ~ ,,; 4.7.9 BAS -

BACKGROUND The onsite Class IE AC, DC, and Preferred AC bus electrical power distribution systems are divided into two redundant and independent electrical power distribution trains. Each electrical power distribution train is made up of several subsystems which include the safety related buses, load centers, ~otor control centers, and distribution panels shown in ~~3~-1.

The Class IE 2400 volt safety related buses, Bus IC and Bus lD, are normally powered from offsite, but can be powered from the DGs, as explained in the Background section of the Bases for LCO 3~.l, "AC Sources - Operating". Each 2400 volt safety related bus supplies one in of Class lE the 480 volt distribution system. "9 1 The 120 volt Preferred AC buses are normally powered from the inverters. The alternate power supply for the buses is a constant voltage transformer, called the Bypass Regulator. Use of the Bypass regulator is governed by LCO 3.. 7, "Inverters - Operating." The bypass regulator is powered from the non-Class IE instrument AC bus, Y-OI. The Instrument AC bus is normally powered through an automatic bus transfer switch, an instrument AC transformer, and isolation fuses. Its normal power source is MCC-1. Loss of power to MCC-1 will cause automatic transfer of the Instrument AC bus to MCC-2.

There are two independent 125 volt DC electrical power distribution subsystems.

APPLICABLE SAFETY ANALYSES 11<.rr 3 c -t.* I~ c,:,z .ro.J( Cckz. .

1 LCO f The AC, DC, and Preferred AC bus electrical power distribution subsystems are required o be OPERABLE. The required power distribution subsystems listed in 3 * *9-1 ensure the availability of AC, DC, and Preferred AC bus rical power for the systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated* OBA.

PALISADES B 3.7.9-1 Amendment No.

Distribution Systems - ~rating B ~g 4.<.~

BASES Maintaining both trains of AC, DC, and Preferred AC bus electrical power distribution subsystems OPERABLE ensures that the redundancy incorporated into.

the plant design is not defeated. Therefore, a single failure within any electrical power distribution subsystem will not prevent safe shutdown of the reactor.

OPERABLE electrical power distribution subsystems require the buses, load motor control centers, and distribution panels listed in

.9-1 to be energized to their proper voltages. In addition, tie breakers between redundant safety related AC power distribution subsystems must be open when a 2400 volt source is OPERABLE for each train. This prevents any electrical malfunction in any power distribution subsystem from propagating to the redundant subsystem. If any tie breakers are closed, the affected redundant electrical power distribution subsystems are considered inoperable. This applies to the onsite, safety related redundant electrical power distribution subsystems. It does not, however, preclude redundant Class lE 2400 volt buses from being powered from the same offsite circuit or preclude cross connecting Class lE 480 volt subsystems when 2400 volt power is available for only one train.

This LCO does not address the power source for the Preferred AC buses. The Preferred AC buses are normally powered from the associated inverter. An alternate source, the Bypass Regulator, is available to supply one Preferred bus at a time, to allow maintenance on an inverter. The proper alignment of the inverter output breakers is addres ed u er the inverter LCOs. Therefore a Preferred AC Bus may be considered operable when powered from either the associated inverter or the Bypass Regu a as long as the voltage and frequency of the supply is correct. ,*--¢AP~>

APPLICABILITY l~

The electrical power distribution subsystems are required to be OPERABLE~~!-

"°'QLQ ~MWt99WN-to ensure that AC, DC, and Preferred AC power is available to the redundant trains and channels of safeguards equipment, instrumentation and controls required to support engineered safe uards e ui ment

vent of !Zit I an accide ~

~ GtiA 3-~-9-0.S are PALISADES . B 3.7.9-2 Amendment No .

BASES Distribution Systems - - Operating B 3.7.9 and 4.7.9 An

operable DC distribution subsys m can cause engineered safety ures t e inoperable. If a redundant s fety feature in the other train ncurrently inoperable, a loss of. safety function could occur. AC ON C.l equires compliance with Conditi 3.7.9.E to assure that the pla utdown if a safet function i lost.

~

With@~ ~u~rn- one train inoperable, the remarn1ng DC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF functions not being supported. Therefore, the required DC buses must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months by powering the bus from the associated battery or charger.

This 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months limit is more conservative than Completion Times allowed for the vast majority of components which would be without power and is a feature of the original Palisades licensing !asis. 1HJS"C72--T I

~D.l and 0.2

If the inoperable distribution power ands to a de radation in the electrical distribution system cmlrirm~~~;;te:EE:SLtti[jxffu[!~r]ifiiio:jj;~lD causes a required Condition is entered, and this results in the loss of a required function, e plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

PALISADES B 3.7.9-4 Amendment No.

Distribution Systems - - Operating B 3.7.9 and 4.7.9 BASES SU~LANCE REQUIREMENTS 3.8 -

SR . . 9 .1 (A6 BYS ali gr1mer1t eheell) ~

This surveillance verifies that the required AC, DC, and Preferred AC bus electrical power distribution subsystems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained.

For those buses which have undervoltage alarmed in the control room, correct

~~\ D'1° voltage may be verified by the absence of an undervoltage alarm.

For those buses which have only one possible power source and have ')~*

undervoltage alarmed in the control room, correct breaker alignmen1nby the absence of an undervoltage alarm. ft'G-i ~\~c.I("'\~~

A Preferred AC Bus may be considered correctly aligned when powered from either the associated inverter or from the bypass regulator. A mechanical interlock prevents connecting two or more Preferred AC Buses to the Bypass Regulator. LCO~ . . 7 and SR~7.l address the condition of supplying a Preferred AC Bu ram the bypas e ulator.

3 The 7 day Frequ cy takes into *S nt the redundant capability of the AC, DC, and Preferred AC bus electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions.

REFERENCES None CT5 TA13LE s 7,q-1 I BA-SES rl1t3tt d 3. g. tt-1 PALISADES B 3.7.9-5 Amendment No.

Distribution Systems - Shutdown

(~30 dl"I~ 4.7.lQ B

ELECTRICAL POWER SYSTEMS B 3~0 aA~- 4 7,1-Q: Distribution Systems - Shutdown BAshV BACKGROUND A description of the AC, DC, and Preferred AC bus electrical power distribution systems is provided in the Bases for LCO 3~cJ* "Distribution Systems - Operating". ~

LCO This LCO requires those, and only those, AC, DC, and Preferred AC distribution subsystems to be OPERABLE which are necessary to support equipment required by other LCOs.

Maintaining these portions of the distribution system energized ensures the availability of sufficient power to operate the plant in a safe manner to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).

APPLICABILITY c:;;=oE; 5" ;-;,J G,~

The electrical power distribution subsystems required to be OPERABLE 111 EOLB l Sf:l!ITQQ',IPf, REFl!iLIM,. Skl!ll"gQWNo, and during movement of irradiated fuel ({It ."

assemblies, provide assurance that equipment and instrumentation is available 1- ,~-u~

to:

Le._a..ll-<- ~ ir

a. Provide coolant inventory makeup,

b. Mitigate a fuel handling accident, UO<- l~wtr c~

c. Mitigate shutdown events that can lead to core damage, ~

d. :mc~~o~~1t~~~~taining the plant in a GQLQ SM!!n~t:;#;;:)

PALISADES B 3.7.10-1 Amendment No.

. ATTACHMENT 8 JUSTIFICATIONS FOR DEVIATIONS SECTION 3.8, ELECTRICAL POWER SYSTEMS - BASES Discussion Note: The CTS Bases for Electrical Power Systems are unique in they have been upgraded to incorporate the format, and much of the content, of NUREG-1432. These Bases have previously been reviewed and found acceptable by the NRC in support of Amendment 180 to the Palisades Technical Specifications dated April 29, 1998. To facilitate the review of the proposed Bases for ITS Section 3.8, a markup of the CTS Electrical Power Systems Bases has been provided which denotes only those differences between the previously approved CTS Bases and the proposed ITS Bases. In addition, a separate "red-line & strikeout" version of NUREG-1432, has been provided and will serve as a comparison between the CTS and NUREG-1432.

A brief discussion of the deviations from the CTS Bases is provided below.

The Change Numbers correspond to the respective deviation shown on the "CTS MARKUPS". The first five justifications were used generically throughout the markup of the CTS Bases.

1. The brackets have been removed and the proper plant specific information or value has been provided.

2. Deviations have been made for clarity, grammatical preference, or to establish consistency within the Improved Technical Specifications. These deviations are editorial in nature and do not involve technical changes or changes of intent.

3. The requirement/statement has been deleted since it is not applicable to this facility.

The following requirements have been renumbered, where applicable, to reflect this deletion.

4. Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect the facility specific nomenclature, number, reference, system description, or analysis description.

Palisades Nuclear Plant Page 1of3 09/04798

.ATTACHMENTS JUSTIFICATIONS FOR DEVIATIONS SECTION 3.8, ELECTRICAL POWER SYSTEMS - BASES Change Discussion

5. These changes are made to reflect Palisades licensing basis, including any associated changes proposed in this submittal (which are justified by DOCs and NSHCs elsewhere), as presented in the associated ITS Specifications. Additional changes are also proposed to establish conformance with NUREG-1432 Bases. Rewording, reformatting, and revised numbering is made to incorporate these changes consistent with Writer's Guide conventions.

6. The B 3.8.1 and B 3.8.4 Bases for those Surveillances that are associated with restrictions on which operational Modes they are allowed to be performed in, already address the issue that "credit may be taken for unplanned events that satisfy a surveillance requirement." In addition, the "credit may be taken ... " concept applies to all surveillances, and is also addressed in the ITS Bases for SR 3.0.1. Therefore elimination of this discussion above all 3. 8 .1 Surveillance Bases is administrative only, with no technical change or change in intent. This presentation is consistent with NUREG-1432 and TSTF-8, Rev. 2.

7. The B 3. 8. 1 Bases discussion of "standby conditions" for the DGs is enhanced to include the existing procedural limitations regarding time after air roll. The intent of this statement is to establish a minimum time at which a diesel generator is at rest prior to commencing the surveillance test. ITS SR 3. 8 .1. 2 provides assurance that a diesel generator would start and be ready for loading in the time period assumed in the safety analysis. Prior to starting a diesel generator for SR 3.8.1.2, a cylinder leakage test is performed by briefly (minimum of 5 seconds) cranking the diesel engine and observing the test cocks for the expulsion of water or oil. To avoid invalidating the test results of SR 3.8.1.2 by "preconditioning" a diesel engine, an elapse time of 20 minutes has been specified since the diesel engine was last air rolled. The specified time is based on engineering judgement considering vendor recommendations. Although this information is presently contained in plant procedures and imposes an additional restriction on the performance of the test, inclusion of this information in the Bases of SR 3. 8. 1. 2 is appropriate since it preserves the original intent of the surveillance test.

8. CTS requirements and Actions (and associated Bases) for DG fuel transfer pumps and DG starting air, are presented in the AC Sources-Operating Specification. ITS administratively relocates these requirements and Actions to a separate Specification (3.8.3): Diesel Fuel, Lube Oil, and Starting Air. This relocation is appropriate for those support system with a justified restoration time that is allowed prior to applying

the restoration time for an inoperable DG.

Palisades Nuclear Plant Page 2 of 3 09/04798

ATTACHl\.fENT 8 JUSTIFICATIONS FOR DEVIATIONS SECTION 3.8, ELECTRICAL POWER SYSTEMS - BASES Discussion

9. TSTF-38 adds clarifying statements to the Bases of the battery inspection surveillance, which are adopted in the Palisades ITS Bases. Since this change only clarifies the existing intent, the change is acceptable.

10. This CTS Bases statement is in conflict with the CTS (and proposed ITS) requirements. The statement was mistakenly included with the recent amendment.

Elimination of the statement corrects an obvious error.

11. Clarification added to indicate the source of information relating resistance to voltage drop.

12. The CTS Bases associated with assumed lube oil consumption have been revised based on recently aquired information from the manufacturer which has been verified by plant specific testing.

\

Palisades Nuclear Plant Page 3 of 3 09/04/98

ATTACHMENT 4 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION REVISED PAGES FOR SECTION 5.0

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27, 1998 REQUEST FOR ADDITIONAL INFORMATION REVISED PAGES FOR SECTION 5.0 Page Change Instructions Revise the Palisades submittal for conversion to Improved Technical Specifications by removing the pages identified below and inserting the attached pages. The revised pages are identified by date and contain vertical lines in the margin indicating the areas of change.

REMOVE PAGES INSERT PAGES REV DATE NRC COMMENT#

INTRODUCTION ATTACHMENT 1 TO ITS CONVERSION SUBMITTAL 5.0-10 5.0-10 09104198 NIA editorial 5.0-11 5.0.11 09104198 NIA TSTF 279 ATTACHMENT 2 TO ITS CONVERSION SUBMITTAL No page change ATTACHMENT 3 TO ITS CONVERSION SUBMITTAL CTS 5.0 pg 13 of 29 CTS 5.0 pg 13 of 29 09104198 NIA TSTF-279 DOC 5.0 pg 2 of 6 5.0 pg 2 of 6 09104198 RAI 5.6-02 DOC 5.0 pg 5 of 6 5.0 pg 5 of 6 09104198 NIA editorial DOC 5.0 pg 6 of 6 5.0 pg 6 of 6 09104198 TSTF-279 ATTACHMENT 4 TO ITS CONVERSION SUBMITTAL No page change ATTACHMENT 5 TO ITS CONVERSION SUBMITTAL NUREG 5.0-8 NUREG 5.0-8 09104198 RAI 5.5-01 NU REG 5.0-10 NU REG 5.0-10 09104198 NIA editorial NUREG 5.0-11 NUREG 5.0-11 09104198 NIA TSTF-279 ATTACHMENT 6 5.0 pg 6of6 5.0 pg 6of6 09104198 NIA TSTF 279 1

Programs and Manuals 5.5

5.5 Programs and Manuals 5.5.4 Radioactive Effluent Controls Program h.

(continued)

Li ni.itati ons on the annual doses or dose commitment to any member of the public due to releases of radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR 190.

5.5.5 Containment Structural Integrity Surveillance Program This program provides controls for monitoring any tendon degradation in pre-stressed concrete containments, including effectiveness of its corrosion protection medium, to ensure containment structural integrity. The program shall include baseline measurements prior to initial operations. The Containment Structural Integrity Surveillance Program, inspection frequencies, and acceptance criteria shall be in accordance with ASME Boiler and Pressure Vessel Code,Section XI, Subsection !WE and IWL.

If, as a result of a tendon inspection, corrective retensioning of five percent (8) or more of the total number of dome tendons is necessary to restore their liftoff forces to within the limits, a dome delamination inspection shall be performed within 90 days following such corrective retensioning. The results of this inspection shall be reported to the NRC in accordance with Specification 5.6.7, "Containment Structural Integrity Surveillance Report."

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Containment Structural Integrity Surveillance Program inspection frequencies.

5.5.6 Primary Coolant Pump Flywheel Surveillance Program

a. Surveillance of the primary coolant pump flywheels shall consist of a 100% volumetric inspection of the upper flywheels each 10 years.

b. The provisions of SR 3.0.2 are not applicable to the Flywheel Testing Program .

Palisades Nuclear Plant 5.0-10 Amendment No. 09/04/98

r Programs and Manuals 5.5

5.5 Programs and Manuals 5.5.7 Inservice Testing Program This program provides controls for inservice testing of ASME Code Class l, 2~ and 3 components. The program shall include the following:

a. Testing frequencies specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda (B&PV Code) as follows:

B&PV Code terminology Required interval for inservice testing for performing inservice activities testing activities Weekly !':: 7 days Monthly !':: 31 days Quarterly or every 3 months ~ 92 days Semiannually or every 6 months !':: 184 days Every 9 months !':: 276 days Yearly or annually !':: 366 days Biennially or every 2 years !':: 731 days b* The provisions of SR 3.0.2 are applicable to the above required intervals for performing inservice testing activities;

c. The provisions of SR 3.0.3 are applicable to inservice testing activities; and

d. Nothing in the B&PV Code shall be construed to supersede the requirements of any Technical Specification.

5.5.8 Steam Generator Tube Surveillance Program This program provides controls for surveillance testing of the Steam Generator (SG) tubes to ensure that the structural integrity of this portion of the Primary Coolant System (PCS) is maintained.

The program shall contain controls to ensure:

a. Steam Generator Tube Sample Selection and Inspection The. inservice inspection may be limited to one SG on a rotating schedule encompassing 6% of the tubes if the results of previous inspections indicate that both SGs are performing in a like manner. If the operating conditions in one SG are found to be more severe than those in the other SG, the sample sequence shall be modified to inspect the most severe conditions .

Palisades Nuclear Plant 5.0-11 Amendment No. 09/04/98

6.0 ADMINISTRATIVE CONTROLS

{.{.( 6.5.5 6.5.6 Primary Coolant Pump Flywheel Surveillance Program

a. Surveillance of the primary coolant pump flywheels shall consist of a 100% volumetric inspection of the upper flywheels each 10 years.

b. The provisions of Surveillance Requirement 4.0.2 are~~plicable to the Flywheel Testing Program.

),{, 1 6.5.7 Inservice fJljjiectig)'( a~ting Program This program provides controls for i nsei<-rv:__i~c:..::e7*'!::!!!!11E~~::==::~~:.::.:~~

ASME Code Class 1, 2, and 3 components \l.,.J.L.lo,..L.W>ol""'"'-"~-.J....l.l...a.i.~~~~~~

The program shall include the following:

a. Testing frequencies specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda (B&PV Code) as follows:

B&PV Code terminology Required interval for inservice testing for performing inservice activities testing activities Weekly s 7 days Monthly s 31 days Quarterly or every 3 months s 92 days Semiannually or every 6 months s 184 days Every 9 months s 276 days Yearly or annually Biennially or every 2 years

~iko~

s 366 days s 731 days A,1

b. The provisions of(S1Lde;nan e ujre tA_,@are applicable

to the above required inter~for performing inservice testing activities; ~ 3~ @

c. The.provi~ions of.@:rve}'fWtCLReq~Epft f-O)lare applicable to 1nserv1ce test1ng act1v1t1es; an

d. Nothing in the B&PV Code shall be construed to supersede the requirements of any Technical Specification.

6-8 Amendment No. i-74, 7-S,

f°'r REVISED 09"4191 I'!> o-f 2. q

I A 'FTACIThffiNT 3 DI§CUSSiO:N~OF CHAPTER 5.0, ADMINISTRATIVE CON)'ROLS CHANGES A.5 CTS 6.4.1 requires that written procedures shall be established, implemented, and maintained for the activities listed. In this list, the CTS contains item b., "Refueling operations, and item c., "Surveillance and test activities of safety-related activities."

These items are included in the procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978 which is referenced in CTS 6.4. la and included in the proposed ITS 5.4. la. Therefore, since these procedures are already required by the reference to Regulatory Guide 1.33, Revision 2, February 1978, they are not included in the proposed ITS. This change is an administrative change since no requirements have changed. This change maintains consistency with NUREG-1432.

A.6 CTS 6.4.1 requires that written procedures shall be established, implemented, and maintained for the activities listed. In this list, the CTS contains item f., "Site Security Plan implementation" and item g., "Site Emergency Plan implementation .. " These items were recommended to be removed from the Technical Specifications in NRC Generic Letter 93-07 since they are duplicative of regulations contained in the Code of Federal Regulations part 50 and 73. This change is considered to be an administrative change since these requirements must still be met as required by the Code of Federal Regulations. This change maintains consistency with NUREG-1432.

A. 7 CTS 6.5. 7 is entitled "Inservice Inspection and Testing Program." In the proposed ITS 5. 5. 7, the title is changed to the "Inservice Testing Program. " This change is considered to be an administrative change since the requirements of the program are unchanged. This change maintains consistency with NUREG-1432.

A.8 CTS 6.6.5b. l lists, among referenced LCOs, "3.10.1." That item is unnecessary and has been deleted. Neither CTS 3.10.1, nor its ITS replacement reference the COLR.

CTS 6.6.5 a. lists the core operating limits that are established and documented in the COLR prior to each core reload. Specifically, these limits are: ASI Limits (CTS 3.1.1), Regulating Group Insertions Limits (CTS 3.10.5), Linear Heat Rate Limits (CTS 3.23.1), and Radial Peaking Factor Limits (CTS 3.23.2). CTS 6.6.5 b.

list the documents approved by the NRC that describe the analytical methods used to determine the core operating limits. As part of this listing, cross references are made to the LCOs pertaining to the affected limit (e.g., ASI Limits, Regulating Group Insertion Limits, etc ... ). In error, CTS 6.6.5 b. l. lists CTS 3.10.1 (Shutdown Margin Requirements) as an LCO related to a document that describes analytical methods used to determine the core operating limits. Since Shutdown Margin is not a cycle dependent limit (the limit is contained in the technical specifications and not in the COLR), referencing CTS 3.10.1 in CTS 6.6.5 b.1 is inappropriate and has been

deleted. This change has been characterized as administrative in nature since it does not alter any requirement of the CTS, but simply corrects an administrative oversight.

Palisades Nuclear Plant Page 2of6 09/04/98

ATT ACHMJF,NT 3 DISCUSSION OF CHANGE§ CHAPTER 5.0, ADMINISTRATIVE CONTIR$.OLS M.4 The CTS does not contain a Safety Functions Determination Program. Proposed ITS 5.5.13 includes this progra.m. This program is added to work in conjunction with the proposed ITS in identifying any loss of safety function which might exist. Because the CTS did not contain this program, and its implementation requires additional evaluations to identify a loss of safety function than what is required in the CTS, this change is considered to be a more restrictive change. This change maintains consistency with NUREG-1432.

M.5 CTS 6.6. 7 contains the reporting requirements for specific accident monitoring instrument channels that are not restored to an Operable status within the required Completion Time. CTS 6.6.7 requires that a report be submitted within 30 days.

Proposed ITS 5.6.6 also contains reporting requirements for specific accident monitoring instrument channels that are not restored to an Operable status within the required Completion Time. However, the ITS requires that a report be submitted within 14 days. As such, the proposed change imposes an additional restriction on plant operations since the time period allowed to submit the report has been shortened from 30 days to 14 days. This change has been proposed to establish consistency with NUREG-1432 and is deemed acceptable since it only involves a change to administrative requirements and does not alter the way in which the plant is operated.

LESS RESTRICTIVE CHANGES - REMOVAL OF DETAILS TO LICENSEE CONTROLLED DOCUMENTS (LA)

LA. l CTS Specification 4.5 .4, Surveillance for Prestressing System (page 4-2 la) and 4.5 .5, End Anchorage Concrete Surveillance (page 4-2lc) were replaced by proposed ITS Specification 5.5.5, the Containment Structural Integrity Surveillance Program. The proposed specification emulates the ISTS treatment of containment structural integrity surveillance requirements. The details associated with containment tendon inspections have been removed from the technical specification and reference has been included in ITS 5.5.5 to ASME Boiler and Pressure Vessel Code,Section XI, Subsections IWE and IWL which establishes the applicable test methods, acceptance criteria and testing frequencies. Removal of these details is acceptable since testing of containment tendons in accordance with ASME Boiler and Pressure Vessel Code,Section XI, Subsections IWE and IWL is specified in 10 CPR 50.55a. Thus, this change eliminates duplication of federal regulations and can be made without an impact on public health and safety. Removal of these details from the CTS and the incorporation of a containment tendon surveillance.program in Section 5.0 of the ITS is consistent with NUREG-1432.

Palisades Nuclear Plant Page 5 of 6 09/04/98

DISCUSSION .

ATTACHMENT 3 CHAPTER 5.0, ADMINISTRATIVE" CONTROLS LESS RESTRICTIVE CHANGES - REMOVAL OF DETAILS TO LICENSEE

-OF CHANGES CONTROLLED DOCUMENT§ (LA)

LA.2 CTS 6.5.7, Inservice Inspection and Testing Program has been revised to delete the*

phrase "including applicable supports." Requirements for inservice inspections of ASME Code Class 1, 2, and 3 components are specificed in 10 CFR 50.55a(g). As used in CTS 6.5.7, "applicable supports" is intended to apply to the inspection of snubbers. Adaptation of this phrase in the CTS was consistent with the NRC' s approach to address concerns related to the relocation of the Snubber LCO from the ISTS NUREGs. Subsequently, the ISTS NUREGs have been modified to delete this phrase in recognition that it duplicates requirements specifed in the CFRs (See Section 5.0, JFD 26 addressing TSTF-279). As such, the deletion of this phrase from the CTS can be made without a significant impact on safety since the inspection of applicable supports continues to be required by 10 CFR 50.55a(g).

LESS RESTRICTIVE CHANGES (L)

There were no "Less Restrictive" changes made to this chapter.

RELOCATED (R)

There were no "Relocated" changes made to this chapter .

Palisades Nuclear Plant Page 6of6 09/04/98

Programs and Manuals 5.5 5.5 Programs ~nd Manuals lo.$.\ 5.5.1 Offsite Qose Calculation Manya] (OQCMl (continuP.d) the affected pages, clearly indicating the area of the page*

that was changed, and shall indicate the date (i.e., month and year) the change was implemented.

fq, ), 2. 5.5.2 Primarv Coolant Soyrces Oytsjde Containment R~

s.S ... CJ 1 y

~~~~;...;_:;_;...-.-=a.:..-s_________ (0 include

a. Preventive *maintena.nce and periodic visual inspection requirements;~

b. Integrated leak test requirements for each system at refueling cycle intervals or less;

<'.'... !:'A'i.e.rt) *

(@

, o.u.-...-..:h\ J.e:\-~.,.,..... : ~ ~ .....: ,. .\.~, . . . ~

Post Accident Samol 109 1

.,cl: ~ c...'°""'£ ..J ..,. ...+.o"" i ... ... :-t-.J.. .... ret..~ c....,..J 5.5.3 . . '-'"'-:c:..\.-.. ..... n\ *o"s-r< ~ c..,"l.;\;t-., ~

This progra11 provides controls that ensure the capabi 1i ty to ~

obtain and analyze reactor coolant, radioactive gases, and particulates in plant gaseous effluents and containment atmosphere samples under accident conditions. The program shall include the following:

a. Training of personnel;

b. Procedures for sampling and analY~ls; and

c. Provisions for maintenance of sampling. and ana_lysis

equ1 pment.

5.5.4 Rad1oact1ye Effluent Controls Progra~

This program conforms to 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from rad~oactive effluents: as low as reasonably (continued)

CEOG STS 5.0-8 Rev 1, 04/07/95

Programs and Manuals 5.5 5.5 Programs and Manuals

~.S.'1 5.5.4 Radioactive Effluent Controls Program (continued)

Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents from each unit to areas beyond the site boundary, conforming to 10 CFR 50,. Appendix I; Limitations on the annual and quarterly doses to a member of the public from iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half lives> 8 days in gaseous effluents released from each unit to areas beyond the site boundary, conforming to 10 CFR 50, Appendix I; and Limitations on the annual dose or dose convnitment to any member of the public due to releases of radioactivity and to radiation from uranium fuel cycle sources, conforming to 40 CFR 190.

5.5.5 C clic i mi This program provides ontrols to tra k the FSAR Secti n (

eye ic and transien~;occurrences to nsure that compo ents are ma* nta i ned ~i-~_b_~.J:~~-~gn limits. ________

C.o"t~:"'""t."'-+ s-t ...... ,. :1-.... ,,...z J:..,h::i,;~,1 s. . . ..-~e:l\ .. ~(..L P.-o!i.-.. ~/

5.5.~ ram This program provides controls for monitoring any tendon degradation in pre-stressed concrete containments, including effectiveness of its corrosion protection medium, to ensure c/

containment structural* integrity. The program shall include baseline measurements prior to initial operations. The~

Surveillance Program, inspection frequencies, and acceptance criterh shall be in accordance ~ith 7{\Ra:g.U1atory Gliide ,l :35J (])

LRivision :g /1$59JJ~ ASrnl D01i...c..r o.rJ H\\Svl\ v'i:..llfl1.L wd-< S<.r.A1>"1 '{[/ '0\

Svbu:+1~r-.I ILVl c..rJ LWl ' (_0

/./,':: b TIM provisions of SR 3.0.2 and SR 3.0.3 are applicable to the

~Surveillance Program inspection frequencies.

~:C":~-~~-;~-i-~~~e"A~n.' rv l----------~

~-~

t., ,5. LP s.5.tJ ~Cool ant Pump Fl vwhe*el Insoect ion Program

.S ._, v c', \ \, " 4 o t -\ 1-.L ? ': """~ .- I +

c. "o \ c. ~ 9-...""" p .f. \1 ....., \.-. e" \ s .> \.... "'- \ I

\Q")* oo\~~._{,.:c.. inS ..~c...*"*°"' "'.,\'. rtk"" <<.r .f-\ .....,\....cc.\S U-C..~ I

CEOG STS 5.0-10 1, 04/07/95 REV1SED 09/04191

Programs and Manuals 5.5

5.5 Programs and Manuals (continued) fo. ~.l. 5. 5 .e?G) Inservice Testing Program This program provides controls for inservice testing of ASME Code Class 1, 2, and 3 components Gncljding apR'1icable suOOortSJ. The @

program shall include the following: ~

a. Testing frequencies specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable AddendaAas follows: (l3f PY Ce>';lf...) <ff)

---=------

1 13 f?V (o ...-t ASMk!:il er jn;c.*

Vess Cod?: ~nd B7ure app icable Add nd erm no ogy or inservice testing actiyities Weekly Monthly Quarterly or every 3 months Semiannua 11 y or every 6 months Every 9 months Yearly or annually Biennially or every 2 years

b. The provisions of SR 3.0.2 are applicable to the above required Frequencies for performing inservice testing activities;

c. The provisions of SR 3.0.3 are applicable to inservice t es t i ng act i vi t i es ; and b ~ Pv

[~~ .... <;i:itc1r=:1,;.no3J s.s.~

{I Steam Generator !SGl Tube Surveillance Program R-evfewer'i ~re*:---Tlie-rrcen es curren lTce sing basis stea generator ~~be surveillance requirements sh l be relocated from , , /j' the LCO a included here. An appropriate administrative ontrol~

I] lV program f rmit should be sed. ______..,..---__,______ !

- (r: ,-1 )HT S (,, .,-,,, \,.,.;I\."°' p,,'i"_ .C._ LT I/~

- CEOG STS 5.0-11

{continued)

Rev 1, 04/07/95 REVISED 09104198

_ _ _J'

T ATTACHMENT 6 JUSTIFICATION FOR DEVIATIONS SPECIFICATION 5.0, ADMINISTRATIVE CONTROLS Chan1:e Discussion

23. NUREG-1432 5.5.6 specifies the requirements for the Tendon Surveillance Program.

The proposed ITS revises this title to the Containment Structural Integrity Surveillance Program and replaces the plant specific requirements which currently exists in CTS 4.5.4 and 4.5.5. This program and the associated report (ITS 5.6.7), include requirements relating to dome delamination in addition to tendon testing. The program and report names were changed accordingly. This change is acceptable because the NUREG-1432 5.5.6 is in brackets to indicate that the plant specific information is to be provided if the report is applicable.

24. NUREG-1432 5.5.9 and 5.5.13 are revised to incorporate TSTF-118 which provides consistent application of SR 3.0.2 and SR 3.0.3 to the Programs referenced by ITS SRs.

25. NUREG-1432 5.6.1and5.6.3 are revised to incorporate TSTF-152 which reflects previous revisions to 10 CFR Part 20 and 10 CPR 50.36a.

26. Reference to the "applicable support" was deleted from the description of the Inservice Testing (IST) Program. The IST Program provides control for testing Code Class 1, 2, and 3 components. The discussion of the IST Program in Section 5 .5 of the ISTS was 1

revised by the NRC to inc lude the "applicable supports" in February 1992 due to concerns related to the relocation of the Snubber LCO from the ISTS NUREGs.

However, this is inappropriate; supports are addressed under the Inservice Inspection Program not the IST Program. Thus, the reference to the "applicable supports" in the IST Program description was deleted. This change is consistent with NUREG-1432 as modified by TSTF-279.

Palisades Nuclear Plant Page 6 of 6 09/04/98

ML18066A302

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