ML18066A370

Summary of 981027-28 Meeting with Util in Rockville,Md Re Issues Involving Plant Submittal for Conversion to Improved Ts.List of Meeting Attendees,Staff Comments & Questions Encl

ML18066A370
Person / Time
Site:	Palisades
Issue date:	01/06/1999
From:	Robert Schaaf NRC (Affiliation Not Assigned)
To:	NRC (Affiliation Not Assigned)
References
NUDOCS 9901210197
Download: ML18066A370 (25)

Text

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• • ___ LICENSEE: Consumer9ergy Company FACILITY:

Palisades Nuclear Plant

SUBJECT:

/

MEETING WITH THE CONSUMERS ENERGY COMPANY TO. DISCUSS THE PALISADES IMPROVED TECHNICAL SPECIFICATION'S CONVERSION The NRC staff met with Consumers Energy representatives at NRC Headquarters on October 27 and 2a; _ 1998, to discuss issu_e's related to the Palisades submittal for conversion* to the improved technical specifications (ITS). Enclosure 1 lists the meeting participants. The

• primary focus of the meeting was to discuss staff comments *and questions related to Section 3.3 of the conversion. Enclosure 2 provides the list of staff comments and questions that were discussed with the licensee during the meeting. These comments w_ere forwarded to -the

. licensee prior to the me~ting to facilitate more effective discussion.

In the course of discussing the staff comments, there were some cases in.which the licensee was able to clarify the information in the submittal or point.out particular information in the

• submittal that satisfied the staff!s concerns. The enclosure indicates that these questions were resolved in th_e meeting and no licensee response will be required. The licensee agreed to provide a response to the remaining questions by February 15, 1999.

The participants also discussed general issues related to the staff's review of the conve*rsion amendment as listed in Enclosure 3.

Docket No. 50-255 *

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I* 'ORIGINAL SIGNED BY Robert *G, ~chaaf, Project Manager Project Direct9rate 111-1 Division of.Reactor.Projects - Ill/IV Office of Niiclear Reactor Regulation

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_.j DOCUMENT NAME: G:\\PD3-1\\WPDOCS\\PALiSADE\\MTSITS01.WPD To receive a co OFFICE PM:PD31 E. LA:PD31 NAME CJamerson DATE 1/ (o 199

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Mr. Nathan L. Haskell Consumers Energy Company cc:

Mr. Thomas J. Palmisano Site Vice President Palisades Plant 27780 Blue Star Memorial Highway Covert, Michigan 49043 Mr. Robert A. Fenech, Sr Vice Pres Nuclear, Fossil, and Hydro Operations Consumers Energy Company 212 West Michigan Avenue Jackson, Michigan 49201 Arunas T. Udrys, Esquire Consumers Energy Company 212 West Michigan Avenue Jackson, Michigan 49201 Regional Administrator, Region Ill.

U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Jerry Sarno, Supervisor Covert Township P. 0. Box35 Covert, Michigan 49043 Office of the Governor P. 0. Box 30013 Lansing, Michigan 48909 U.S. Nuclear Regulatory Commission Resident Inspector's Office Palisades Plant 27782 Blue Star Memorial Highway Covert, Michigan 49043 Palisades Plant Drinking Water and Radiological Protection Division Michigan Department of Environmental Quality 3423 N. Martin Luther King Jr Blvd P. 0. Box 30630 CPH Mailroom Lansing, Michigan 48909-8130

• Michigan Department *of Attorney General Special Litigation Division 630 Law Building P.O. Box 30212.

Lansing, Michigan 48909 August 1998

MEETING ATIENDEES FOR OCTOBER 27 AND 28, 1998, MEETING ON THE PALISADES IMPROVED TECHNICAL SPECIFICATIONS CONVERSION NAME Robert Schaaf*

Mary Lynn Reardon*

. Carl Schulten Tilda Liu*

Clyde Shiraki*

Richard Smedley*

Barry.Young

• Part-time participant AFFILIATION NRC/NRR/PD31, Project Manager NRC/NRR/TSB, Conversion Lead Reviewer NRC/NRR/TSB, Section 3.3 Lead Reviewer NRC/NRR/TSB, Section 3.0/4.0 Lead Reviewer NRC/NRR/TSB, Section 3.7 Lead Reviewer Consumers Energy, Licensing Supervisor Consumers Energy, Licensing Engineer ENCLOSURE 1

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Palisades Improved TS Review Comments

. Section 3.3, Instrumentation Definitions Channel Calibration, Channel Functional Test The ITS proposes to adopt the STS definition for channel calibration except the term "display" is replaced with the term "interlock;" the requirement to cross calibrate RTDs following sensor

• element replacement is not adopted and the exclusion of neutron detectors is added to the definition. Comment: Deviations from STS definitions require a staff approved NEI TSTF.

The staff notes that TSTF-205, Rev 2 proposes changes to the channel calibration and channel functional test definition which eliminates unnecessary references to specific channel components in the definitions and clarifies the Bases. The staff recommends adopting the final form of TSTF-205.

Consumers Energy Response:

Bases Instrumentation LCOs Bases review RAls will be provided following discussion and agreement on ITS LCOs.

Consumers Energy Response:

3.3.1-1 ITS Applicability JFD8 JFD 8 references changes which are approved by TSTF-85, Rev. 1. This TSTF reformats the applicability by moving Mode and applicable conditions to Table 3.3.1-1. These TSTF changes were not included as stated. Comment: Provide a revised JFD 8. Also, revise JFD 8 to include discussion justifying deviation from the STS Applicable Conditions "any RTCB's closed and any control element assemblies capable of being withdrawn."

Consumers Energy Response:

3~3.1-1a JFD6 Comment: Revise JFD 6 to give a design basis justification for not adopting the STS RPS Instrumentation - Shutdown LCO.

Consumers Energy Response:

3.3.1-1b Comment: Verify ITS surveillances in LCO 3.3.1 require testing Variable High Power Trip Function reset feature for power ascension and decension. Provide a Bases discussion giving the basis for the TS requried testing.

Consumers Energy Response:

3.3.1-2 ITS Required Action B.1 JFD 12 The ITS markup eliminates the Action to place one channel in bypass whereas the Bases markup includes discussion that the 3.0.4 provisions are suspended for this Condition because one inoperable channel is tripped and the other is bypassed; Comment: Provide discussion to support the 3.0.4 exception without relying on channel bypass features.

Consumers Energy Response:

ENCLOSURE 2.

Palisades Improved TS Review Coi:nments Section 3.3, Instrumentation 3.3.1* 3 ITS Condition C JFD "None" (assume JFD 5 applies)

CTS 3.17.1 ;3.b requires (in addition to placing a trip unit in the trip condition) power to be reduced to less than 70% RTP within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> if the two inoperable channels are Power Range Nuclear Instrument channels. The ITS adds condition C to provide an action for CTS 3.17.1.3.b

• Comment: Consider combining the C.1 Action to reduce power within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> with Condition B, as a new Action B.1.2 with a note that this action (B.1.2) only applies for two inoperable Power Range Nuclear instrument channels. This eliminates entering concurrent actions (Condition B and Condition C) for the special condition of two inoperable power range channels.

Comment: Provide additional justification for not adopting ISTS Condition C. Condition C provides an action to recalibrate or limit power to less than 70% if one or more power range channels are inoperable. The proposed ITS requires the associated channels to be tripped.

Consumers Energy Response:

• • • Resolved during 10/27/98 meeting, no Consumers Energy Response required.

3.3.1* 4 CTS 4.17.1, footnote (b)

ITS SR 3.3.1.3 CTS Table 4.17.1, footnote b, requires calibration of the Variable High Power Function through comparison with Heat Balance every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when RTP is greater than 15%. ITS SR 3.3.1.3 adds an allowance where this surveillance is only required when the absolute difference between the calorimetric calculation is 2.0%. STS SR 3.3.1.3 provides this allowance below 1.5% absolute difference. Comment: There is no discussion for the Less Restrictive Change to CTS requirements or justification for deviation from the STS for this change. Provide missing documentation.

Consumers Energy Response:

3.3.1* 5 CTS 4.18.2.1(b)

CTS 4.18.2.1 (b) requires individual excore channel me~sured Axial Offset (AO) compared to the total core AO measured by the incore channels to determine if the excore monitoring system must be recalibrated. ITS SR 3.3.1.4 (Insert 2) introduces the acronym ASI for the excore channel comparison. Comment: It is not clear that ASI and Axial Offset (AO) are.

equivalent terms. Provide clarification and appropriate change documentation.

Consumers Energy Response:

2

Palisades Improved TS Review Comments Section 3.3, Instrumentation 3.3.1-6 CTS 3.17.1, M.1 ITS Required Action D,JFD 5 DOC M.1 states that cts 3.17.1 does not provide specific requirements for inoperable automatic bypass removal channels that are associated with certain RPS instrument functions.

ITS 3.3.1 places a requirement in the LCO that applicable automatic bypass removal channels must be operable. ITS Condition D applies to one or two inoperable bypass removal channels.

Required Action D.1 requires the inoperable bypass removal channel to be disabled within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.or Required Action D.2 provides the option to declare affected trip units inoperable within one hour from time of discovery of the inoperable condition which allows another 7 days to place a trip unit in trip.

The ISTS Condition D specifies requirements for one inoperable automatic bypass removal channel and Condition E specifies requirements for two inoperable automatic bypass removal channels. ISTS Required Action D.1 requires the inoperable channel to be disabled within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Required Action D.2.1 provides the option to place the trip units in bypass or trip and then

. enter D.2.2 to restore the bypass removal channel. Thus, the ISTS requires an action within one hour place the automatic bypass removal channel in a safe configuration. JFD 5 states the ITS reflects the current licensing basis. Comment: The staff notes that DOC M.1 states that CTS do not provide specific requirements for inoperable automatic bypass removal channels. Thus, the proposed ITS requirements to declare the trip units inoperable represents a generic change to the ISTS and a change to the CTS. Revise the ITS and associated DOCs to adopt the ISTS Conditions D and E. Comment: The staff also notes it is unnecessary for ITS required actions to state "declare the affected channel trip units inoperable and enter the appropriate Condition". The provisions of LCO 3.0.2 require TS actions to be met upon discovery of failure to meet an LCO.

Consumers Energy Response:

3.3.1-7 CTS 3.17.2.5 DOC M.1 Comment: The last paragraph of this DOC discusses an M-DOC change that is unrelated to the first three paragraphs of the discussion. Revise the submittal.. Revise the justification from "consistent with current practice" to a more specific statement to explain the more restrictive requirements that are being adopted in ITS.

. Consumers Energy Response:

3.3.1-8 CTS 4.18.2.1.b CTS 4.18.2.1 b requires a comparison of excore channel measured Axial Offset (AO) to the total core AO measured by the incores. If the excore and incore measurements are greater than.02 apart, the excores are to be adjusted. STS SR 3.3.1.3 requires that the excore detectors be "calibrated" using the incore.detectors. Comment: Revise the ITS to replace ITS SR 3.3.1.4

• requirement to "Compare" with i*calibrate."

Consumers Energy Response:

3

Palisades Improved TS Review Comments Section 3.3, lnstn-!mentation 3.3.1-9 ITS Required ActionsE, FG & H CTS 3.17.1, DOC M.1 In the ITS Note

• applies to 3.17.1.2.a and to 3.17.1.3.c. This note states that Actions are not required for inoperable High Startup Rate or Loss of Load instrument channels. No other CTS actions apply to these functions. DOC M.1 justifies adding new conditions E, F, G, and H for Loss of Load and High Startup Rate instrument channels based on these requirements being consistent with current practice though not required for CTS for these functions. Comment:

Thus, the proposed ITS requirements represent a generic change to the ISTS and a change to the CTS. Revise the ITS and associated DOCs to adopt the ISTS Conditions or provide additional justification giving a design basis justification or operational hardship position for not adopting the ISTS.

Consumers Energy Response:

3.3.1-10 ITS SR 3.3.1.3 CTS T4.17-1, footnote (b)

STS SR 3.3.1.2 (ITS SR 3.3.1.3) requirements to calibrate power range monitors is modified to delete reference to "excore" power range channels. Comment: CTS requirements provide few details related to the STS SR to perform a channel calibration and adjust the power range and

b. T power channels to agree with the calorimetric. Provide DOC and JFD discussions to justify proposed CTS and STS changes.

Consumers Energy Response:

• • • Resolved during 10/27/98 meeting; Consumers Energy not required to respond.

3.3.1-11 ITS SR 3.3.1.4, Note CTS 4.18.2.1.b DOC L.5 L.5 justifies the addition of the note to allow 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for performing the excore calibration using the incore instruments after thermal power exceeds 25%. Comment: Provide additional discussion in DOC L.4 to justify using 25% RTP for starting the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> window for completing the required surveillance.

• Consumers Energy Response:

3.3.1-12 ITS SR 3.3.1.6 CTS T 4.17-1, footnote (c)

JFD5 The ITS proposes to modify the STS by eliminating the use of the defined term "CHANNEL CALIBRATION" and addition of the surveillance detail with a test signal" for the power range excore channel test requirements. Comment: Revise ITS SR 3.3.1.6 to use the defined term CHANNEL CALIBRATION. Surveillance requirement details are moved to the Bases in the ITS program. Provide an LA DOC for eliminating CTS details related to using "test signals" to perform channel calibrations.

Consumers Energy Response:

4

Palisades Improved TS Review Comments Section 3.3, Instrumentation 3.3.1-13 ITS SR 3.3.1.6, SR 3.3.1.8 CTS T 4.17-1, footnote (c)

CTS T 4.17-1, footnote (d), (e); T 4-17-6 JFD23 JFD 23 states that neutron detectors are specifically excluded from CHANNEL CALIBRATION.

Additionally, this JFD states that TSTF-81 is not incorporated.* TSTF-81 is approved and provides the allowance in a note to the appropriate SRs that neutron detector are excluded from CHANNEL CALIBRATION. The ITS proposes to delete all occurrences of this note. This results in requirements to calibrate all neutron detectors because a CHANNEL CALIBRATION includes testing of "all required sensors." Comment: The staff has not accepted changing the STS d~finition of CHANNEL CALIBRATION. Revise the ITS to incorporate the STS SR Note for instrument channels with neutron detectors.

Consumers Energy Response:

3.3.1-14 STS SR 3.3.1.7 JFD 14 STS SR 3.3.1.7 requires a Functional Test be performed on each automatic bypass removal function once within 92 days prior to each reactor startup. This requirement is deleted in the ITS. JFD 14 states that the 18 month CHANNEL CALIBRATION adequately tests these functions. However, the 18 month CHANNEL CALIBRATION (STS SR 3.3.1.8) Bases does not discuss testing of the automatic bypass removal functions. Comment: Revise the ITS to include this requirement. Otherwise all changes to the STS format and content require an approved NEI TSTF unless a plant specific justification based on operational hardship or design is accepted by the staff for the STS deviation.

Consumers Energy Response:

3.3.1-15 ITS SR 3.3.1.7 CTS T 4.17-1, footnote (d), (e)

CTS T 4-17-6 JFD 14 JFD 14 states that STS SR 3.3.1.7 has been deleted, since the 18 month CHANNEL CALIBRATION surveillance is considered adequate to ensure the bypass removal channels are functioning properly. The CTS requirements referenced by JFD 14 do not discuss bypass removal channels. Comment: Provide a DOC to substantiate CTS references include testing bypass removal channels. Include documentation to support the stated testing such as copies of plant procedures.

Consumers Energy Response:

• • • Resolved during 10/27/98 meeting; Consumers Energy not required to respond.

Refer to comment 3.3-14 3.3.1-16 ISTS T 3.3.1-1 (page 2 of 2)

JFD28 Comment: JFD 28 is included for justification to replace STS table functions With CTS requirements. JFD 28 does not justify the proposed changes. Provide a correction of the STS markup.

Consumers Energy Response:

5 I

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Palisades Improved ts Review Comments*

Section 3.3, Instrumentation

• 3.3.1-17 STS Figure 3.3.1-1,.3.3.1,..2, and 3.3.1-3 JFD 17 STS figures for Thermal Margin/Low Pressure Trip Setpoints: ASI versus A 1 are replaced with plant specific values. Comment: This is a SCOPE issue because it.is a generic change to the STS and a change to the ITS.

Consumers Energy Response:

• • • Resolved during 10/27/98 meeting; Consumers Energy not required to respond.

3.3.1-18 ITS 3.3.1, Applicability CTS 3.17.1 DOCA.2 The CTS Applicability requirement "when there is fuel in the reactor" is deleted without discussion. Comment: Provide a L-DOC for this CTS change.

Consumers Energy Response:

3.3.1-19 CTS 3.17.1.Sb DOCA.4 ITS are changed to add specific actions for placing the plant in a condition where affected equipment is not required to be operable. Comment: Provide an M-DOC replacement for A.4.

Consumers Energy Response:

• • • Resolved during 10/27/98 meeting; Consumers Energy not required to respond.

3.3.1-20 ITS 3.3.1 ITS 3.3.2 CTS T 3.17.1 CTS 3.17.1 DOC A.5 DOC A.4 The CTS Table column, "Minimum Operable Channels" is deleted. Comment: Revise A.5 to include discussion that total channels is unchanged and ITS conditions.do not depend on minimum operable channels for entry into actions.

Consumers Energy Response:

3.3.1-21 ITS 3.3.1 CTS 3.17.1 footnote (a)

DOCA.6 Comment: Confirm that ITS requires same two.channels during the same applicable conditions to confirm the deletion is an administrative change.

Consumers Energy Response:

3.3.1-22 ITS 3.3.1 CTS 3.17.1 Footnote (b)

DOCA:7 Comment: Revise the DOC to include the statement from A.9, "This change essentially moves requirements from one TS to another, and therefore, is considered administrative."

Consumers Energy Response:

6 I

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Palisades Improved TS Review Comments Section 3.3, Instrumentation 3.3.1~23 *ITS 3.3.1 CTS T 4.17.1 Footnote (b)

DOC A~8 This DOC concludes that the addition of ITS SR to TM/LP is necessary since there is no additional testing required. Comment: Explain why the addition is purely administrative.

Consumers Energy Response:

3.3.1-24 ITS 3.3.1 CTS T2.3.1 DOCA.10 This DOC discusses changes to the CTS that result in deleting limitations associated with RPS trip settings with three primary coolant pumps operating. Comment: Revise the DOC to be ari L-DOC. Consumers Energy Response:

3.3.1-25 CTS 3.17.1 DOC M.1

• Comment: Third paragraph on the third line, revise to read "channel bypass".

Comment: The fourth paragraph justifies the addition of ITS conditions E, F, G, and H as consistent with current practice. Add details to this discussion to explain the safety basis for this position.

Consumers Energy Response:

3.3.1-26 ITS 3.3.6 CTS Tables 3.17.6, 4.17.6 CTS Tables 3.17.6 and 4.17.6, Function 19, Fuel Pool Rad Monitor, and Function 20; Containment Refueling Radiation Monitor, show that these functions are moved to ITS 3.3.6, Refueling Containment Radiation High Instrumentation. ITS 3.3.6 does not include instrument functions by these names. Comment: Describe the safety function(s) performed these instrument channels and the safety systems they support.

Consumers Energy Response:

3.3.1-27 CTS Table 3.17.6 DOC L.3.

CTS Table 3.17.6 Functions 12 & 20 are modified by footnote (a) eliminating the applicability of Specification 3.0.4. Comment: This change is marked up as if it were included in ITS 3.3.1, Condition D as a Note.* ITS 3.3.1 Condition D does not include a note or any provision for eliminating the applicability of Specification 3.0.4. Provide clarification including all applicable documentation for the change.

• Consumers Energy Response:

3.3.1-28 CTS Table 3.17.6 CTS Table 3.17.6, Function 19 is modified by footnote (b) deleting the applicability of Specifications 3.0.3, 3.0.4, and 4.0.4. Footnote (b) is marked up as a deletion in the CTS Mark-up and two annotations are provided "See 3.3.6" and "See also 3.2". Comment: It is unclear where Function 19.requirements are located in the ITS and where the footnote (b) exceptions are applied. Provide clarification and appropriate_ documentation for the change.

Consumers Energy Response:

7.

Palisades Improved TS Review Comments Section 3.3, Instrumentation 3.3.1-29 ITS 3.3.1Table3.3.1-1 CTS Table 2.3-1 The Allowable Value for the Variable High Power Trip Function in CTS Table 2.3;.1 is stated as a percentage above "core power" with a minimum of less than or equal to 30% "Rated Power" and a maximum of less than or equal to 106.5% Rated Power. ITS Table 3.3.1-1 changes the stated percentage above "core power", to "ATP", and stated minimum and maximum percentage values in "Rated Thermal Power",versus the CTS "Rated Power". Comment: No discussion or justification is provided for the changed terms in the ITS. This change also results in a change in STS presentation for the Variable High Power Trip Function that is not discussed or justified. The change from the STS presentation appears to be unnecessary.

Provide discussion and justification for the changed terms, describing the difference between the CTS and ITS terms Consumers Energy Response:

. 3.3.1-30 ITSTable 3.3.1-1 Function 2, High Startup Rate Allowable Value Comment: The High Startup Rate function is proposed for ITS with the ALLOWABLE VALUE

. set at "not applicable." The ITS also proposes channel check, channel functional test and channei calibration SRs. Provide the plant procedures for performing the channel calibration on this RPS function. Identify how the Palisades setpoint methodology relates to the procedure calibration limits.

Consumers Energy Response:

3.3.1-31 STS 3.3.2 JFD6 ISTS LCO 3.3.2, "RPS Instrumentation - shutdown" is not used in the ITS. JFD 6 states that the.Palisades design does not include a RPS Instrumentation - Shutdown.. ITS Bases for RPS High Startup Rate state that this trip function serves as a backup to the administratively enforced startup rate limit. Comment: Provide additional explanation to justify not adopting the ISTS LCO 3.3.2. Include discussion comparing the functional capability of ITS Table 3.3.1-1, F1,mction 2, High Startup Rate with ISTS function Power Rate of Change - High.

Consumers Energy Response:

• • • Resolved during 10/27/98 meeting;' Consumers Energy not required to respond.

3.3.2-1 ITS 3.3.2 JFD5 Changes are made to Condition E required actions which take the plant outside the LCO Applicability based on the plant unique applicability proposed by JFD 8.

• Comment": Hold approval of these proposed changes for the resolution of comment 3.3.1-1.

Consumers Energy Response:

• • • Resolved during 10/27/98 meeting; Consumers Energy not required to respond.

8

. Palisades Improved TS Review Comments Section 3.3, Instrumentation 3.3.3*1 ITS 3.3.3 CTS 3.17.2, 3.17.3 JFD 10 Operational bypasses are deleted from the CTS ESF applicability and operational bypass channel TS are deleted from ITS ESF applicability. The ITS proposes to include actions (Required Action C.1) for the SIRWT function which require placing the inoperable SIRWT channel in bypass within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. JFD 1 O states that most ESF functions do not have bypass capability. It would appear that the SIRWT channels can be bypassed, yet CTS Function 2.c (T3.17.2) shows that this function has no operational bypass. Comment: Explain the difference between the CTS operational bypass and channel bypass. Explain the use of the bypass corrective action in ITS Action C.1. Provide a revised LCO Applicability which includes a requirement to have bypass channels operable or operational bypasses operable for those ESF functions that have bypass TS requirements in CTS 3.17.2 and CTS 3.17.3.

Consumers Energy Response:

3.3.3*2 ITS 3.3.3, T3.3.3-1 JFD N/A The format for numbering Functions listed in this table is consistent with the STS however, it could result in operators questioning the efficacy of procedures based on the TS numbering scheme. Comment: The SIS, CHA and RAS Functions for ESF actuations are detected by a single process parameter. These Functions are listed in T3.3.3-1 as Functions 1.a, 3.a and 5.a.

The staff recommends deleting the "a" designation because alternate process parameters for actuating ESF do not exist for Palisad.es and hence no "b" Functions are present in the table,

e.g., 1.b, 3.b and 5.b.

Consumers Energy Response:

• • • Resolved during 10/27/98 meeting; Consumers Energy not required to respond.

3.3.3*3 ITS 3.3.3 DOCA.3, A.5 CTS 3.17.2, 3.17.3 The DOCs address two proposed changes. The first deletes CTS references to operational bypasses, and the second addressed TS Applicabilities changes. Comment: The staff

• accepts A.3 and A.5 for the Applicability changes. Revise DOCs A.3 and A.5 to state that operational bypasses are moved to ITS LCO 3.3.4.

Consumers Energy Response:

• • • Resolved during 10/27/98 meeting; Consumers Energy not required to respond.

3.3.3*4.

ITS 3.3.3 DOC A.4 CTS 3.17.2 The DOC states that a note was added to CTS which allows separate condition entry for each ESFAS trip and applicable bypass removal function. Comment: The st~ff notes that references to operational bypasses are moved to ITS 3.3.4. Revise DOC A.4 to accurately describe the ITS separate condition entry note.

Consumers Energy Response:

• • • Resolved during 10/27/98 meeting; Consumers Energy not required to respond.

9 I +---* ---*- *.

Palisades Improved TS Review Comments Section 3.3, Instrumentation 3.3.3-5 ITS 3.3.3, Condition B CTS 3.17.2.3, 3.17.3.3 DOC L.1 The L.1 DOC justifies adopting the STS note in Action B that LCO 3.0.4 is not applicable for the condition of two inoperable channels. This* note permits changes in plant Modes while relying on remedial actions provided in the actions. The staff notes that the L.1 DOC addresses two important safety concerns for the condition of two inoperable channels: the low probability of an event requiring ESFAS with one channel tripped and a second channel inoperable; and the one out of two channel logic that remains to actuate on ESF signals retains single failure protection.

The staff notes however, that the LCO 3.0.4 note is included with a completion time to place one of two inoperable channels in trip within one hour. The ITS retains the CTS completion time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Thus, the plant could operate for a period of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> without single failure protection before one channel is required to be tripped. Comment: The staff cannot agree to the use of the LCO 3.0.4 note combined with deviating from the STS completion times for tripping and restoring one inoperable channel without additional justification. Include an explanation of the operational reasons for requiring up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. to place an inoperable channel in trip.

Consumers Energy Response:

• • • Resolved during 10/27/98 meeting; Consumers Energy not required to respond.

3.3.3-6 ITS 3.3.3 DOC none CTS Table 3.17.2, function 1.d The CTS requires four pressurizer pressure instrument channels to be operable with an operational bypass at less than or equal to 1700 psia PCS pressure. This requirement is translated as Pressurizer Low Pressure in ITS Table 3.3.3-1. The FSAR contains two SIS.

actuation logic input functions; Pressurizer Low Pressure and Pressurizer Low Low Pressure.

Comment: Provide discussion for deleting the low, low pressurizer pressure input to SIS.

Consumers Energy Response:

3.3.3-7 ITS 3.3.3 DOC none CTS Table 3.17.3 ITS change the STS applicability for the SG low pressure function to conform to the ITS LCO 3.7.2 MSIV and LCO 3.7.3 MFIV applicabilities as note (a) to Table 3.3.4-1. This is a change to the CTS and to the STS. Comment: Provide a ju~tification for this change.

Consumers Energy Response:

• • • Resolved during 10/27/98 meeting; Consumers Energy not required to respond.

3.3.4-1 ITS 3.3.4 JFD/DOC none CTS Table 3.17,2 requires two SIS logic (Initiation, Actuation, and low pressure block reset) two channels to be operable. ITS 3.3.4 specifies the SIS logic as "pressurizer pressure -low."

Comment: Provide discussion for this change..

Consumers Energy Response:

10 i*-* -----*- -*--***-------

-~--- -*--*--* ---* -*--*- -**

Palisades Improved TS Review Comments Section 3.3, Instrumentation 3.3.4-2 ITS 3.3.4 JFD/DOC none CTS Table 3.17.2 and 3.17.3 require two manual and two logic channels for SIS, RAS, AFAS, CHP, CHR, and SGLP. ITS 3.3.4 requires two ESF Manual Initiation and two ESF Actuation Logic channels and associated bypass removal channels for each ESF Function specified in the LCO table. ITS Table 3.3.4-1 lists six ESF Functions: SIS, RAS, AFAS~ CHP, CHR, and SGLP.

Comment: All functions, except CHP, list Manual Initiation Functions twice; once in the LCO and again as a separate function in Table 3.3.4-1. Provide additional justification to explain the translation of CTS LCO requirements into the proposed ITS.

Consumers Energy Response:

3.3.4-3 ITS 3.3.4 JFD/DOC none T 3.3.4-1 is titled, "Engineered Safety Features Actuation Logic and Manual Channel Applicability." Comment: A more appropriate title is", "Engineered Safety Features Actuation Logic and Manual Initiation" Consumers Energy Response:

3.3.4-4 ITS SR 3.3.4.1, SR 3.3.4.3 CTS Tables 3.17.2 and 4.17.2 DOCA.1 CTS Tables 3.17.2 and 4.17.2Function1b, SIS Logic, CHANNEL FUNCTIONAL TEST references footnote. (a), requiring verification of all automatic actuations and automatic resetting of the low pressure block each 18 months. This CTS SR is shown to be ITS SRs 3.3.4.1 and 3.3.4.3. However, the requirements of footnote (a) to verify automatic actuation and automatic resetting of the low pressure block is deleted. Comment: Additional discussion and justification for the change is required in the conversion documentation to verify the current licensing basis is maintained. Explain how the automatic low pressure block actuation and reset are tested by ITS SR 3.3.4.1 and ITS SR 3.3.4.3 as required for ITS Table 3.3.4-1 Function 1 b.

Consumers Energy Response:

3.3.4-5 ITS 3.3.4 DOCA.6 CTS Tables 3.17.2 and 3.17.3 CTS Tables 3.17.2 and 3.17.3 are revised to incorporate ITS Table 3.3.4-1 Footnote (c),

allo,wing manual initiation achieved by any individual component controls for RAS and.AFAS (DOC A.6 states SGLP also, although neither the CTS mark-up nor the ITS apply Footnote (c) to the SGLP Function). Comment: It is not clear from the discussion of change what "any individual controls" includes. It is not clear that these ESF Functions include more than 2 Manual Initiation trains initiated by one control switch each. Provide additional clarification of the hardware configuration including any additional actuation devices not included in LCO 3.3.4.

This is a SCOPE issue because it is a change to the STS and a change to the ITS. Provide justification for not adopting current TS requirements for these functions.

Consumers Energy Response:

I 11 1

'---------~-------

Palisades Improved TS Review Comments Section 3.3, Instrumentation

• 3.3~4-6 ITS 3.3.4 JFD/DOC none CTS Table 4.17.2 CTS includes requirements to perform an AFAS Logic CHANNEL FUNCTIONAL TEST at a 92 day interval. The ITS translates the CTS requirement as SR 3.3.4.2 which specifies testing is to be performed using test circuits. Comment: This is a SCOPE issue because it is a change to the STS and a change to the ITS. Provide justification for not adopting current TS requirements for these functions.

Consumeres Energy Response:

. 3.3.4-7

• ITS 3.3.4 JFD 11 CTS Tables 3.17.2 and 4.17.2, Functional Units 1.b and 1.c JFD 11 is not used in ITS 3.3.4. Comment: Provide a revised submittal markup.

Consumers Energy Response:

3.3.4-8

. ITS 3.3.4 JFD9

.CTS Tables 3.17.2 and 4.17.2.

Bypass channels are included in the ITS LCO as "associated bypass removal channels."

Comment: Revise the ITS SRs to include testing requirements for bypass removal channels and modify Table 3.3.4-1 to specify those Functions that have bypass capability.

Consumers Energy Response:

3.3.4-9 ITS 3.3.4, DOC A.3 ITS 3.3.3, DOCs M.1 & M.3 CTS 3.17.2.5 and 3.17.3.5 The "Minimum OPERABLE Channels" column and TS actions based on this requirement are deleted from CTS 3.17.2.5 and 3.17.3.5. These CTS specifications are included in ITS LCOs 3.3.3 and 3.3.4. In the CTS mark up for ITS 3.3.3 the changes are discussed in DOC M.1 and in CTS 3.17.3.5 the changes are discussed in DOC M.3. The DOCs contain identical justifications. In the CTS mark up for ITS 3.3.4 these same changes are discussed in DOC A.3. The staff notes that Mode changes that follow in subsections a) and b) of CTS 3.17.2.5 and 3.17.3.5 are also identical and that the DOC justifications are the same for the CTS mark up for ITS 3.3.3 and 3.3.4.

Comment: The staff questions the use of both a more restrictive and administrative change categorization for the same CTS change. Evaluate the differences between the CTS markup M-DOCs and A-DOCs and provide a consistent category justification.

Consumers Energy Response:

12

- --- **-*-~-,.-**---**----*---**----..

Palisades Improved TS Review Comments Section 3.3, Instrumentation 3.3.4-10 JFD 9 CTS Table 3.17.3 CTS Table 3.17.3 indicates a permissible operational bypass for a Steam Generator Low Pressure Function of "less than 550 psig Steam Pressure". ITS Table 3.3.4-1, Footnote (c) changes the allowed bypass pressure to "less than 565 psia Steam Generator Pressure".

Comment: It is not clear that the CTS bypass pressure is measured by Steam Generator Pressure instrumentation or Steam Line Pressure instrumentation. Should the ITS assume that the ITS bypass pressure is measured by the Steam Generator Pressure instrumentation? The changed values are not discussed or justified. Provide discussion and justification for the change including any difference in measured parameters, monitoring instrumentation, scaling factors, and why the engineering units of measure are changed from psig. to psia.

Consumers Energy Response:

3.3.4-12 ITS SR 3.3.4.1 CTS Table 4.17.2 ITS SR 3.3.4.1 requires performance of a functional test" using test circuits, every 92 days.

ITS SR 3.3.4.2 requires performance of a CHANNEL FUNCTIONAL TEST using test circuits, every 92 days. Comment: The functional test of ITS SR 3.3.4.1 is assumed to be a different type of test that h~s not been defined. In addition, both tests are to be performed "using test circuits". This information, as to how the test is to be performed, belongs in the ITS Bases.

Clarify surveillance test requirements based on defined test methods and format requirements according to the STS.

Consumers Energy Response:

• • • Resolved during 10/27/98 meeting; Consumers Energy not required to respond.

See Comment 3.3.4-6 3.3.5-1 ITS 3.3.5, DOC M.1 JFD9 The ITS proposes to adopt the STS LCO for LOP DG start. The M.1 DOC discusses the applicability for this LCO as MODES 1, 2, 3, 4 and when the associated DG is required to be operable. Comment: The ITS markup changes the STS Applicability requirements from MODES 1, 2, 3, 4 and when associated DG is required to be OPERABLE by LCO 3.8.2, "AC Sources-Shutdown." The proposed ITS represents a generic change to the STS and is not acceptable. Revise the ITS Applicability for LCO 3.3.5 to be consistent with NUREG-1432, Rev.1.

Consumers Energy Response:

3.3.5-02 Comment:STS SR 3.3.6.3 states:" Perform CHANNEL CALIBRATION with setpoint (emphasis added) Allowable Values as follows:" ITS SR 3.3.5.1 deletes the word "setpoint" without any discussion or justification. Provide discussion and justification for the change to STS wording.

Consumers Energy Response:

• • Discuss with Comment 3.3.5-03 13

Palisades Improved TS Review Comments Section 3.3, Instrumentation 3.3.5-03 Comment: STS SR 3.3.6.3 provides Allowable Values for the DG-LOVS Degraded Voltage, Loss of Voltage and Time Delay Functions. The Allowable Values are stated with an upper and lower value (i.e. Degraded Voltage Function ~3180V and ~3220 V). The corresponding SR in the ITS is SR 3.3.5.1. The Allowable Value in ITS 3.3.5.1 for the Degraded Voltage Function is

~2184 V, providing no setting tolerance around the Allowable Value. Provide Allowable Values for DG-UV Start Degraded Voltage, Loss of Voltage and Time Delay functions with upper and lower setting limits, consistent with the STS SR 3.3.6.3 presentation, and provide a basis for the Allowable Values.

Consumers Energy Response:

3.3.5-04 ITS. LCO 3.3.5 Bases Markup Bases insert 1 describes the two levels of undervoltage protection relays installed on each

• 2,400 volt bus (1 C and 1 D). The Bases state that each relay measures voltage on all three phases, and protects against sudden voltage loss on the corresponding bus using a three-out-of-three phases coincident logic. Once the logic is made up the actuation relay will trip its respective incoming bus circuit breakers, start its associated DG, initiate bus load shedding, and activate annunciators in the control room. The Bases describes a three channel detection system with a single actuation relay for each bus. Comment: Identify the number of installed calibrated devices that sense voltage loss for each bus. Identify the number of channels associated with these devices. Provide information regarding the reliability of the DG-UV Start instrument channels for the proposed 18 month calibration interval and relate channel drift characteristics to the need for a periodic channel functional test. Revise LCO 3.3.5 channels requirements to be consistent with TS defined channels.

Consumers Energy Response:*

3.3.6-01 JFD 9 provides discussion and justification for deleting the automatic actuation logic and manual trip functions from STS 3.3.7. The discussion states that each of the two refueling CHR channels have an associated logic circuit, therefore, the licensee considers the channel to include the actuation circuit. The licensee also states that a manual trip feature is included iri the design but its function is not assumed in the safety analysis. Comment: It is not clear why the manual trip function is not included in ITS 3.3.6, because this system is classified as a Safety System, according to IEEE 603. Additionally, certain instrumentation features are integral to the format and content of this and other LCOs in the STS, thus the manual function and automatic actuation logic should be included in ITS 3.3.6. Are there failure modes of the manual circuitry that could render one or both channels inoperable? Comment: The.

proposed SRs include CHANNEL CHECK, CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION. Which channel test verifies the allowable value? Why isn't the allowable value included in the TS?

• Which channel test verifies the channel logic?

Consumers Energy Response:

14

Palisades Improved TS Review Comments Section 3.3, Instrumentation 3.3.6-02 JFD 9 STS (3.3. 7) Condition B addresses manual trip or actuation logic channels inoperable and requires isolation of the valves rendered inoperable by this instrumentation with subsequent entry into the affected LCOs. Comment: JFP 9 is annotated in the mark-up for deleting Condition B but does not specifically address eliminating the actions of Condition B. The deviation from the STS seems to be preference because the Palisades design would allow for STS required actions to apply; isolation of the specific valve(s) rendered inoperable by the instrumentation or' require the safety function of the system to be initiated, thus preserving the plant analysis. Provide discussion and justification for these STS deviations.

Consumers Energy Response:

• • Discuss with Comment 3.3.6-01.

3.3.6~03 JFD 8 JFD 8 states that the radiation channels have dual purposes; to isolate containment and to place the CRVS system in the emergency mode of operation. Comment: The proposed ITS delete STS LCO 3.3.8, Control Room Isolation Signal. When one or more of these channels become inoperable some or all capability to pressurize the CR is lost. Discuss the safety implications of not including an ITS LCO that provides remedial actions to place the.control room in the emergency mode for one or more inoperable radiation isolation channels during Modes 1-4 and during refueling or core alteration operations. Justify these STS deviations.*

Consumers Energy Response:

• • Discuss with Comment 3.3.6-01.

3.3.6-04 GOC AS.

CTS Table 3.17.6, Function 20, Note a.

The A.5 discussion addresses notes (a) and (b) but the CTS changes only apply to note (a).

Note (a) provides that the provisions of specifications 3.0.4 and 4.0.4 are not applicable. Note (b) also includes an exception to 4.0.4. Comment: Provide an M-DOC or L-DOC for these changes because CTS exceptions to specifications (which currently allow changing Modes without meeting the LCO and entry into the LCO without meeting SRs) do not apply to ITS.

Consumers Energy Response:

• • • Resolved during 10/27/98 meeting; Consumers Energy not required to respond'.

15

Palisades Improved TS Review Comments Section 3.3, Instrumentation 3.3.7-01 Containment Isolation Valve Position The STS require*2 containment Isolation valve (CIV) position indication channels to be operable for each penetration flow path as modified by Notes a and b.. Note a states that position

• indication is not required if penetrations are isolate.d as described in the note. Note b states that penetrations with one installed control room indication only require one position indication channel to be operable. The ITS proposes 1 required CIV position indication channel for each valve with Note a. Note b js deleted. The STS change justification (Attachment 6, Discussion

7) states that this change is to reflect plant design, which includes only one position indication channel per valve, and furthermore proposed TS are consistent with current design and licensing basis since not all penetrations are equipped with CIVs that include position indication.

Comment: Change T3.3.7-1 to require 2 CIV position indication channels per penetration and adopt STS Note b. The PAM LCO is constructed for separate condition entry for each function.

Thus, for the CIV function in T3.3.7-1, two position indication channels per penetration are required and the ACTIONS Conditions apply separately for each penetration resulting in a 30 day allowed outage time (AOT) for the first inoperable channel in a penetration and a 7 day AOT for the second inoperable channel. The staff notes that the STS Bases clarify that only active valves are required to have installed PAM position indication'. Therefore, if the staff approved a AG 1.97 deviation because a valve did not have Category I position indication then the position indication for that valve is not be covered by this TS and a single valve in the penetration is required to have operable position indication. Therefore, revise T3.3.7-1 to include Note b to CIV position indication.

Consumers Energy Response:

• • • Resolved during 10/27/98 meeting; Consumers Energy not required to respond.

3.3.7-02 Table 3.3.7-1, Note (a)

CTS 3.17.4.3 L.7 L.7 justifies the addition of alternate TS allowances in the ITS to isolate containment penetrations. Currently, the CTS requires inoperable valves to be locked closed if they are not returned to operable status, whereas the ITS specifies repair or shutdown. Comment: The STS riote adopted in T3.3.7-1 is not a required action, but it provides an alternate method for complying with the LCO, by isolating the valve(s) in such a manner that their safety function is performed. This allowance is not evaluated in L.7.

Consumers Energy Response:

• • • Resolved during 10/27/98 meeting; Consumers Energy not required to respond.

3.3.7-03

• Action B.1, CTS 3.17.1-3.17.3, Functions 1-15 CTS 3.17.4 (CETs)

ITS Action 8.1 is to initiate action in accordance with Specification 5.6.6 if one channel of inoperable equipment cannot be restored to operable status. CTS 3.17.3 for PIVs has an

• alternate allowance which requires isolating and locking closed valves with inoperable position indication. If CTS repair actions (or in the case of CIVs, isolation) are not met, thenC'if"S 3.17.4 for Functions 1-15 and CTS 3.17.4.7.a for CETs requires the reactor to be in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 4 within 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> if inoperable functions are not restored to operable status.

Comment: L.1 does not evaluate all CTS 3.17.4.1 and 3.17.4.a changes that result from adopting the less restrictive ITS Action 8.1. Revise the submittal to provide justifications for each less restrictive CTS change that results from transl~ting CTS into the STS format.

Consumers Energy Response:

16

Palisades Improved TS Review Comments Section 3.3, Instrumentation 3.3.7-04 SR 3.3.7.2 The STS SR 3.3.7.2 Note that indicates that neutron detectors are excluded from Channel Calibration has been deleted in the ITS Markup. Attachment 6, Discussion 6 states that this exclusion is being incorporated within the definition of Channel Calibration. Comment: The staff has not approved Channel Calibration definition changes. The submittal should be revised to conform to the STS.

• Consumers Energy Response:

3.3.7-05 ITS T3.3.7-1, CET Functions The STS require two channel per CET per core quadrant, with a channel defined in Note (c) as consisting of 2 CETs. The CTS requirement is 4 CET channels per core quadrant. Thus, CTS requirements can be translated into the STS format without a change to the STS format.

Comment:.Revise the ITS to require 2 required CET channels and adopt Table 3.3.11-1 Note (c) in ITS T3.3.7-1.

Consumers Energy Response:

• • • Resolved during 10/27/98 meeting; Consumers Energy not required to respond.

3.3.7-06 DOC L.5 This DOC is used to justify eliminating a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> requirement to initiate the alternate preplanned monitoring method for RVLS instruments inoperable and incapable of monitoring reactor level for post-accident management. Comment: Provide additional discussion for why the proposed change assures that the appropriate safety margin is maintained.

Consumers Energy Respo.nse:

3.3.8-01 CTS 3.17;5.2 ITS 3.3.8, Action A CTS 3.17.5.2 requires shutdown to HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and continued shutdown to a PCS temperature below 300 degrees F, within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the required Action of CTS 3.17.5.1 are not met. The corresponding ITS 3.3.8 Condition B reduces the Completion Time to reach MODE 3 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduces the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Completion Time for shutdown to MODE 4 to 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. DOC M.3 provides discussion and justification for the change based on operating experience. The corresponding STS 3.3.12 Condition B requires shutdown to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, consistent with the proposed ITS 3.3.8 Condition B, however, the Completion Time for shutdown to MODE 4 is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> instead of the proposed 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Comment: No JFD is provided for the STS deviation. This change in Completion Time neither maintains the current licensing basis nor conforms to the STS. Provide additional discussion and justification for the CTS change and for the STS deviation based on the specific Palisades design or applicable analyses.

Consumers Energy Response:

• • • Resolved during 10/27/98 meeting; Consumers Energy not required to respond.

3.3.8-02 ITS LCO 3.3.8 STS LCO 3.3.12 an.d STS 3.3.12 Condition A are reworded to specify "one channel of each Shutdown System Function" in the corresponding ITS 3.3.8 Specification format. This rewording seems to be a presentation preference only.. Comment: Reformat ITS 3.3.8 LCO, Condition A, Required Action A.1 consistent with STS 3.3.12, including Table 3.3.12-1 listing of Functions and Required number of channels.

Consumers Energy Response:

17

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• ~.*'4 Palisades Improved TS Review Comments Section 3.3, Instrumentation 3.3.8-03 CTS4.17.5 DOC L.1 All CTS Table 4.17.5 required quarterly CHANNEL CHECKS are deleted in the corresponding ITS 3.3.8. Deletion of the CHANNEL CHECKS i~ based on the fact that the channels have to be energized each quarter (transferring actuation capability to the Alternate Shutdown System}

in order to perform the testing. The only* other required surveillance on these channels is performed every 18 months as a CHANNEL CALIBRATION. Comment: Explain what is meant by "control is removed from the control room" in L.1 in order to perform a CHANNEL CHECK surveillance requirement as required by CTS. Discuss operational hardships and safety concerns that result from the test.

Consumers Energy Response:

3.3.8-04. ITS 3.3.8 The STS SR 3.3.12.3 Note excluding the neutron detectors from the CHANNEL CALIBRATION is deleted in ITS SR 3.3.8.4. Comment: The staff has not approved Channel Calibration definition changes. The submittal should be revised to conform to the STS.

Consumers Energy Response:

3.3.8-05

.ITS 3.3.8 The reactor trip circuit breaker open/close indication is deleted in ITS SR 3.3.8.3 without discussion or justification. Comment: Provide discussion and justification for the STS deviation, based on Palisades specific design.

Consumers Energy Response:

• • • Resolved during 10/27/98 meeting; Consumers Energy not required to respond.

3.3.8-06 CTS 4.17.5.

The CTS Table 4.17.5 channel functional test for P8Bs (functions 13, 14 and 15) are deleted in ITS SR 3.3.8.3 without discussion or justification. Comment: Revise ITS SR 3.3.8.3 to include channel functional test for these functions.

. Consumers Energy Response:

• • • Resolved during 10/27/98 meeting; Consumers Energy not required to respond.

3.3.8-07 ITS Required Action A.1, SR 3.3.8.1 Proposed ITS Action A.1 requires "Provide equivalent shutdown capability." The language specifying the action is vague. Upon completing the actions to provide an equivalent capability it appears that the LCO is met. Comment: Provide discussion explaining the deviation from the *STS action based on Palisade~ specific design.

Consumers Energy Response:

3;3.8-08 DOC A.4

. This discussion equates elimination of the number of channels included in CTS for transfer.

• circuits with ITS SR 3.3.8.2 which requires a* functional test of the transfer circuits together with the ITS definition of OPERABLE-OPERABILITY. Comment: The proposed CTS changes are not equivalent. Provide an alternate CTS change justification.

Consumers Energy Response:

• • • Resolved during 10/27/98 meeting; Consumers Energy not required to respond.

18

Palisades Improved TS Review Comments Section 3.3, Instrumentation 3.3.8-09 DOC LA.1 Table 3.17.5, Table 4.17.5 This discussion states that CTS transfer functions listed in the tables are details related to component identification. The CTS lists both the component identifying number and the generic name (transfer function). Comment: The result of the proposed CTS change is to delete a specific TS requirement that is related to a design detail or operator instruction.

Provide an alternate CTS change justification.

Consumers Energy Response:

• • • Resolved during 10/27/98 meeting; Consumers Energy not required to respond.

3.3.8-10 DOC M.3 This discussion equates elimination of the number of channels included in CTS for transfer circuits with ITS SR 3.3.8.2 which requires a functional test of the transfer circuits together with the ITS definition of OPERABLE-OPERABILITY. Comment: The proposed CTS changes are not equivalent. Provide an alternate CTS change justification.

Consumers Energy Response: *

• • • Resolved during 10/27/98 meeting; Consumers Energy not required to respond.

3.3.9-01 CTS 3.17.6 DOC R.3 provides discussion and justification for relocating CTS 3.17.6, Table 3.17.6, Functions 8, 9, 10, and 11 and associated note (a), and Table 4.17.6 Functions 8, 9, 10, and 11 and associated Note (c), containing requirements for primary safety valve position indicators, PORV position indicators, PORV block valve position indicator, and for the service water break detector respectively. Comment: The CTS 3.17.6 Mark-up does not include Functions 1 O and

11. Provide the CTS Mark-up pages that include these Functions. DOC R.3 provides adequate justification for the relocated requirements.

Consumers Energy Response:

3.3.9-02 CTS 3.17.6 DOC R.4 provides discussion and justification for relocating CTS 3.17.6, Table 3.17.6 Function 19 and associated Note (b) requiring two fuel pool area radiation monitors OPERABLE in HOT STANDBY and above. Comment: The CTS 3.17.6 Mark-up does not include the pages containing these requirements. Provide the CTS Mark-up pages that include this Function.

DOC R.4 provides adequate justification for the relocated requirements.

Consumers Energy Response:

3.3.9-03 The STS SR 3.3.13.3 Note excluding the neutron detectors from the CHANNEL CALIBRATION is deleted in ITS SR 3;3.9.2. Comment: The staff has not approved Channel Calibration definition changes. The submittal should be revised to conform to the STS.

Consumers Energy Response:

19

Palisades Improved TS Review Comments

• Section 3.3, Instrumentation 3.3.9-04 CTS Table 3.17.6 DOCA.3 The CTS source range monitor (SAM) applicability ("less than 1 E-4% Rated Power, with fuel in the reactor") becomes applicabilities in Section 3.3 and 3.9 of the ITS. A.3 states that in the ITS format, this CTS applicability is not directly translated into the ITS modes; however, the SAM applicability requirements would place the plant in one of following four conditions: MODE 6; MODE 2; or MODES 3, 4, or 5. MODE 6 requires two SRMs. A.3 states that MODE 2 requirements are stated in ITS 3.3.1, and that MODE 3, 4, 5 requirements are stated in 3.9 except for those given in LCO 3.3.1.

Comment: Provide additional discussion to support the A.3 discussion that the SAM channel requirements of the CTS are unchanged (<1 E-4 %ATP

.and fuel in the reactor) in the proposed ITS, particularly for applicability in "MODE 2" (LCO 3.3.1) and in "MODES 3, 4, 5 with more than one rod capable of withdrawal and the PCS boron concentration at the REFUELING BORON CONCENTRATION" (LCO 3.3.1). Comment: The ITS proposes to delete STS LCO 3.3.2 (RPS-Shutdown) yet RPS shutdown requirements are included in LCO 3.3.1. Additionally, JFD 8 does not fully justify changing the CTS and STS applicabilities to accommodate the Palisades individual control rod circuit breakers. This presentation must provide a design basis for not adopting STS format.

Consumers Energy Response:

3.3.9-05 TSTF-136 is incorporated in ITS 3.3.9 Required Action A.2 to reflect the combination of STS.

3.1.1 and 3.1.2 in the ITS (See JFD 12). Comment: TSTF-136 does not show that both SR 3.1.1.1 and SR 3.1.2.1 are retained. Instead the traveler shows these SRs were combined into a single test requirement.

Consumers Energy Response:

3.3.9-06 DOC A.2 CTS 3.17.6.'1 This discussion justifies eliminating the CTS Action to place the plant in Hot Shutdown within 15 minutes if neutron monitoring channels are inoperable. The justification relates that CTS requirements are moved to ITS LCO 3.1.1 because LCO 3.1.1 requirements for Shutdown Margin not met applies the same time frame (15 minutes) to restore shutdown margin.

Comment: The DOC is unclear. Elaborate on the administrative. nature of the change.

Consumers Energy Response:

20

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I J

Palisades Improved TS Review Comments Section 3.3, Instrumentation 3.3.10-1 ITS 3.3.10 CTS Table 3.17.3

• DOCA.2 The ITS proposes a new LCO for Engineered Safeguards Room Ventilation instrumentation.

This instrumentation isolates apump room on a high radiation signal. In th.e CTS this Function is listed with other ESF isolation instrumentation. Comment: The justification for this proposed change states "an additional Specification is included... :... to ensure an assumption of the radiological consequences analysis of the LOCA is maintained. The staff notes that ITS specifications 3.3.3 and.3.3.4 contain the other ESF Functions from CTS Table 3.17.3, including radiation monitors which actuate valve closure signal for example on the MSIVs and

• the MFIVs. The staff questions the basis for the additional specification, and recommends instead including the ESRV Instrumentation requirements in ITS LCOs 3.3.3 and 3.3.4. As a note to the construction of the proposed LCO 3.3.10, separate condition entry is not needed because the same action is required for one or both required channels of ESRV inoperable.

Consumers Energy Response:

21

t I

GENERAL ISSUES RELATED TO THE REVIEW OF CONSUMERS ENERGY'S IMPROVED TECHNICAL SPECIFICATION CONVERSION SUBMITIAL OCTOBER 27 AND 28, 1998

1. General discussion of issues related to Section 1.0, Use and Applications, and Section 3.7, Plant Systems.

2. Status of Consumers Energy development of Tables for incorporation into Safety Evaluation (SE). Tables to include:

Table A (Administrative Changes)

Table L (Less Restrictive Changes)

Table M (More Restrictive Changes)

Table RL (Relocated Details)

Table R (Relocated Specifications) *

3. Consumers Energy will need to develop Less Restrictive Categories for reference in Table L. The docketed SE list and. description of Less Restrictive Categories for the Calvert Cliffs conversion were provided as an example. The staff will provide additional discussion in the. SE for less restrictive changes that do not fit into a category.

4. Consumers Energy will need to develop Relocated Less Restrictive Requirements (the 0 RL 0

changes). The docketed SE list and description of Relocated Less Restrictive*

• Requirements for the Calvert Cliffs conversion were provided as an example.

5. The staff discussed the status of the draft ITS SE. "Boiler Plate 0 information has been prepared, dates of NRC requests for additional information (RAls) and supplemental letters submitted by Consumers Energy are added to the draft SE as they are issued or received, "beyond scope" evaluations from NRC Technical Branches are incorporated as they are provided, and Palisades license amendments issued since the Palisades application for the ITS conversion amendment on January 26, 1998, are listed.

ENCLOSURE3