ML18066A423

Forwards Answers to 990311 Telcon Request for Addl Clarification & Revs Re ITS Section 3.4.Markups of Previously Submitted TS Pages & Revised Pages for Section 3.4 Also Encl

ML18066A423
Person / Time
Site:	Palisades
Issue date:	03/22/1999
From:	Haskell N CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18066A424	List: ML18066A423 ML18066A425
References
NUDOCS 9903300296
Download: ML18066A423 (27)

Text

A CMS Energy Company Palisades Nuclear Plant Tel: 616 764 2276 27780 Blue Star Memorial Highway Fax: 616 764 2490 Covert, Ml 49043 Nathan L. Haskell Director, Licensing March 22, 1999 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS - ADDITIONAL REVISIONS - ITS SECTION 3.4 On January 26, 1998, Consumers Energy Company submitted a Technical Specifications Change Request (TSCR) to revise the Palisades Technical Specifications to closely emulate the Standard Technical Specifications for Combustion Engineering Plants, NUREG-1432.

On November 9, 1998, Consumers Energy Company responded to a Request for Additional Information concerning Sections 3.4, Primary Coolant System, and 3.9, Refueling, of that TSCR. During a telephone call on March 11, 1999, the NRC staff requested additional clarification and revisions regarding Section 3.4. This letter provides the response to those NRC requests. It also includes one technical change made as a result of comments from the Palisades staff.

The following Enclosures to this letter have been provided:

Enclosure 1 contains: a) answers to the NRC requests; and, b) markups of the previously submitted pages to show where revisions have been made.

Enclosure 2 contains markups of the previously submitted pages to show the technical change made aS a result of comments from the Palisades Staff.

Enclosure 3 contains revised pages for Section 3.4.

I/

The technical change identified by the Palisades staff revises a note in ITS SR 3.4.1.3, ~'!/

verification of the Primary Coolant System flow rate. The note, as presented in both STS and in our January 26, 1998 ITS submittal, states "Not required to be performed until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after

<>: 90% RTP." The CTS have essentially the same verification requirement (SR 4.15), but with performance required "within the first 31 days of rated power operation."

(-~9-9-03-300296 990322 I PDR *ADOCK 05000255 P PDR

!I

The initial ITS submittal changed the CTS requirement to more closely emulate the STS.

Subsequent Palisades staff reviews, however, concluded that this more restrictive change conflicted with our methodology for conducting the required flow measurement. Therefore the ITS note has been revised to retain the current licensing basis. The pages contained in to this letter revise that SR note to state: "Not required to be performed until 31 EFPD after:::: 90% RTP." The following discussion explains why the current licensing basis is being retained for this SR:

The most common, and perhaps accurate, method used to perform the PCS total flow surveillance is by means of a primary to secondary heat balance (calorimetric) with the plant at or near full rated power. This is the test method currently utilized by Palisades.

The most accurate results for such a test are obtained with the plant at or near full power when differential temperatures measured across the reactor are the greatest.

Consequently, the test should not be performed until reachi.ng near full power (i.e.,.'.'.'.. 90% RTP) conditions.

Similarly, test accuracy is also influenced by plant stability. In order for accurate results to be obtained, steady state plant conditions must exist to permit meaningful data to be gathered during the test. Typically, following an extended shutdown the secondary side of the plant will take up to several days to stabilize after power escalation. It is impracticable to perform a primary to secondary heat balance of the precision required for the PCS flow measurement until stabilization has been achieved. Furthermore, an integral part of the Palisades PCS flow heat balance involves the use of Ultrasonic Flow Measurement (UFM) equipment for measuring steam generator feedwater flow. This equipment requires, by design, a minimum of 3 days of stable plant operation at or near full power conditions before it can be used. Typically, we have experienced the need for up to a week of stable plant conditions before the feedwater UFM equipment yields usable data.

The changes being submitted herein do not alter the conclusions of the No Significant Hazards Considerations contained in our January 26, 1998 submittal.

SUMMARY

OF COMMITMENTS This submittal contains no new commitments and no revisions to existing commitments.

irector, Licensing Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Enclosures

CONSUMERS ENERGY COMPANY ADDITIONAL REVISIONS - ITS SECTION 3.4

.To the best of my knowledge, the content of this response to the NRC telephone requests of March 11, 1999, concerning Section 3.4 of our January 26, 1998 License Amendment request for conversion to Improved Technical Specifications, is truthful and complete.

Sworn and subscribed to before me this tXJrw:L day of ~ 1999.

~~~

Mary Ann Engle, Notary Public Berrien County, Michigan (Acting in Van Buren County, Michigan)

My commission expires February 16, 2000 r ':

ENCLOSURE 1 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS ADDITIONAL REVISIONS - ITS SECTION 3.4 RESPONSE TO NRC REQUESTS SECTION 3.4, PRIMARY COOLANT SYSTEM

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO AUGUST 24, 1998 REQUEST FOR ADDITIONAL INFORMATION SECTION 3.4, PRIMARY COOLANT SYSTEM NRC REQUEST #1 :

The first NRC question requested clarification as to why the two ITS LCO 3.4.1 limitations involving .Primary Coolant System flow were expressed in different units.

Consumers Energy Response:

The current Palisades safety analyses utilize an assumption that the reactor inlet temperature is bounded as required by the equation presented as ITS LCD 3.4.lb. Therefore, it is desired to retain that requirement as a Technical Specification limit.

The reasons for presenting the minimum Primary Coolant System flow requirement in gallons per minute, rather than pounds mass per hour, are explained in our pending Technical Specification change request on that subject, dated June 17, 1998.

Affected Submittal Pages:

No page changes.

1

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO AUGUST 24, 1998 REQUEST FOR ADDITIONAL INFORMATION SECTION 3.4, PRIMARY COOLANT SYSTEM NRC REQUEST #2:

The second NRC question requested that an incorrect TSTF reference on page 3.4-4 of our mark up of the STS, and in the associated JFD be corrected.

Consumers Energv Response:

The noted errors have been corrected.

Affected Submittal Pages:

Att 5, NUREG 3.4.2, page 3.4-4 Att 5, NUREG 3.4.2, page B 3.4-8 Att 6, JFD 3.4.2, page 2 of 2 2

~S Minim~emperature for Criticality ru... --  :. -1ov.c... 3.4.2

'?R 1mPrr\ V _ p \JI 10.

0

~c..S ~ ~<.S 3.4 <WctofilcooLANT SYSTEM (;S) 3.4.2 ~S Minimum Temperature for Criticality p 5~

(j) LCO 3. 4. 2 Each :S 1oop average temperature (T ....;) sha 11 be ~ ){~*..µ. Nile.. t1 f..

~~

APPLICABILITY: more RCS lo ps < [535)"F r more RCS 1 ops < .[535)" and ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

~IF *-;.Jp A. T...i in_~ne or more c£:.s A.l Be in MODE0 2 30 minutes loops not within ..., '"" i REQUIREMENTS m nu es.

IS"Tf*2.7~:LNSLRT ~ prevent

~ . is is il.f.I. 3 REFERENCES 1. FSAR, Section~.

CEOG STS B 3.4-8 Rev 1, 04/07/95

• ~c.ha.n¥ -.* e .

. e .

11'1 4ppl1eo.fJ,/1t'/ ~r 1$13 3.4.t th N'JU.* IL/Ji. . IS CM~1.3fcrrt <.v*~ the..

r 1I r Afpl/co,b,/1flu P-fa.tc.d {:'~ :tSiS ~.i.1.z. in NvP.f.b *l"i!>O ( f>fw Pl.AA+s)

Nr;R,~-,1{?>1(~1rvo"~usr..f10.f'\ts), iht.t~ (, t() rsrs sR3.v,z.1 .... ATTACHMENT6 11 a..r-.d JUSTIFICATION FOR DEVIATIONS 1 SPECIFICATION 3.4.2, RCS MINIMUM TEMPERATURE FOR CRITICALITY I

Change Djscussjon

• 6.. The Applicability of ITS LCO 3.4.2 and the Frequency of SR 3.4.2.1, as well as their associated Bases discussions, have been revised)JaseQ..0R proposed GeHerie Cke:Hge X T8TP 27, Rev.2. The LCO now applies whenever the plant is in MODE 1 or MODE 2 with kerr ~ 1.0 regardless of PCS temperature. l;'he SR Frequency has been changed from "30 minutes thereafter" to "12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />." Although the change is effectively more restrictive (i.e., the Applicability includes all of MODE 1 and the performance of SR 3.4.2.1 must continue even above 535°F) the intent of the change is to correct the current presentation which could lead to an inadvertent violation of the Frequency for SR 3 .4.2.1. Restating the Applicability such that an unexpected 1 decrease in PCS temperature (e.g., during a plant startup) would not result in,Jn c.J I . SR 3.0.1 violation, and establishing the Frequency of SR 3.4.2.1 such that@&'oes not L

divert operators during the performance of critical plant evolutions to fulfill data logging requirements, is considered to be a benefit to overall plant safety. Thi! eka:Hge is consistent with NUREG-1432 as modified by proposed TSTF-27, Rev.z..3 An X additional change has been made in the ITS to the Bases of SR 3.4.2.1. The phrase which states "is frequent enough to prevent the inadvertent violation of the LCO" has been deleted since this statement is not entirely true.

7. Required Actio~ A. I and its associated Bases discussion have been revised to maintain consistency with the Applicability. The Applicability of ISTS 3 .4. 2 is MODE 1 and MODE 2 with kerr ~ 1.0. ISTS Required Action A.1 requires the plant to be placed in MODE 3 which is outside the Applicability requirement. As such, to maintain consistency with the Applicability, Required Action A. l has been revised to place the plant in MODE 2 with kerr ~ 1.0. This change is consistent with NUREG-1432 as modified by TSTF-26.

8. The LCO Bases discussion has been modified to be consistent with the Applicability;/

'f8TP 27, Rev. 2 m0aified ~he AppliGaeility efl8T8 3.4.2 by eliminating the upper plant condition of < 535 °F, aOO-p~1iaiR8""'"0AfuR+1m9 chaRg8& -t0 the-Be:ses.4 However;-'f-&'FF-21;-Re~4i4-net..r~~SG\!S&iea assoei-ated with the LCO. The LCO Bases discussion C9AtiRYes t0 sta~ taat "+he LGO is oRiy applicable b@low 535 °~~tffis.clla~e~GG-B&.5es thSettSSiOH £6 matefi the F~sed-Applicabil.it¥ whicl1.-was..chang.e<i by l'S'J:~, Rev. ih-Palisades Nuclear Plant Page 2 of 2 01/20/98

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO AUGUST 24, 1998 REQUEST FOR ADDITIONAL INFORMATION SECTION 3.4, PRIMARY COOLANT SYSTEM NRC REQUEST #3:

The third NRC question requested that we revise ITS 3.4.4 to restore the explicit requirement for the PCS loops to be 11 0PERABLE 11 as is done in both CTS and STS.

Consumers Energv Response:

The requested change has been made.

Affected Submittal Pages:

Att l, ITS 3.4.4, page 3.4.4-1 Att 2, ITS 3.4.4, page B 3.4.4-2 Att 2, ITS 3.4.4, page B 3.4.4-3 Att 3, CTS 3.4.4, page 3-lb, (ITS 3.4.4, page 1 of 1)

Att 3, DOC 3.4.4, page 1 of 3 Att 5, NUREG 3.4.4, page 3.4-7 Att 5, NUREG 3.4.4, page B 3.4-18 Att 5, NUREG 3.4.4, page B 3.4-19 Att 6, JFD 3.4.4, page 2 of 2 3

e PCS Loops - MODES 1 and 2 3.4.4 3.4 PRIMARY COOLANT SYSTEM (PCS) 3.4.4 PCS Loops - MODES 1 and 2 o~M~ o.l\J LCO 3.4.4 Two PCS loops shall beAin operation.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of LCO A.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> not met.

SURVEILLANCE REQUIREMENTS SU~VfILLANCE FREQUENCY SR 3.4.4.l Verify each PCS loop is in operation. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Palisades Nuclear Plant 3.4.4-1 Amendment No.

• 01/20/98

PCS Loops - MODES 1 and 2 B 3.4.4 BASES APPLICABLE Both transient and steady state analyses have been SAFETY ANALYSES performed to establish the effect of flow on ONB. The (continued) transient or accident analysis for the plant has been performed assuming four PCPs are in operation. The majority of the plant safety analyses are based on initial conditions at high core power or zero power. The accident analyses that are of most importance to PCP operation are the Loss of Forced Primary Coolant Flow, Primary Coolant Pump Rotor Seizure and Uncontrolled Control Rod Withdrawal events (Ref. 1).

Steady state DNB analysis had been performed for the four pump combination. The steady state DNB analysis, which generates the pressure and temperature and Safety Limit (i.e., the Departure from Nucleate Boiling Ratio (DNBR) limit), assumes a maximum power level of 112% RTP. This is the design overpower condition for four pump operation.

The 112% value is the accident analysis setpoint of the trip and is based on an analysis assumption that bounds possible instrumentation errors. The DNBR limit defines a locus of pressure and temperature points that result in a minimum DNBR greater than or equal to the critical heat flux correlation limit.

PCS Loop~ - MODES 1 and 2 satisfy Criteria 2 and 3 of 10 CFR 50.36(c) (2).

LCO The purpose of this LCO is to require adequate forced flow for core heat removal. Flow is represented by having both PCS loops with both PCPs in each loop in operation for removal of heat by the two SGs. To meet safety analysis acceptance criteria for DNB, four pumps are required qt rated power.

PERABILITV°"'?eqUiremen1sY.eTat'edv.r:*-fne *~GSln M DE an f .

are addr. sed by LCO 3.3.1, Re tor Protective System LEAKAG II 11 11

• ~_: . (RPS) Ins .umentation, and LCO .4.13, PCS Operational 11

~------------...-;.,.-

x Each OPERABLE loop consists of two PCPs providing forced flow for heat transport to an SG t.hat is OPERABLE in accordance with the Steam Generator Tube Surveillance Program. SG, and hence PCS loop OPERABILITY with regards to SG water level is ensured by the Reactor Protection System (RPS) in MODES 1 and 2. A reactor trip places the plant in MODE 3 if any SG water level is s 25.9% (narrow

.range) as sensed by the RPS. The minimum level to declare the SO OPERABLE is 25.9% (narrow range).

Palisades Nuclear Plant B 3.4.4-2 01/20/98 3- b

PCS Loops - MODES 1 and 2 B 3.4.4 BASES APPLICABILITY In MODES 1 and 2, the reactor can be critical and thus has the potential to produce maximum THERMAL POWER. Thus, to ensure that the assumptions of the accident analyses remain valid, all PCS loops are required to be in operation in the!e MODES to prevent DNB and core damage.

The decay heat production rate is much lower than the full power heat rate. As such, the forced circulation flow and heat sink requirements are reduced for lower, noncritical MODES as indicated by the LCOs for MODES 3, 4, 5, and 6.

Operation in other MODES is covered by:

LCO 3.4.5, "PCS Loops-MODE 311; LCO 3.4.6, "PCS Loops-MODE 411; LCO 3.4.7, 11 P.CS Loops-MODE 5, Loops Filled";

LCO 3.4.8, "PCS Loops-MODE 5' Loops Not Filled";

LCO 3.9.4, "Shutdown Cooling (SOC) and Coolant Circulation-High Water Level" (MODE 6); and LCO 3.9.5, "Shutdown Cooling (SOC) and Coolant Circulation-Low Water Level" (MODE 6).

• ACTIONS If the requirements of the LCO are not met, the Required Action is to reduce power and bring the plant to MODE 3.

This lowers power level and thus reduces the core heat removal needs and minimizes the possibility of violating DNB limits.

The Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonable, based on operating ,experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging safety systems.

It should be noted that the reactor will trip and place the plant in MODE 3 as soon as the RPS senses less than four PCPs operating, Palisades Nuclear Plant B 3.4.4-3 01/20/98 J-c..

e  ;

~ . ~ '-f ~ PC~ "-.oop ~

• Mo 0 E6 3

-:t:-t"":* .

' 6:; PRIMARY COOLANT SYSTEM * .

Applies to status of coolant of the primary which must operation.

3 .1. 0 erable At east one pr, mary coo ant pump or e coo a flow rate eater than or equal t 2810 gpm shall be i operat~cn wheneve.r a ange is being made i the boron concentra ion of the primary c lant and the plant i operating in cold s tdown or above,, cept during an emerg cy loss of coolant ow situation.

Under ese circumstances, e. boron concentrati u~o ~~ t~

may be increased J,

wit no rimar coolant s or shutdo~n cool* g pumps runni~---

Four primary coolant* pumps shall be in operation whenever the reactor is operated above hot shutdown, w1 ne o owing excep ion:

Before removing a pump from service, thermal power shall *be reduced as specified in Table 2.3.1 and appropriate corrective action implemented. With one pump out of service, return the pump to service within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (return to four-pump operation) or be in hot shutdown (or below) with the reactor tripped (from the C-06 panel, opening the 42-01 and 42-02 circuit breakers) within t~e next 12.hours. Start-up (above hot shutdown) with less than fc~r pumps is not permitted and power operation with less than three pumps is not permitted.

(1) When the AS! exceeds the limits specified in the COLR, within 15 minutes initiate corrective actions to restore the AS! to the acceptable region. Restore the ASI to acceptable values within one hour or be at less than 70% of rated power within the following two hours.

. Revised ll/04/98 3-lb ~ -J 1 o~ I No. ~, &;, S, H-9. W,, .W. 4:-6+, ~.

.: :'." * .i

L-~ *.

• • .* *, r **

. . "~

(

~; ,

1* * *

• ATTACHMENT 3 DISCUSSION OF CHA.i"lGES SPECIFICATION 3.4.4, PCS LOOPS MODES 1 AND 2 ADMINISTRATIVE CHANGES (A) l ~*

• 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 Specifi:cations ..*

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. o~~-...---~~----~---~~~~~----

A.2 CTS 3.1. lb requires our primary coolant pumps to be in o eration. CTS 3.1. ld requires both steam enerators be capable of performing t ir heat transfer function.

Proposed ITS 3.4. requires two PCS loops to be in oper tion. The Bases of ITS 3.4.4 clarifies that the perability requirements related to ste generators in Modes 1 and 2 are addressed b LCO 3. 3 .1, "Reactor Protection Sy st (RPS) Instrumentation," and LCO 3.4.13, R S Operational Leakage." As such, a earn generator is considered Operable wh it has adequate water level (LCO 3.3 1), and tube integrity is demonstrate acceptable in accordance with the Ste Generator Tube Surveillance Program ( 0 3.4.13). Therefore, it is not nece ary to stipulate the requirement for Operable earn generators in ITS 3.4.4 since thi requirement is adequately addressed by other sp ifications. Thus, the difference betw n the CTS and the ITS for PCS loops and ste generators can be characterized as a ministrative since there is no change in the re irements. This change is consistent ith NUREG-1430, "Standard Technical Spec* ications, Babcock and Wilcox Plants" hich previously corrected the disjoint bet een the LCO and Surveillance Require ents that presently exists in NUREG-1431

(" tandard Technical Specifica~ions, Wes. nghouse Plants") and NUREG-1432.

A.3 CTS 3.1. lb requires four PCPs to be in OPeration "whenever the reactor is operated above hot shutdown." Proposed ITS 3.4.4 requires four PCPs to be in operation in*

MODES 1 and 2. The CTS plant condition of "hot shutdown" translates to "MODE 3" in the ITS .. As such, the CTS requirement to have four PCPs in operation above "hot shutdown" is the same as the ITS requirement to have four PCPs in operation in MODES 1 and 2. Thus, the difference between the CTS and the ITS can be characterized as administrative since there is no change in requirements between the CTS and ITS.

• This change is consistent with NUREG-1432.

Palisades Nuclear Plant Page 1of3 11704798

~ ~.

c:

1 and 2 3.4.4 3.4 - COO-LAHT SYSTEM (lcs) 3.4.4 ~s Loops-MODES l and 2 crs 3./.( b i$3.4.4 Two &.s loops sha 11 be ({ipER;@LE i!d) in operation.

t p.C R~Q x

3. /. / d Sit:i f\J l6 3 x

APP LI CAB I LI TY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of LCO A. l Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> not met.

SURVEILLANCE REQUIREMENTS *.

SURVEILLANCE FREQUENCY p

SR 3.4.4.1 Verify each '3CS loop is in operation. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> CEOG STS 3.4-7 Rev 1, 04/07/95

RCS Loops~MODES 1 and 2 B 3.4.4 BASES APPLICABLE aspect for this LCO is the &McfO'ff co~lant forced flow rate, SAFETY ANALYSES which is represented by the number of1'"<8CS loops in service.

(continued)

The purpose of this LCO is to require adequate forced flow for core heat removjl. Flow is represented by having both f '8CS loops with bothr,<<cPs in each 1oop in op er at ion for removal of heat by the two SGs.

• To meet safety analysis acceptance criteria for DNB, four pumps are required at rated power.

o consists of two RCPs provid g forced ansport to an SG that is OPE LE in the Steam Generator Tube Sur eillance Program. SG and hence RCS loop, OPERABIL with regard to el is ensured by the Reactor otection System DES 1 and 2. A reactor tri aces the plant in

• (continued)

CEOG STS B 3.4-18 Rev 1, 04/07/95 STlT

9 f i&cs Loops-HODES l and 2 B 3.4.4 BASES LCO MOOE 3 if any G level is s [25]% sensed by the RPS. The (continued) minimum wate level to declare th SG OPERABLE is 25 .

Car~~

APPLICABILITY In MODES 1 and 2, the reactor (fi)critical and thus has the potential to produce maximum THERMAL POWER. Thus, to ensure that the assumptions of the accident analyses remain valid, allP~s loops are required to be OPERABLE and in operation in these MODES to prevent DNB and core damage.

The decay heat production rate is much lower than the full power heat rate. As such, the forced circulation flow and heat sink requirements are reduced for lower, noncritical MODES as indicated by the LCOs for MODES 3, 4, 5, and 6.

LCO LCO LCO 3.4.5, 3.4.6, 3.4.7, Is Operation in other MODES is covered by:

'r Loops-MODE 3*;

S Loops-MODE 4*;

S Loops-MODE 5, Loops Filled*;

LCO 3.4.8, S Loops-MODE 5, Loops Not Filled*;

LCO 3.9.4, "Shutdown Cooling (SOC) and Coolant Circulation-High Water Level* (MODE 6); and LCO 3.9.5, *shutdown Cooling (SOC) and Coolant Circulation-Low Water Level* (MODE 6).

ACTIONS src:r The Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging safety systems.

(continued)

CEOG STS B 3.4-19 Rev 1, 04/07/95

• 3-A

ATTACHM:ENT 6 JUSTIFICATION FOR DEVIATIONS SPECIFICATION 3.4.4, RCS LOOPS - MODES 1 AND 2 Change Discussion

7. ISTS LCO 3.4.4 requ'res two RCS loops to be "Operable and in peration." The only surveillance require ent associated with ISTS 3 .4 .4 (SR 3 .4 .4 .1 is to verify that each RCS loop is in ope tion. As stated in 10 CFR 50.36, "survei ance requirements are requirements relat' g to tests, calibration, or inspection to ass re that the necessary quality of system and components is maintained, that facilit operation will be within safety limits, an that the limiting conditions for operations ill be met." Thus, the Technical Spec fication are structured to ensure that the Ii iting conditions for operations wi be met by listing periodic tests in the sur'.l illance requirements.

ISTS 3.4.4 es not contain a surveillance requirement o verify that each RCS loop is Operable. or a RCS loop to be considered Operable, 1t must have an Operable Stea Generator SG). An SG is considered Operable whe it has adequate level, and tub integrity 's demonstrated acceptable in accordance~ th the Steam Generator Tube Surveill nee Program. In NUREG-1432, SG level m MODEs 1 and 2 is ensure y LCO 3. 3 .1, "Reactor Protective System (RPS) Ins rumentation," and SG integr* is ensur d by LCO 3.4.13, "RCS Operational Lea age." As such, it is not nece ary to stip ate that each RCS loop be Operable* in IS S 3.4.4 since the requiremen for Op rability is adequately addressed by others ecifications. Therefore, pro osed IT 3.4.4 has been revised to state "Two P loops shall be in operation.' This ange is consistent with NUREG-1430, " andard Technical Specificati ns, Babcock nd Wikox Plants" which previously corr cted the disjoint between the CO and Surveillance Requirements that presently exists in NUREG-1431 ("St dard Technical Specifications, Westinghouse Plants") d NUREG-1432. Conform' g changes have also been made to the Bases consisten with NUREG-1430.

Palisades Nuclear Plant Page 2 of 2 01/20/98

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO AUGUST 24, 1998 REQUEST FOR ADDITIONAL INFORMATION SECTION 3.4, PRIMARY COOLANT SYSTEM NRC REQUEST #4:

The fourth NRC question requested that we clarify if Palisades meets the criterion for the SR frequency extension provided by TSTF 93.

Consumers Enerav Response:

TSTF 93, Revision 3, allows the frequency for performing SR 3.4.9.2 (verification of pressurizer heater capacity) to be extended from 92 days to 18 months if the plant has non-dedicated safety-related [pressurizer] heaters which normally operate.

Palisades safety-related pressurizer heaters are normally in service during plant operation. They are capable of being powered from the emergency diesel generators through Class lE switchgear.

Affected Submittal Pages:

No page changes.

4

ENCLOSURE 2 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS ADDITIONAL REVISIONS - ITS SECTION 3.4 TECHNICAL CHANGE SECTION 3.4, PRIMARY COOLANT SYSTEM

.e PCS Pressure, Temperature, and Flow DNB Limits.

3.4.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B.. Required Action and B.1 Be in MODE 2. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Ti me not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.1.1 Verify pressurizer pressure ~ 2010 psia and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />

!> 2100 psia.

SR 3.4.1.2 Verify PCS cold leg temperature 2 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />

$ 542.99 + 0.0580(P-2060)+ O.OOOOl(P-2060) 2

+ 1.125(W-138) - 0.0205(W-138) *

. SR 3.4.1.3 kcHt.Jlep..L CJ1~f\1-Verify PCS total flow rate is 18 months

~ 352,000 gpm.

After each plugging of 10 or more steam generator tubes Palisades Nuclear Plant 3.4.1-2 Amendment No. 11/04/98

e PCS Pressure, Temperature, and Flow DNB Limits B 3.4.1 BASES SURVEILLANCE SR 3.4.1.3 (continued)

REQUIREMENTS The Frequency of 18 months reflects the importance of verifying flow after a refueling outage where the core has been altered, which may have caused an alteration of flow resistance. PCS flow rate must also be verified after plugging of each 10 or more steam generator tubes since plugging 10 or more tubes could result in an increase in PCS flow resistance. Plugging less than 10 steam generator tubes will not have a significant impact on PCS flow resistance and, as such, does not require a verification of PCS flow rate. 31 E.F'PD The SR is modified by a No~e~.!states the SR is only required to be performed (f4 after ~ 90% RTP. The Note is necessary to all ow measurement of the f1;w rate at AS S1.1GH) normal operating conditions at o~er~in MODE ~~he urve1 ance canno e per orme in MODE 2 or below, and will not yield accurate results if performed below 90% RTP.

REFERENCES 1. FSAR, Section 14.1 The most common, and perhaps accurate, method used to perform the PCS total flow surveillance is by means of a primary to secondary heat balance (calorimetric) with the plant at or near full rated power. The most accurate results for such a test are obtained with the plant at or near full power when differential temperatures measured across the reactor are the greatest. Consequently, the test should not be performed until reaching near full power (i.e.,~ 90% RTP) conditions. Similarly, test accuracy is also influenced by plant stability. In order for accurate results to be obtained, steady state plant conditions must exist to permit meaningful data to be gathered during the test.

Typically, following an extended shutdown the secondary side of the plant will take up to several days to stabilize after power escalation. It is impracticable to perform a primary to secondary heat balance of the precision required for the PCS flow measurement until stabilization has been achieved. Furthermore, an integral part of the PCS flow heat balance involves the use of Ultrasonic Flow Measurement equipment for measuring steam generator feedwater flow. This equipment requires, stable plant operation at or near full power conditions before it can be used.

Palisades Nuclear Plant B 3.4.1-5 01/20/98

ATT ACHl\.fE~T 3 DISCl'.SSION OF CH.~~GES SPECIFICATION 3.4.l, PCS PRESSCRE, TE'.\IPERATCRE & FLO\V D~B LL\IITS

\tf. 3 CTS 4. 15 specifies the requirement for primary system flow measurement and states that the measurement shall be made *'within the first 31 days of rated power operation.** Proposed SR 3 .4.1. 3 also requires a verification of the primary system 3/ Cf Pb flow rate but stipulates that the SR must be performed within ~ h~u0after reaching or exceeding 903 Rated Thermal Power. SR 3.4.1.3 is more restrictive than CTS 4.15 since i~Qfmiti}Oth the/ime (jl days vers~?s 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) iiflCT)power level (1003 versus 903) associac;.;d with theperformance of the test. :hus. the time the

. reactor may be operated near the point where DNB could be most limitin4. \~hour a verification of the required primary system flow rate, is reduced. This is an-- \ Ci.e, ~jo,%)

additional restriction on plant operations and is consistent with NUREG-1432. J P RESTRICTIVE CHA.'1'GES - REMOVAL OF DETAILS TO LICENSEE CONTROLLED DOClTMENTS (LA)

LA. l

• CTS 4.15 states that the primary system flow measurement shall be made with *'four primary coolant pumps in operation. Proposed SR 3.4. l .3 does not specify the number of pumps required to be in operation since the only requirement (of this LCO) is to meet the minimum tlow assumed in the analysis. The number of primary coolant pumps required to be in operation to meet the safety analysis assumption for forced flow and core heat removal (and ultimately the acceptance criteria for DNB) is provided in proposed ITS 3.4.4, PCS Loops-MODES 1 and 2. The Bases of ITS 3 .4.4 specify that both PCS loops with both primary coolant pumps shall be in operation. Since the details regarding the number of primary coolant pumps is adequately covered in the Bases for ITS 3.4.4, it is not necessary to place this detail in the SR for flow measurement. Placing these details in the Bases provides adequate assurance that they will be maintained since the Bases are controlled by the Bases Control Program proposed in ITS Chapter 5.0. This change is consistent NUREG-1432.

Palisades Nuclear Plant Page 4 of 6 11104/98

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Pressure, Temperat..ire, and F1:iw 1:N6{ ** ~* ~s

3. 4. ;

SURVEILLANCE RE U!RE~ENTS continued 1

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• . 'CEOG .STS 3.4*3 Rev l, 04/07/95 Revised 11/04/98

CfS Pressure, Temp-ure, and FlowfoNa.(Limits B 3.4.1 BASES SURVEILLANCE SR 3.4.1.2 REQUIREMENTS (continued) S1nce e 1re c on . a ows a omp on ime o 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> o restore parameters that are ot within limits, the 12 our Surveillance Frequency fo cold leg temperature is suf icient to ensure that the RCS oolant temperature can be re tored to a normal operation, eady state condition foll ing load changes and other e ected transient ope tions. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval as been shown by op ating practice to be suffici t to regularly assess for p ential degradation and to ver fy operation is within fet anal sis assum tions.

The 12 h ur Surveillance Fr uency for RCS total flo rate is perf rmed using the ins lled flow instrumentati n. The 12 hou Frequency has been shown by operating expe ience to be su icient to assess f r potential degradation and to veri operation is with'n safety analysis assum ions.

performance SR 3 .4.1 a5 i a ow l ns w ca brated nd verifies that the actual within the bounds of the anal ses.

The Frequency of ;(1~months reflects the importance of verifying flow after a refueling outage where the core has been altered, which may have caused an alteration. of flow v resistance. 1' 31 £PPD I\

The SR is modified by a N~~h~i J~tates the SR is only (

• required to be performed .\f.2 h r l after ~j'(90J% RTP. The Note is necessary to allow measurement of the flow rate at J.NSll.1 i1 normal operating conditions at power in MODE 1,,,. J'he XX l'c Hrv1c.c.l (continued) c.. h 0. '(\ (:,"1-CEOG STS B 3.4-5 Rev 1, 04/07/95

_I

SECTION 3.4 INSERT J PCS flow .rate must also be verified after plugging 10 or more steam generator tubes since plugging 10 or more tubes could result in an increase in PCS flow resistance. Plugging less than 10 steam generator tubes will not have a significant impact on PCS flow resistance and, as such, does not require a verification of PCS flow rate.

-lc c. Hl\11 ",* L cHA.vG-<..

The most common, and perhaps accurate, method used to perform the PCS total flow surveillance is by means of a primary to secondary heat balance (calorimetric) with the plant at or near full rated power. The most accurate results for such a test are obtained with the plant at or near full power when differential temperatures measured across the reactor are the greatest. Consequently, the test should not be performed until reaching near full power (i.e., 2. 90% RTP) conditions. Similarly, test accuracy is also influenced by plant stability.

In order for accurate results to be obtained, steady state plant conditions must exist to permit meaningful data, to be gathered during the test. Typically, following an extended shutdown the secondary side of the plant will take up to several days to stabilize after power escalation. It is impracticable to perform a primary to secondary heat balance of the precision required for the PCS flow measurement until stabilization has been achieved. Furthermore, an integral part of the PCS flow heat balance involves the use of Ultrasonic Flow Measurement equipment for measuring steam generator feedwater flow. This equipment requires, stable plant operation at or near full power conditions before it can be used. As such, ...

B 3.4-5