ML18066A441

Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review

ML18066A441
Person / Time
Site:	Palisades
Issue date:	03/30/1999
From:	Haskell N CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18066A442	List: ML18066A441 ML18066A443
References
NUDOCS 9904060083
Download: ML18066A441 (6)

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 30, 1999 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS - PARTIAL RESPONSE TO JANUARY 26, 1999 REQUEST FOR ADDITIONAL INFORMATION - ITS SECTION 3. 7 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 January 26, 1999, the NRC requested additional information regarding Sections 3.6, Containment, and 3. 7 Plant Systems, of that TSCR. This letter provides both responses to the NRC questions and associated editorial revisions for ITS Section 3.7 of our.January 26, 1998 submittal. It also includes one technical change, which was made as a result of comments from the Palisades staff.

The technical change identified by the Palisades staff revises the specified water level in ITS LCO 3.7.9, Ultimate Heat Sink. The water level proposed in this revision agrees with that in the design basis document for that level necessary to assure adequate NPSH for the service water pumps. The revised pages are included in Enclosure 3.

The NRC RAI of January 26, 1999 referred to an expected response date of March 31, 1999.

Subsequently, in a telephone conversation with the NRR Project Manager for Palisades, Consumers Energy received permission to delay the Section 3.6 response to allow additional time for preparation and internal review.

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04060083 990330 R ADOCK 05Q00255 PDR ~-~~ l

The following Enclosures to this letter have been provided:

Enclosure 1 contains: a) answers to the Request for Additional Information (RAI) and, b) markups of the previously submitted pages to show where revisions have been made.

Enclosure 2 contains marked-up ITS submittal pages incorporating editorial corrections.

Enclosure 3 contains revised pages for Section 3. 7, along with a list of revised pages and instructions for page replacement. These revised pages reflect changes resulting from our response to the RAI questions and the changes identified in Enclosure 2. Each revised page is dated for identification.

The changes being submitted herein do not alter the conclusions of the No Significant Hazards Considerations contained in our January 29, 1998 submittal.

SUMMARY

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

• ~

zthan I

L. Haskell

~irector, Licensing I

ac Administrator, Region Ill, USNRC

( Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Enclosures

CONSUMERS ENERGY COMPANY RESPONSE TO JANUARY 26, 1999 RAI To the best of my knowledge, the content of this response to the NRC Request for Additional Information dated January 26, 1999 concerning Section 3. 7 of our January 26, 1998 License Amendment request for conversion to Improved Technical Specifications, is truthful and complete.

~Mtwbit ath8J1L Haskell

/Director, Licensing

.- *-111 Sworn and subscribed to before me this 3o day of~ 1999.

~~~

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

My commission expires February 16, 2000

ENCLOSURE 1 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JANUARY 26, 1999 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS SECTION 3.7, PLANT SYSTEMS

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JANUARY 26, 1999 REQUEST FOR ADDITIONAL INFORMATION SECTION 3.7, PLANT SYSTEMS NRC REQUEST:

3.7.1 Main Steam Safety Valves (MSSVs)

No comments.

NRC REQUEST:

3.7.2 Main Steam Isolation Valves (MSIVs) 3.7.2-1 CTS 3.5.1 ITS 3.7.2 Applicability and Bases JFD #2 Comment:: (Contractor comment 3.7.2-5) The ITS Bases discussion of Applicability has been modified to state "Mode 1, ~, and in Modes 2 and 3 except when both MSIVs are closed and deactivated." This is different from the ITS LCO 3.7.2 Applicability without specific explanation provided.

Consumers Energy Response:

The ITS bases were only modified from the STS by addition of a comma following the "1" of MODE 1. The confusion exists only in the markup of STS, where the circled "2" is intended to call out that the addition of a comma is explained in JFD 2. The clean copy of the bases provided in Attachment 2 of our initial submittal clarifies this issue.

Affected Submittal Pages:

No page changes .

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• CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JANUARY 26, 1999 REQUEST FOR ADDITIONAL INFORMATION NRC REQUEST:

SECTION 3.7, PLANT SYSTEMS 3.7.2-2 CTS 3.5.1.f ITS 3.7.2 JFD #6 Comment: (Contractor comment J.7.2~6) The last sentence of the first and fourth paragraphs of the ITS Bases discussion on Applicable Safety Analyses, have not been adopted. The STS text which provides the explanation of the credit taken for the MSIVs should not be removed ~ntil all plant specific analyses that are applicable have been included. The discussion identified in JFD #6 should be expanded and included here in the ITS Bases.

Consumers Energv Response:

It is agreed that the information in JFD 3.7.2 #6 would be an enhancement to the Bases for Specification 3.7.2. As such, the information in JFD #6 has been added to the Applicable Safety Analyses discussion in the Bases.

Affected Submittal Pages:

Att 2, ITS 3.7.2, page B 3.7.2-2 Att 5, NUREG 3.7.2, page B 3.7-7 insert

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