ML18066A488

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Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately
ML18066A488
Person / Time
Site: Palisades Entergy icon.png
Issue date: 06/04/1999
From: Rogers D
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18066A489 List:
References
NUDOCS 9906110231
Download: ML18066A488 (5)


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A CMS Energy Company Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, Ml 49043 June 04, 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 3.6, CONTAINMENT 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 responses to the NRC questions and associated editorial revisions for ITS LCOs 3.6.1, 3.6.2, 3.6.4, 3.6.5, and 3.6. 7 of our January 26, 1998 submittal. Responses to NRC comments on ITS Section 3. 7 were submitted on March 30, 1999; responses to comments on the remaining Section 3.6 LCOs will be submitted separately.

The NRC RAI dated 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.

The Enclosure to this letter 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.

Replacement pages for all of Section 3.6 of our January 26, 1998 conversion submittal will be provided with the response to the NRC comments on ITS LCOs 3.6.3 and 3.6.6.

'I {

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SUMMARY

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

David W. Rogers General Manager CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Enclosures

  • CONSUMERS ENERGY COMPANY PARTIAL 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 3.6 of our January 26, 1998 License Amendment request for conversion to Improved Technical Specifications, is truthful and complete.

(11 Iv* ~:,___I David W. Rogers 0

General Manager Sworn and subscribed to before me this 'f-#... day of _g,_,_t/J/ILU

___ 1999.

Deborah L Malins, Notary Public Van Buren County, Michigan My commission expires September 17, 2000

ENCLOSURE 1 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255

  • CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS PARTIAL RESPONSE TO JANUARY 26, 1999 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS SECTION 3.6, CONTAINMENT LCOs 3.6.1, 3.6.2, 3.6.4, 3.6.5, & 3.6. 7

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JANUARY 26, 1999 REQUEST FOR ADDITIONAL INFORMATION SECTION 3.6, CONTAINMENT NRC REQUEST:

3.6.0 General 3.6.0-1 DOC A.2 (CTS Markup for ITS 3.6.1)

DOC A.2 (CTS Markup for ITS 3.6.2)

CTS 3.6 CTS 4.5 ITS 3.6 Bases DOC A.2 in Attachment 3 for the CTS markups for ITS 3.6.1 and 3.6.2 states "The Bases of the current Technical Specifications for this section have been completely replaced by the revised Bases that reflect the format and applicable content consistent with NUREG-1432. The revised Bases are shown in the proposed Technical Specifications Bases." There are no CTS Bases provided nor is there any reference in the CTS markup to specifically indicate where DOC A.2 applies. In addition a similar DOC A.2 is not provided in Attachment 3 and the CTS markups for the other five ITS 3.6 LCOs.

Comment: Revise the CTS markup to indicate where DOC A.2 or a similar DOC applies for all ITS LCOs. Provide the appropriate discussions and justifications in Attachment 3 for the other five ITS 3.6 LCOs.

Consumers Energy Response:

On some pages of the CTS, Bases information is contained on the same page as the Limiting Conditions for Operation and Surveillance Requirements. As part of the CTS markups provided to support conversion to the ITS, a generic Discussion of Change (usually DOC A.2) is used to explain that the CTS Bases are replaced by the revised Bases of the ITS. For ITS 3.6.1 and ITS 3.6.2, no Bases information was contained on those CTS markup pages. Thus, DOC A.2 was inappropriately included in Attachment 3 for specifications 3.6.1 and 3.6.2. Therefore, has been modified to correct this error by indicating DOC A.2 was "Not Used."

The remaining specification in Section 3.6 have been reviewed to ensure this error was not contained in those specifications. A complete compilation of all CTS markup pages, including the superseded Bases pages, has been provided as Volume 2 to the Palisades ITS submittal.

Affected Submittal Pages:

Att 3, DOC 3.6.1, page 1 of 6 Att 3, DOC 3.6.2, page 1 of 11 1