Text

Proposed Tech Specs Re Partial Response to 990126 Request RAI for ITS Section 3.6, Containment
	ML18066A490
Person / Time
Site:	Palisades
Issue date:	01/20/1998
From:	; CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	;
Shared Package
ML18066A489	List: ML18066A488; ML18066A490;
References
	NUDOCS 9906110233
	Download: ML18066A490 (195)
	v • d • e

ATTAC1'ENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.1, CONTAINMENT ADMINISTRATIVE CHANGES (A)

A.1 RRI

~.~.o *I A.2 A.3 All reformatting and renumbering are in accordance with NUREG-1432. As a result, the Technical Specifications (TS) should be more readily readable, and therefore understandable by plant operators as well as other users. The reformatting, renumbering, and rewording process involves no technical changes to existing Technical Specifications.

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

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

Not Uot.d.

he Bases of current Technical Specific 10ns for this section hav een completely eplaced by e revised Bases that reflect e format and applicable ntent consistent ith N

-1432. The revised Bases e shown in the propose echnical CTS 3.6.1 specifies that "CONTAINMENT INTEGRITY shall be maintained." In the proposed ITS 3.6.1, this is changed to "Containment shall be OPERABLE." The CTS defines "CONTAINMENT INTEGRITY" in the definitions in Chapter 1.0 in parts (a) through (e). The proposed ITS separates the contents of the definition for "Containment Integrity" into the applicable ITS LCOs. Specifically, parts (b) and (e) of the definition are addressed in proposed ITS LCO 3.6.1. Parts (a) and (d) are addressed in proposed ITS LCO 3.6.3, "Containment Isolation Valves." Part (c) is addressed in: proposed ITS LCO 3.6.2,,"Containment Air Locks." The proposed ITS 3. 6.1, Containment, encompasses the applicable part of CTS 3. 6.1 and definition for "Containment Integrity" and therefore this is considered to be an administrative change to match the terminology and structure of NUREG-1432.

, -- 9qo6iio233--99o6o4--

PDR ADOCK 05000255 p

PDR Palisades Nuclear Plant Page 1of6 01/20198

/

AAI 3.(Q.o-1 ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS ADMINISTRATIVE CHANGES (A)

A.1 A.2 All reformatting and renumbering are in accordance with NUREG-1432. As a result, the Technical Specifications (TS) should be more readily readable, and therefore understandable by plant operators as well as other users. The reformatting, renumbering, and rewording process involves no technical changes to existing Technical Specifications.

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

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

Net LJf:J rrent Technical Specifications for s section have been complet eplaced by the vised Bases that reflect the format d applicable content consiste t The revised Bases are shown* the proposed Technical A.3 CTS 3.6.1.2 specifies that "CONTAINMENT INTEGRITY shall be maintained" with CONTAINMENT INTEGRITY being defined in Chapter 1.0, Definitions. The proposed ITS takes the elements of "CONTAINMENT INTEGRITY" and restructures them into three LCOs: 3.6.1, Containment; 3.6.2, Containment Air Locks; 3.6.3, Containment Isolation Valves. Therefore, for proposed ITS 3.6.2, CTS 3.6.1 is restructured to read "Two Containment Air Locks shall be maintained." This change is consistent with NUREG-1432.

Palisades Nuclear Plant Page 1of11 01/20/98 1-b

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

3.6.1 Containment 3.6.1-1 DOC A.1 DOCA.5 DOC LA.2 DOC LA.4 DOC L.1 JFD 2 JFD 6 CTS 1.0 CONTAINMENT INTEGRITY Item e CTS4.5.1 CTS 4.5.2.a(1)

CTS 4.5.1.a.(2)

CTS 4.5.2.a.(4)

CTS 4.5.2.b CTS 4.5.2.d STS SR 3.6.1.1 and Associated Bases ITS SR 3.6.1.1 and Associated Bases CTS 1.0 "Containment Integrity" Item e, CTS 4.5.1, 4.5.2.a(1), 4.5.2.a(2), 4.5.2.a(4), 4.5.2.b, and 4.5.2.d specify various leak rate testing requirements and criteria for containment. STS SR 3.6.1.1 requires the visual examination and leakage rate testing be performed in accordance with 1 O CFR 50 Appendix J as modified by approved exemptions. ITS SR 3.6.1.1 modifies STS SR 3.6.1.1 to conform to TSTF 52. The STS is based on 10 CFR 50 Appendix J Option A while the ITS is based on 10 CFR 50 Appendix J Option B. Changes to the STS with regards to Option A versus Option B are covered by a letter from Mr. Christopher I. Grimes to Mr. David J. Modeen, NEI dated 11/2/95 and TSTF-52 as modified by staff comments of 10/96.

The ITS changes are not in conformance with the letter and TSTF 52 modified by staff comments. In particular, Amendment 174 only approved 10 CFR 50 Appendix J Option B for the Type A tests only. The Type Band C tests must still be done in accordance with Option A.

Thus, only those leakage tests ~ssociated with Option B Type A test may be relocated to the Containment Leakage Rate Testing Program. This includes CTS 4.5.1 with regards to Type A tests only. All other CTS requirements specified above must be retained in the ITS as SRs or Notes to the SRs. See Comment Numbers 3.6.1-7, 3.6.1-8, 3.6.1-9, 3.6.2-1, 3.6.2-3, 3.6.2-18, 3.6.2-19, and 3.6.3.-1.

Comment:

Licensee to update submittal with regards to 11/2/93 letter, TSTF-52 as modified by staff comments and the above comments or provide additional justification for deviations.

See Comment Numbers 3.6.1-7, 3.6.1-8, 3.6.1-9, 3.6.2-1, 3.6.2-3, 3.6.2-18, 3.6.2-19 and 3.6.3-1.

2

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

3.6.1-1 (continued)

Consumers Energy Response:

ITS 3.6.1, "Containment" and ITS 3.6.2, "Containment Air Locks" have been revised such that they no longer reference the Containment Leakage Rate Testing Program for Type 8 and C leak rate tests performed in accordance with 10 CFR 50, Appendix J, Option A As such, the acceptance criteria for Type 8 and C tests is now stated in its respective Surveillance Requirement, and the testing Frequency is in accordance with 10 CFR 50, Appendix J, Option A, as modified by approved exemptions.

Revision 1 of TSTF-52 was also reviewed to adopt those changes from revision 0 of that generic change that are applicable to Type A testing performed in accordance with 10 CFR 50, Appendix J, Option 8.

Affected Submittal Pages:

Section 3.6.1 Att 1, ITS 3.6.1, page 3.6.1-1 Att 2, ITS 8 3.6.1, page B 3.6.1-1 Att 2, ITS 8 3.6.1, page 8 3.6.1-2 Att 2, ITS 8 3.6.1, page 8 3.6.1-3 Att 2, ITS B 3.6.1, page 8 3.6.1-4 Att 3, CTS, page 4-19 (3 of 8)

Att 3, CTS, page 4-20 (4 of 8)

Att 3, CTS, page 4-21 (5 of 8)

Att 3, DOC 3.6.1, page 4 of 6 Att 3, DOC 3.6.1, page 5 of 6 Att 3, DOC 3.6.1, page 6 of 6 Att 4, NSHC 3.6.1, page 1 of 2 Att 5, NUREG 3.6.1, page 3.6-2 Att 5, NUREG 3.6.1, page 8 3.6-1 Att 5, NUREG 3.6.1, page 8 3.6:-2 Att 5, NUREG 3.6.1, page 8 3.6-3 Att 5, NUREG 3.6.1, page B 3.6-4 Att 6, JFD 3.6.2, page 2 of 2 3

Affected Submittal Pages:

Section 3.6.2 Att 1, ITS 3.6.2, page 3.6.2-4 Att 2, ITS 3.6.2, page B 3.6.2-7 Att 3, CTS page 4-19 (3 of 5)

Att 3, CTS page 4-20 (4 of 5)

Att 3, CTS page 4-21 (5 of 5)

Att 3, DOC 3.6.2, page 5 of 11 Att 3, DOC 3.6.2, page 8 of 11 Att 3, DOC 3.6.2, page 10 of 11 Att 4, NSHC 3.6.2, page 2 of 6 Att 4, NSHC 3.6.2, page 3 of 6 Att 5, NUREG 3.6.2, page 3.6-6 Att 5, NUREG 3.6.2, page 8 3.6-17 Att 5, NUREG 3.6.2, page 8 3.6-18 Att 6, JFD 3.6.2, page 1 of 3

3.6 CONTAINMENT SYSTEMS 3.6.1 Containment LCO 3.6.1 Containment shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION A.

Containment A.1 inoperable.

B.

Required Action and B.l associated Completion Ti me not met.

Mil B.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.1.1 l'ftt A REQUIRED ACTION Restore containment to OPERABLE status.

Be in MODE 3.

Be in MODE 5.

SR 3. 6.1.2 Verify containment structural integrity in accordance with the Containment Structural Integrity Surveillance Program.

1.J\\JSERT SR. ~.ii.I.!>~

Containment 3.6.1 COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 6 hours 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months FREQUENCY In accordance with the Containment Leak Rate Testing Program In accordance with the Containment Structural Integrity Surveillance Program Palisades Nuclear Plant 3.6.1-1

.2-o._

Amendment No.

01/20/98

INSERT SURVIELLANCE FREQUENCY SR 3.6.1.3

N()TE--------------------------------

Local leak rate tests shall be performed at 2 55 psig.

Perform required Type B and C leakage rate testing,

N ()TE-------

except for containment air lock testing, in accordance SR 3.0.2 is not with 10 CFR 50, Appendix J, Option A, as modified applicable.

by approved exemptions.

The leakage rate acceptance criterion is ~ 1.0 La.

In accordance with However, during the first unit startup following 10 CFR 50, testing performed in accordance with I 0 CFR 50, Appendix J, ()ption A, Appendix J, ()ption A, as modified by approved as modified by exemptions, the leakage rate acceptance criteria are approved exemptions

< 0.6 La for the Type Band Type C tests.

3.6.1-1 3-b

Containment B 3.6.l B 3.6 CONTAINMENT SYSTEMS B 3.6.1 Containment BASES BACKGROUND The containment is a reinforced concrete structure with a cylindrical wall, a flat foundation mat, and a shallow dome roof.

The foundation slab is reinforced with conventional mild-steel reinforcing.

The internal pressure loads on the base slab are resisted by both the external soil pressure and the strength of the reinforced concrete slab. The cylinder wall is prestressed with a post tensioning system in the vertical and horizontal directions.

The dome roof is prestressed utilizing a three way post tensioning system.

The inside surface of the containment is lined with a carbon steel liner to ensure a high degree of leak tightness during operating and accident conditions.

The concrete structure is required for structural integrity of the containment under Design Basis Accident (DBA) conditions. The steel liner and its penetrations establish the leakage limiting boundary of the containment.

Maintaining the containment OPERABLE limits the leakage of fission product radioactivity from the containment to the environmentL SR 3.6.1.1,leakage rate requirements comply with 10 CFR 50, Appendix J, Option B for Type A tests and Option A for Type B and C tests, as modified by approved exemptions.

The isolation devices for the penetrations in the containment boundary are a part of the containment leak tight barrier.

To maintain this leak tight barrier:

a.

All penetrations required to be closed during accident conditions are either:

1.

capable of being closed by an OPERABLE automatic containment isolation system, or Palisades Nuclear Plant B 3.6.1-1

6-c...

01/20/98

BASES BACKGROUND (continued)

APPLICABLE SAFETY ANALYSES Containment B 3.6.1

2.

closed by manual valves, blind flanges, or de-activated automatic valves secured in their closed positions, except as provided in LCO 3.6.3, "Containment Isolation Valves";

b.

Each air lock is OPERABLE, except as provided in LCO 3.6.2, "Containment Air Locks";

c.

The equipment hatch is properly closed and sealed.

The safety design basis for the containment is that the containment must withstand the pressures and temperatures of the limiting DBA without exceeding the design leakage rate.

The DBAs that result in a release of radioactive material within containment are a Loss of Coolant Accident (LOCA), a Main Steam Line Break (MSLB), and a control rod ejection accident (Ref. 1). In the analysis of each of these accidents, it is assumed that containment is OPERABLE such that release of fission products to the environment is controlled by the rate of containment leakage.

The containment was designed with an allowable leakage rate of 0.10% of containment air weight per day (Ref. 3).~

leakage rate is defined in 10 CFR 50, Appendix J, 0 ion as La:

the maximum allowable containment leakage ra e a the calculated maximum peak containment pressure (Pa) of 53 psig, which results from the limiting design basis LOCA.

(Ref. 2). For the Palisades Nuclear Plant, the calculated maximum peak containment pressure results from a MSLB accident.

However, since the limiting accident from an offsite dose perspective is a LOCA, this pressure is used as Pa.

The Pa value of 53 psig represents the analytical value found in Reference 1, rounded up to the next whole number.

Satisfactory leakage rate test results are a requirement for the establishment of containment OPERABILITY.

The containment satisfies Criterion 3 of 10 CFR 50.36(c)(2)

Palisades Nuclear Plant B 3.6.1-2 3-d

.01/20/98

BASES

/U\\I

~.lP.l *I LCO APPLICABILITY ACTIONS Containment B 3.6.1 Compliance with this LCD will ensure a containment configuration, including the equipment hatch, that is structurally sound and that will limit leakage to those leakage rates assumed in the safety analysis.

Individual leakage rates specified for the containment air lock (LCO 3.6.2) and purge valves which have resilient seals (LCD 3.6.3) are not specifically part of the acceptance criteria of 10 CFR 50, Appendix J. Therefore, leakage rates exceeding these individual limits only result in the containment being inoperable when the leakage results in exceeding the overall acceptance criteria of 1.0 La.

In MODES 1, 2, 3, and 4, a OBA could cause a release of radioactive material into containment.

In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES.

Therefore, containment is not required to be OPERABLE in MODE 5 to prevent leakage of radioactive material from containment.

The requirements for containment during MODE 6 are addressed in LCO 3.9.3, "Containment Penetrations."

In the event containment is inoperable, containment must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time provides a period of time to correct the problem conmensurate with the importance of maintaining containment OPERABILITY during MODES 1, 2, 3, and 4. This time period also ensures that the probability of an accident (requiring containment OPERABILITY) occurring, during periods when containment is inoperable, is minimal.

Palisades Nuclear Plant B 3.6.1-3 3-e.

01/20/98

BASES ACTIONS (continued)

SURVEILLANCE REQUIREMENTS R~I 3.&.1-I tl'JSlR\\

B.1 and B.2 Containment B 3.6.1 If containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply.

To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SR 3.6.1.2 This SR ensures that the structural integrity of the containment will be maintained in accordance with the provisions of the Containment Structural Integrity Surveillance Program.

S R 3.(o. t.?, ~

Palisades Nuclear Plant B 3.6.1-4 01/20/98 3-f

INSERT SR 3.61.3 Maintaining the containment OPERABLE requires compliance with the Type B and C leakage rate test requirements of 10 CFR 50, Appendix J, Option A, as modified by approved exemptions. Testing is performed at pressures ;:: 55 psig. As left leakage prior to the first startup after performing a required 10 CFR 50, Appendix J, Option A, leakage test is required to be< 0.6 La for combined Type B and C leakage. At all other times between required leakage rate tests, the acceptance criteria is based on an overall Type A leakage limit of~ 1.0 La. At ~ 1.0 La the offsite dose consequences are bounded by the assumptions of the safety analysis. SR Frequencies are as required by Appendix J, Option A, as modified by approved exemptions. Thus, SR 3.0.2 (which allows Frequency extensions) does not apply. These periodic testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in the safety analysis.

SR 3.6.1.3 is modified by a Note which states that local leak tests shall be performed at pressures ;:: 55 psig. This value corresponds to the design pressure of the containment and bounds the maximum expected internal pressure resulting from an MSLB or design basis LOCA.

B 3.6.1-4

4.4 4:5 4.5.1 The containment integrated leak rate testing shall be performed in accordance with the Containment Leak Rate Testing Program.

~'};.(-/ I 4.5.2 I ~~cal r:k tction Tesu I @

r-~~~~~~~~'"'"T'--~~~~~~.--~--..--~~~~-.-~~-

{ s~ 3.~.I..:!; { c<:..!.l)~~~~~~

(2)

Local leak rate

sts for checking airlock door seals within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of each door opening shall be per ormed as follows:

'{a) A between Personnel e seals test shall be pe formed on the irlock at ~ 1.0 psig.

{b) ssure test shall be perfo med on the Emergency Escape Ai lock at ~ 55 psig. A se contact check shall be perfo ed on the Emergency Esca e Airlock following each fu) pressure test. Emergen Escape Airlock qoor opentng; solely for the purpose o strongback removal and perform nee of the seal contact eek, does not necessi ate additional ressure estin.

@ Acceptable methods of t~sting are.halogen gas detection, soap c.:_.:.:;:r--........ -,bubble, pressure decay, or equ1valent.

x (c). F.uel trans(er tube.

Q.. (~).I.solat1on *v.alves an t.h~ t_estable fluid systems' 1 ine

~

penetrating the containment.

(e) Other containment compone~ts which require leak repa r in order to meet the acceptance criterion for any integ ated leak rate test.

4-19 Amendment No. ~.

3-~

c.

I

( 1)

(2)

(3) isolation valves n.ot contact check between the If at any ime it is determined that 0.6 L0 is exceeded, repairs hall be initiated inmediately.

If repairs are not compl ed and conformance to the acce ance criterion of 4.5.. b(l) is not demonstrated withi 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , the plant sh 1 be placed in at least HOT SH DOWN within the next hours and in COLD SHUTDOWN wit

the followin 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

(3) If the Perso el airlock door seal leakage is grea er than

0. 023 L ** or if the Emergency Escape....1J)ek-1joor se contact_

check fail to meet its acceptance criterion, re irs shall be initiated ll'Rlediately to restore the door seal t the acceptan criteria of specification 4.5.Z.b(Z) or 4.5.Z.b(3).

In the e ent repairs cannot be completed withi 7 days, the plant s a 11 be placed in at 1 eas.t HOT SHUTDOW within the next 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the foll ing 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

f

'.:Je&.

I J.c,.z.

(4) lock door seal* leakage results in on door causing tot cont1inment leakage to exceed 0.60 l. the door shall be de ared inoperable and the *remaining OPE BLE door shall be I

i 1ately locked closed* and tested wi in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

As long the remaining door ts found to be OP BLE, the provisions f 4.S.2.c(2) do not apply. Repairs sh 11 be initiated innediat1ly to establish conformance w th specification 4.5.2.b(l). In the event conformance to this specification cannot~ established within 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months the plant shall be placed in at least HOT SHUTDOWN wit n the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 0 hours0 days 0 hours 0 weeks 0 months .

Entry and exit ts permissible throu a "locked* air lock door to perfor11 repairs on the affected air lock components.

CONTAINMENT TSCR REV Z 4-20 611aA~e 7, Amendment No. ~. 74, ~.

S"pu.:~c.~o-

'].l.:,,f RRI ~.~J* j 4.5 I 0 <!.Flt 5 0' Af f J ol'i ft 4.5.Z

~,J "81. \\

.s~ 3.~.l.3 4.5.3

a.

b.

c.

The cont nment equipment tch and the fuel tube sh 1 be tested at e h refueling outag each t used, if that sooner.

b)

A fu1.1 air ock penetration test shall be perf rmed at six-mont intervals. During the period betw n the six-mon tests when CONTAINMENT INTEGRITY required, a reduc pressure test for the door seals o a full air lock enetration test shall be performed ithin 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months af r either-each iir lock door opening r the first of a s ies of openings.

The isolatf o valves shall be demonstrated OPERABLE by performan of a cyclin test and verification of isolation time for auto isolation lves prior to declaring the valve to be OPERABLE a ter maintenan, repair, or replacement work is performed on the alve or its a ociated actuator, control, or power circuit.

Each i lation valve shall be demonstrated OPERABLE by ve fying that each containment isolation right channel or left hannel test signal, applicable isolation valves actuate to the requ;red pos tton during COLD SHUTDOWN or at least.once per ref eling cycle.

T e isolation. time.. o.f* each power operated or automat c valve shall e verified in accordance with Section XI of the A E Boiler and Pressure Vessel Code.

Prior to the reactor going critical after a ref ling outage, a visual check will be made to confirm that all

ocked-closed*

manual containment isolation valves are close and locked (except for valves that are open under administrativ control as permitted by LCO 3.6.1).

e.

Each three months the isolation valves m st be stroked to the position required to fulfill their safe y function unless it is estiblished that such operation is no practical during plant operation. The latter valves shall full-stroked during each COLD SHUTDOWN.

.4-Zl 3-j Amendment No. ~' ~' -i-14,

~:z..

ee ltc,.Z.)

A.7 (continued)

ATTAC1'ENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.1, CONTAINMENT These changes are all considered to be administrative in that there is no significant impact to operation of the plant and they reflect the terminology and usage rules of p, Prl ~.IP*l-'

NUREG-1432.

~.A8 N~w S S<c. W~1

P-tL. l~ 1- /)~iRE ~~RICTIVE CHANGES (M)

There were oo "More R-estrieti'1s" ~baag0s ma.au ia ~fleeifieetieBS 3.6.1.

P.,f\\ t M. I s cc. 'L.> lm. r 3,14.1-'-(

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

.LA.1

'tion of CONTAINME T INTEGRITY, part (b) tes "The equipment ha h is properly closed an sealed." Proposed ITS 3..1 requires that the containment e OPERABLE. The B es defines what is require to make the containme OPERABLE. Therefo e, specific discussions of closure status of the e ui me hatch will be containe the Bases. Changes to the Bases will be made in

accordance with the Bases Control Program as discussed in TS Chapter 5.0, Administrative Controls. This change maintains consistency with NUREG-1432.

LA.2 CTS 4.5.2d(l)(a) whic addresses in part the Test Frequency for Loe Leak Detection Tests states "The co inment equipment hatch and the fuel transfer be shall be tested at each refueling o ge or after each time used, if that be sooner. " In the proposed

~

ITS the progr ic requirements fo~.contairiment leak rate test' g is found in *the 8entainment Rate Testing Program whichis-centained*in

Chapter 5.0, Administrativ Contt:el&. The particular_ details of how and w n the testing is performed i ound in the plant document which implements am. This is acceptable mce the programmatic requirements and accepta ce criteria are found in the

TS A. * 'strative Controls section as discussed above. C anges to the plant proced es will be made in accordance with the plant pro edure change process. This chan maintains consistency with NUREG-1432.

Palisades Nuclear Plant Page 4of6 01/20/98 J-~

RAI 3.6.1-1 DOC 3.6.1 A.8 The Frequency of proposed ITS SR 3. 6.1. 3 is modified by a Note which states that "SR 3. 0. 2 is not applicable." The inclusion of this Note is for clarification purposes only and is considered Administrative in nature since the CTS does not contain an explicit exemption from the testing frequency of 10 CFR 50, Appendix J. Thus, both the CTS and ITS preclude frequency extensions for Type B and C leakage rate tests. This change is consistent with NUREG-1432.

3-)

RAI 3.6.1-1 DOC 3.6.1 LA.2 CTS 4.5.2d specifies the test frequency for individual penetrations and containment isolation valves as "at least every refueling outage, not exceeding a two year interval except as specified in (a) below". CTS 4.5.2d(l)(a) states that "the containment equipment hatch and the fuel transfer tube shall be tested at each refueling outage or after each time used, if that be sooner." In the ITS, Type B and C containment leak rate testing is required by SR 3.6.1.3. The Frequency for SR 3.6.1.3 is stated as "in accordance with 10 CFR 50, Appendix J, Option A, as modified by approved exemptions." The frequencies for Type Band C leak tests required by CTS 4.5.2d are equivalent to the frequencies stipulated in 10 CFR 50, Appendix J, Option A. Specifically, Appendix J Section III, paragraph D.2(a) states "Type B tests, except tests for air locks, shall be performed during reactor shutdown for refueling, or other convenient intervals, but in no case at intervals greater than 2 years. If opened following a Type A or B test, containment penetrations subject to Type B testing shall be Type B tested prior to returning the reactor to an operating mode requiring containment integrity". Appendix J Section III, paragraph D.3 states, "Type C tests shall be performed during each reactor shutdown for refueling but in no case at intervals greater than 2 years." Since the testing frequencies of CTS 4.5.2d are equivalent to the testing

frequencies in 10 CFR 50, Appendix J, Option A, these details can be deleted from CTS 4.5.2d without any affects on public health and safety. This change is consistent with NUREG-1432.

3-fY)

LA.3 LA.4 ATTACH1\\1ENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.1, CONTAINMENT CTS 4.5.2a(3) specifies that "Acceptable methods of testing are halogen gas detection, soap bubble, pressure decay, or. equivalent." The acceptable methods of testing are contained in the FSAR Section 5.8.8.2.2. These testing details are not required to be included in the proposed ITS and will be controlled by the !SAR. Changes to the FSAR are made in accordance with the provisions of 10 CPR 50.59. This change maintains consistency with NUREG-1432.

CTS 4.5.2a.(4) parts (a) through (e) specifies the components which are required to have a local leak rate measured. Part (b) specifies in part that the air lock door seals are tested. This becomes part of SR 3.6.2.1 and will be addressed with ITS LCO 3.6.2. The remaining information is considered to be details which are already addressed in the FSAR Section 5.8.8.2.2 regarding what must have a local leak rate test performed on it. The testing is perfonned in accordance with the requirements spec1 ie e"Containmeftt Leak RMe Testing Program. The content of the details of the types of things which must have a local leak rate test performed will be controlled in the FSAR. Changes to the FSAR are made in accordance with the provisions of 10 CFR 50.59. This change is consistent with NUREG-1432.

RA\\ 3.lo.1-C\\

LESS RESTRICTIVE CHANGES (L)

~

~ O. (DO L.1 The CTS require~ents for Type B and C leak"\\ate testing are being revised such that the leakage limit for Type B and C testin is La only during the first plant startup ollowmg testing performed in accordance wi the Gomainmeat Leak ~e Test "Program. After this, the new limit will now become s: 1.0 La. This means that if the te~ting is performed during a refueling outage, the total Type Band C leakage must be "I.ls-left" a s: tt)O prior resuming power operations. Following this, the leakage limit for the remainder of time until the test is performed again becomes 1.0 La for the total containment leakage. Overall containment integrity is maintained because the results of Type B and C testing must be. compared against the overall containment leakage limit to ensure that the leakage remains s: 1.0 La.

Palisades Nuclear Plant Page 5 of 6 01/20/98

L. l (continued)

ATTAC1'ENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.1, CONTAINMENT CTS 4.5.2.c(l) specifies actions to be taken if.60 La is exceeded for Local Leak Detection Tests. The actions in 4.5.2.c(l) to initiate repairs immediately and shut down if the acceptance criteria of 4.5.2.b(l) is not met (ensuring total leakage from all penetrations and isolation valves shall not exceed.60 La) wi 1 no longer a 1. In the roposed I

, 'the acceptance er ena an testmg requenc~ ill only exist in the ontainmen Leak Rate Testi Program which is found

TS Administrative Control ection 5.5 14. This is simi r~to~th~e~C~T~S~C~o~nt~a~inm~e~~W).~~~~P-'-~~~...,.

Palisades Nuclear Plant ll..Y.ee.ff durin0 t>-.-<..firs.f uni+ s+o.r+vP toU.OW1nQ fts+1n~

~r-torm<.cl

'" a.c.c.orda."c.(. w 1 +H

/() CF-I....S 0 J Afft,nJ1i ~

Page 6 of 6 01/20/98 3-o

LESS RESTRICTIVE CHANGE L.1 ATTACHMENT 4 NO SIGNIFICANT HAZARDS CONS~ERATION SPECIFICATION 3.6.1, CONTAINMENT ID C.FR SDI A~tdtiJ, 0 f t1A11 A The CTS requirements for Type B and C leak rate testing are being revised such that the leakage limit for Type B and C testin s s.60 La only during the first plant startup following testing performed in accordance with

. After this,_

the new limit will now become ~ 1.0 La. This means that if the testing is performed during a refueling outage, the total Type Band C leakage must be "as-left" at s.60 La prior resuming power operations. Following this, the leakage limit for the remainder of time until the test is performed again becomes 1.0 La for the total containment leakage. Overall containment integrity is mainta4ied because the results of Type B and C testing must be compared against the overall containment leakage limit to ensure that the leakage remains s 1.0 La.

testing. This change aJ&.~~iseW'eiisteaey with NUREG-1432,aB meEliaeEl ey tfie i:ftteftt ef iRaasky 9WBef'S gFeap geaerie emmge TS'fF-5i.

Palisades Nuclear Plant

/L~tc.f't dur1"'t ~h(. rirs+. LJMt S.J.a.r-tu('

.f4llow1n0 _-+c.lt1r\\j pt..rf.orttwd In a.c..c.ord "'f'l:.L w ' t#J 1 o c ~ 5 o I

Aeflc.tvl,~ \\1",

Page 1of2 01/20/98 3-p

Containment iAtefospheric ai)(1 Dual)}--~

3. 6. l SURVEILLANCE REQUIREMENTS APrl

~.(p.\\* \\

t c...1s

't. ~.I c.:rS

't. S-. '2.

J.(!)

SR

©

~~

~o..+CL le~~"~

c\\S !.f. ).4 t..t.S-: S'

.u*.~

'P "°j"e.._..

SR 3.6.1.2 CEOG STS SURVEILLANCE The lea ge rate acceptance

~ 1.0

. However, during e first unit start following testing erfonned in accor ance with 10 CFR 50 Appendix J, as modi ied by approved exe ptions, the le age rate acceptance criteria are < 0.

L for the Type B and pe C tests, and 0.75 L. for the Ty A test.

Verify containment structural inte~

in accordance with the Containment~

Surveillance Program.

3.6-2 FREQUENCY In accordance with the Containment ft'TnOOn)

~llance Program Rev 1, 04/07/95

INSERT SURVIELLANCE FREQUENCY SR 3.6.1.3

N()TE--------------------------------

Local leak rate tests shall be performed at~ 55 psig.

Perform required Type B and C leakage rate testing,

N()TE-------

except for containment air lock testing, in accordance SR 3.0.2 is not with 10 CFR 50, Appendix J, ()ption A, as modified applicable.

by approved exemptions.

The leakage rate acceptance criterion is :;;; 1.0 La.

In accordance with However, during the first unit startup following 10 CFR 50, testing performed in accordance with 10 CFR 50, Appendix J, ()ption A, Appendix J, ()ption A, as modified by approved as modified by exemptions, the leakage rate acceptance criteria are approved exemptions

< 0.6 La for the Type B and Type C tests.

3.6-2

Containment - -

B 3.6.l B 3.6* CONTAINMENT SYSTEMS B 3.6.1 Containment lcAifuospherfc)

I BASES e-ACKGROUND Q.

The containment consists of ur6 concrete re tor bu* din I(£>

~. 1ts steel 11AaP~ and the penetrations through this structure. The structure 1s des1gned to contain radiotctive material that may be released from the reactor core following a Design Basis Accident (OBA). Additionally, this structure provides shielding from the fission products that may be present in the conta-lmnent atmosphere following accident conditions.

The containment is a reinforced concrete structure with a

~

~-

cylindrical wall, a flat foundation mat and a shallow dome r;;:)

,~;...... h,c.a cl.,.:.,.._ co-.J"'-

.,.~ 1-------r--o'"i-o,._f........ IFor coijtainmenW with ungrputed tendons.I the cyJ inder I\\!,>

,.....: \\cl -~+e.e.I.,.~:,"-~~.... e>"

wa is prestressed with a post tensioning system in the

r.

vertical and horizontal direction~@,the dome roof 1s I SL'

-n-u.. :~""~~~ P""ss~~

prestressed utilizing a three way pifst tensioning system.

\\...::l

/... ~s 0.... -\\4 bc..S.(. sl"'b The inside surface of the containment is lined with a carbon steel liner to ensure *a high degree-of leak tightness during a.~,...,:s~.l ~

\\:... ~ ~

operating and accident condition$.

e,....~r~ :..,:\\ fNIJS"'rt..

~

Q The concreteliil~ed for structural integrity of the I ~j) a........ ol. ~~ -::\\.."4.W.-.... f containment under OBA conditions. The steel liner and its r.,

~e penetrations establish the leakage limiting boundary of the

--\\\\--.

r-~:--t0rc.M(

(.o,..C..I'~

containment. Maintaining the containment OPERABLE limits s\\~\\.

the leakage of fission product radioactivity from the containment to the envtconment. "Sil 3.6.1.1 leaka e rate 11Z\\

I/

X 1 5 n '1. / I 1..

requ remen s comp y w

, ppen 1 x

1, as ~

0.1"\\a

,.....J.I.JI' *.:J modified by appr9ved exemptions.

> opr.*..... 'O hi.. T.lfe A +.!s :

It>

\\

11...J 0 **- ~ J:;.,. T.,rc t!..C...4-t!~

\\V Rfi 1*

The isolation devices for the penetrat1ons 1n t e

. ~.u,J-containment boundary are a part of the containment leak tight barrier. To maintain this leak tight barrier:

a.

All penetrations required to be closed during accident conditions are either:

-'t

_L

?... t:sc.<f~s: t-l-...k-Pl.. ~

- CJ,-..,,~ i"'-'"'"""\\k o.:t-

1.

capable of being closed by an OPERABLE automatic containment isolation system, or (continued)

B 3.6-1 Rev * @iJo1J9~

1)Ai. ~

BASES BACKGROUND (continued)

b.

c.

2.

closed by manual valves, blind flanges, or de-activated automatic valves secured in their closed positions, except as provided in LCO 3.6.3, "Containment Isolation Valves*;

e pressurized s ling mechanism as oc1ated with a penetration, exc t as provided ~n CO 3.6.[ ], is OPERABLE.

APPLICABLE The safety design basis for the containment 1s that the SAFETY ANALYSES containment must withstand the pressures and temperatures of the limiting OBA without exceeding the design leakage rate.

1=... -"-a. p._\\:s....l<!'s II~-

Pla-t;

~

c:,..lc.-\\a.+-*cl,.......,_;_..... _

rcall:..

c-+..:"'""'e""~ preu..... ~ rts... 1\\.s

+,. 0_

a. l"\\S.t..~.........ae"'1": H *..e*C"j

<;;"(.L. -+N. \\;-:+.~ a.cc.:d.c""+- ~-

of;"~L."'.las~ rerSt*t..t: ~ Is o.. 1,..0C..A,..+-h: 5 '1.-csS'~~ ; ~

... ~cJ a..S r... -n-i"......!.-.. +

S.3rs;1r 'is,...........le.l. "'P ~,._+&-a..

~

..,,1-.......R...,...,~ r...~... J. ;...

.. e~c,... _..._ *I.

LCO CEOG STS The DBAs that result in a release of radioactive material within containment ~re a loss of coolant accident, a mai~r:-ll lru ste111 line break (MSLBlt and a control ~litftent assembly~ ~

ejection accident (Refu.i~). In the ana ysis of each of I~

these accidents, it is assumed that containment is OPERABLE such that release of fission products to the environment is controlled by the rate of containment leakage. The

~A-l containment was designed with an allowable leakage rate of

"!> '1 h (0.10~ of containment air weight per day (Ref. 3

This Ir.;:.,*}(

leakage rate is defined in 10 CFR 50, Appendix J

, ~

as t..: the maximum allowable containment leakage 0

t e calculated maximu* peak containment press~ (P,) of psig, which results from the limiting~

, lwD1ch is al I~

es as1 (Ref~)* I© I des.,.. b.c.sl~ 1..oc.AI Satisfactory leakage rate test results are a requirement for the establishment of containment OPERABILITY.

B 3.6-2 Rev 11 04/07/95 3-}-

~At

~.~J*l - BASES LCO (continued)

APPLICABILITY ACTIONS CEOG STS t i me, the G6f111&+Re-t;Ji-+:lo'&ei-H--at1<!i--E;....+i~'lt9llt-111itfl~

< O 6 L., iRd tRe gverall Type A 1 eakage nnut be < o. 7! t *.

Compliance with this LCO~~ensure a containment

/U'\\

configuration, including equipment hatch~ that l\\JJ is structurally sound and that will limit leakage to those leakage rates assumed in the safety analysis *

.... i...:cJ... h<-

lndividual leakag~rates specified for t e containment ai:4 lock (LCO 3.6.2) tand purge valves resilient seals I CI)

(LCO 3.6.3)t"are not specifically part of the acceptance criteria of 10 CFR 50, Appendix J. Therefore, leakage rates exceeding these individual limits only result in the containment being inoperable when the leaka e results in exceeding th~ptance criteria of A endi 10

~<£)

.OLcL In MODES 1, 2, 3, and 4, a OBA could cause a release of radioactive *material into containment.

In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES.

Therefore, containment is not required to be OPERABLE _in MODE 5 to prevent leakage of radioactive material from containment. The requirements for containment during MODE 6 are addressed in LCO 3.9.3, *containment Penetrations.*

In the event containment is inoperable, containment must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time provides a period of time to correct the problem co11111ensurat~ with -the importance of maintaining containmentt--during HODES 1, 2, 3, and 4. This time period I~

also ensures that the probability of an accident (requiring containment OPERABILITY).occurrin~during periods when

\\'Cb) containment is inoperable~is minimal.

B.1 and 8.2 If containment cannot be restored. to OPERABLE status within the required Completion Time, the plant must be brought to a (continued)

B 3*.6-3 Rev 1, 04/07 /95

BASES ACTIONS SURVEILLANCE REQUIREMENTS

(...... Tc.:..... """' e... -t-Le.,J:..

RA.~ Te,k p;o.,~e.-

CEOG sis Containment ]CA'tl60sphef~c{ 1-@

B 3 **

B.l and B.1 (continued)

MOOE in which the LCO does not apply.

To achieve this status,.*the plant must be brought to at least HOOE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to HOOE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Complet.1on Times are reasonable, based on operating experience, to reach the required plant conditions from full power cond1t1ons 1n an orderly manner and without challenging plant systems.

SR 3.6.1.2 B 3.6-4 SK. 3.~-- (.?:,

~A~

3-y (continued)

Rev 1, 04/07/95 x

y.

INSERT SR 3.6 1 3 Maintaining the containment OPERABLE requires compliance with the Type B and C leakage rate test requirements of 10 CFR 50, Appendix J, Option A, as modified by approved exemptions. Testing is performed at pressures ~ 55 psig. As left leakage prior to the first startup after performing a required 10 CFR 50, Appendix J, Option A, leakage test is required to be < 0.6 La for combined Type B and C leakage. At all other times between required leakage rate tests, the acceptance criteria is based on an overall Type A leakage limit of~ 1.0 La. At ~ 1.0 La the offsite dose consequences are bounded by the assumptions of the safety analysis. SR Frequencies are as required by Appendix J, Option A, as modified by approved exemptions. Thus, SR 3.0.2 (which allows Frequency extensions) does not apply. These periodic testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in the safety analysis.

SR 3.6.1.3 is modified by a Note which states that local leak tests shall be performed at pressures ~ 55 psig. This value corresponds to the design pressure of the containment and bounds the maximum expected internal pressure resulting from an MSLB or design basis LOCA.

B 3.6-4

ATTACHMENT 6 JUSTIFICATION FOR DEVIATIONS SPECIFICATION 3.6.1, CONTAIN1\\.1ENT Change Discussion

7.

8.

10.

~f>t\\ ~£.,.\\-1 II.

The proposed ITS includes a discussion of the Main Steam Line Break (MSLB) accidenno clarify the basis of the term "Pa" since the MSLB accident results in the maximum calculated containment pressure for the design basis accidents. However, as discussed in the Bases, the limiting accident from an offsite dose perspective (i.e.,

affected by containment leakage) is the Loss of Coolant Accident (LOCA). Therefore, the maximum calculated LOCA pressure will be the Pa pressure. The Pa provided in the Bases represents the analytical limit provided in the FSAR (currently 52.64 psig) rounded up to 53 psig.

The Palisades Nuclear Plant used Regulatory Guide 1.35 as a reference for the Containment Structural lngerity Surveillance Program but does not fully commit to Regulatory Guide 1.35. Therefore, this reference is not included in the proposed ITS.

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

A statement is tided in the propose as or ctmns

.,., an "If the over containment leakage rate exc ds the limits of LCO 3.6.1, the Conditions f that LCO must be entered in ccordance with Actions Note 3 change is plant specific preference to e a reminder that the limits of apply if e overall containment leakage ate has been exceeded.

The Palisades Nuclear Plant is considered to be an "Atmospheric" containment. The heading titles referring to either "Atmospheric" or "Atmospheric and Dual" are deleted since they add no value to the usage of the plant specific Palisades Nuclear Plant Technical Specifications. In addition, the portions of NUREG-1432 which are provided for "dual" containments are not applicable to the Palisades Nuclear Plant.

Palisades Nuclear Plant Page 2of2 01/20/98 3-'f

3.6.1 JFD 11 A new SR (SR 3.6.1.3) has been added to address equipment and penetrations subject to Type Band C leakage rate tests in accordance with 10 CFR 50, Appendix J, Option A. The creation of an additional SR is necessary since the Type A testing specified in SR 3. 6.1.1 is performed in accordance with 10 CFR 50, Appendix J, Option B. The requirement and Frequency of ITS SR 3.6.1.3 is similar to ISTS SR 3.6.1.1 with the exception that it contains an explicit requirement to perform leak rate tests at~ 55 psig consistent with the CTS. Conforming changes have been made to the Bases.

ISTS SR 3.6.1.1 was also modified by deleting the sentence which reads, "Failure to meet air lock and purge valve with resilient seal leakage limits.... does not invalidate the acceptability of these overall leakage determination unless their contribution to the overall Type A, B, and C leakage causes that to exceed limits. " The basis for this deletion is that the limit for air lock leakage is the same limit as the limit for combine Type B and C leakage and because there is no unique leakage limit specified for purge valves with resilient seals.

ACTIONS CONDITION REQUIRED ACTION D.

Required Action and D.1 Be in MODE 3.

associated Completion Time not met.

AND.

D.2 Be in MODE 5.

SURVEILLANCE REQUIREMENTS SR 3.6.2.1 SURVEILLANCE

------NOTES---------------

1.

An ino rable air lock door does at invali ate the previous successf perfo mance of the overall air ock leak ge test.

2.

Re lts shall be evaluated a inst a eptance criteria applicab e to s 3.6.1.1.

Per rm required air lock lea age rate Containment Air Locks 3.6.2 COMPLETION TIME 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours FREQUENCY te ing in accordance with t e Containment In ac rdance with he SR 3.6.2.2 L k Rate Testing Program.

Con inment Le Rate T ting Program Verify only one door in the air lock can be 18 months op~ned at a time.

Palisades Nuclear Plant 3.6.2-4 Amendment No.

01/20/98

SR 3.6.2.1

1.

2.

3.

4.

NOTES-------------------

An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

Results shall be evaluated against acceptance criteria of SR 3.6.1.3 in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions.

A seal contact check shall be performed on the emergency escape air lock following each full pressure test.

Emergency escape air lock door opening, solely for the purpose of strongback removal and performance of the seal contact check, does not necessitate additional pressure testing.

Local leak rate tests, other than personnel air lock doors, shall be performed at :i: 55 psig.

Perform required air lock leakage rate testing in accordance with 10 CFR 50, Appendix J, Option A, as modified by approved exemptions.

The acceptance criteria for air lock testing are:

a.

Overall air lock leakage rate is s 1.0 L. when tested at :i: P.

and combined with all penetrations and valves subjected to Type B and C tests. However, during the first unit startup following testing performed in accordance with 10 CFR 50, Appendix J, Option A, as modified by approved exemptions, the leakage rate acceptance criteria is< 0.6 L.

when combined with all penetrations and valves subjected to Type B and C tests.

b.

For each personnel air lock door, leakage rate is s 0.023 L.

when tested at :i: 10.0 psig.

c.

An acceptable emergency escape air lock door seal contact check consists of a verification of continuous contact between the seals and the sealing surfaces.

NOTE------

SR 3.0.2 is not applicable In accordance with 10 CFR 50, Appendix J, Option A, as modified by approved exemptions

BASES ACTIONS (continued)

SURVEILLANCE REQUIREMENTS R

Pl I

?;.l;.\\-1 D.l and D.2 Containment Air Locks B 3.6.2 If the inoperable containment air lock cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply.

To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SR 3.6.2.1 Maintaining containment air locks OPERABLE requires compliance with the leakage rate test requirements of~

(

fontairifuent Leak Rat[ Testing ProjrariLl This SR reflects the leakage rate testing requirements with re ard to air lock leakage (Type B leakage tests). Te per10 ic testing IOCFR SD1 APP.:.11cJ1t r, requirements verify that the air lock 1 eakage does not DP+ M 11.... ao exceed the allowed fraction of the overall.containment

. ' 1 ~. ~'1 1

,,, J ") leaka e rate.

The Frequency is required b 11 1oci 1\\lc.a "ot <l.pfoLt

~ Lea a e es,

rogra * --

e.-rt t..'f"r\\ ~>-hons.

[:

h..('

The SR has been modified by.tWEt Not~s. Note 1 states that*

DJjlRi I an inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

This is considered reasonable since either air lock door is capable of providing a fission product barrier in the event of a OBA.

Note 2 has been added to this SR requiring the results to be evaluated against the acceptance criteria of SR 3.6.1.(ll.3 This ensures that air lock leakage is properly accoun~d f~ in detenn1ning the overall containment leakage rate.

!NSlR1 2..

Tfif. ac~.Ha.iHt. C.r11<.n~ t"r\\. ~11.flkJ cl1Jn;, 1 r11flaL a.Jr Jd<.i: arJ s~~~a:~~~l'\\+.s ~ -J'+~,,,CAL Slte-4~1,a.+to"s RAI

~.fQ.'l-lt; (lv!SeJ +tie cu.~P+,n~ c.r1-lu-1a...f'or overaJ.L "T'fk 5 ~ f..

. kKa.°cf' fifh,~ a.rid Prou1d'fll flew a.u.t,f~llct..

C.r1-kr10..

4'or th\\ fc.rie"'"~L.

o..1r.Jor..>. &ilocrS a.ncl -+he. e..r,.,..1..t'deri,c.y a.1 r )(X.t: dbors { &f. 2..)

Palisades Nuclear Plant B 3.6.2-7

~-0--b 01/20/98

INSERT 1

[From previous paragraph]... Thus, SR 3.0.2 (which allows Frequency extensions) does not apply.

Two exemptions to the requirements of 10 CFR 5,0, Appendix J have been granted for the containment air locks. The exemption granted by letter dated December 6, 1989 provides partial relief from the requirement of Paragraph III.D.2.(b)(ii) to leak test, at or above the calculated design basis accident peak containment pressure (Pa), containment air locks which were opened during a period when containment integrity was not required. This exemption permits the substitution of a between-the-seal leak test at a.reduced pressure, but not less than l 0 psig, provided that no maintenance, modification, or other activity has been performed which could affect the sealing capability of the air locks.

The exemption granted by letter dated September 30, 1997 applies only to the emergency escape air lock and provides partial relief from the requirement of Paragraph III.D.2.(b )(ii) and Paragraph III.D.2.(b)(iii). The requirement of Paragraph III.D.2.(b)(ii) is discussed above.

Paragraph III.D.2.(b)(iii) requires air locks opened during periods when containment integrity is required to undergo a full air lock pressure test within 3 days after being opened. This exemption permits the performance of a door seal contact verification check in lieu of the final pressure test following the opening of the emergency escape air lock doors for post-test restoration or seal adjustment. This exemption does not affect compliance with the requirement to perform a full pressure air lock test at 6 month intervals, or the requirement to perform a full pressure air lock test within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of opening either air lock door during periods when containment integrity is required.

INSERT 2 Note 3 clarifies that iterative pressure testing of the emergency escape air lock is not required when the air lock doors are opened solely for the purpose of strongback removal and performance of the seal contact check. Note 4 ensures that air lock testing, other than door seal testing, is performed at a pressure ~ 55 psig consistent with other type Band C tests.

4.4 17 Sr< 3.~.;>.-I 4b' s~ 3.1a.i.1

~

c., a.nd N*1l. 3 Deleted

~~cal~ction Tests I ~

(1)

Local lea rate tests, other than Personnel between e seals tests, shall be perform irlock doors at ~ SS psig.

Local 1 ak rate tests for checking airlo 72 ho s of each door opening shall be door seals within rformed as follows:

A between the seals test shall b performed on the Personnel Airlock at ~ 10 psig.

A full pressure test shall be erformed on the Emergency Escape Airlock at ~ 55 psig. A seal contact check shall be performed on the Emergen Escape Airlock following each full pressure test.

ergency Escape Airlock door opening, solely for the p pose of strongback removal and performance of the seal ntact check, does not necessitate additional essure testin.

cf]

Acceptable methods of testing are ha ogen gas detection, soap bubble, pressure decay, or equivalent.

SR.3.(..2..I (4)

( s..-

~.c..'

(a)

{c)

(d) u

'..&.... r.

'1

<s-..::l.<..1 :>

Air lock~d equ!rn:nt door sea s.

I olation valves on the te table fluid systems' enetrating the containm t.

Other containment comp ents which require order to meet the ace tance criterion for leak rate test.

4-19 Amendment No. ** He, H-S, H-4, 177

~

(0.2 Rn l 3.0.1--}

..St< 3.~.1-.,f l*a. I Sf.J '4. l..j

'C ~

rn,,_;

I CONTAINMENT (j'ijTS) :5YST~M.S Local Lea@etection Tests /{continued,} @

penetrations (2)

The lea ge for a Personnel airlock doo exceed. 023 L **

(3)

An a eptable Emergency Escape Airlo cons sts of a verification of conti seas and the sealing surfaces.

door seal contact check ous contact between the Entry and exit ts permissible through a "locked~ air lock door to perfor111 repai-f's on the affected air lock components.

4-20 Glla11~e 7, Amendment No. ~. 74, -t-7+,

4.5

~Al 3.'7. t-/

4.5.3 CONTAINMENT TESTS

{j)

Test Frequency (1)

Ind1v1 al penetrations and containm t isolation valves be 1 rate tested at a frequency at least every ref eling, not exceedin a two-yea interval, except as s cif1ed in a and b below:

a.

The isolation lves shall be demonstrated OPERABLE by p rformance of a cycling st and verification of isolation time fo auto isolation va es prior to declaring the valve to be OP BLE after maintenance repair, or replacement work is performed on the valve or its as ciated actuator, control, or power circui *

b.

c.

e.

Each is ation valve shall be demonstrated OPERABL by verifying that o each containment isolation right channel left channel test gnal, applicable isolation valves actuate o their required posi ion during COLD SHUTDOWN or at least once r refueling cycle.

1 isolation time of each power operated or a tomatic valve shall verified in accordance with Section XI of he ASHE Boiler and ressurt Vessel Code.

Prior to tht reactor going critical refueling outage, a visual check w111 be made to confirm that 11 *1ocked-closed*

manual containment isolation valves are osed and locked (except for valves that are open under administr. tive control as permitted by LCO 3.6.1).

Each three months the isolation valv must be stroked to the position required to fulfill their s fety ~unction unless it is established that such operation is ot practical during plant operation. The latter valves shal be full-stroked during each COLD SHUTDOWN.

4-21

~,3 - a_ f See 3.~.I)

Se.e 3.t...1)

I

< A'OD

~trr"E l ~ $ ~ J. i,. -i. 1 ~ '-......J. :.. m) Amendment No. 26, Hi, H4, l

<*W (~

"l. -1.. <R 3.1..1.I., '--> !~ "J:T-') ~

?a.'i/' S.I 5'

.__ -----<c...~D S~ 3.(o.L,"2.. c.S..f.:.~.... J. :.... r-rs-'> @

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS A.12 The proposed ITS includes two Notes in SR 3.6.2.1. The second Note states "Results A.13 t\\A-1

~.<,.i-3 A. \\4 ft!\\'

A

-,.~Yl--

.1 s shall be evaluated against acceptance criteria of tali (",gmailnneHt I.@ak :Rate Testiag 5 R ~.(,./.~

Pregram in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions." CTS 4.5.2c(2) starts out by stating "If at any time it is determined that total containment leakage exceeds La.... " This implies that the air lock leakage, as well as any other containment leakage, is always compared against the overall containment leakage requirements. Therefore, the addition of this note is an administrative change to provide a reminder to compare the test results against the.

overall containment leakage limit. This change is consistent with NUREG-1432.

-~--~---*~--~-*~--*-* ~~~~~~~-::--:--r--i CTS 4.5.2c(3) states "if ir lock door seal leakage is gr ter than 0.023 La.... " In e proposed ITS this beco es Condition A which states " ne or more containment a*

locks with one conta*

ent air lock door inoperable.

The CTS air lock door se leakage limit of 0.0 La is specified in"the propos tl ITS.Containment<Leak Ra Test program. There~ e, the Condition A only refer o the door being inoperable. The words "One or ore" are added in the propose ITS to clarify which Conditi should be entered if o e door in each air lock is inop able. This is acceptable sin overall con ent leakage must still rema* within the limits of LCO 3.6 Note 4.

se chan es are consistent wi UREG-1432.

Palisades Nuclear Plant Page 5of11 01/20/98 3-~

3.6.2 DOC A.14 The Frequency of proposed ITS SR 3.6.2.1 is modified by a Note which states that "SR 3.0.2 is not applicable." The inclusion of this Note is for clarification purposes only and is considered Administrative in nature since the CTS does not contain an explicit exemption from the testing frequency of 10 CFR 50, Appendix J. Thus, both the CTS and ITS preclude frequency extensions for Type Band C leakage rate tests. This change is consistent with NUREG-1432.

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS LESS RESTRICTIVE CHANGES-REMOVAL OF DETAILS TO LICENSEE CONTROLLED DOCUMENTS (LA)

LA.1 LA.2 CTS 4.5.2a(3) specifies* that "Acceptable methods of testing are halogen gas detection, soap bubble, pressure decay, or equivalent." The acceptable methods of testing are contained in the FSAR Section 5.8.8.2.2. These testing details are not required to be included in the proposed ITS and will be controlled by the FSAR. Changes to the FSAR are made in accordance with the provisions of 10 CPR 50.59. This change maintains consistency with NUREG-1432.

CTS 4.5.2d.(l)(b) specifies that a full air lock penetration test is perlormed at six month intervals, and between this test period, either a reduced pressure test for the door seals, or a full air lock penetration test will be performed within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after either, each air lock door opening or the first of a series of openings. Proposed SR 3.2.6.1 requires the performance of testing "in accordance with Palisades Nuclear Plant Page 8of11 01/20/98 r

3 L

3.6.2 DOC LA.2

... 10 CPR 50, Appendix J, Option A, as modified by approved exemptions." The frequencies for air lock testing required by CTS 4.5.2d are equivalent to the frequencies stipulated in 10 CPR 50, Appendix J, Option A. Specifically, Appendix J Section III, paragraph D.2(b)(i) states "air locks shall be tested prior to initial fuel loading and at 6 month intervals thereafter at an internal pressure not less than Pa." Paragraph D.2(b)(i) states "air locks opened during periods when containment integrity is required by the plant's Technical Specifications shall be tested within 3 days after being opened".... "For air locks doors having testable seals, testing the seals fulfills the 3 day test requirements. " Since the testing frequencies of CTS 4.5.2d(l)(b) are equivalent to the testing frequencies in 10 CPR 50, Appendix J, Option A, these details can be deleted from CTS 4.5.2d(l)(b) without any affects on public health and safety. This change is consistent with NUREG-1432.

L.2 C..f~__\\

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS CTS 4.5.2c(4) specifies requirements for air lock door seal leakage causing the total containment leakage to exceed.60 La. These requirements are not included in the proposed ITS 3.6.2 relative to exceeding.60 La, as sufficient actions are provided to ensure containment OPERABILITY is maintained. Proposed ITS 3.6.2 Condition A and C provide ACTIONS for air lock doors being inoperable. In accordance with the acceptance criteria in CTS 4.5.2b(2) aiKI alsg CT~ l;i.j.14~ which is consistent with

~

proposed~ift rrg 5, 5.14 ~r ~i C9RtaillmeRt :b~ak R.at~ Tist Prggram, the acceptance criteria for containment air lock door seal leakage is ~.023 Lav:~............ e-re---.-1s_,

no impact on containment leakage if one air lock door seal leakage is >.60 La as long as there is a)tOPERABLE door in the air lockeas is i.m¥liis in tke seeeH& seftteftee ef CTS 4 s 2c'4~ mhicb states "As long as the i:emaiilmg dgor is fwn4 tg 9e OP~~~. tke fJFelfisieRB ef 4.~.2.s(2) Ele net e:1313ly7' The CTS requirement to test the remainiiig OPERABLE door, which was required to be locked closed, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is also not required to be performed included in the proposed ITS. In accordance with the usage rules of NUREG-1432, equipment is assumed to be OPERABLE between surveillance periods unless there is some reason to believe otherwise. Therefore, there is no reason to perform a confirmatory test for OPERABILITY if there is no indication that the OPERABLE door seals are degraded.

The proposed ITS Required Actions and Frequency in ACTION A of verifying the OPERABLE door is closed in the affected air lock within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND locking the OPERABLE door closed in the affected air lock within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AND verifying the OPERABLE door is locked closed in the affected air lock once per 31 days are sufficient to ensure that containment OPERABILITY is maintained. As long as an OPERABLE door exists, the leakage through the other door is irrelevant.

Therefore, the acceptance criteria of. 60 La and additional associated actions are no longer required. This change is considered to be less restrictive since additional actions beyond those addressed by proposed ACTION A for air lock door seal leakage being >.023 La (wftieft is Sf>eeitiea iR f>Fepesea ITS 5.5.14, Cemaitlmeft1: Leak R:atc V

TestiBg PTegram) are not needed to maintain containment OPERABILlTY. This I\\

change is consistent with NUREG-1432.

Palisades Nuclear Plant Page 10of11 01/20/98 o. k

2.

ATTACH1\\1ENT 4 NO SIGNIFICANT HAZARDS CONSIDERATION SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change does not involve a physical alteration of the plant. No new or different type of equipment will be installed or changes made to plant parameters which govern normal plant operation. The proposed change still ensures that an OPERABLE containment air lock door is closed. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does this change involve a significant reduction in a margin of safety?

The proposed change increases the allowed outage time for an inoperable containment air lock door and does not require repairs to be initiated immediately as long as an OPERABLE door is closed within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , locked \\Vithin 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and periodically verified to be locked closed every 31 days. Therefore, since an OPERABLE door is locked closed and will ensure that containment leakage is within limits and the OPERABLE door is verified to be locked closed every 31 days, there is no significant reduction in the margin of safety.

LESS RESTRICTIVE CHANGE L.2 CTS 4.5.2c(4) specifies requirements for air lock door seal leakage causing the total containment leakage to exceed.60 La. These requirements are not included in the proposed ITS 3.6.2 relative to exceeding.60 La, as sufficient actions are provided to ensure containment OPERABILITY is maintained. Proposed ITS 3.6.2 Condition A and C provide SfU.(p z.t ACTIONS for air lock doors being inoperable. In accordance with the~tance cntena m CTS 4.5.2b(2) aHEi alse CTS f;.S.14,.. which is consistent with those proposedVm ITS 5.5.14 fer

~

tlle Comainmtilat Liak Rate Test PregraH.1:1 the acceptance criteria for containment air lock door ( S._ ~

)

seal leakage is ~.023

'¥"There is no impact on containment leakage if one air lock door seal tioc. m-3

e age is >.

as ong as ere is PERABLE door in the air lock.as is im:'lie8 Hi tae second sentence. of CIS A. 5 2c'4> whjclLstates " Ai Ions aw the temaining Q00i is Ee\\laQ t0 ee OPE.RABLE., EB@flr0-visi0BB ef 4.~.2.e(l~ Els Ret llf'f'ly." The CTS requirement to test the remaining OPERABLE door, which was required to be locked closed, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is also not required to be performed included in the proposed ITS. In accordance with the usage rules of NUREG-1432, equipment is assumed to be OPERABLE between surveillance periods unless there is some reason to believe otherwise. Therefore, there is no reason to perform a confirmatory test for OPERABILITY if there is no' indication that the OPERABLE door seals are degraded.

Palisades Nuclear Plant Page 2of6 3~CLL 01/20/98

ATTACHMENT 4 NO SIGNIFICANT HAZARDS CONSU)ERATION SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS LESS RESTRICTIVE CHANGE L.2 (continued)

The proposed I'!_S Required Actions and Frequency in ACTION A of verifying the OPERABLE door is closed in the affected air lock within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND locking the OPERABLE door closed in the affected air lock within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AND verifying the OPERABLE door is locked closed in the affected air lock once per 31 days are sufficient to ensure that containment OPERABILITY is maintained. As long as an OPERABLE door exists, the leakage through the other door is irrelevant.

R Pt \\

,.&.\\"" \\

Therefore, the acceptance criteria of.60 La and additional associated actions are no longer required. This change is considered to be less restrictive since additional actions beyond those addressed by proposed ACTION A for air lock door seal leakage being >.023 La (which is X

s~Bsifisa ia prgpg~ed ITS 5 5 14, Containment I eak Rate Te~tms Fregram) are not needed to main.tain. containment OPERABILITY. This change is consistent with NUREG-1432.

1.

Does the change involve a significant increase in the probability or consequence of an accident previously evaluated?

The proposed change deletes the required actions which are to be performed if the containment air lock door leakage would cause total containment leakage to exceed

. 60 La. Sufficient actions are already provided if air lock door seal leakage exceeds

. 023 La which includes ensuring that the OPERABLE door is closed. By closing the OPERABLE air lock door, the leakage from the other door is irrelevant since containment integrity is ensured by the OPERABLE door which is closed and locked.

Therefore, since containment OPERABILITY has not been impacted there is no significant increase in the probability or consequences of an accident.

2.

Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change does not involve a physical alteration of the plant. No new or different type of equipment will be installed or changes made to plant parameters which govern normal plant operation. The proposed change continues to limit the amount of leakage from containment by ensuring that an OPERABLE door is closed and locked.

In addition, overall containment leakage is still limited to 1.0 La and any contribution to this leakage limit from the air lock door seals must still be evaluated. Thus, this.

change does not cr~te the possibility of a new or different kind of accident from any accident previously evaluated.

Palisades Nuclear Plant Page 3 of 6 01/20/98 3-a_fY\\

ACTIONS lcontinuedl CONDITION li.5.1..c.U)

0. Required Action and c..-rs associated Completio~

(.(4J r;me not met.

SURVEILLANCE REQUIREMENTS D. l 00 D.2 Containment Air LocksUAtmoApheric ai)(i Dual¥-@

3. 6.

REQUIRED ACTION COMPLETION TIME Be ;n MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Be in HOOE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE FREQUENCY C..T5 4

i;;, i..d, 1. k SR 3.6.2.1 f{Al r\\

3.fu,t-1

"'-'"' I x

&J5£rL\\

CEOG STS

1.

2.

a.

1

b.

air lock leakage rate 1s L.] 111hen tested at ~ P **

is 3.6-6 3-8.,(\\

(continued)

Rev 1, 04/07/95 I

\\

I

SR 3.6.2.l

1.

2.

3.

4.

INSERT

NOTES-------------------

An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

Results shall be evaluated against acceptance criteria of SR 3.6.1.3 in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions.

A seal contact check shall be performed on the emergency escape air lock following each full pressure test. Emergency escape air lock door opening, solely for the purpose of strongback removal and performance of the seal contact check, does not necessitate additional pressure testing.

Local leak rate tests, other than personnel air lock doors, shall be performed at :.:: 55 psig.

Perform required air lock leakage rate testing in accordance with 10 CFR 50, Appendix J, Option A, as modified by approved exemptions.

The acceptance criteria for air lock testing are:

a.

Overall air lock leakage rate is 5: 1.0 L. when tested at <: P. and combined with all penetrations and valves subjected to Type Band C tests. However, during the first unit startup following testing performed in accordance with 10 CFR 50, Appendix J, Option A, as modified by approved exemptions, the leakage rate acceptance criteria is< 0.6 L. when combined with all penetrations and valves subjected to Type B and C tests.

b.

For each personnel air lock door, leakage rate is

~ 0.023 L, when tested at <: 10.0 psig.

c.

An acceptable emergency escape air lock door seal contact check consists of a verification of continuous contact between the seals and the sealing surfaces.

3.6-6 3-eco

1'-J"()TE------

SR 3.0.2 is not applicable In accordance with 10 CFR 50, Appendix J, Option A, as modified by approved exemptions

BASES ACTIONS SURVEILLANCE REQUIREMENTS

~I<' ro. +t -fc s ts 1 o +n i.r J~n ~~f'Sonfl'l:.l. Cl.ii'

.<dt. i.:s CLOO r:s, a. rt fl!. r tor""-d. a. t Pri:.ssvrc..s '?.: 55 Psid.

CEOG STS Containment Air Locks /<AtmoWheric a;t\\d Dual~!--::§ B 3.6.

C.l. C.2. and C.3 (continued)

Additionally, the affected air lock(s) must be restored to OPERABLE status within the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time.

The specified time period is considered reasonable for restoring an inoperable air lock to OPERABLE status, assuming that at least one door is maintained closed in each affected air 1 ock.

0.1 and Q.2 If the inoperable containment air lock cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a HOOE in which the LCO does not apply.

To achieve this status, the plant must be brought to at least MOOE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to HOOE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power eond1t1ons in an orderly manner and without challenging plant systems.

SR 3.6.2.1

'The SR has been modified by two Notes.

Note 1 states that an inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

This is considered reasonable since either air lock door is capable of providing a fission product barrier in the event of a OBA.

Note 2 has been added to this SR requiring the r~~~lt! to be evaluated against the acceptance criteria of (continued)

B 3.6-17 Rev 1, 04/07 /95 SubCl!.3uc.n1 O.mc.iialmtnt3 to 1-nc. "Ec.Hii.l'4L S f(t.rfica.il61l -:._J re.vis~ -+m ac.~c cr.+c.r1~ {er oi..e.ro.J I TY11c. 5 ~ C.

~~0

c..Q,,,u+s o..Nl frcvldc.rJ ~w a.cet.p-irul c-t-Cri~c.r.o... -t6r +k p:..rsei"ri<.L au* itJ:..K d.oor~ a.rJ

~'"°oenc.y c1tl" JoLJ< d OolS (~~. z)

~-~p

INSERT 1

[From previous paragraph]... Thus, SR 3.0.2 (which allows Frequency extensions) does not apply.

Two exemptions to the requirements of 10 CFR 50, Appendix J have been granted for the containment air locks. The exemption granted by letter dated December 6, 1989 provides partial relief from the requirement of Paragraph IiI.D.2.(b )(ii) to leak test, at or above the calculated design basis accident peak containment pressure (Pa), containment air locks which were opened during a period when containment integrity was not required. This exemption permits the substitution of a between-the-seal leak test at a reduced pressure, but not less than 10 psig, provided that no maintenance, modification, or other activity has been performed which could affect the sealing capability of the air locks.

The exemption granted by letter dated September 30, 1997 applies only to the emergency escape air lock and provides partial relief from the requirement of Paragraph m.D.2.(b )(ii) and Paragraph III.D.2.(b)(iii). The requirement of Paragraph III.D.2.(b)(ii) is discussed above.

Paragraph III.D.2.(b )(iii) requires air locks opened during periods when containment integrity is required to undergo a full air lock pressure test within 3 days after being opened. This exemption permits the performance of a door seal contact verification check in lieu of the final pressure test

following the opening of the emergency escape air lock doors for post-test restoratfon or seal adjustment. This exemption does not affect compliance with the requirement to perform a full pressure air lock test at 6 month intervals, or the requirement to perform a full pressure air lock test within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of opening either air lock door during periods when containment integrity is required.

B 3.6-17

~Prl

'!l.&;i. \\-1 BASES SURVEILLANCE REQUIREMENTS Containment Air Locksl(AtJflospherii and Du~)~

B 3 ** 2 SR 3.6.2.l (continued) 3 v

SR 3.6.1..l(. ~his ensures that air lock leakage is properly

~

accounted fo~in determining the overall containment leakage rate.

SR 3.6.2.2 The air lock interlock is designed to prevent simultaneous opening of both doors in a single air lock. Since both the inner and outer doors of an air lock. are designed to withstand the maximum expected post accident containment pressure, closure of either door will support containment OPERABILITY.

Thus, the door interlock feature supports containment OPERABILITY while the air lock is being used for personnel transit into and out of containment. Periodic testing of this interlock demonstrates that the interlock will function as designed and that simultaneous opening of th& inner and outer doors ~ill not in~dvertently occur.

Due to the urel mechanical nature of this interlock, and given r--~r-,.--,+/-::==r==r=t:=----~th~a~t:.,,.t;..;h;..;;e~i n~t:..;e~r:;o=c7 k::lme~c an s.11 s cha 11 enged when this t.est s only required to be REFERENCES I i. 7 10 CFR sj, Ap.eendif J. I

& (ChD.p~3._{D_(%)=-_F_SA_.~ (SJ#@~

©.

FSAR,. Section sf' lJ@

I I CD I©

..... e.v~ \\ e "'-.'*"s. ""TNL. l B....,_... ~ i:-~t~ ic \\.... ~eJ o" ~

N.t.J 4-o

~4-r+o....-....j\\..:) s"'""'e:l\\c.... u_ ~e

... ~

c..o.....l;~.".+k..+.. f,1, d-'"'\\... f' '4~

o..... +.. ~

1 G...... ~ -14..... i'Q'4*e"~.;e-Q_ ~, \\oss... ~ c.o **.+..:....,,_..... t-O?e~BI UT"#

i-' ~

'S....-:\\\\o..... c.(... lo.l~ re~~... -eJ w:-"'~.... ~, "'*,.~.

the. I~ rnlNith Fr1e1c.nc.f -"'*'" fhc. 111~u)6C..t' 1s dt1!+1ftul lo~ y 6il erierte. OfWA.+in e~ Af1~nCL.~

CEOG STS 8 3.6-18 Rev 1, 04/07/95 3 - a_,._....

INSERT 2 Note 3 clarifies that iterative pressure testing of the emergency escape air lock is not required when the air lock doors are opened solely for the purpose of strongback removal and performance of the seal contact check. Note 4 ensures that air lock testing, other than door seal testing, is performed at a pressure 2'. 55 psig consistent with other type B and C tests.

B 3.6-18

ATTACHMENT 6 JUSTIFICATION FOR D~VIATIONS SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS Change Discussion Note:

l.

2.

3.

4.

5.

\\

6.

~~.IP.v\\

I.rJSc((i

~

This attachment provides a brief discussion of the deviations from NUREG-1432 that were made to support the development of the Palisades Nuclear Plant ITS. The Change Numbers correspond to the respective deviation shown on the "NUREG MARKUPS." The first five justifications were used generically throughout the markup~

of the NUREG. Not all generic justifications are used in each specification.

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

Deviations have been made for clarity, grammatical preference, or to establish consistency within the Improved Technical Specifications. These deviations are editorial in nature and do not involve technical changes or changes of L.-itent.

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

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

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

This change reflects the current licensing basis/technical specification. The Palisades CTS note is more explicit to clarify that a door which has been "locked" in order to comply with ACTIONS can be used to perfonn repairs on the affected components.

This is consistent with the application of the note and removes any confusion when applying this note to a door which has locked.

The Palisades Nuc ear ant pe orms e ype testmg a*

ock testing) in accordance with 10 C 50 Appendix J, Option A. How er, it is proposed to inclu all of the limits for c ntainment leakage tests (Type A, B d C) in the Containment Leak Rate Testing ogram as was indicated in TSTF-5 which implements Option to 10 CFR 50 Ap endix J. Therefore, where approp

te, *the proposed ITS word* g for the Type B d C tests (including the air lock tes g) also references the Containment ak Rate Testing Program in a simil context as that proposed

TSTF-52 for onverting to 10 CFR 50 Appendix Option B.

I Palisades Nuclear Plant Page 1of3 01/20/98 3-cct

INSERT 3.6.2 JED 6 ISTS SR 3.6.2. l (ITS SR 3.6.2.1) has been revised to reflect certain aspects of air lock testing presently contained in the CTS. This includes; 1) the addition of Note 3 which allows the emergency escape doors to be opened for strongback removal and performance of a seal contact check following testing, 2) explicit acceptance criteria for the emergency escape air lock doors, and 3) reference to Option A of 10 CFR 50, Appendix J. The Bases for ISTS SR 3.6.2.1 (ITS SR 3.6.2.1) were revised to provide conforming changes to the actual SR, and to include a discussion on the NRC staff approved exemptions to 10 CFR 50, Appendix J as they relate to the containment air locks.

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

3.6.1-2 DOC A.1 DOC A.7 DOC A.4 (ITS 3.6.3)

CTS 3.6.1.a ITS 3.6.1, 3.6.2 and 3.6.3 APPLICABILITY and Associated Bases CTS 3.6.1.a requires the CONTAINMENT INTEGRITY to be maintained when the plant is above COLD SHUTDOWN. ITS 3.6.1, 3.6.2, and 3.6.3 APPLICABILITY requires containment, the containment air locks, and the containment isolation valves to be OPERABLE in MODES 1, 2,3, and 4. This CTS change is acceptable; however, the change is simply justified as a generic editorial reformatting change (DOC A.1). The technical equivalency of the Palisades Modes of Operation definitions are significantly different from the proposed ITS modes of operation as is discussed in DOC A.7, (DOC A.4 for ITS 3.6.3). The appropriate justification for this change would be DOC A. 7 (DOC A.4 for ITS 3.6.3) or an equivalent.

Comment:

Revise the CTS markup to show this change as DOC A. 7 (DOC A.4 for ITS 3.6.3) or an equivalent. Provide additional discussion and justification as necessary.

Consumers Energy Response:

A new DOC has been added to Specification 3.6.1 (DOC A.9), Specification 3.6.2 (DOC A.15),

and Specification 3.6.3 (DOC A.16) to describe the equivalence in wording of CTS 3.6.1 a and the ITS Applicability of Modes 1, 2, 3, and 4.

Affected Submittal Pages:

Att 3, CTS page 3-40 (3.6.1, page 1 of 8)

Att 3, CTS page 3-40 (3.6.2, page 1 of 5)

Att 3, CTS page 3-40 (3._6.3, page 1 of 5)

Att 3, DOC 3.6.1, page 4 of 6 Att 3, DOC 3.6.1, page 5 of 11 Att 3, DOC 3.6.1, page 6of10 4

i

- --------~

3.6 CONTAINMENT SYSTEM{f>

R~t.1-'2.

Le.a 3.6.1 CONTAINMENT ~N#GRitfj shal~ be lma!'fttaiPi"ed*-ltif'C:f.AiL' I /@ A.q I)

Appl:c.~b:l:t::l

. 6.2

~ c ~.i...2./

b.

When the reac~r vessel head is r. moved (unless the CS boron

~~J.i"-

concentratiQI( is at REFUELING B ON CONCENTRATION and l/

c.

When posit ve reactivity ch nges are made b boron dilution or

~

CONTROL 0 motion (except for testing one ONTROL ROD at a time A

r.=::=--~~~~~~~~~~--h ACTION:

L*2-With one or more c tainment isolation valves in erable (including R/lll ~.lo.I*~

during perfonaanc of valve testing), maintain t.~st-one isolation valve OPERABLE each affected penetration t t is open and either:

a.

LE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ; or

b.

Isol te each affected penetration thin 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months by use of at least on closed and deactivated automa c valve, closed manual valve, or ind fl ange; or Be in at least HOT SHUTDOWN thin the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the follow 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

The containment ternal pressure shall not exceed:.

a.

1.5 psig hen above COLD SHUTDOWN. and below HOT*

b.

1.0 p g when 1n_POWER.OPERATJON.or HOT STAN Y.

With co ainment internal pressure above the l it, restore pressure to withi the limit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , or be in at 1 ast HOT SHUTDOWN within the xt 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and 1 n COLD SHUTDOWN wi tM the fo 11 owi n 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

The containment a erage air temperature shalf not exceed 14 when the plant is above LO SHUTDOWN~ With containment average ai temperature above the limi, restore temperature to within the limit ithin 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , or be in at l ast HOT SHUTDOWN within the; next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

d. in COLD wi in the followin 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .*

3.6.4 wo independent containment ydrogen recombiners shall be PERABLE when the plant is in POWER OPE ION or HOT STANDBY.

With on recombiner inoperable, restore the i operable recombiner to OPERAS status within 30 a or be 1n at lea HOT SHUTDOWN within _the next

_h.o.w-s.

3.6.5 The con ainment purge exhaust and air oom supply isolation v lves shall be lo ed closed whenever the plant i above COLD SHUTDOWN.

1th one cont nment purge exhaust or air ro supply isolation valv not locked cl ed, lock the valve closed with 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in at l st HOT S

DBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months a ~ in COLD SHUTDOWN wit n the ollowin 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

3-40 Amendment No. ~. ~.

3. 6 CONTAINMENT SYSTEM© A,*,.,. Loi-l:.s of'E"~A-'3L£ Ll-0 3.6.~0NTAINMENT N GR Y shall be maintained:*

Arel:c:.... ~:l:~

a.

When the plant is laboye* COLD jHuTOowij, /,-;.... -M.-o_CES_t_, z._,l_c._..J._'1__,/

3.6.2

f.6.3

b.

c.

ACTION:

With one or e containment isolation-valve inoperable {including during perfo ance of valve testing), ma*int n at :l:eut-one isolation

.J~ in-each affected penetrati. that is open and either:

a.

Res re the inoperable valves to O RABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ;

b.

I o1ate each affected penetr&ti

~1th1n 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months by use of at, ast ne closed and deactivated aut atic valve, cl~sed manual blind flange; or Be in at least HOLSHUTDOW within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and within the follo 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

The contain nt internal pressure shal not exceed:

a.

1.5 p ig when above COLD SHUTDOW and below HOT STANDBY

b.

1g when in POWER OPERATION or HOT STANDBY.

With con inment internal pressure a ove the limit, restore pressure to within t e limit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , orb in at least HOT SHUT WN within h r and in COLO SHUT within th owi h

3.6.4 Two 1 dependent containment hydro en recombiners shall b OPERABLE when the lant is in POWER OPERATION o HOT STANDBY.

With on recombiner inop rable, restore the inoperabl recombiner to OPERABL status within 30 a s or be in at least HOT SH TDOWN within the next hour 3.6.5 Th containment purge exhaust a air room supply isola ion valves shall be locked closed whenever the p ant is above COLD* SHUT WN.

With one co tainment purge exhaust or ai room supply isolation alve not locked c osed, lock the valve closed thin 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in a least HOT S ANDBY within the next 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN w thin the erfonn

~.

fl.A I !i.fD.,3 -l/.

3.6 3.6.00) 3.6.2 J.6.3 3.6.4 l.L,oJ.i..J ~

-~

(A~~ Ccrun A /Jot!)

and 1.0 psig when in POWER OPE With containment internal pres re above the limit, r tore pressure t within the limit within 1 hou, or be in at least HO SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD HUTDOWN within the fo owing 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

({Al

~-lo.j-2, u.t~~.!,plu.......-::-__:.i::r-::;:~-:;--=:rl'.i,~~ir~71~'

.... ~,

~

...... }pc~~=.5~o.r::--;-;;a---;:i:-;--~-- ff1. 6

ATTACI'ENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.1, CONTAINMENT A. 7 (continued)

These changes are all considered to be administrative in that there is no significant impact to operation of the plant and they reflect the terminology and usage rules of p, 111 3.lP*l-1 NUREG-1432.

~,A8 Nr?.Jw l S<c. W~1' f~.. r-r1

,, /'IA.q tJew

~

'1i.i. * \\"',_

MORE RESTRICTIVE CHANGES (M)

There were ft6 "More &estristive" ~b.a:ag@s mafll} ia ~f>esifis~iens 3. 6.1.

rt\\. I s cc. -:r:,..,Jm. r LESS RESTRICTIVE-REMOVAL OF DETAILS TO LICENSEE CONTROLLED DOCUMENT (LA),

LA.1

~al~

RPri 3.(,.1-5 "tion of CONTAINME T INTEGRITY, part (b) tes "The equipment ha h is properly closed an sealed." Proposed ITS 3..1 requires that the containment e OPERABLE. The B es defines what is require to make the containme OPERABLE. Therefo e, specific discussions of closure status of the e ui me hatch will be containe the Bases. Changes to the Bases will be made in

accordance with the Bases Control Program as discussed in TS Chapter 5.0, Administrative Controls. This change maintains consistency with NUREG-1432.

LA.2 CTS 4.5.2d(l)(a) whic addresses in part the Test Frequency for Loe Leak Detection Tests states "The co inment equipment hatch and the fuel transfer be shall be tested at each refueling o ge or after each* time used, if that be sooner." In the proposed

~

ITS the progr.

ic re*quirements fof).containment leak rate tesf g is found in the Gontainment Rate Testing Program which is-<.mntained in*

Chapter 5.0, Administrativ Cont:ffM&. The particular details of how and w n the testing is performed i ound in the plant document which implements Fam. This is acceptable mce the programmatic requirements and accepta ce criteria are found in the

- TS Ad. * "strative Controls section as discussed above. C anges to the plant proced es will be made in. accordance with the plant pro edure change process. This chan maintains consistency with NUREG-1432.

Palisades Nuclear Plant Page 4of6 01/20/98

+-J

3.6.1 DOC A.9 3.6.2 DOC A.15 3.6.3 DOC A.16 CTS 3.6.la requires that Containment Integrity be maintained "when the plant is above Cold Shutdown. In the ITS, this statement is equivalent to an Applicability of Modes 1, 2, 3, and 4 since the CTS definition of Cold Shutdown is essentially the same as the ITS definition of Mode 5. That is, each represents a plant condition at which the average temperature of the primary coolant is below its boiling point at one standard atmosphere. From an analytical perspective, there is no significant difference between the CTS value of 210°F and the ITS value of 200°F for the upper temperature limit in Mode 5. Therefore, replacing the CTS phrase "when the plant is above Cold Shutdown" with an Applicability of "Mode 1, 2, 3, and 4" is considered to be Administrative in nature. This change is consistent with NUREG-1432.

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS rV\\\\

~.t,p.\\* \\

A.12 The proposed ITS includes two Notes in SR 3.6.2.1. The second Note states "Results A.13

~p,\\

"l..16*1*1 A 4

-;;)

. \\

shall be evaluated against acceptance criteria of tAi C~Rtainmeat ls~ak Rate Testiftg Sp, ~.L,./.~

PFagfftffi: in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions." CTS 4.5.2c(2) starts out by stating "If at any time it is determined that total containment leakage exceeds La.... " This implies that the air lock leakage, as well as any other containment leakage, is always compared against the overall containment leakage requirements. Therefore, the addition of this note is an administrative change to provide a reminder to compare the test results against the overall containment leakage limit. This change is consistent with NUREG-1432.

CTS 4.5.2c(3) states "if ir lock door seal leakage is gr ter than 0.023 La.... " In e proposed ITS this beco

es Condition A which states " ne or more containment a*

locks with one contai ent air lock door inoperable.' The CTS air lock door se leakage limit of 0.0 La is specified in"the propos Cl ITS ~ontainment Leak Ra Test program. Therefi e, the Condition A only refer o the door being inoperable. The words "One or ore" are added in the propose ITS to cfarify which Conditi should be entered if o e door in each air lock is inop able. This is acceptable sin the overall con

ent leakage must still rema* within the limits of LCO 3.6 Note 4. T fse chan es are consistent wi UREG-1432.

Palisades Nuclear Plant Page 5of11 01/20/98

~-f

3.6.1 DOC A.9 3.6.2 DOC A.15 3.6.3 DOC A.16 CTS 3.6.la requires that Containment Integrity be maintained "when the plant is above Cold Shutdown. In the ITS, this statement is equivalent to an Applicability of Modes 1, 2, 3, and 4 since the CTS definition of Cold Shutdown is essentially the same as the ITS definition of Mode 5. That is, each represents a plant condition at which the average temperature of the primary coolant is below its boiling point at one standard atmosphere. From an analytical perspective, there is no significant difference between the CTS value of 210°F and the ITS value of 200°F for the upper temperature limit in Mode 5. Therefore, replacing the CTS phrase "when the plant is above Cold Shutdown" with an Applicability of "Mode 1, 2, 3, and 4" is considered to be Administrative in nature. This change is consistent with NUREG-1432.

ATTACHMENT 3 DISCUSSION O:F CHANGES SPECIFICATION 3.6.3, CONTAINMENT ISOLATION VALVES

~~~~~~~~~~~~

A.15 The proposed ITS includes notes in proposed Required Action A.2 and D.2 which state "Isolation devices in high radiation areas may be verified by use of administrative means." __ This allowance minimizes personnel exposure and recognizes that high radiation areas are usually restricted such that the probability of misalignment of the valves is very small. This change is considered to be administrative in that it clarifies that the verification required by Required Action A.2 and D.2 may be performed by administrative means. The verification requirement still exists but the Note allows special provisions for high radiation areas to minimize.personnel exposure while still keeping track of the containment isolation valve's status. This change is consistent with NUREG-1432.

A.r1,.Jr..w Sc.<-

1rJHe.\\

fl.if+ l 3.b, 1-i_

S-~.ltllS r./tt

~A I.?.l-~* 3 -3 S<-~ 1 AJS l.(\\ Rr+ t 3.<,. 3 *5 Palisades Nuclear Plant Page 6of10 01/20/98

3.6.1 DOC A.9 3.6.2 DOC A.15 3.6.3 DOC A.16 CTS 3.6.la requires that Containment Integrity be maintained "when the plant is above Cold Shutdown. In the ITS, this statement is equivalent to an Applicability of Modes 1, 2, 3, and 4 since the CTS definition of Cold Shutdown is essentially the same as the ITS definition of Mode 5. That is, each represents a plant condition at which the average temperature of the primary coolant is below its boiling point at one standard atmosphere. From an analytical perspective, there is no significant difference between the CTS value of 210°F and the ITS value of 200°F for the upper temperature limit in Mode 5. Therefore, replacing the CTS phrase "when the plant is above Cold Shutdown" with an Applicability of "Mode 1, 2, 3, and 4" is considered to be Administrative in nature. This change is consistent with NUREG-1432.

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

3.6.1-3 DOC A.4 CTS 3.6.1.c STS LCO 3.9.4 ITS 3.6.1 APPLICABILITY and Associated Bases CTS 3.6.1.c requires CONTAINMENT INTEGRITY be maintained when positive reactivity changes are made by boron dilution or control rod motion. DOC A.4 provides a discussion with regards to CONTAINMENT INTEGRITY and SHUTDOWN MARGIN specified in ITS LCO 3.1.1 and 3.9.1 in MODES 5 and 6. As states in ITS B 3.6.1 Bases - APPLICABILITY, the containment is not required to be OPERABLE in MODES 5 or 6 except as specified in ITS LCO 3.9.3. As such, the discussion in DOC A.4 is incorrect. Because containment OPERABILITY is not required in MODE 5, the requirements specified in CTS 3.6.1.c is deleted which would make the change a Less Restrictive (L) change. For MODE 6 Containment OPERABILITY is limited to the APPLICABILITY associated with ITS LCO 3.9.3, thus the change associated with CTS 3.6.1.c with regards to ITS 3.6.1 is an Administrative change moving this requirement to ITS 3.9.3. The staff considers the overall change to be a Less Restrictive (L) change.

Comment:

Revise the CTS markup and provide a discussion and justification for the Less Restrictive (L) change.

Consumers Energv Response:

A new DOC (L.2) has been provided to justify deletion of the CTS requirement to maintain containment integrity when the plant is in Cold Shutdown and reactivity changes are being made by boron dilution or control rod motion.

Affected Submittal Pages:

Att 3, CTS page 3-40 (1 of 8)

Att 3, DOC 3.6.1, page 6 of 6 Att 4, NSHC 3.6.1, page 2 of 2 5

3.6 Le.a 3.6.1 Aeel:c.~b:l:t.'.'l

. 6.2 3.6.4 3.6.5 CONTAINMENT SYSTEM{V R~t.1-'2..

CONTAINMENT ~NJEGRiffi shall.~e /ma}6ta1'17ed*lt--

lC'.l?i=e.AiLE" 1 /@ f\\,q I) *

©

~hen the plant is laboie. COLD/SHUTDOflNl jil\\ Mo-oi"S 111,L..--Ji+I ~ (S-... lu)

~ \\:"

~.1..2./

b.

When the reaci<)r vessel head is r. moved (unless the CS boron

~~f.1"-

concentratiQJ( is at REFUELING B ON CONCENTRATION and l/

c.

When posit ve reactivity ch nges are made b boron dilution or

~

CONTROL D motion (except for testing one ONTROL ROD at a time A

r.=::=---~~-:-----~~~~~~~~

ACTION:

L* z.

With one or more c tainment isolation valves in erable (including RPll ~.b.I*~

during perfonaanc of valve testing), maintain t ~st-one isolation valve OPERABLE each affected penetration t t is open and either:

a.

LE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ; or

b.

Isol te each affected penetration thin 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months by use of at least on closed and deactivated automa c valve, closed* manual valve, or ind flange; or Be in at least HOT SHUTDOWN thin the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the follow 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

The containment ternal pressure shall not exceed:.

a.

1.5 psig hen above COLD SHUTDOWN. and below HOT*

b.

1.0 p g when in_POWER.OPERATJON_or HOT STAN Y.

With co ainment internal pressure above the l it, restore pressure to withi the limit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , or be in at l ast HOT SHUTDOWN within the xt 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and 1 n COLD SHUTDOWN wi tM the fo 11 owi n 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

The containment a erage air temperature shalf not exceed 14 when the plant is above LD SHUTDOWN~ With containment average ai temperature above the limi, restore temperature to within the limit ithin 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , or be in at l ast HOT SHUTDOWN within the; next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

d. in COLD wi in the followin 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .*

3-40 e J,{..1 s-~

Amendment No. ~' ~,

'Pi:.~ 1... ~ ~

L.1 (continued)

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.1, CONTAINMENT CTS 4.5.2.c(l) specifies actions. to be taken if.60 La is exceeded for Local Leak Detection Tests. The actions in 4.5.2.c(l) to initiate repairs immediately and shut down if the acceptance criteria of 4.5.2.b(l) is not met (ensuring total leakage from all penetrations and isolation valves shall not exceed.60 La) wi 1 no longer a 1. In the

roposed I

, the acceptance er ena an testmg requenc).; ill only exist in the ontainmen Leak Rate Tesf Program which is found

TS Administrative Control ection 5.5 14. This is simi r,.!;to~th~e:...:C~T,:;.;S~C~o~nta~inm~e~..o:~o6Mtlollt...~~......i.Ml!:.o-~..,.

Palisades Nuclear Plant ll.J<.eef'i durin0 tl\\-t. +irs.f 1.m1f s+o.r+vP toLJ..ow1na tts+in~

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/fl a.c.c.otda.l"\\c.(. w 1 +H

/() CP.I... s 0 J Atp~J,y ~

Page 6 of 6 01/20/98

.5-}J

DOC 3.6.1 L.2 CTS 3.6.lc requires Containment Integrity be maintained "when positive reactivity changes are made by boron dilution or control rod motion (except for testing one control rod at a time). " In the ITS, containment integrity is ensured by operating the plant within the limits established in LCO 3.6.1, "Containment", LCO 3.6.2, "Containment Air Locks", and LCO 3. 6. 3, "Containment Isolation Valves." The Applicability for these specifications is Modes 1, 2, 3, and 4. The ITS contains no requirement equivalent to containment integrity in Mode 5, and only a less stringent requirement in Mode 6 referred to as containment closure (LCO 3.9.3, "Containment Penetrations") which is only applicable during Core Alteration or movement of irradiated fuel in the containment. As such, the requirement to maintain containment integrity in the ITS is less restrictive than the requirement in the CTS since the ITS would allow positive reactivity changes and control rod motion in Modes 5 or 6. This change is acceptable since in Modes 5 and 6, the probability and consequences of an event which would required containment integrity is reduced due to the pressure and temperature limitations in these Modes. Furthermore, by definition Mode 5 requires the reactor to be shutdown (subcritical) by > 1 % ti k/k. In addition, ITS 3.1.1, "Shutdown Margin (SDM)"

requires SDM be~ 2%. In Mode 6 ITS 3.9.1, "Boron Concentration" requires sufficient boron concentration to maintain the reactor subcritical by~ 5% lip with all control rods withdrawn.

These requirements ensure that reactivity changes from boron dilutions or control rod motion can be made without approaching a condition (criticality) in which containment integrity would be needed. This change is consistent with NUREG-1432.

5-c__

ATTACH1\\.1ENT 4 NO SIGNIFICANT HAZARDS CONSIDERATION SPECIFICATION 3.6.l, CONTAINMENT

1.

Does the change involve a significant increase in the probability or consequence of an accident previously eval~ated?

The proposed change increases the acceptance criteria for Type B and C tests from

.60 La to 1.0 La for the total containment leakage. Previously the.60 La for Type B and C tests acted as a "trigger point" to ensure actions were taken such that the overau **

acceptance criteria of 1.0 La were not violated. In addition the actions to initiate immediate repairs are not required unless total containment leakage exceeds 1.0 La.

The 1.0 La limit for total containment leakage remains in the proposed ITS. Any leakage from Type B and C tests which would put total containment leakage over 1.0 La must still be evaluated. Therefore, there is no significant increase* in the probability or consequences of an accident previously evaluated.

2.

Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change does not involve a physical alteration of the plant. No new or different type of equipment will be installed or changes made to plant parameters which govern normal plant operation. The proposed change will continue to ensure total containment leakage is monitored to ensure that it stays within the bounds of the analysis.

Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does this change involve a significant reduction in a margin of safety?

The proposed change preserves the total containment leakage rate of 1.0 La but does not require actions to be ~en once the Type B and C tests exceed.60 La as long as the contribution of the Type B and C tests do not make the total containment leakage to exceed 1.0 La. Therefore, this change does not involve a significant reduction in a margin of safety.

Palisades Nuclear Plant Page 2 of 2 01/20/98 5-d

NSHC 3.6.1 L-2 CTS 3.6.1 c requires Containment Integrity be maintained "when positive reactivity changes are made by boron dilution or control rod motion (except for testing one control rod at a time)." In the ITS, containment integrity is ensured by operating the plant within the limits established in LCO 3.6.1, "Containment, LCO 3.6.2, "Containment Air Locks", and LCO 3.6.3, "Containment Isolation Valves." The Applicability for these specifications is Modes 1, 2, 3, and 4. The ITS contains no requirement equivalent to containment integrity in Mode 5, and only a less stringent requirement in Mode 6 referred to as containment closure (LCO 3.9.3, "Containment Penetrations") which is only applicable during Core Alteration or movement of irradiated fuel in the containment. As such, the requirement to maintain containment integrity in the iTS is less restrictive than the requirement in the CTS since the ITS would allow positive reactivity changes and control rod motion in Modes 5 or 6. This change is acceptable since in Modes 5 and 6, the probability and consequences of an event which would required containment integrity is reduced due to the pressure and temperature limitations in these Modes. Furthermore, in Mode 5 ITS 3.1.1, "Shutdown Margin (SDM)" requires SDM be~ 2%, and in Mode 6 ITS 3.9.1, "Boron Concentration" requires sufficient boron concentration to maintain the reactor subcritical by

~ 5% Llp with all control rods withdrawn. Thus, reactivity changes from boron dilutions or control rod motion can be made without approaching a condition (criticality) in which containment integrity would be needed. This change is consistent with NUREG-1432.

1.

Does the change involve a significant increase in the probability or consequence of an accident previously evaluated?

2.

Analyzed events are assumed to be initiated by the failure of plant structures, systems or components. The proposed change relaxes the plant conditions in which containment integrity must be maintained. This change does not alter any accident precursors or initiators and thereby does not involve a significant increase in the probability of an accident previously evaluated.

The consequences of a p~eviously analyzed event are dependent on the initial conditions assumed for the analysis, and the availability and successful functioning of the equipment assumed to operate in response to the analyzed event, and the setpoints at which these actions are initiated. The proposed change does not alter the initial assumptions of any accident analysis, or alter the design assumptions of any system or component relied upon to function in the event of an accident. Therefore, this change does not involve a significant increase in the consequence of an accident previously evaluated.

Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change does not involve a p.J;iysical alteration of the plant. No new equipment is being introduced, and no installed equipment is being operated in a new or different manner. The proposed change only relaxes an administrative requirement associated with containment integrity. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does -this change involve a significant reduction in a margin of safety?

The margin of safety is determined by the design and qualification of plant equipment, the operation of the plant within analyzed limits, and the point at which protective or mitigative actions are initiated. The proposed change eliminates the requirement to maintain containment integrity during reactivity changes from boron dilutions or control rod motion while the plant is in Modes 5 or 6. The purpose of maintaining containment integrity is to prevent the uncontrolled release of radioactive material to the environment in the event of an accident that is capable of generating elevated temperature or pressure changes in the containment atmosphere. Controlled reactivity changes from boron dilutions or control rod motion in Mode 5 or 6 are not events that would directly result in elevated temperatures and pressures in the containment atmosphere. As such, containment integrity is not needed during these evolutions. Therefore, relaxing the requirement to maintain containment integrity in Mode 5 and 6 does not involve a significant reduction in a margin of safety.

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

3.6.1-4 DOCA.6 CTS 3.0.3 CTS 3.6.1.a CTS 4.5.4 CTS 4.5.5 CTS 4.5.6 ITS 3.6.1 ACTIONS ITS SR 3.6.1.2 ITS5.5 CTS 4.5.4, 4.5.5, and 4.5.6 specify surveillance tests which are required to be performed for containment structural integrity. The proposed ITS has included these tests into a Containment Structural Integrity Surveillance Program in ITS 5.5. The replacement of these SRS by ITS SR 3.6.1.2, the movement of the details of these CTS SRs to ITS 5.5, and the justification provided for these changes - (DOC A.6) is acceptable. However, the CTS markup does not show the addition of ITS 3.6.1 ACTIONS that are associate with ITS SR 3.6.1.2. A failure of these CTS requirements would require entry into CTS 3.0.3. In addition, if containment integrity cannot be maintained for reasons other than leakage or inoperable containment isolation valves, then CTS 3.0.3 is entered. Thus, the associated ITS ACTIONS would be considered as a minimum an Administrative change.

Comment:

Revise the CTS markup to show the addition of ITS 3.6.1 ACTIONS with regards to the failure of CTS 4.5.4, 4.5.5 and 4.5.6. Provide the appropriate discussions and justifications for this change.

Consumers Energy Response:

A new DOC (M.1) has been provided and the CTS markup pages revised to justify the addition of ITS 3.6.1 Actions with regards to the failure to meet the containment structural integrity surveillance requirements.

Affected Submittal Pages:

Att 3, CTS page 4-21 a (3.6.1, page 6 of 8)

Att 3, DOC 3.6.1, page 4 of 6 6

/Ab.D. ?:,.to.I ACTlbtVS.~ ~

\\-to~ SR 3.(Q, f.2_

/ e0 c-:~-------:-~-.---.--.--.-~~~~~~~H~ ~~

5"R J.~.. \\.1..

Ve--~ c..o~........... < s+.-....-~--

... +e..r-~+-1 :....

......c..... k,.. ~ "':""-.. ~

F.. ~,

'""-===:;;;;:;~~G.,,.:~~~:.....

~-~~;-r:t"'=Sf=r~=+v=.r;=o..\\=J:=,.,=+=e=~"::'.lc='1=S=u.=r=~e=*,\\\\=.:a<ee==\\)=r=o1~i;:A~ll"-~,=====::::-.

.... ~...J c

"':~#-c..

4.5 CONTAINf1ENT TESTS C--~.. ~... -~

H ;"-'= tiu*11.l 4.5.4

i.

Tendon inspe t1on shall bt accomplished at five year interv1ls for the life of he plant. The scheduled inspect1o dates for all subsequent nspect1ons may be varied by not mo than plus or minus ont ye1r fr

tht bast schedule.

b.

The surve1 lance tendons shall bt randomly bu representatively selected f Oii each of tht following groups:.

c.

1.

A mi illUll of 4 dOlll tendons including o 1 from each dome tend n group.

2.

A *i 1.ua of 4 vertical tendons.

3.

A

nimu11 of S hoop tendons.

For eac 1nsptct1on~ tht tendons shall bt 11cted on a random basis 1 c1pt that tho SI tendons who st rout ng has b11n mod1.f 1 ed to clear p nitrations shall bt excluded frOll ht SlllPl*.

During each t1ndon 1nsptct1on, tht follow ng field testing shall be p1rf o

1.

4.

5.

1ft-off readings shall be tak1n fo each of tht surveillance 1ndons. The tests shall include

following actions:

Ont tendon, randoaly selected fro11 each group of tendons during tach inspection; shal be subj1cted to essentially cQ11Plet1 d1t1nsioning to 1de ttfy broken or damaged wires.

(b) Tht simultaneous *asur... n* of 1long1tton and jacking force during r1t1ns1on1ng all bt a1dt at 1 minimWI of thr1t approxiaat1ly 1qu1ll spaced levels of force between th* s11ttn9 force nd 11ro.

Whil1 th* tendon ts in tht dtt nsioned state, 11ch wtrt in the tendon *ill be checked for con inutty.

Thrte *trt1, ont froll 1ach of a vertical, a hoop and a domt t1ndon *ill bt r1110vld and 1 nttfttd for inspection. At each succ1ssiv1 surveillance, tht wires will be selected frOll different tendons.

Each of ht inspection wires r1110vtd will be visually inspected for t d1nc1 of corrosion or other d1l1t1rtous effects and s lts taken for laboratory testing.

Tht sheathing filler shall inspected visually for color and coverage and s19'1lts shall be obtained for laboratory testing.

Tendon anchorage hardware such as blaring plates, stressing washers, sh1*s and button 11ds shall bt visually inspected for evid1nc1 of corros~on or ther d1l1t1rious tfftcts.

"* Ao, ~. 174 October 31, 1996 J:,.1'.,jri-1'7 S..nlll!i\\\\:~('

Pl"'o1 r-a1"\\

A. 7 (continued)

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.1, CONTAINMENT These changes are all considered to be administrative in that there is no significant impact to operation of the plant and they reflect the terminology and usage rules of R Ptl ~.lP*I-'

NUREG-1432.

~A8 N~w

7. S<c. ~~1'

P..Pr'

/'IA.9 Ntw

~

'!.i. * \\.. ?-

MORE RESTRICTIVE CHANGES (M)

There were no "More Restrieti-vs" 6ha:ages maaG ia SflseifieatioHS 3. 6.1.

t.~\\-L/

f11. I S<c. t,..,.\\Dtl LESS RESTRICTIVE-REMOVAL OF DETAILS TO LICENSEE CONTROLLED DOCUMENT (LA)

LA.1

~u:r~

RAI 3.(,.1-5 In CTS 1.0 defi 0tion of CONTAINME T INTEGRITY, part (b) tes "The equipment ha h is properly closed an sealed." Proposed ITS 3..1 requires that the containment e OPERABLE. The B ses defines what is require to make the containme OPERABLE. Therefo e, specific discussions of closure status of the e ui me hatch will be containe the Bases. Changes to the Bases will be made in

accordance with the Bases Control Program as discussed in TS Chapter 5.0, Administrative Controls. This change maintains consistency with NUREG-1432.

LA.2 CTS 4.5.2d(l)(a) whic addresses in part the Test Frequency for Loe Leak Detection Tests states "The co inment equipment hatch and the fuel transfer be shall be tested at each refueling o ge or after each time used, if that be sooner." In the proposed

--? ITS the progra ic requirements fo~.containment leak rate test* g is found in*the Gontainment Rate Testing Program whichis-cent-ained*in Chapter 5.0, Administrativ Contf91&. The particular details of how and w n the testing is performed i ound in the plant document which implements ram. This is acceptable mce the programmatic requirements and accepta ce criteria are found in the

TS A. * *strative Controls section as discussed above. C anges to the plant proced es will be made in accordance with the plant pro edure change process. This chan maintains consistency with NUREG-1432.

Palisades Nuclear Plant Page 4 of 6 01/20/98

&-b

3.6.1 DOC M.1 CTS 4.5.4, CTS 4.5.5 and CTS 4.5.6 specify the tests, inspections, frequencies and acceptance criteria necessary to ensure the structural integrity of the containment is maintained. Although not explicitly stated, failure to meet these surveillance requirements would result in the containment being declared inoperable (in accordance with CTS 3.6) since containment integrity could no longer be assured. Since the CTS does not contain an explicit Action Statement for an inoperable containment, the plant must be placed in at least Cold Shutdown within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months . In the ITS, periodic verification of containment structural integrity is required by SR 3.6.1.2. Upon failure to meet the requirements of SR 3.6.1.2, Required Actions A and B ofITS 3.6.1 would require the plant to be placed in Mode 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The addition of explicit actions in the ITS to address the failure to meet the containment structural integrity surveillances has been characterized as more restrictive since it requires the plant to be placed in Mode 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , versus the 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months allowed in the CTS to reach Cold Shutdown. This change is consistent with NUREG-1432.

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

3.6.1-5 DOC LA.1 CTS 1.0 CONTAINMENT INTEGRITY ITS B 3.6.1 Bases - BACKGROUND The CTS markup of CTS 1.0 CONTAINMENT INTEGRITY and DOC LA.1 only relocates item b to ITS B 3.6.1 Bases. This is incorrect. While CTS 1.0 CONTAINMENT INTEGRITY items a, c, and d correctly show that these items are associated with or are the basis for the requirements in ITS 3.6.2 and 3.6.3, they are also relocated to ITS B 3.6.1 Bases - BACKGROUND, and should be included in DOC LA.1.

Comment:

Revise the CTS markup and DOC LA.1 to show that CTS 1.0 CONTAINMENT INTEGRITY items a, c, and d are also relocated to ITS B 3.6.1 Bases - BACKGROUND.

Consumers Energy Response:

Specification 3.6.1, DOC LA.1 has been revised to show that CTS 1.0, "Containment Integrity" items a, c, and d have been relocated to the Bases of ITS 3.6.1.

Affected Submittal Pages:

Att 3, CTS page 1-2 (3.6.1, page 2 of 8)

Att 3, DOC 3.6.1, page 4 of 6 7

1.0 s~:u.. 1.l (continued) 5' p=.:-.C-c.,J.;. -

TC:.. I

~

A C NNEL FUNCTIONAL TEST shall be the inje ion of a simulated signal i

o the channel to verify that it is OPE BLE, including any alarm and rip initiating function.

COLP SHUTDOWN The COLD SHUTDOWN condition shall e when the primary coolant SHUTDOWN BORON CONCENTRATION and.,. is less than 210°F.

a.

All nonau mat1c conh1nnient 1solat

n valves and blind closed PERABLE).

(t.;> _ The_uncontrolled containment leakage satisfies Specification~ j ~

CONTROL BOPS CONTROL RODS shall full-length shutdown and regulating rods.

~

- ~1 The COLR is the d ument that provides cycle specific parameter imits for the current load cycle. These cycle specific parameter imits shall be detenn ed for each reload cycle in accordance with Specification.6.5. Plant operation within these limits i addressed in individua Specifications.

DOSE E IVALENT 1*131 shall be that concentration o 1-131 (µCi/gm) whic alone would produce the same thyroid dose a the quantity and iso pie mixture of 1-131, 1-132, 1-133, 1-134 a 1-135 actually pr ent. The thyroid dose conversion.factors u d for this calculation*

s all be those listed in Table III of TID-1484, *calculation of istance Factors for Power and Test Reactor tes.*

1-2 Amendment No. ** 4i, 54, i+, '8,

, ~. m, w, ~. ~.

7- 0----

A.7 (continued)

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.1, CONTAINMENT These changes are all considered to be administrative in that there is no significant impact to operation of the plant and they reflect the terminology and usage rules of p., rr1 3.lP*l-'

NUREG-1432.

~.A8 Ne,w

~ S<c. ~~1

At.~.\\.. ?- /)~iRE ~~RICTIVE CHANGES (M)

There were ftO "More ReskictiN@" d~aag@& maa0 ia ~f>ecifieatiens 3. 6.1.

f11, I Sec. ~~Dtl LESS RESTRICTIVE-REMOVAL OF DETAILS TO LICENSEE CONTROLLED DOCUMENT (LA)

LA.1

!Mai~

AA/

3.(,.1-5 "tion of CONTAINME T INTEGRITY, part (b) tes "The equipment ha his properly closed an sealed." Proposed ITS 3.. 1 requires that the containment e OPERABLE. The B ses defines what is require to make the containme OPERABLE. Therefo, specific discussions of closure status of the e ui me hatch will be containe the Bases. Changes to the Bases will be made in accordance with the Bases Control Program as discussed in TS Chapter 5.0, Administrative Controls. This change maintains consistency with NUREG-1432.

LA.2 CTS 4.5.2d(l)(a) whic addresses in part the Test Frequency for Loe Leak Detection Tests states "The co inment equipment hatch and the fuel transfer be shall be tested at each refueling o ge or after each time used, if that be sooner." In the proposed

~

IT~ the progr ic requirements fo~.containment leak rate test' g is found in the Gontainrnent Rate Testing Program which is-contained* in*

Chapter 5.0, Administrativ Con~. The particular details of how and w n the testing is performed i ound in the plant document which implements ram. This is acceptable mce the programmatic requirements and accepta ce criteria are found in the

TS A

'strative Controls section as discussed above. C anges to the plant proced es _will be made in accordance with the plant pro edure change process. This chan maintains consistency with NUREG-1432.

Palisades Nuclear Plant Page 4 of 6 01/20/98 7~b j

3.6.1 DOC LA.1 In CTS 1.0, the definition of Containment Integrity addresses, in part, the status of: a) all nonautomatic containment isolation valves and blind flanges, b) the equipment hatch, c) containment air lock doors, and d) all automatic containment isolation valves. Proposed ITS 3.6.1 requires the containment be Operable. To be Operable, the containment and its associated penetrations must limit leakage to an acceptable limit. The Bases of ITS 3.6.1 describes the isolation devices for the containment penetrations that form part of the leak tight barrier. This includes all automatic and nonautomatic containment isolation valves, blind flanges, air locks, and the equipment hatch. Since the details of what constitutes containment integrity are adequately described in the Bases of ITS 3.6.1, a separate definition is no longer required.

7-~

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

3.6.1-6 DOC LA.4 JFD 3 CTS 4.5.2.a (4)(a)

STS B 3.6.1 Bases - BACKGROUND ITS B 3.6.1 Bases - BACKGROUND CTS 4.5.2.a(4)(a) states that the local leak rate shall be measured for containment penetrations that employ bellows. DOC LA.4 states that this item is relocated to the FSAR. Based on the definition of CONTAINMENT INTEGRITY in NUREG - 0212 CE-STS, Containment penetrations containing bellows fall under STS B 3.6.1 Bases - BACKGROUND, item d., pressurized sealing mechanisms associated with penetrations. ITS B 3.6.1 Bases - BACKGROUND deletes item d based on the justification (JFD 3) that it is not applicable to the facility. The staff believes based on the above discussion that STS B 3.6.1 Bases - BACKGROUND item d is applicable to Palisades.

Comment:

Revise the CTS/ITS markup and DOC LA.4 to show that CTS 4.5.2.a(4)(a) with regards to "bellows" is relocated to ITS B 3.6.1 Bases - BACKGROUND.

Consumers Energy Response:

CTS 4.5.2a(4) items (a) through (e) lists the type of components subjected to local leak rate testing. This list is not intended to describe each component type installed in the Palisades containment, rather it describes the types of component required to be leak tested in accordance with 10 CFR 50, Appendix J. Specifically, Appendix J, Section 11.G.1 includes containment penetrations whose design incorporates "piping penetrations fitted with expansion bellows". Although CTS 4.5.2a(4) item (a) lists "containment penetrations that employ... bellows", this feature is not part of the Palisade's containment design. As such, deletion of item "d" in the ISTS Bases Background section based on facility design (JFD 3) is appropriate.

As described in DOC LA.4, the component types listed in CTS 4.5.2a have been relocated to the FSAR. Placing this information in the FSAR is acceptable since this document can not revise the types of components required to be local leak rated tested (as specified by 10 CFR 50 Appendix J), without prior NRG approval.

Affected Submittal Pages:

No page changes.

8

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

3.6.1-7 DOC LA.4 JFD 6 CTS 4.5.2.a(4)(a)

ITS 3.6.3.5 and Associated Bases CTS 4.5.2.a(4)(a) states that the local leak rate shall be measured for containment penetrations that employ resilient seal gaskets. DOC LA.4 states that this item is relocated to the FSAR. It is assumed that the penetrations referred to in this CTS requirement also include the penetrations associated with the purge valves. Thus this item is not relocated but becomes ITS SR 3.6.3.5. See Comment Number 3.6.1-1.

Comment:

Revise the CTS markup to reflect the above discussion. See Comment Number 3.6.1-1.

Consumers Energy Response:

CTS 4.5.2a(4) and its subparagraphs were part of the initial Palisades License issued prior to the existence of Appendix J. Neither that requirement, nor Appendix J includes a six month test of valves with resilient seats. As discussed in the response to RAI 3.6.1-6, CTS 4.5.2a(4) simply lists the type of components required to be leak tested in accordance with 10 CFR 50, Appendix J. Thus, relocation of this information to the FSAR is acceptable.

The actual requirement for testing valves with resilient seals is CTS 4.2 Table 4.2.2, item 13 "Containment Purge and Ventilation Isolation Valves." Specifically, item 13b requires the performance of a leak rate test between these valves at least once every 6 months. That requirement has become SR 3.6.3.5 in the ITS. The requirement to test valves with resilient seats was added to the Palisades Technical Specifications by Amendment #90 on August 26, 1985. See response to RAI 3.6.3-29.

Affected Submittal Pafles:

No page changes.

9

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

3.6.1-8 DOC LA.4 JFD 6 CTS 4.5.2.a.(4)(d)

STS SR 3.6.1.3.11 and Associated Bases (NUREG 1434)

STS SR 3.6.1.3.14 and Associated Bases (NUREG 1433)

ITS SR 3.6.1.1 and Associated Bases CTS 4.5.2.a(4)(d) requires that the local leak rate test shall be measured for isolation valves on the testable fluid systems' lines penetrating the containment. DOC LA.4 states that this is being relocated to the FSAR. Based on Comment Number 3.6.1-1, this item involves Type Band C testing and thus cannot be relocated out of TS. In addition, it is indeterminate from the CTS and the ITS if these particular isolation valves require a hydrostatic leak rate test. In the development of NUREG-1432, a specific SR with regards to hydrostatically testing containment isolation valves for leakage was not included because the CEOG states that most units did not have any valves that were hydrostatically tested valves. This was not the case for the BWRs (NUREG 1433 and 1434), which had hydrostatically tested valves. In that case, STS

SR 3.6.1.3.11 (NUREG 1434) and STS SR 3.6.1.3.14 (NUREG 1433) were included in the NUREGs. Changes to the STS with regards to Option A versus Option B are covered by a letter from Mr. Christopher I. Grimes to Mr. David J. Modeen, NEI dated 11/2/95 and TSTF-52 as modified by the Staff. Neither document deleted or relocated those BWR SRS, but retained the SRS in a modified form. Thus, the Staff requires that CTS 4.5.2.a.(4)(d) be retained if these valves are hydrostatically leak tested. See Comment Numbers 3.6.1-1 and 3.6.3-1.

Comment:

Revise the CTS/ITS markups to show CTS 4.5.2.a(4)(d) as being retained as an SR in ITS 3.6.3. Provide additional discussions and justifications as necessary for this change.

See Comment Numbers 3.6.1-1 and 3.6.3-1.

Consumers Energy Response:

As stated in DOC LA.4, CTS 4.5.2a(4) parts (a) through (e) specify the types of components which are required to be leak te~ted. This listing is not intended to be a comprehensive list of all components leak tested at the Palisades plant, but simply reflects the type of components required to be leak tested in accordance with 10 CFR 50, Appendix J. That requirement is retained as ITS SR 3.6.1.1 The Palisades containment design does not include any fluid system penetrations that require a hydrostatic test. Thus, it is not necessary to include a specific surveillance requirement in the ITS to address valves that are hydrostatically tested.

Affected Submittal Pages:

No page changes.

10

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

3.6.1-9 DOC L.1 JFD 6 CTS 4.5.2.b (1)

CTS 4.5.2.c (1)

CTS 4.5.2.b(1) and 4.5.2.c (1) limits the total leakage from all penetrations and isolation valves to <0.6 La. DOC L.1 states that the CTS requirements for Type Band C leak rate testing are being revised such that the leakage limit is ~ 0.60 La. during the first plant startup following testing performed in accordance with the Containment Leak Rate Test Program. This is unacceptable. 1 O CFR 50 Appendix J Option A which applies to Palisades limits the Type B and C leakage limit during the first plant startup following testing performed in accordance with 10 CFR 50 Appendix J Option A to< 0.60La. See Comment Number 3.6.1-1.

Comment:

Revise the DOC to conform to 10 CFR 50 Appendix J Option A requirements.

See Comment Number 3.6.1-1.

Consumers Energy Response:

Specification 3.6.1 DOC L-1 has been revised to conform to 10 CFR 50, Appendix J, Option A.

Specifically, the limit for Type B and C leakage tests during the first plant startup following testing performed in accordance with 10 CFR 50, Appendix J, is stated as < 0.60 La.

Affected Submittal Pages:

See response to RAI 3.6.1-1 11

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JANUARY 26, 1999 REQUEST FOR ADDITIONAL INFORMATION.

SECTION 3.6, CONTAINMENT NRC REQUEST:

3.6.1-10 JFD 4 STS B 3.6.1 Bases - BACKGROUND ITS B 3.6.1 Bases - BACKGROUND The first sentence in STS B 3.6.1 Bases - BACKGROUND states that "The containment consists of the concrete Reactor Building (RB), its steel liner,... " ITS B 3.6.1 Bases -

BACKGROUND modifies this sentence by deleting the words "Reactor Building (RB)". The justification used (JFD 4) for this change states that the change reflects facility specific nomenclature, number, etc. The change results in the sentence being incomplete and not making sense.

Comment:

Delete this change or replace the STS words with plant specific nomenclature.

Consumers Energy Response:

The first sentence in the ITS 3.6.1 Bases Background section has been revised to form a complete sentence.

Affected Submittal Pages:

Att 2, ITS 3.6.1, page B 3.6.1-1 Att 5, NUREG 3.6.1, page B 3.6-1 12

Containment B 3.6.1 B 3.6 CONTAINMENT SYSTEMS B 3.6.1 Containment BASES BACKGROUND a..,...d SR a.fc>>,1.3

_ The ~ontainment is a reinforced concrete structure with a cylindrical wall, a flat foundation mat, and a shallow dome roof.

The foundation slab is reinforced.with conventional mild-steel reinforcing. The internal pressure loads on the base slab are resisted by both the external soil pressure and the strength of the reinforced concrete slab. The cylinder wall is prestressed with a post tensioning system in the vertical and horizontal directions. The dome roof is prestressed utilizing a three way post tensioning system.

The inside surface of the containment is lined with a carbon steel liner to ensure a high degree of leak tightness during operating and accident conditions.

The concrete structure is required for structural integrity of the containment under Design Basis Accident (DBA) conditions. The steel liner and its penetrations establish the leakage limiting boundary of the containment.

Maintaining the containment OPERABLE limits the leakage of fission product radioactivity from the containment to the environment.

SR 3.6.1.lJleakage rate requirements comply with 10 CFR 50, Appendix J, Option B for Type A tests and Option A for Type B and C tests, as modified by approved exemptions.

The isolation devices for the penetrations in the containment boundary are a part of the containment leak tight barrier. To maintain this leak tight barrier:

a.

All penetrations required to be closed during accident conditions are either:

1.

capable of being closed by an OPERABLE automatic containment isolation system, or Palisades Nuclear Plant B 3.6.1-1 01/20/98

Containment~

B 3.6.l B 3.6* CONTAINMENT SYSTEMS B 3.6.1 ContainmentlCAifuospherfc)

I BASES BACKGROUND Q.

The containment consists of URt concrete re tor bu' din f ~

~, its steel liAaF~ and the penetrations through this structure. The structure is designed to contain radiot~tive material that may be released from the reactor core following a Design Basis Accident (OBA).

Additionally, this structure provides shielding from the fission products that may be present in the conta-irunent atmosphere following accident conditions.

~:;:,,""~Jo.~*.~ s\\.. ~ ;s The containment is a reinforced concrete structure with a

~

l 11

,j...*

A Cylindrical Wall, a flat foundation mat.Jo and a ShallOW dome a)

,~;"'"\\-:....... <(

0

~_,.. _

""~1--__

r;...;o;..;:o.._f~

... [For codta1nmenti$ with ungrjjuted tendons.I the cyJinder 10 l"'r"':\\.l -$+eel r~:,r..~:.... ").

wall is prestressed with a post tensioning system in the 1

~

vertical and horizontal direction~~;the dome roof is lrL°'

-nu. :~~-n~~ frli!ss~~

prestressed utilizing a three way p'ifst tensioning system.

\\..'.:l 1....:.Js 0

..... -14 ba.s~. s\\o.b The inside surface of the containment is lined with a carbon steel liner to ensure *a high degree of leak tightness during i::.~,...,\\:s~J. ~ bo~ ~

operating and accident conditions'.

e,,..~r~ :.:>:\\ er.e>s.... rt_.

-~

Q The concrete'[R&l~ed for structural integrity of the I ~j,i o.."'~ i\\...L ;: \\-.. "4~.. f contiinment under OBA conditions. The steel 1 iner and its r

~

..+,

penetrations establish the leakage limiting boundary of the

~

'('~:~~ru.41: (..a,..t..f'*!

i i

h i

t OPERABLE 1. *t containment.

Ma nta ning t e conta nmen im1 s s\\~\\.

the leakage of fission product radioactivity from the containment to the env onment.

SR 3.6.1.1 leaka e rate 11::;1.

/ X 1 s l'I

'2.. / I ~

requ remen s comp y w1

, ppen x

, as ~

0..h"

"'.,I,IJ \\ *~

mod1f1ed by appr9ved xempt1ons.

> opt-;..... 'O ft.... "'Tire A +~s :

fi;'t 11..J 0 *.A p. ~, T.,,. 13..C...~,!~

\\V Rfi\\

j The isolation devices for the penetrations n t e

. ~.1.9.\\-

containment boundary are a part of the containment leak tight barrier. To maintain this leak tight barrier:

~@G j'fsJ

. \\

a.

All penetrations required to be closed durtng accident conditions are either:

1.

capable of being closed by an OPERABLE automatic containment isolation system, or (continued)

B 3.6-1

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

3.6.1-11 JFD9 JFD 2 (ITS 3.6.2)

ITS 3.6.1 and Associated Bases ITS B 3.6.2 Bases - C.1, C.2, and C.3 JFD 9 states that "A statement is added in the proposed ITS Bases for Actions C.1, C.2, and C.3.... " ITS 3.6.1 does not contain an ACTION C nor is JFD 9 indicated in the markup of ITS 3.6.1 and its associated Bases. Based on the wording of JFD 9, it appears to be related to a change to the Bases for ITS 3.6.2 ACTION C.1, C.2, and C.3. However, JFD 2 is referenced for this change.

Comment:

Revise ITS markup to correct this discrepancy.

Consumers Energy Response:

ISTS 3.6.1 JFD 9 has been deleted since that discussion was not related to any changes used in the development of the Bases for ITS 3.6.1. JFD 9 was intended to describe a change mad~

to the Bases of ITS 3.6.2 for Actions C.1, C.2, and C.3. Since the change to the Bases for ITS 3.6.2 simply provides additional clarification and does not alter the intent of the specification, it is adequately addressed by JFD 2.

Affected Submittal Pages:

Att 6, JFD 3.6.1, page 2 of 2 13

ATTAC1'ENT 6 JUSTIFICATION FOR DEVIATIONS SPECIFICATION 3.6.1, CONTAINMENT Change Discussion

7.

8.

10.

The proposed ITS includes a discussion of the Main Steam Line Break (MSLB) accidenno clarify the basis of the term "Pa" since the MSLB accident results in the maximum calculated containment pressure for the design basis accidents. However, as discussed in the Bases, the limiting accident from an offsite dose perspective (i.e.,

affected by containment leakage) is the Loss of Coolant Accident (LOCA). Therefore, the maximum calculated LOCA pressure will be the Pa pressure. The Pa provided in the Bases represents the analytical limit provided in the FSAR (currently 52.64 psig) rounded up to 53 psig.

The Palisades Nuclear Plant used Regulatory Guide 1.35 as a reference for the Containment Structural Ingerity Surveillance Program but does not fully commit to Regulatory Guide 1.35. Therefore, this reference is not included in the proposed ITS.

_J:./.pj. ~~

A statement is tided in the proposed IT as or Actions C. I, c.2, an

.3 o state "If the over containment leakage rate exc ds the limits of LCO 3.6.1, the Conditions f that LCO must be entered in ccordance with Actions Note 3 change is plant specific preference to h e a reminder that the limits of apply if e overall containment leakage

~te has been exceeded.

The Palisades Nuclear Plant is considered to be an "Atmospheric" containment. The heading titles referring to either "Atmospheric" or "Atmospheric and Dual" are deleted since they add no value to the usage of the plant specific Palisades Nuclear Plant Technical Specifications. In addition, the portions of NUREG-1432 which are provided for "dual" containments are not applicable to the Palisades Nuclear Plant.

Palisades Nuclear Plant Page 2 of 2 01/20/98 13-~

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

3.6.2 Containment Air Locks 3.6.2-1 DOC A.1 DOC A.12 DOC LA.2 DOC L.2 JFD 2 JFD 6 JFD 10 CTS 1.0, CONTAINMENT INTEGRITY Item e CTS 4.5.1 CTS 4.5.2.a (2)

CTS 4.5.2.a. (4).(b)

CTS 4.5.2.b (2)

CTS 4.5.2.b (3)

CTS 4.5.2.c (4)

CTS 4.5.2.d (1) (b)

STS SR 3.6.2.1 and Associated Bases ITS SR 3.6.2.1 and Associated Bases See Comment Numbers 3.6.1-1, 3.6.2-3, 3.6.2-18 and 3.6.2-19.

Comment:

See Comment Numbers 3.6.1-1, 3.6.2-3, 3.6.2-18, and 3.6.2-19.

Consumers Energy Response:

See response to RAI 3.6.1-1, 3.6.2-3, 3.6.2-18, and 3.6.2-19 Affected Submittal Pages:

No page changes.

14

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

3.6.2-2 DOC A.1 DOCA.7 CTS 3.6.1.a ITS 3.6.2 APPLICABILITY AND ASSOCIATED BASES See Comment Number 3.6.1-2.

Comment:

. See Comment Number 3.6.1-2.

Consumers Energy Response:

See response to RAI 3.6.1-2 Affected Submittal Pages:

No page changes.

15

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

3.6.2-3 DOC A.1 DOC A.13 JFD 6 CTS 4.5.2.c(3) and 4.5.2.c(4)

ITS 3.6.2 ACTION A and Band Associated Bases CTS 4.5.2.c(3) provides corrective action when the personnel air lock door seal leakage is above 0.023 La and less than 0.60La or the emergency Escape Lock door seal contact fails to meet its acceptance criterion. ITS 3.6.2 Action A includes these situations into a single Condition of when one or more air locks with one door are inoperable. ITS 3.6.2 Action A is acceptable; however, the technical basis provided as this being an editorial and an Administrative change is unacceptable. DOC A.1 justifies the editorial reformatting or rewording of the CTS 4.5.2.c(3) as being in the Containment Leak Rate Testing Program which is unacceptable (See Comment Numbers 3.6.1-1 and 3.6.2-1.) DOC A.13 describes the addition of the words "one or more" as clarification when this is a Less-Restrictive (L) change to permit continued operation if one Operable door can be closed in each air lock. CTS 4.5.2.c(3) does not permit more than one air lock to be inoperable; otherwise, this requires a plant shutdown per Specification 3.0.3. In addition, CTS 4.5.2.c(3), along with CTS 4.5.2.c(4) would allow both doors in the personnel air lock to exceed the seal leakage limit of 0.023La as long as the total leakage from one door did not exceed 0.60La. ITS 3.6.2 ACTIONS A and B are more restrictive than the CTS ACTIONS in this case.

Comment:

Revise the CTS markup and provide additional discussions and justifications to justify these changes. See Comment Numbers 3.6.1-1, and 3.6.2-1.

Consumers Energy Response:

All references to the Containment Leak Rate Testing Program as they pertain to Type B and C leak rate tests have been revised to reference 1 O CFR 50, Appendix J. This change and the affected ITS submittal pages were addressed in the response to RAI 3.6.1-1.

A new Less Restrictive change (DOC L.4) has been provided to justify the addition of the phrase "one or more" as it pertains to inoperable air lock doors addressed by ITS 3.6.2, Condition A. This change supersedes (deletes) DOC A.13 In addition, DOC L.4 also justifies the addition of ITS 3.6.2 Actions Note 2 which allows separate entry condition for each air lock.

This change supersedes (deletes) DOC A.4.

A new More Restrictive change (M.3) has been provided to justify deletion of the allowance to have two air lock doors with leakage in excess of their specified limit, but within 0.60 La for up to 7 days.

Affected Submittal Pages:

Att 3, CTS page 3-40 (ITS 3.6.2, page 1 of 5)

Att 3, CTS page 4-20 (ITS 3.6.2, page 4 of 5)

Att 3, DOC 3.6.2, page 2 of 11 Att 3, DOC 3.6.2, page 5 of 11 Att 3, DOC 3.6.2, page 7 of 11 Att 3, DOC 3.6.2, page 11 of 11 Att 4, NSHC 3.6.2, page 6 of 6 16

3. 6 CONTAINMENT svSTEH© A,*.-- Ll>(..1::.s of'E"~A-13L£ I ~

Lc.,o 3.6.~0NTAINMENT N GR Y shall be ma;ntained:*

~

Arel:c.~~:l:~

a.

When the plant is laboye **coLo jHuroowf!, j';... -t'\\-o-tlES--1.-z.-

11-... -J-'"{-.I

b.

c.

ACTION:

With one or e containment isolation valve inoperable (including dur1ng perfo ance of valve testing), maint n at.lent-one isolation valve OPE

.LE fo. each affected penetrati. that 1s open and either:

a.

Res re the inoperable valves to O RABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ;

b.

I olate each affected penetrati within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months by use of at ast ne closed and deactivated aut atic valve, cl~sed manual val e, blind flange; or within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

3.6.2 The contain nt internal pressure shal not exceed:

f.6.3 3.6.4 3.6.5

-~I

a.

1.5 p ig when above COLD SHUTDOW and below HOT STANDBY and

b.

ig when in POWER OPERATION or HOT STANDBY.

With con inment internal pressure a ove the limit, restore pressure to within t e limit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , orb in at least HOT SHUT WN within h rs and in COLD SHUTDO within th owi h

Two i dependent containment hydro en recombiners shall b OPERABLE when the lant is in POWER OPERATION o HOT STANDBY.

With on recombiner inop rable, restore the inoperabl recombiner to OPERABL status within 30 a s or be in at least HOT SH TDOWN within the next hours Th containment purge exhaust a air room supply isola ion valves shall be locked closed whenever the p ant is above COLD *SHUTD WN.

With one co tainment purge exhaust or ai room supply isolation alve not locked c osed, lock the valve closed thin 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in a least HOT S ANDBY within the next 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN w thin the erf orm LADD AC.Tio~ N<::>.\\E L. o..$

<( ~DO A<:.TICN

~O"T"E 1 c..~

5ee 3.1 *. lf)

R 1t t 3.fo./*)

~

CONTAINMENT lj1ijSj 5YST~M.S Local Lea@etection Test~ /('continued)} D

. SR 3.(o.'-.,/

- a.'

s~~ ~;./

th.

Sf.J ~.J..j

'C:

(fi.2 b *

(1) penetrations isolation valves (2)

The lea ge for a Personnel airlock doo exceed

. 023 L,.

(3). An a eptable Emergency Escape Airlo door seal contact check cons sts of a verification of conti ous contact between the seas and the sealing surfaces.

( c. /Correct1yfiAct1on) 1

exceeded, rn.~ k~Y<_

I. ~---~~----~~~__.;;.;;.....;;.;.;.;....;..;_----~----..;..;.;.,;.~_;_;;.;,;,,.;,.;,.-"-..;..;_;,;.;..;;.;~~

and in~1" Entry and exit is permissible through a "lockedlf air lock door to perfor11 repairs on the affected air lock components.

4-20 JU;-h 6hilA!je 7, Amendment No. ~. -t-74, ~.

A.4 A.5

..DVSLltT A.6 ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS n the proposed ITS/ ACTI ote is a e w lcliStates eparate condit10 entry is allowed for eacq/ air lock." This note allmefs the air locks to be tracked un r separate_ LCO cl~ks. This is an explana~ note to explicitly state how th CO racking shoulcybe accomplished. Previously in the CTS is was a matter interpretatiot This is considered an Jfi!ministrative change to explicit!

rovide guidance ol)'the use of LCO trac~. It is highly unlikely that both r locks would be inoperabi/at the same time giv<?Jf their limited use in MODES 1, 2 and 4. The equir Actions specify that4lle OPERABLE door must be clos a in one hour which

~nsur G~~:~ s~

_;~~*~~~-This-~~z:~~:.:th _I In the proposed ITS, ACTION Note 3 is added which states "Enter applicable Conditions and Required Actions of LCO 3.6.1 "Containment," when air lock leakage results in exceeding the overall containment leakage rate. " This note provi4e8 guidance in accordance with LCO 3.0.6 to specify when other TS should be. followed.

This note is considered to be administrative in nature in that it provides guidance on the use and application of the ITS where it wasn't explicitly addressed as part of the CTS. J These changes are consistent with NUREG-1432.

The CTS Section 1.0, Definitions, contains the definition for "CONTAINMENT INTEGRITY." As stated in Administrative Change A.3, proposed ITS 3.6.2 specifies the requirements for Containment Air Locks. The element of the CTS defined term CONTAINMENT INTEGRITY which relates to air locks is item (c) which states "At least one door in each air lock is properly closed and sealed." This statement forms the Required Actions A.l, B.l, and C.2 in the ACTIONS for Containment Air Locks which ensure that the Containment remains isolated. The CTS phrase "and sealed" is not included in the proposed ITS as it is implicit in the use of an "OPERABLE" door.

. This change is consistent with NUREG-1432.

Palisades Nuclear Plant Page 2of11 01/20/98 I&-~

~11 \\

A.12

~.(Q. \\* \\

A.13 A. \\4 ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS The proposed ITS includes two Notes in SR 3.6.2.1. The second Note states "Results shall be evaluated against acceptance criteria of tR.i CQRtailnneRt l.iak &ate Tes~iftg SA 3,L,./.~

PregFIHfl in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions." CTS 4.5.2c(2) starts out by stating "If at any time it is determined that total containment leakage exceeds La.... " This implies that the air lock leakage, as well as any other containment leakage, is always compared against the overall containment leakage requirements. Therefore, the addition of this note is an administrative change to provide a reminder to compare the test results against the overall containment leakage limit. This change is consistent with NUREG-1432.

__ A/of LIO? cl.

7

____,...._.,,.___~-~~---::--::-Jr--i CTS 4.5.2c(3) states "if.,air lock door seal leakage is gr ter than 0.023 La.... " In e proposed ITS this beco.. es Condition A which states " ne or more containment a*

locks with one conta' ent air loc_k door inoperable.' The CTS air lock door se leakage limit of 0.0 La is specified in"the propos tl ITS..f:ontainment Leak Ra Test program. There~ e, the Condition A only refer o the door being inoperable. The words "One or ore" are added in the propose ITS to clarify which Conditi should be entered if o e door in each air lock is inop able. This is acceptable sin the overall con

ent leakage must still rema* within the limits of LCO 3.6 Actions Note 4. T fse chan es are consistent wi UREG-1432.

Palisades Nuclear Plant Page 5of11 01/20/98

/l_p -d

M.2 ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS Proposed ITS 3.6.2 adds a Condition C which addresses the cases where one or more containment air locks are inoperable for reasons other than Condition A or B.

This would include situations such as both air lock doors inoperable at the same time.

The CTS does not specify requirements for air locks other than the door seals must be within leakage limits and the CTS definition of "Containment Integrity" requires that at least one door in each air lock is properly closed and sealed. If proposed Condition C is entered, Required Action (R.A.) A.l requires action to be initiated immediately to evaluate overall containment leakage rate per LCO 3.6.1, and a door must be verified closed in the affected air lock within one hour. If the limits of LCO 3.6.1 is entered, then the R.A.s and Completion Times are consistent with the shutdown required by CTS LCO 3.0.3. However, R:A. C.3 requires that the air lock be restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . These actions are equal to or more restrictive than any actions specified in the CTS for air lock inoperability. In particular, the requirement to restore the air lock to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is more restrictive than the CTS restoration times. Therefore, this is considered to be a more restrictive change. This change is consistent with NUREG-1432.

Palisades Nuclear Plant Page 7of11 01/20/98

3.6.2 DOC M.3 CTS 4.5.2c(3) provides the corrective actions "if the personnel air lock door seal leakage is

>0.023 La, or ifthe emergency escape (air) lock door seal contact check fails to meet its acceptance criterion." CTS 4.5.2c(3) allows both personnel air lock doors to exceed their specified leakage limit, or both emergency escape air lock doors to exceed their acceptance criterion for up to 7 days provided that leakage from one door does not cause the total containment leakage to exceed 0.60 La. CTS 4.5.2c( 4) provides the corrective actions if door seal leakage results in one door causing the total containment leakage to exceed 0.60 La. This specification does not limit the magnitude of the leakage rate provided one Operable door in the affected air lock is locked closed. CTS 4.5.2c(4) requires that repairs be initiated imffiediately and conformance with the specification established in 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . If at any time it is determined that containment leakage exceeds 0.60 La (e.g., from two inoperable doors in one air lock) but is

< 1.0 La, CTS 4.5.2c(l) requires that repairs be initiated immediately and conformance with the specification established in 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . In ITS 3.6.2, if both doors in an air lock are declared inoperable for failure to meet their surveillance requirement acceptance criteria (i.e., leakage for the personnel air lock, and seal contact for the emergency escape air lock), Condition C is entered. Provided the overall containment leakage limit does not exceed 1.0 La, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are provided to return one door to an Operable status. The Actions of the ITS are more restrictive than the CTS since they limit the time that two air lock doors can be inoperable due to excessive leakage. This additional restriction is appropriate since it limits the duration two air lock doors can be inoperable to a reasonable time for restoring one door to Operable status. This change is consistent with NUREG-1432.

/f!J-f

L.3 ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS x bo1"

~re_

The actions of CTS 4.5.2c have.been revised to allow en nd exiting of the bf ~1" X

containment when one door in~-containment air locks}\\( iloperable. Proposed 0..\\r ie<.1~

X ITS 3.6.2 Condition A, Required.Action Note 2 states that "entry and exit is (lr\\ 1f'ofQ1Qblc. y permissible for 7 days under administrative control.

This purpose of this Note is to allow ingress and egress through an Operable containment air lock door, that is required to be closed and locked to isolated the air lock penetration, to perform technical specification related and non-technical specification related activities -on equipment inside containment. The allowance is permitted for up to 7 days provided appropriate administrative controls are instituted. This allowance is acceptable due to the low probability of an event that could pressurize the containment during the short time that the Operable door is expected to be opened. This change is consistent with NUREG-1432.

RA* :,."*~:3 L. 4 tJe..w

~"'"' ~

t11t-r

Palisades Nuclear Plant Page 11of11 01/20/98

3.6.2 DOC LA CTS 4.5.2c(3) provides the corrective actions if the personnel air lock doors exceed their leakage limit, or the emergency air lock fails to meet its acceptance criterion for seal contact. In ITS 3.6.2, these same occurrences are addressed by Condition A which states "one or more containment air locks with one containment air lock door inoperable." ITS Condition A represents a relaxation from CTS 4.5.2c(3) since the ITS allows one inoperable door in the personnel air lock to exist concurrently with one inoperable door in the emergency air lock. The CTS does not address multiple air locks with inoperable doors. Thus, if multiple inoperabilities occurred, entry into LCO 3.0.3 would be required. In addition to allowing multiple inoperabilities, the ITS Actions for containment air locks are also modified by a Note which states" Separate Condition entry is allowed for each air lock." The addition of this Note allows separate Completion Time tracking for each Condition starting from the time of discovery of the situation that required entry into the specified Condition. The allowance to have one or more containment air locks with one containment door inoperable, and to permit separate condition entry for each inoperability is acceptable since the Operable door in each air lock ensures that a leak tight containment barrier is established and that the appropriate compensatory measures are taken to ensure the barrier (door) is maintained Operable. This change is consistent with NUREG-1432.

1&-A

3.

ATTACHMENT 4 NO SIGNIFICANT HAZARDS CONSIDERATION SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS Does this change involve a significant reduction in a margin of safety?

The proposed change allows the Operable locked closed air lock door, in an air lock with an fooperable door, to be opened briefly to facilitate entry and exit of containment. Except for the brief period the Operable door is opened to allow personnel to ingress and egress the air lock, the air lock is capable of performing its intended containment pressure boundary function. Opening the Operable door for a brief period has been found acceptable based on the extreme low probability of an event occurring that would challenge the containment pressure boundary while the door was opened. The proposed change reduces the potential for a plant transient resulting from a unnecessary plant shutdown due to component repairs or to perform technical specification related activities which require entry inside containment. As such, any reduction in a margin of safety during the brief period the Operable air lock door is opened is offset by the reduction in a potential plant transient. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

RA l 3.".2.-3 L, Lf

{V~w

sec. ~\\

Palisades Nuclear Plant Page 6 of 6 01/20/98 I u

-_A.,

3.6.2 NSHC L.4 CTS 4.5.2c(3) provides the corrective actions if the personnel air lock doors exceed their leakage limit, or the emergency air lock fails to meet its acceptance criterion for seal contact. In ITS 3.6.2, these same occurrences are addressed by Condition A which states "one or more containment air locks with one containment air lock door inoperable." ITS Condition A represents a relaxation from CTS 4.5.2c(3) since the ITS allows one inoperable door in the personnel air lock to exist concurrently with one inoperable door in the emergency air lock. The CTS does not address multiple air locks with inoperable doors. Thus, if multiple inoperabilities occurred, entry into LCO 3.0.3 would be required. In addition to allowing multiple inoperabilities, the ITS Actions for containment air locks are also modified by a Note which states" Separate Condition entry is allowed for each air lock." The addition of this Note allows separate Completion Time tracking for each Condition starting from the time of discovery of the situation that required entry into the specified Condition. The allowance to have one or more containment air locks with one containment door inoperable, and to permit separate condition entry for each inoperability is acceptable since the Operable door in each air lock ensures that a leak tight containment barrier is established and that the appropriate compensatory measures are taken to ensure the barrier (door) is maintained Operable. This change is consistent with NUREG-1432.

1.

Does the change involve a significant increase in the probability or consequence of an accident previously evaluated?

2.

Analyzed events are assumed to be initiated by the failure of plant structures, systems or components. The proposed change allows one personnel air lock door to be inoperable concurrent with one emergency air lock door, and allows separate completion time tracking for each inoperability. Entry into required action in the technical specifications and the method used to track completion times are not assumed to initiate any analyzed events. Therefore, the proposed change does not involve a significant increase in the probability of an accident.

The consequences of a previously analyzed event are dependent on the initial conditions assumed for the analysis, and the availability and successful functioning of the equipment assumed to operate in response to the analyzed event. The proposed change does not alter the assumed mitigatory function of the remaining Operable containment air lock door.

Thus, the consequence of an accident occurring during the time that one containment air lock door is inoperable is the same as the consequences for an,accident with multiple air lock doors inoperable. Therefore, the proposed change does not involve a significant increase in the consequences of an accident previously evaluated.

Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change does not involve a physical alteration of the plant. No new or different type of equipment will be installed or changes made to plant parameters which govern normal plant operation. The proposed change still ensures that an OPERABLE containment air lock door is closed. Thus, this. change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does.this change involve a significant reduction in a margin of safety?

The margin of safety is a function of the overall containment leakage. The proposed change allows one inoperable door in the personnel air lock to exist concurrently with one door in the emergency air lock and allows the completion time for each inoperability to be tracked separately. During the period when multiple inoperabilities exist, the remaining Operable door in each air lock continues to ensure that leakage from the containment atmosphere is within the limits assumed in the safety analysis.

As such, there is no increase in the amount of radioactive material released to the environment. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

/&-.f

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

3.6.2-4 DOC A.4 CTS 4.5.2.c ITS 3.6.2 ACTIONS Note 2 and Associated Bases CTS 4.5.2.c has been modified to add ITS 3.6.2 ACTIONS Note 2 which states "Separate Condition entry is allowed for each air lock." The CTS justifies this change as an Administrative change (DOC A.4). DOC A.4 states that "This is an explanatory note to explicitly state how the LCO tracking should-be accomplished. Previously in the CTS [th]is was a matter of interpretation." This statement provides insufficient information with regards to how the CTS is consistently interpreted in this area so that the staff can determine whether this change is Administrative, More Restrictive, or Less Restrictive (L). See Comment Number 3.6.2-5.

Comment:

Provide additional discussion and justification to show how Consumers Energy interprets the CTS with regards to this change. See Comment Number 3.6.2-5.

Consumers Energ,v Response:

Relative to containment air locks, CTS 4.5.2c only provides corrective actions when the personnel air lock door seal leakage is greater than its specified limit, or the emergency air lock seal contact check fails to meet its acceptance criteria. Upon discovery the air lock door acceptance criteria can not be met, the affected door is declared inoperable and the required actions initiated. Although the CTS does not address multiple inoperable air locks, it does address two doors in the same air lock with excessive leakage. If this event were to occur, Consumers Energy would consider the start of the allowed specified interval to begin with the first inoperability. The subsequent inoperability would not re-zero the clock. As such, the addition of the separate entry condition note in the ITS (Note 2) represents a relaxation from current plant practices. The justification for this change was included in the response to RAl-3.6.2-3.

Affected Submittal Pages:

No page changes.

17

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

3.6.2-5 DOC A.4 CTS 4.5.2.c ITS 3.6.2 ACTIONS Note 2 and Associated Bases CTS 4.5.2.c, Corrective Actions, has been modified to add ITS 3.6.2 ACTIONS Note 2 which states "Separate Condition entry is allowed for each air lock.". The CTS proposed change to separate condition entry for each air lock now permits concurrent inoperabilities in both air locks. DOC A.4 does not mention that each applicable ITS condition statement allows "one or more" air locks to be inoperable under the Required Actions stated in each condition. The CTS requirements only recognizes one inoperability at a time which must be restored to OPERABLE status within 7 days. When concurrent inoperabilities are encountered, there is no corrective (compensatory) actions provided other than following the rules for a CTS 3.0.3 plant shutdown.

The CTS change is acceptable under the proposed new ITS Required Actions; however, this is a Less Restrictive (L) change rather than an Administrative change.

Comment:

Revise the CTS markup and provide a discussion and justification for this Less Restrictive (L) change.

Consumers Energy Response:

See response to RAI 3.6.2-3 and RAI 3.6.2-4.

Affected Submittal Pages:

No page changes.

18

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

3.6.2-6 DOC A.5 CTS 4.5.2.c ITS 3.6.2 ACTIONS Note 3 and Associated Bases CTS 4.5.2.c has been modified to add ITS 3.6.2 ACTIONS Note 3 which states "Enter applicable Conditions and Required Actions of LCO 3.6.1 "Containment", when air lock leakage results in exceeding the overall containment leakage rate." DOC A.5 states that this Note provides guidance on use and application of the ITS where it wasn't explicitly addressed as part of the CTS. DOC A.5 only addresses the ITS aspects, application and interpretation of this Note and does not provide sufficient information with regards to how the CTS is consistently interpreted in this area so that the staff can determine whether this change is Administrative, More Restrictive, or Less Restrictive (L).

Comment:

Provide additional discussion and justification to show how Consumers Energy interprets the CTS with regards to this change.

Consumers Energy Response:

DOC A.5 has been revised to provide additional justification with regards to how the CTS is structured relative to containment air lock leakage limits and overall containment leakage limits.

Affected Submittal Pages:

Att 3, DOC 3.6.2, page 2 of 11 19

A.4 A.5

.D\\&!m A.6 ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS n the proposed ITSJ ACTION" Note 2 is aaded'wfiiCirStates eparate condit10 entry is allowed for eacq/~ir lock.... This note all°'s the air locks to be tracked un r separate_ LCO clgtks. This is an explana~ note to explicitly state how th CO racking shoulcy6e accomplished. Previously in the CTS is was a matter interpretatio~ This is considered an/dministrative change to explicit!

rovide guidance OQ.'.the use of LCO trackipg. It is highly unlikely that both r locks would be inoperabulat the same time give;{their limited use in MODES 1, 2 and 4. The equir Actions specify tha}.<the OPERABLE door must be clos a in one hour which ensur that the safety functfon is performed. This change is c.¢nsistent with N

G-1432.

-t.::..~-*~"--**"'~"-.. -~----------..:./:...---~~***-***-*~*-*-----

In the proposed ITS, ACTION Note 3 is added which states "Enter applicable Conditions and Required Actions of LCO 3.6.1 "Containment," when air lock leakage results in exceeding the overall containment leakage rate." This note provi4~

guidance in accordance with LCO 3.0.6 to specify when other TS should be followed.

This note is considered to be administrative in nature in that it provides guidance on the use and application of the ITS where it wasn't explicitly addressed as part of the CTS.1 These changes are consistent with NUREG-1432.

The CTS Section 1.0, Definitions, contains the definition for "CONTAINMENT INTEGRITY." As stated in Administrative Change A.3, proposed ITS 3.6.2 specifies the requirements for Containment Air Locks. The element of the CTS defined term CONTAINMENT INTEGRITY which relates to air locks is item (c) which states "At least one door in each air lock is properly closed and sealed." This statement forms the Required Actions A.l, B.l, and C.2 in the ACTIONS for Containment Air Locks which ensure that the Containment remains isolated. The CTS phrase "and sealed" is not included in the proposed ITS as it is implicit in the use of an "OPERABLE" door.

This change is consistent with NUREG-1432.

Palisades Nuclear Plant Page 2of11 01/20/98

1q-CJ_/

3.6.2 DOC A.5

... The intent ofITS 3.6.2 Action Note 3 is to provide guidance to the ITS user to take the appropriate Actions of Specification 3.6.1 when the containment leakage rate acceptance criteria is exceeded. Note 3 does not imply any additional requirements, but simply provides a cross-reference between two specifications. Thus, the addition of Note 3 can only be.

characterized as an "Administrative" change. The corresponding requirements in the CTS that would be cross-referenced are; CTS 4.5.2c(2) which requires that corrective actions be initiated "if at any time it is determined that the total containment leakage rate exceeds La", and CTS 4. 5.2d(1 )(b) which requires a full air lock penetration test. The inoperability of air lock doors due to excessive leakage are treated consistently between the ITS and CTS. That is, if one door is* declared inoperable due to excessive leakage, the remaining Operable door fulfills the containment isolation function. If both doors are inoperable due to excessive leakage, the total leakage must be evaluated against the overall containment leakage limit.

/9-h

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

3.6.2-7 DOC A.6 CTS 1.0 "CONTAINMENT INTEGRITY" Item c ITS 3.6.2 ACTIONS A, B, and C and Associated Bases CTS 1.0 "CONTAINMENT INTEGRITY" Item c requires "At least one door in each air lock is properly closed and sealed." The CTS markup shows the words "and sealed" as being deleted.

DOC A.6 states that the definition forms the basis for ITS 3.6.2 Required Actions A.1, B.1 and C.2. It further states that "The CTS phrase "and sealed" is not included in the proposed ITS as it is implicit in the use of an "OPERABLE" door." If this were the case, then the change is a Less Restrictive (LA) change rather than an Administrative change because OPERABILITY is defined in the Bases. However, "sealed" also connotes "locked". Thus the definition also forms the basis for ITS 3.6.2 Required Actions A.2 and B.2 which. requires the OPERABLE door to be locked closed. Thus "and sealed" should not be deleted. See Comment Number 3.6.2-8.

Comment:

Revise the CTS markup and provide additional discussion and justification for this change. See Comment Number 3.6.2-8.

Consumers Energy Response:

In the CTS and ITS the word "sealed" as it applies in the phrase "each air lock door is properly closed and sealed" means the door is closed tightly such that it restricts the leakage of air. It is not intended to connote "locked." The safety function of the containment air lock doors is to establish a leak tight isolation barrier in the containment air lock penetration. To perform this function, the air lock doors must be closed and sealed. Air lock doors are considered sealed when their leakage is within the specified acceptance criteria for individual air lock door seal tests, or when the overall air lock leakage rate is ~ 0.60 La when combined with all penetrations and valves subject to Type B and C tests and the tests have been performed within the specified surveillance interval. Thus, "closed and sealed" in both the CTS and ITS describe a condition that only relates to Operable containment air lock doors.

As stated in DOC A.6, the word "sealed" is implicit in the definition of an Operable air lock door.

The word "sealed" is not a detail relocated from a CTS requirement to a licensee controlled document and thus, was not characterized as a "Less Restrictive Administrative" (LA) change.

Rather, this change represents an editorial deletion of a word whose concept is inclusive in the ITS Section 1.0 definition of Operability. Accordingly, this change has been characterized as Administrative in nature since the actual word "sealed" has not been relocated.

Affected Submittal Pages:

No page changes.

20

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

3.6.2-8 DOC A.6 CTS 1.0 "CONTAINMENT INTEGRITY" Item c ITS 3.6.2 ACTIONS A, B, and C and Associated Bases CTS 1.0 "CONTAINMENT INTEGRITY" Item c requires "At least one door in each air lock is properly closed and sealed." DOC A.6 states that the definition forms the basis for ITS 3.6.2 Required Actions A.1, B.1, and C.2. Depending on the type of inoperability of the air lock door, the inoperable door could also meet this requirement of the definition. However, ITS 3.6.2 Required Actions A.1, A.2, B.1, B.2 and C.2 only apply to the OPERABLE door. This would be a More Restrictive change (limiting the actions to OPERABLE door only).

Comments:

Revise the CTS markup and provide additional discussion and justification for this More Restrictive change.

Consumers Energy Response:

See response to RAI 3.6.2-7 Affected Submittal Pages:

No page changes.

21

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

3.6.2-9 DOC A.8 DOC M.1 DOC L.1 CTS 4.5.2.c ITS 3.6.2 RA A.3 Note, RA B.3 Note and Associated Bases CTS 4.5.2.c is modified by the addition of ITS 3.6.2 RA A.3, and RA 8.3 Notes which state "Air lock doors in high radiation areas may be verified locked closed by administrative means."

DOC A.8 states that these Notes are added to clarify that the verification required by the Required Actions may be performed by administrative means and thus is considered as an Administrative change. Nothing in the CTS states that locked closed air lock doors are to be or can be verified locked closed by administrative means. Thus for RA A.3 the change would be considered as a Less Restrictive (L) change since the addition of RA A.3 is a Less Restrictive change (DOC L.1 ). For RA 8.3 the change is More Restrictive since the addition of ACTION B is a More Restrictive change (DOC M.1 ).

Comment:

Revise the CTS markup and provide additional discussions and justifications for these Less Restrictive (L) and More Restrictive changes.

Consumers Energy Response:

A new justification (DOC M.4) has been provided to address the addition of ITS Required Actions A.1, A.2, A.3, and the Note for Required Action A.3. DOC L.1 justified the deletion of the CTS corrective ac.tions to immediately initiate repairs and to complete the repairs within 7 days. The acceptability of this deletion was based on the compensatory measures provided by Required Actions A.1, A.2, and A.3. These compensatory measures represent additional restrictions on plant operations that were not previously justified. The Note for Required Action A.3 which allows air lock doors in high radiation areas to be verified by administrative means was inappropriately characterized as an Administrative change (DOC A.8) instead of a More Restrictive change. That error has been rectified by deleting DOC A.8 and justifying the change in DOC M.4.

The More Restrictive aspect of the Note for Required Action 8.3 which was also inappropriate characterized as an Administrative change by DOC A.8, has been incorporated in a revised version of DOC M.1:

Affected Submittal Pages:

Att 3, CTS page 4-20 (ITS 3.6.2, page 4 of 5)

Att 3, DOC 3.6.2, page 3 of 11 Att 3, DOC 3.6.2, page 6 of 11 Att 3, DOC 3.6.2, page 7 of 11 22

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The lea ge for a Personnel airlock doo e~ceed. 023 L,.

(3)

An a eptable Emergency Escape Airlo door seal contact check cons sts of a verification of conti ous contact between the seas and the sealing surfaces.

Entry and exit is permissible through a "locked" air lock door to perfona repairs on the affected air lock components.

4-20 CONTAINMENT TSCR 6RaR~e 7, REV Z Amendment No. -t-ai, -t-74, -t-7+,

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A.7 A.8 AAI 3.to.i*9 RA' 3.{g.1. wf 0 ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS CTS 4.5.2.c(3) and (4) state "... the plant shall be placed in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ." In the proposed ITS, Condition D contains the same requirement when Required Actions and Associated Completion Times are not met except that the plant must be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within a total of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . With respect to temperature between the CTS and ITS, the proposed ITS MODE 3 is specified by being greater than 300°F while the CTS HOT SHUTDOWN is greater than 525°F. While the ITS covers a broader range, for a shutdown there is no effective difference for achieving either temperature in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months since they are specified as "greater than." For the CTS COLD SHUTDOWN versus the ITS MODE 5, the temperature requirement is being less than 210°F versus being less than 200°F in the ITS. This difference of 10 degrees is negligible and has no significant impact on operations. The other parameter which is common between the CTS terms HOT SHUTDOWN and COLD SHUTDOWN and the corresponding ITS MODES 3 and 5 is the reactivity condition. The ITS MODE 3 and 5 are defined, *as a reference point, by a reactivity condition of Keff <. 99. However, in ITS Section 3.1, the equivalent amount of SHUTDOWN MARGIN is required as that specified in the CTS definitions of HOT SHUTDOWN and COLD SHUTDOWN. Therefore, the amount of SHUTDOWN MARGIN is considered to be same when the requirements of proposed ITS 3.1 are considered. The time to reach the CTS COLD SHUTDOWN is specified

as "... within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months " while the ITS allows a total of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months to reach MODE 5. Therefore, even if the plant is already in MODE 3 the full 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months are allowed. This change reflects the usage rules as specified in NUREG-1432. These changes are all considered to be administrative in that there is no significant impact to operation of the plant and they reflect the terminology and usage rules of NUREG-1432.

o+

The proposed ITS. eludes noteslii ProposedAction A and B3which state "Air lock doors in high radi tion areas may be verified locked c sed by administrative means."

This allowance

es personnel exposure and r ognizes that high radiation areas are usually res 1cted such that the probability of

alignment of the doors is very small. This ge is considered to be administr ive in that it clarifies that the verification equired by Required Action A.3 B.3 may be performed by administra -ve means. The verification requir ent still exists but the Note allows special p visions for high radiation areas to

ize personnel exposure while still keep in

rack of the OPERABLE door's s

s. This change is consistent with

-1432.

Palisades Nuclear Plant Page 3of11 01/20/98

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS MORE RESTRICTIVE CHANGES (M)

M.1 Proposed ITS 3. 6. 2 has an Act' n B to address the containment air lock interlo mechanism being inoperable. CTS 3.6.1.3 did not specify actions for this c dition

~A-I as it only addressed an inop able "air lock" which was subject to interpreta on.

3.'-* 7.-C\\

Proposed Action B require an OPERABLE door to be closed in 1 hours1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , I eked in

~f'1°...=, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and verified loc d closed once per 31 days. The proposed ITS lso includes S--.<. ~

Note 2 at the top of the equired Actions of ACTION B. Note 2 states Entry and exit of containment is penni sible under the control of a dedicated individu. " This allowance maintains requirement that only one door be opened at time but is relying on an individ al who opens one door at a time rather than r ying on the interlock mechanis for cases where the interlock mechanism ma not be operating properly. The req irement to open only one door at a time has ot changed. The Palisades CTS al does not contain a requirement for perfo

g a surveillance test on the containment ir lock interlock mechanism. Proposed ITS.6.2.2 adds this surveillance w ch will require that the interlock mechanis be tested every 18 months.

Since the CT did not specify Actions or Surveillances fo the interlock mechanism, these change are considered to be more restrictive. Th e changes are consistent with NUREG-1 2.

Palisades Nuclear Plant Page 6of11 01120/98

3.6.2 DOC M.1 In ITS 3.6.2, for a containment air lock to be considered Operable, the air lock (door) interlock mechanism must be Operable. In the CTS, the containment air lock door interlock mechanism is not required for containment air lock Operability. As such, inclusion of the door interlock mechanism in the definition of an Operable containment air lock is considered to be an additional restriction on plant operations. The addition of this requirement is appropriate since the door interlock mechanism functions to ensure that a gross breach of containment does not exist when the containment is required to be Operable by only allowing one air lock door to be opened at a time. Inclusive with this change is a new Condition (Condition B) which addresses the inoperability of one or more interlock mechanism, and the corresponding Required Actions and Completion Times (B.1, B.2, B.3) which provide the appropriate compensatory measures. The Required Actions are modified by three Notes. Note I states that Required Actions B.1, B.2, and B.3 are not applicable if both doors in the same air lock are inoperable and Condition C is entered, Note 2 allows containment ingress and egress under the controls of a dedicated individual, and Note 3 allows lock closed air lock door in high radiation areas to be verified by administrative means. The addition of Notes 2 and 3 are appropriate since they continue to ensure a leak tight containment barrier is provided. Note 1 eliminates conflicts in the ITS usage rule and as described in DOC A.9 Lastly, a new Surveillance Requirement (SR 3.6.2.2) has been added to perform an interlock test every 18 months. That SR ensures the interlock feature will functioned as designed. The addition of these More Restrictive changes are consistent with NUREG-1432.

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS M.2 Proposed ITS 3.6.2 adds a Condition C which addresses the cases where one or more containment air locks are inoperable for reasons other than Condition A or B. This would include situations such as both air lock doors inoperable at the same time.

The CTS does not specify requirements for air locks other than the door seals must be within leakage limits and the CTS definition of "Containment Integrity" requires that at least one door in each air lock is properly closed and sealed. If proposed Condition C is entered, Required Action (R.A.) A. l requires action to be initiated immediately to evaluate overall containment leakage rate per LCO 3.6.1, and a door must be verified closed in the affected air lock within one hour. If the limits of LCO 3. 6.1 is entered, then the R.A.s and Completion Times are consistent with the shutdown required by CTS LCO 3.0.3. However, R.A. C.3 requires that the air lock be restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . These actions are equal to or more restrictive than any actions specified in the CTS for air lock inoperability. In particular, the requirement to restore the air lock to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is more restrictive than the CTS restoration times. Therefore, this is considered to be a more restrictive change. This change is consistent with NUREG-1432.

. A-I

~.v,c..-3 N1. 3 /\\kw 5-c c..

l.t'>~1 Palisades. Nuclear Plant Page 7of11 01/20/98 illl'

3.6.2 DOC M.4 CTS 4.5.2c(3) provides the corrective actions if one personnel air lock door exceeds its leakage limit, or one emergency air lock door fails to meet its acceptance criterion for seal contact. In ITS 3.6.2, these same occurrences are addressed by Condition A. The CTS corrective actions require that repairs be initiated to restore the leak tightness of the door seal immediately, and to complete the repairs within 7 days or place the plant in cold shutdown.

The Required Actions of Condition A dictate the Operable air lock door be verified closed within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (RA A.1), the Operable air lock door be locked closed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (RA A.2), and a verification that the Operable doors is lock closed once per 31 days (RA A.3).

The CTS corrective actions to initiate repairs immediately and to complete the repairs in 7 days has been deleted in the ITS as justified in DOC L.1. The addition of ITS Required Actions A.1, A.2, and A.3 represent additional restrictions on plant operations. These restrictions are appropriate since the remaining Operable doors fulfill the function of the containment isolation barrier and, by locking the Operable door and performing periodic verifications, assurance is provided the isolation barrier is maintained. Required Action A.3 is also modified by a Note which allows air lock doors in high radiation areas that are locked closed in accordance with Required Action A.3 to be verified by administrative means. This allowance is appropriate since access to these areas is typically restricted and thereby, the probability of a door being misaligned once it has been verified to be in the proper position is small. This change is consistent with NUREG-1432.

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

3.6.2-10 DOC A.9 DOC M.1 CTS 4.5.2.c ITS 3.6.2 Action 8 and Associated Bases CTS 4.5.2.c is modified by the addition of ITS 3.6.2 ACTION 8. The addition of ITS 3.6.2 ACTION 8 is considered a More Restrictive change since the CTS does not contain an equivalent action. The markup further shows that ITS 3.6.2 ACTION B is modified by the addition of Note 1 to the Required Actions. This change is considered as an Administrative change as stated in DOC A.9 to clarify the usage rules of TS. This is incorrect. The addition of ITS 3.6.2 ACTION B would automatically add all corresponding Notes and Conditions, which would make the change a More Restrictive change rather than an Administrative change.

Comment:

Revise the CTS markup and provide additional justification and discussion for this More Restrictive change.

Consumers Energy Response:

See response to RAI 3.6.2-9 Affected Submittal Pages:

No page changes.

23

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

3.6.2-11 DOC A.10 CTS 4.5.2.c(4)

CTS 4.5.2.d(1) (b)

ITS SR 3.6.2.1 Note 1 and Associated Bases CTS 4.5.2.d (1 )(b) is modified by a Note which states "An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage tests." This change is considered as an Administrative change as stated in DOC A.10 to clarify the usage rules of TS. This is incorrect. CTS 4.5.2.c(4) requires the locking closed and leak testing of the OPERABLE air lock door when one air lock door is inoperable due to leakage. Thus, the adding of this Note is a Less Restrictive (L) change rather than an Administrative change, since the CTS requires the additional leak testing.

Comment:

Revise the CTS markup and provide additional discussion and justification for this Less Restrictive (L) change.

Consumers Energy Response:

The corrective action of CTS 4.5.2c(4) to test the Operable door in an air lock with one door declared inoperable due to excessive seal leakage has been deleted as justified in DOC L.2.

The corrective actions of CTS 4.5.2c(4) only require that repairs be initiated to establish conformance with the leakage limits specified for the air lock door seal and do not require a retest of the air lock penetration. As such, the addition of Note 1 to ITS SR 3.6.2.1 which states "an inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test" has been characterized as an Administrative change as described in DOCA.10.

Affected Submittal Pages:

No page changes.

24

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

3.6.2-12 DOC A.11 CTS 4.5.2.c ITS 3.6.2 Required Actions Note 1 and Associated Bases CTS 4.5.2.c is modified by ITS 3.6.2 Required Actions Note 1 which states that "Required Actions A.1, A.2, and A.3 are not applicable if both doors in the same air lock are inoperable and Condition C is entered." This change is considered as an Administrative change as stated in DOC A.11 to clarify the usage rules of TS. This is incorrect. There is nothing in the CTS which relates to this and thus would allow one to consider this change as Administrative.

Furthermore, as stated in Comment Number 3.6.2-3, both doors could be inoperable and the Adions associated with the ITS would be More Restrictive. Since there is no CTS requirement in this area, t,he staff does not consider this change to be Administrative.

Comment:

Revise the CTS markup and provide additional discussion and justification for this change.

Consumers Energy Response:

The addition of Note 1 to the Required Actions associated with Condition A has been characterized as Administrative in nature since it neither imposes any new requirement, nor relaxes any existing requirement in the CTS. The intent of this Note is to eliminate a confliet in the structure of the ITS Required Actions. Specifically, if two air lock doors in one air lock are declared inoperable due to excessive seal leakage, Condition A and Condition C are both entered. Since Required Action A.1, which requires an Operable door be verified closed within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months can not be met without the subject note, Condition D would be entered requiring a plant shut down. This conflict does not exist in the CTS since two doors in one air lock are addressed by a single requirement (CTS 4.5.2c(3)). The differences between the CTS actions

and the ITS Required Actions have been justified in DOCs M.2, M.3, M.4, L.1, L.2, and L.4.

Affected Submittal Pages:

No page changes.

25

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

3.6.2-13 DOCA.13 CTS 4.5.2c(3)

ITS 3.6.2 ACTIONS Note 3 ITS 3.6.2 ACTION A CTS 4.5.2.c(3) is modified by the deletion of the statements on door seal leakage. The basis for this deletion is that the information is contained in ITS 3.6.2 ACTION A. DOC A.13 justifies this deletion which is acceptable. However, DOC A.13 contains the following statement: "This is acceptable since the overall containment leakage must still remain within the limits of LCO 3.6.3 ACTIONS Note 4." The staff believes that this is an incorrect statement. ITS 3.6.3 deals with containment isolation valves which have nothing to do with containment air lock leakage. The statement should either refer to ITS 3.6.1 or ITS 3.6.2 ACTIONS Note 3.

Comment:

Correct this discrepancy.

Consumers Energy Response:

See response to RAI 3.6.2-3 Affected Submittal Pages:

No page changes.

26

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

3.6.2-14 DOC M.1 CTS 3.6.1 CTS 4.5.2.c ITS 3.6.2 ACTION Band Associated Bases CTS 4.5.2.c provides corrective action for excessive air lock seal leakage but no specific actions for an inoperable air lock door interlock mechanism. ITS 3.6.2 ACTION B provides explicit Required Actions when one or more air lock door interlock mechanisms are inoperable.

It is acceptable to add ITS ACTION B; however, the categorization of this CTS change should be Less Restrictive (L) rather than administrative. Per DOC M.1, CTS 3.6.1.3 addresses only an inoperable air lock which was subject to interpretation." First, there is no CTS 3.6.1.3 requirement for Palisades; and secondly, when there is no corrective action for an undefined condition, then Action must be in accordance with the plant shutdown requirements of CTS 3.0.3. ITS 3.6.2 ACTION B permits continued power operation under the successful completion of the Required Actions B.1, B.2 and 8.3. ITS 3.6.2 Required Action B, Note 2 permits an alternate method to duplicate the function of the door interlock mechanism which enables continued power operation. The addition of ACTION B including Note 2 both represent Less-Restrictive changes to the CTS contrary to the first seven sentences of DOC M.1. The last four sentences of DOC M.1 describe the More Restrictive change of the addition of a surveillance for the air lock door interlock mechanism.

Comment:

Revise the CTS markup and provide additional discussion and justification to reflect the correct categorization of these CTS changes.

Consumers Energy Response:

Including the containment air lock door interlock mechanism in the definition of Operability for the containment air locks has been characterized as a "More Restrictive" change since the CTS does not consider this feature to be related to air lock Operability. As such, addition of the Actions and surveillance requirement related to the air lock door interlock mechanism are also considered More Restrictive. In the CTS, containment air lock Operability is established by the ability of the air locks to provide *a leak tight barrier. This condition does not rely on the operation of the air lock door interlock mechanism. In addition, CTS LCO 3.0.3 only applies when an LCO or action requirement can not be met. Since the CTS does not consider the air lock door interlock mechanism to be related to air lock Operability, failure of this feature does not invoke the actions of CTS LCO 3.0.3.

In response to RAl-3.6.2-9, DOC M.1 was revised to provide additional justification for the addition of the air lock door interlock mechanism to ITS 3.6.2. As part of that change, the inappropriate reference to CTS 3.6.1.3 was deleted.

Affected Submittal Pages:

No page changes.

27

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

3.6.2-15 DOC M.1 JFD 8 CTS 4.5.2.c STS SR 3.6.2.2 and Associated Bases ITS 3.6.2 ACTION B ITS SR 3.6.2.2 and Associated Bases CTS 4.5.2.c provides corrective action for air lock excessive seal leakage but no specific actions for an inoperable air lock door interlock mechanism. ITS 3.6.2 ACTION B provides explicit Required Actions when one or more air lock door interlock mechanisms are inoperable.

ITS SR 3.6.2.2 is the associated SR which verifies the OPERABILITY of the air lock door interlock mechanism. STS SR 3.6.2.2 verifies that only one door in the air lock can be opened at a time on a frequency of 184 days. TSTF-17 modifies STS SR 3.6.2.2 and associated Bases by deleting the Note and changing the frequency to 24 months. ITS SR 3.6.2.2 and its associated Bases implement TSTF-17; however, the SR frequency and Bases changes are not in accordance with TSTF-17. While the SR frequency change is acceptable based on Palisades current refueling cycle of 18 months, the changes made to the Bases are unacceptable. The changes made to the STS Bases by TSTF-17 justify changing the frequency from the STS frequency of 6 months to a longer frequency, and are appropriate regardless of which longer frequency is used (18 or 24 months).

Comment:

Licensee to update submittal to be in accordance with TSTF-17.

Consumers Energy Response:

The Bases of ITS SR 3.6.2.2 has been revised to be consistent with NUREG-1432 as modified by TSTF 17.

Affected Submittal Pages:

Att 2, ITS B 3.6.2, page B 3.6.2-8 Att 5, NUREG B 3.6.2, page B 3.6-18 Att 6, JFD 3.6.2, page 2 of 3 28

BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.2.2 Containment Air Locks B 3.6.2 The air lock interlock is designed to prevent simultaneous opening of both doors in a single air lock. Since both the inner and outer doors of an air lock are designed to withstand the *maximum expected post accident containment pressure. closure of either door will support containment OPERABILITY.

Thus, the door interlock feature supports containment OPERABILITY while the air lock is being used for personnel transit into and out of containment.

Periodic testing of this interlock demonstrates that the interlock will function as designed and that simultaneous opening of the inner and outer doors will not inadvertently occur.

Due

~d to the purely mechanical nature of this interlock, and given that the interlock mechanism is not normally challenged when

-the. o,.,rJ.ocK. ~

c-eAtai nme11t is used for entry and exit (procedures require strict adherence to single door opening), this test is*only required to be performed every 18 months.

The 18 month frequency is based on the need to perform this Surveillance

~itl

,~

under the conditions that apply during plant outage, and the 3.<o.~-\\J potential for loss of containment OPERABILITY if the The. /g men+H 1 Survei 11 ance were performed with the reactor at power.

Fi 1

rc.,uc.nc.jL~..,+~_ 1~krla.l<

The Ifs £ciQlh\\ Frequency is based on engineering judgment and s ~v.s'("'"t\\<;(.I ~

on

s considered adequate given that the interlock is not

~et\\c.ric ~fl'f) norma 11 y cha 11 enged during use of the airlock.

t.Wtrle.n~

REFERENCES

1.

FSAR. Chapter 14

2.

FSAR, Section 5.8 Palisades Nuclear Plant B 3.6.2-8 01/20/98

~Prl

?l.(9. \\-1 BASES SURVEILLANCE REQUIREMENTS Containment Air Locks lcAtj(jospheriJ and Ou~)~

B 3 ** 2 SR 3.6.2.l (continued)

SR 3.6.IJ(?~his ensures that air lock leakage is properly {

accounted fo~in determining the overall containment leakage rate.

SR 3.6.2.2 The air lock interlock 1s designed to prevent simultaneous opening of both doors in a single air lock. Since both the inner and outer doors of an air lock. are designed to withstand the maximum expected post accident containment pressure, closure of either door will support containment OPERABILITY.

Thus, the door interlock feature supports containment OPERABILITY while the air lock is being used for personnel transit into and out of containment.

Periodic testing of this interlock demonstrates that the interlock will function as designed and that simultaneous opening of the inner and outer doors will not inadvertently occur.

Due to the urel mechanical nature of this interlock, and given r--~,.......,.--,....t::=:::;===;r=t:...__~th~a~t~t~h:.:::e~i n;:.t:.;:e~r :;._o~c7 k::;me~c an s.11 s cha 11 enged when this test s only required to be REFERENCES It. I 10 CFR sj, Appendi/ J. I I I

@ ~h3 ©(%)

FSA~~~

I CD

©@

FSAR,_ Section sf' J:,@

j Q)

....

e.v~ \\ e ""-~s. --n-a. l B,.,_.... ~ ~~t~ ir \\:.... ~eJ o.... ~ ~

-h

~.er-\\:.... -

~~) sl,A.,... e:l\\e.... c.A.. ~~,,..fl,..,. c..a.... J;~...... f -tk.+.. rr'1 d..... :....., c. f' \\a...

o~~... -t-1 &..... ~ -a,.._ ~oh"~*o..Q_ ~,. \\oss oJ;: c.o.A*...:""........... + 0?5~ABI UT"#

i'.ff..&. '5......-:\\\\o.."'c.(....Jer-4. fe.. ~,..... eJ w:4- ~

.,.~... "* f a.-.>f!.T"

the. I~ Yribi'I th Fr1vc.nc.f,r,,. -\\'he. 111-lu }6C.t" / S a1.1..r+1fit.d tJ~ y 6 n enc.ric. o fur;.Jin e.~ t°c,r/e..nCL, CEOG STS B 3.6-18 Rev I, 04/07/95

ATTACHMENT 6 JUSTIFICATION FOR DEVIATIONS SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS Change Discussion

6.

(Continued)

7.

8.

This reformatting of the requirements to the Containment Leak Rate Testing Program does not change the requirements for Option A testing but rather provides a consistent approach for referencing all of the containment leakage requirements. In addition, some editorial changes were also made as part of TSTF-52 and reflected in the proposed Bases.

The Palisades design has on "personnel air lock" which is used for prima and out of containment.

e other airlock is the "emergency escape airlo "which is normally not used except the case of emergencies. Therefore, any wo performed on the inner door of th ersonnel airlock would be accomplished by e ering through the OPERABLE oute ersonnel air lock door which may have been eked due to complying with AC ONS. This is consistent with the Palisades N lear Plant operating practice nd allowances in the CTS. In addition, Note to the ACTIONS in NUREG-1432 a the proposed ITS also allows this. Therefore e NUREG-1432 statement cone

g using an OPERABLE air lock to gain co inment entry to repair the inoperabl air lock, if ALARA conditions perm.it, may be good operating practice at some pl

, it is not the desired or recommended practic at Palisades. This is considere o be a plant specific change to reflect the Palis Cies design and operating practices The wording in the Bases has been revised to fleet the Palisades Nuclear Plant d ign and use of the containment air locks.

The Palisades CTS does not contain a surveillance to test the interlock mechanism of the airlock. SR 3.6.2.2 is added in the proposed ITS. TSTF-17, Rev. l, revises the Frequency of performing the surveillance from 184 days to 24 months to reflect that the surveillance is performed in the conditions that apply in a plant outage where the airlock is primarily used. For Palisades the Frequency is changed to 18 months to correspond with the current cycle lengths. The proposed changes to NUREG-1432 reflect the wording to perform the surveillance at the 18 month Frequency. T e final sentence of e TST -

or e R 3.. 2.2 ases provides age ric

ustificati for the Frequency This sentence is not* corporated since the ext entenc rovides a more a This change is consistent with TSTF-17, Rev. 1.

Palisades Nuclear Plant Page 2of3 01/20/98

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

3.6.2-16 DOC M.2 CTS 4.5.2.c ITS 3.6.2 ACTION C CTS 4.5.2.c is modified by the addition of ITS 3.6.2 ACTION C. This change is characterized as a More Restrictive change (DOC M.2). The staff does not agree that the total change is a More Restrictive change. DOC M.2 only addresses a small portion of the change. There are a number of conditions associated with this change in the CTS. First, if both doors in both air locks are inoperable for other than leakage, then CTS 3.0.3 must be entered. For this case, ITS 3.6.2 ACTION C is entered for all inoperabilities except for the interlock inoperable and it is a Less Restrictive (L) change. In the second case, if both doors in both air locks are inoperable for leakage that is >0.023La but ~0.60L3, then the addition of ITS 3.6.2 ACTION C is a More Restrictive change. In the third case, if both doors in both air locks are inoperable for leakage with at least one door having a leakage of ~0.023La and ~0.. 60 La and at least one door having a leakage >0.60La then ITS 3.6.2 ACTION C would be less restrictive than the CTS since CTS 3.0.3 would be entered. In the fourth case, if both doors in both air locks are inoperable*

for leakage that is >0.60La, then ITS 3.6.2 ACTION C is less restrictive since CTS 3.0.3 would have to be entered. _Overall, the total change result is a Less Restrictive (L) change.

Comment:

Revise the CTS markup and provide the appropriate discussions and justifications for this Less Restrictive change (L) change.

. Consumers Energy Response:

RAI 3.6.2-16 discusses four separate cases of the containment air lock doors being inoperable.

Each case is evaluated separately as follows:

Case 1 This case addresses both doors in both air locks being inoperable for reasons other than leakage. In the CTS (and the ITS), the only requirement for containment air lock doors is that their leakage is within limit. (In t_he ITS, the interlocks is required but, its Operability does not affect door Operability.) As such, it is not possible to have both doors in both air locks inoperable for reasons other than leakage. Since the inoperability described in the first case can not exist, no specific evaluation between the CTS and ITS was made.

Case 2 This case addresses both door in both air locks being inoperable due to door leakage> 0.023 La, but~ 0.60 La. In response to RAI 3.6.2-3, two new justifications have been provided.

DOC M.3 justifies the more restrictive aspect of both doors in one air lock being inoperable at the same time, and DOC L.4 justifies the less restrictive aspect of having multiple air locks inoperable due to excessive door seal leakage. The combination of these two justifications address the condition presented in the second case.

29

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

3.6.2-16 Consumers Energy Response: (continued)

Case 3*

This case applies when both doors in one air lock have leakage in excess of 0.023 La* The first door's leakage is assumed to be> 0.023 La and :.:; 0.60 La. The second door's leakage is assumed to be ~ 0.60 La.

If leakage from an air lock door causes total containment leakage to exceed 0.60 La, CTS 4.5.2c(4) requires the affected door be declared inoperable and the remaining operable door be closed, locked, and tested within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . As long as the remaining door is found operable, the provisions of CTS 4.5.2c(4) allow 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to reduce total containment leakage from all penetrations and isolation valves to<.60 La. Operable, as it is used in CTS 4.5.2c(4),

implies leakage from the second door does not cause total containment leakage to exceed (1.0) La. As such, CTS 4.5.2c(4) would allow both doors in a single air lock to have leakage rates in excess of that amount which causes the total containment leakage to exceed 0.60 La provided repairs are completed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . This position was found acceptable in the staffs Safety Evaluation related tq Amendment No. 126 for the Palisades plant dated June 1, 1989 which states:

[Note; at the time this SE was written the wording of CTS 4.5.2c(4) was contained in CTS 4.5.2c(3)].

"... the licensee modified the action statement associated with TS 4.5.2.c.(3) so that if the one air lock door seal leakage. causes total containment leakage to exceed 0. 60 La, the door must be declared inoperable and the remaining operable door shall be lock closed and tested within four (4) hours. If the seal leakage of the remaining door causes total containment leakage to exceed 0.60 La, in conformance with specification TS 4. 5. 2.b. (1) and the TS cannot be met within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , the licensee would be required to place the plant in cold shutdown within the following 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The staff does agree with the modified action statement since it is similar to the statement used in the TSs of other nuclear power plants and does meet the guidance provided in the Combustion Engineering Standard Technical Specifications. On this basis, the staff finds the modified action statement for TS 4.5.2.c.(3) to be acceptable. which limits total leakage from all penetrations and isolation valves to < 0. 60 La requires that repairs be initiated immediately and conformance with the specification established in 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ".

If leakage from the second door is ~ 1.0 La, the actions of CTS 4.5.2c(2) must be taken.

CTS 4.5.2c(2) states that if at any time it is determined that total containment leakage exceeds (1.0) La, within one hour action shall be initiated to place the plant in Hot Shutdown within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in Cold Shutdown within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . This action is equivalent to the actions of ITS 3.6.2 which requires entry into the applicable Conditions and Required Actions of LCO 3.6.1 when leakage results in exceeding the overall containment leakage rate acceptance criteria. That aspect of the change is. neither More Restrictive, nor Less Restrictive.

Therefore, the overall change from the C.TS to the ITS to address air locks with more than one door which exceeds its leakage limit is considered to be More Restrictive as justified in DOC M.3.

30

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

3.6.2-16 Consumers Energy Response: (continued)

Case4 This case addresses both doors in one air lock with leakage ::e: 0.60 La. This case is similar to Case 3 previously evaluated since no distinction is made between door seal leakage rates of

e: 0.023 La, and total containment leakage rates of< 1.0 La. That is, if door seal leakage result in a total containment leakage rate ::e: 0.60 La and < 1.0 La, CTS 4.5.2c(1) allows 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to establish compliance with the specification. If door seal leakage is ::e: 1.0 La, the actions of CTS 4.5.2c(2) shall be invoked.

Affected Submittal Pages:

No page changes.

31

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

3.6.2-17 DOC L.3 JFD 7 CTS 4.5.2.c(3) and 4.5.2.c(4)

STS 3.6.2 ACTION A ITS 3.6.2 ACTION A and Associated Bases CTS 4.5.2.c(3) requires air lock seal leakage exceeding the 0.023La acceptance limit, but not exceeding the total containment 0.60La leakage limit, to be restored to OPERABLE status within 7 days. CTS 4.5.2.c(4) requires air lock seal leakage causing overall containment leakage to exceed 0.60La that the leakage limit shall be restored to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . ITS 3.6.2 Action A addresses this inoperability by allowing the inoperability to be restored or locking an OPERABLE air lock door to ensure Containment is maintained OPERABLE, except for 7/48 hour period when entry is required to repair the inoperable door.

The intention of the STS 3.6.2 Action A Required Actions Note 2 is to restrict the period when inoperable doors concurrently exist in both air locks. When the STS permits one air lock door inoperable in the first air lock (while its OPERABLE door is locked closed), the second OPERABLE air lock may be used without limit because the safety function is maintained. In the STS, if both air locks are inoperable, entry for repairs and other activities are limited to a single 7 day restricted period after which if one air lock is not make OPERABLE then a plant shutdown may be required due to the inability to perform SRs on equipment in containment. At Palisades, the second air lock is the Emergency Escape Air Lock that is not used. Being in ITS 3.6.2 ACTION A is not deemed an emergency. Correspondingly, the second air lock is made unavailable for credit in the indefinite operation permitted under this proposed ITS ACTION; yet it is part of the LCO and the ACTIONS apply to it. Therefore, STS 3.6.2 ACTION A RA Note 2 is modified in the ITS to delete the bracketed phrase "[if both air locks are inoperable.]" This phrase is bracketed to take into account those plants which only have one air lock which Palisades does not. In Palisades' case, it is a question of what is the safe and prudent thing to do - use an inoperable air lock or use an OPERABLE air lock for entry and exit into containment. The staff believes the prudent and safe thing to do is to use the OPERABLE air lock, not the inoperable air lock for entry and exit and if both air locks become inoperable then entry and exit should be restricted. Thus the changes made to ITS 3.6.2 ACTION A Required Actions Note 2, ITS 8 3.6.2 Bases ACTIONS (Note 1 discussion), and ITS 8 3.6.2 Bases A.1, A.2 and A.3 are unacceptable.

In addition, the discussions and justifications in DOC L.3 and JFD 7 are not consistent with each other, e.g., DOC L.3 discusses other reasons for using the air locks for entry and exit while JFD 7 restricts it only to air lock repair.

Comment:

Revise the CTS/ITS markup to conform to the STS and provide additional discussion and justification for this Less Restrictive (L)change.

32

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

3.6.2-17 (continued)

Consumers Energy Response:

ITS Required Action "A" Note 2 has been revised to be consistent with the ISTS by including the phrase "if both air locks are inoperable." Conforming changes were also made to the Bases including corrections to ITS 3.6.2 Bases Action Note 1 and the Bases discussion for Required Actions A.1, A.2, and A.3. Lastly, JFD 7 has been deleted in its entirety since the deviation discussed by that JFD no longer applies.

Affected Submittal Pages:

Att 1, ITS 3.6.2, page 3.6.2-1 Att 2, ITS 3.6.2, page B 3.6.2-3 Att 2, ITS 3.6.2, page B 3.6.2-5 Att 3, DOC 3.6.2, page 11 of 11 Att 4, NSHC 3.6.2, page 4 of 6 Att 5, NUREG 3.6.2, page 3.6-3 Att 5, NUREG 3.6.2, page B 3.6-13 Att 5, NUREG 3.6.2, page B 3.6-15 Att 6, JFD 3.6.2, page 2 of 3 33

3.6 CONTAINMENT SYSTEMS 3.6.2 Containment Air Locks Containment Air Locks 3.6.2 LCO 3.6.2 Two containment air locks shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS

~---NOTES------------------------------------

1. Entry and exit is permissible through a 11 locked 11 air lock door to perform repairs on the affected air lock components.

2.

Separate Condition entry is allowed for each air lock.

3. Enter applicable Conditions and Required Actions of LCO 3.6.1, 11Containment, 11 when leakage results in exceeding the overall containment leakage rate acceptance criteria.

CONDITION A.

One or more containment air locks with one containment air lock door inoperable.

Palisades Nuclear Plant REQUIRED ACTION

NOTES------------

1. Required Actions A.1, A.2, and A.3 are not applicable if both doors in the same air lock are inoperable and Condition C is entered.

2. Entry and exit is permissible for 7 days under administrative COMPLETION TIME control SJ. 1~ bzstn a.1r ~

CJ.re.., no~blt (continued}

3.6.2-1 Amendment No.

01/20/98.

.3.3 -{}._/

x

BASES APPLICABILITY Containment Air Locks B 3.6.2 In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment.

In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES.

Therefore, the containment air locks are not required in MODE 5 to prevent leakage of radioactive material from containment.

The requirements for the containment air locks during MODE 6 are addressed in LCO 3.9.3, "Containment Penetrations.

11 ACTIONS The ACTIONS are modified by three notes.

The first note RF>i\\ ~.b.~*11 allows entry and exit to erform re airs on the affected air lock component.

f repairs on e1 er oar mus e per orme~

~ewi +hc.loa.tr~~

then it is permissible to enter the air lock through the Sld< or+rc. da>c"

1'oPERABLE door, even if this door has been locked to comply with ACTIONS.

This means there is a short time during which the containment boundary is not intact (during access through the OPERABLE door).

The ability to open the OPERABLE door, even if it means the containment boundary is temporarily not intact, is acceptable because of the low probability of an event that could pressurize the containment during the short time in which the OPERABLE door is expected to be open. After each entry and exit, the OPERABLE door must be immediately closed.

A second Note has been added to provide clarification that, for this LCD, separate Condition entry is allowed for each air lock. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable air lock.

Complying with the Required Actions may allow for continued operation, and a subsequent inoperable air lock is governed by subsequent Condition entry and application of associated Required Actions. A third Note has been included that requires entry into the applicable Conditions and Required Actions of LCD 3.6.1, "Containment," when leakage results in exceeding the overall containment leakage limit.

Palisades Nuclear Plant B 3.6.2-3 01/20/98 33-b

BASES ACTIONS

*

t ~ b.+n (111r ~~~

ha.vc. o.t\\ lllb~I( door, 11.s '=t da:y f\\S-trle'fiot\\

be~ins wnU\\ fto\\~ ~

a.1r 1t:tt= 1s dis~'

1 no rt..roJo'-

A.1. A.2. and A.3 (continued)

Containment Air Locks B 3.6.2 The Required Actions have been modified by two Notes.

Note 1 ensures that only the Required Actions and associated Completion Times of Condition C are required if both doors in the same air lock are inoperable. With both doors in the same air lock inoperable, an OPERABLE door is not available to be closed. Required Actions C.1 and C.2 are the appropriate remedial actions. The exception provided by Note 1 does not affect tracking.the Completion Time. from the initial entry into Condition A; only the requirement to comply with the Required Actions.

Note 2 allows use of the air lock for entry and exit for 7 days under administrative control

Containment entry may e require o per arm ec n1ca pecifications (TS)

Surveillances and Required Actions, as well as other activities on equipment inside containment that are required by TS or activities on equipment that support TS-required equipment. This Note is not intended to preclude performing other activities (i.e., non-TS-required activities) if the containment was entered, using the inoperable air lock, to perform an a 11 owed activity listed above. This a 11 owance is acceptable due to the low probability of an event that could pressurize the containment during the short time that the OPERABLE door is expected to be open.

8.1. B.2. and B.3 With an air lock interlock mechanism inoperable in one or more air locks, the Required Actions and associated Completion Times are consistent with those specified in Condition A.

The Required Actions have been modified by two Notes.

Note 1 ensures that only the Required Actions and associated Completion Times of Condition C are required if both doors in the same air lock are inoperable. With both doors in the same air lock inoperable, an OPERABLE door is not available to be closed. Required Actions C.1 and C.2 are the appropriate remedial actions. Note 2 allows entry into and exit from containment under the.control of a dedicated individual stationed at the air lock to ensure that only one door is opened at a time (i.e., the individual performs the function of the interlock).

Palisades Nuclear Plant B 3.6.2-5 01/20/98 33-c...

RAI

~.t..2.-11 L.3 ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS bo1"

~~

The actions of CTS 4.5.2c haveJ::een revised to allow en and exiting of the

~1 *.p ~"tfl containment when one door in~ containment air locks* inoperable. Proposed 0.\\r.R.Q(.I~

ITS 3.6.2 Condition A, Required Action Note 2 states that "entry and exit is (lr\\. 11"1ofQnlblc. y permissible for 7 days under administrative control. " This purpose of this Note is to allow ingress and egress through an Operable containment air lock door, that is required to be closed and locked to isolated the air lock penetration, to perform technical specification related and non-technical specification related activities on equipment inside containment. The allowance is permitted for up to 7 days provided appropriate administrative controls are instituted. This allowance is acceptable due to the low probability of an event that could pressurize the containment during the short time that the Operable door is expected to be opened. This change is consistent with NUREG-1432.

f{A-1 j.'7./..-;3 L. 4 tJe.w

~"'" :tNS ta.-1' Palisades Nuclear Plant Page 11of11 01/20/98 33-d I

3.

ATTACHMENT 4 NO SIGNIFICANT HAZARDS CONSIDERATION SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS Does this change involve a significant reduction in a margin of safety?

The margin of safety is a function of the overall containment leakage. The proposed change does not re~uire tha~ immediate actions be taken to repair the inoperable door or test the OPERABLE door. Failure of one air lock door seal test does not mean the other seal will fail its test. As long as the OPERABLE door is closed and there is every reason to believe the seals in the OPERABLE door are. still OPERABLE, then the overall containment leakage should still be within limits. Therefore, not requiring immediate repairs to the inoperable door or requiring that a test be performed on the OPERABLE door does not involve a significant reduction in a margin of safety.

LESS RESTRICT~ijCHANGE L.3. *~

"/.

The actions of CTS.5.2c have been revised' o allow entry and exiting of the containment V\\

when one door in~containment air locl<S operable. Proposed ITS 3.6.2 Condition A, {1.j: bot<l Required Action Note 2 states that "entry and exit is.permissible for 7 days under fl:;.~~

administrative controlsf" This purpose of this Note is to allow ingress and egress through an Operable containment air lock door, that is required to be closed and locked to isolated the air lock penetration, to perform technical specification related and non-technical specification related activities on equipment inside containment. The allowance is permitted for up to 7 days provided appropriate administrative controls are instituted. This allowance is acceptable due to the low probability of an event that could pressurize the containment during the short time that the Operable door is expected to be opened. This change is consistent with NUREG-1432.

1.

Does the change involve a significant increase in the probability or consequence of an accident previously evaluated?

Analyzed events are assumed to be initiated by the failure of plant structures, systems or components. The proposed change does not result in any hardware changes. The containment air locks are not assumed to initiate any analyzed event. The proposed change only allows entry and exiting of_faontainment through the Op~rable door of a containment air lock when one door iniije containment air loc1' f moperable.

Therefore, the proposed change does not involve a significant increase in the probability of an accident previously evaluated.

Palisades Nuclear Plant Page 4of6 01/20/98 e_

c.T"S ?.'-*'

c.:r s 1 i..1.0..

c:r~ ~. :5'. 2 <.( i)

Containment Air Locks l<At}llospheri(/and Dua14r-@

3. 6.

3.6 CONTAINMENT SYSTEMS 3.6.Z Containment Air Locks j(Atmftspheric aij(i Dual)!

LCO 3.6.2 frwof'containment air locl<:{srshall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS

NOTES------------------------------------

1. Entry and exit is permissible to erform repairs on the affected air lock components.

I @

2. Separate Condition entry is allowed for each air lock.

3. Enter applicable Conditions and Required Actions of LCO 3.6.1,

containment,* when leakage results in exceeding the overall containment.

leakage rate acceptance criteria.

CONDITION A.

One or 1110re containment air locks with one containment air lock door inoperable.

CEOG STS REQUIRED ACTION

NOTES-----------*

1. Required Actions A.l,

~~~ A.Z, and A.3 are not applicable if both doors in the same air lock are inoperable and Condition C is entered.

2. Entry and exit is permi ss i bl e for 7 days

under administrative controls \\if ~eth air leek! are iReperable}:

3.6-3 COMPLETION TIME (continued)

Rev 1, 04/07/95

-BASES LCO

{continued)

APPLICABILITY ACTIONS CEOG STS Containment Air LockslCAtn)6spheric And Dual)~

B 3.6.2 Each_ air 1 ock is required to be OPERABLE.

For the air 1 ock to be considered OPERABLE, the air lock interlock mechanism must be OPERABLE, the air lock must be in compliance with the Type B air lock leakage test, and both air lock doors must be OPERABLE.

The interlock allows only one air lock door of an air lock to be opened at one time. This provision ensures that a gross breach of containment does not exist when cont_ainment is required to be OPERABLE.

Closure of a s1ng1e¥door in each air lock is sufficient tol~

provide a leak tight barrier following postulated events.

Nevertheless, both doors are kept closed when the air lock -

is not -being used for nonna 1 entry into ~

exit from

. I '[;'

containment.

~

In MODES 1, 2, 3, and 4, a OBA could cause a release of radioactive material to containment.

In HODES 5 and *6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these HODES.

Therefore, the containment air locks are not required in MODE 5 to prevent leakage of radioactive material from

containment. The requirements for the containment air locks during HOOE 6 are addressed in LCO 3.9.3,. "Containment Penetrations.*-

33-_s e.u e,,.. ~

s oec""..._ __

l.. c.k.~ 4-... c.*-. \\

~ ;-tt,.. AC..T\\ofJ S.

(continued)

B 3.6-13 Rev 1, 04/07/95

BASES ACTIONS CEOG STS Containment Air Locks I (Atli}§spheri/t and 011 ~ f-*@

B 3..

A.I. A.2; and A.3 (continued) closed by use of administrative means.

Allowing verification by administrative means is considered acceptable, since acce~s to these areas is typically restricted. Therefore, the probability of misalignment of the door, once it has been verified to be in the proper position, is small.

The Required Actions have been modified by two Notes.

Note 1 ensures that only the Required Actions and associated Completion Times of Condition C are required if both doors in the same air lock are inoperable. With both doors in the same air lock inoperable, an OPERABLE door is not ava.,;,.i.... l........,___,

to be closed.

Req~ired Actions C.l and C.2 are the pro~~

appropriate remedial actions. The exception!:!f} te oes not affect tracking the Completion Time from the initial entry into Condition A; only the requirement to comply with the Required Actions.

Note 2 allows use of the air lock for entry and exit for 7 days under administrative controls~~

bath aiP leeks ~ave an inapePa~le ~aa~. This 7 day

~es\\Pie\\1aA be9iAE w~aA t~a E&Q~A~_ai~ laQk is ~iseavePed 1Aa~ePa~le. Containment. entry may be required to perform Technical Specifications (TS)* Surveillances and Required Actions, as well as other activities on equipment inside containment that are required by TS or activities on equipment that support TS-required equipment. This Note is not intended to preclude performing other activities (i.e.,

non-TS-required activities) if the containment was entered, using the inoperable-air lock, to perfon1 an allowed activity listed above. This allowance is acceptable due to the low probability of an event that ~ould pressurize the containment during the short time that the OPERABLE door is expected to be open.

B.1. B.2. and B.3 With an air lock interlock mechanism inoperable in one or more air locks, the Required Actions and associated Completion Times are consistent with those specified in Condition A.

The Required Actions have been modified by two Notes.

Note 1 ensures that only the Required Actions and associated Completion Times of Conditioo C are required if both doors (continued)

B 3.6-15 Rev 1, 04/07/95 3 3 --"--

l

ATTACHMENT 6 JUSTIFICATION FOR DEVIATIONS SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS Change Discussion

6.

(Continued)

7.

. 8.

. This reformatting of the requirements to the Containment Leak Rate Testing Program does not change the requirements for Option A testing but rather provides a consistent

approach for referencing all of the containment leakage requirements. In addition, some editorial changes were also made as part of TSTF-52 and reflected in the proposed Bases.

The Palisades design has on "personnel air lock" which is used for pr*

access in and out of containment. T e other airlock is the "emergency escape airlo " which is normally not used except the case of emergencies. Therefore, any WO performed on the inner door of th ersonnel airlock would be accomplished by e ering through

the OPERABLE oute ersonnel air lock door which may have been eked due to complying with AC ONS. This is consistent with the Palisades N lear Plant operating practice d allowances in the CTS. In addition, Note to the ACTIONS in NUREG-1432 the proposed ITS also allows this. Therefore e NUREG-1432 statement cone

g using an OPERABLE air lo~k to gain co ent entry to repair the inoperabl air lock, if ALARA conditions permit, may be good operating practice at some pla

, it is not the desired or recommended practic at Palisades. This is considered o be a plant specific change to reflect the Palis Cles design and operating

practices The wording in the Bases has been revised to eflect the Palisades Nuclear Plant d ign and use of the containment air locks.

The Palisades CTS does not contain a surveillance to test the interlock mechanism of the airlock. SR 3.6.2.2 is added in the proposed ITS. TSTF-17, Rev. 1, revises the Frequency of performing the surveillance from 184 days to 24 months to reflect that the surveillance is performed in the conditions that apply in a plant outage where the airlock is primarily used. For Palisades the Frequency is changed to 18 months to correspond with the current cycle lengths. The proposed change~ to NUREG-1432 reflect the wording to perform the surveillance at the 18 month Frequency. T e final sentence of e T -

I or e R 3.. 2.2 ases provides age ric

ustificati for the Frequency This sentence is not**. corporated since the ext entenc rovides a more a This change is

s consistent with TSTF-17, Rev. 1.

\\.

Palisades Nuclear Plant Page 2of3 01/20/98 3J-.,..<_

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

3.6.2-18 JFD 3 STS B 3.6.2 Bases SR 3.6.2.1 ITS B 3.6.2 Bases SR 3.6.2.1 STS B 3.6.2 Bases SR 3.6.2.1 states the following: "The acceptance criteria were established during initial air lock and containment OPERABILITY testing." ITS B 3.6.2 Bases SR3.6.2.1 deletes this statement based on JFD 3 which states that it is not applicable to Palisades. This is unacceptable. The STS statement provides the basis of how and when the air lock leakage was established. At Palisades the leakage acceptance criteria may not have been established during the initial air lock and containment OPERABILITY testing, but may have been established at some other time or by some other method. Thus, the ITS should reflect this.

See Comment Numbers 3.6.1-1and3.6.2-1.

Comment:

Revise the markup of ITS B 3.6.2 Bases SR 3.6.2.1 to include the STS sentence on establishment of air lock leakage acceptance criteria or modify it to reflect the plant specific criteria. See Comment Numbers 3.6.1-1 and 3.6.2-1.

Consumers Energy Response:

The Bases for ITS SR 3.6.2.1 has been revised to include a sentence on the establishment of the air lock leakage acceptance criteria.

Affected Submittal Pages:

Att 2, ITS 3.6.2, page B 3.6.2-7 Att 5, NUREG 3.6.2, page B 3.6-17 34

BASES ACTIONS (continued)

SURVEILLANCE REQUIREMENTS

. Rf\\\\

~.(o.\\-1 D.l and D.2 Containment Air Locks B 3.6.2 If the inoperable containment air lock cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply.

To achieve thfs status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times ar~ reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without chall~nging plant systems.

Palisades Nuclear Plant B 3.6.2-7 01/20/98 3~-(}-/

BASES ACTIONS SURVEILLANCE REQUIREMENTS

~i< fO.k -fest-1 o+ncr t~n f.e.rlon~t.. a.1r iat~ door.s, o.. r~

ftrtorm.d* a. t frtssvrc.s ? SS Psid' CEOG STS Containment Air Locks j{AtmoWheric a/id Dual~!--@

B 3.6.

C.l. C.2. and C.3 (continued)

Additionally, the affected air lock(s) must be restored to.

OPERABLE status within the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time.

The specified time period is considered reasonable for restoring an inoperable air lock to OPERABLE status, assuming that at least one door is maintained closed in each affected air lock.

0.1 and D.2 If the inoperable containment air lock cannot be restored to OPERABLE status wtthin the requfred Completion Time, the plant must be brought to a MODE in which the LCO does not apply.

To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SR 3.6.2.1 The SR has been modified by two Notes. Note 1 states that an inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

This is considered reasonable since either air lock door is capable of providing a fission product barrier in the event of a OBA.

Note Z has been added to this SR requiring the r~~~lts to be evaluated against the acceptance criteria of (continued)

B 3.6-17 Rev 1, 04/07 /95

$ub£e._sc.;c.nf O.mc.nalmc.nt3 to fh<. -&~"'l SP<c..rfiec.'tltil'\\ -.)

~vist.J'4-the ac.~~c Crt-fU-IQ. ~r Oi..e.ra.J/ 'TVPc. f>i C...

~l'ia.Oc..QMufS Cl.rd trw/dvJ f'e.w a.cc.cpi1.n C:(.

Cri~~r.o... -\\t.r +h-c... p~rs6nf1<.l aAr ltX..K door~ a.,.J

~c..'()¢1'\\c.'( Cl.tr -Jo<J< d Oo~ (~~. Z.)

3'1-.b I©

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

3.6.2-19 JFD 10 STS B 3.6.2 Bases - APPLICABLE SAFETY ANALYSES ITS B 3.6.2 Bases - APPLICABLE SAFETY ANALYSES STS B 3.6.2 Bases - APPLICABLE SAFETY ANALYSIS in the paragraph for atmospheric containments states the following: "This leakage rate is defined in 1 O CFR 50 Appendix J (Ref.1), as La:... which is a design basis MSLB (Ref 2)." This statement is based on 10 CFR 50 Appendix J, Option A. TSTF-52 Revision 1 modifies this statement to reflect 1 O CFR 50 Appendix J Option B. ITS B 3.6.2 Bases - APPLICABLE SAFETY ANALYSES modifies this sentence to reflect, based on JFD 10, Palisades' design with regards to Pa* the Type A test performed using 10 CFR 50 Appendix J Option B, and the Type B and C testing performed using 10 CFR 50 Appendix J Option A. The modification is incomplete in that it does not address the exemption granted to Consumers Energy with regards to Pa as it relates to Option A versus Option B. See Comment Numbers 3.6.1-1 and 3.6.2-1 Comment:

Revise the ITS markup of ITS B 3.6.2 Bases - APPLICABLE SAFETY ANALYSES to accurately reflect the exemption granted on Pa with regards to 10 CFR 50 Appendix J Option A versus Option B. See Comment Numbers 3.6.1-1 and 3.6.2-1.

Consumers Energy Response:

The Palisades containment structure, including the associated access openings and penetrations, was designed to contain radionuclide at the pressures and temperatures resulting from a Design Basis Accident (DBA) in which the total energy contained in the Primary Coolant System water was assumed to be released into the containment through a double-ended guillotine break of one of the primary coolant hot leg pipes. The design of the Palisades containment is consistent with General Design Criteria, Criterion 50 which states, in part, "The reactor containment structure, including access openings, penetrations, and the containment heat removal system shall be designed so that the containment structure and its internal compartments can accommodate, without exceeding the design leakage rate and with sufficient margin, the calculated pressure _and temperature conditions resulting from any loss-of-coolant accident."

10 CFR 50, Appendix J, Option A defines Pa as "the means to calculate peak containment internal pressure related to the design basis accident specified either in the technical specifications or associated bases." In the Applicable Safety Analyses section of the Bases for ITS 3.6.2, the DBAs which result in the highest peak internal containment pressure are the MSLB and LOCA. The values of these two events have been included in the Bases of ITS 3.6.2 for completeness. In addition, and consistent with the current licensing basis, a statement has been included in these Bases to clarify that Type B leakage rate tests performed in accordance with 10 CFR 50, Appendix J, Option A are performed at pressures ~ 55.0 psig.

Affected Submittal Pages:

Att 2, ITS 3.6.2, page B 3.6.2-2 Att 5, NUREG 3.6.2, page B 3.6-12 Att 6, JFD 3.6.2, page 3 of 3 35

BASES APPLICABLE SAFETY ANALYSES LCO Containment Air Locks B 3.6.2 The DBAs that result in a release of radioactive material within containment are a Loss of Coolant Accident (LOCA), a Main Steam Line Break (MSLB) and a control rod ejection accident (Ref.~1). In the analysis of each of these accidents, it is assumed that containment is OPERABLE such that release of fission products to the environment is controlled by the rate of containment leakage.

The containment was designed with an allowable leakage rate of 0.10% of containment air weight per day (Ref. 2). This leakage rate is defined in 10 CFR 50, Appendix J, Option A, as e c cu a re re a e o the esign basis accident For the Palisades Nu ear Plant, he design basis ace* ent for the plant is large break OCA.

The calculate maximum peak contain nt pres re results from a M B accident.

However, since the lim"ting accident from a offsite dose perspec ve is a LO A, this containment essure is used as Pa.

The Pa value o 53 psig represents e analytical value f nd in ef erence 1 rounded to the next who 1 e n ber. ~T!'!"'h~i s---

a owa e ea age ra e arms e as1s or t e acceptance criteria imposed on the SRs associated with the air lock.

The containment air locks satisfy Criterion 3 of 10 CFR 50.36(c)(2).

Each containment air lock forms part of the containment pressure boundary.

As part of the containment pressure boundary, the air lock safety function is related to control of the containment leakage rate resulting from a DBA.

Thus, each air lock's structural integrity and leak tightness are essential to the successful mitigation of such an event.

Each air lock is required to be OPERABLE.

For the air lock to be considered OPERABLE, the air lock interlock mechanism must be OPERABLE, the air lock must be in compliance with the Type B air lock leakage test, and both air lock doors must be OPERABLE.

The interlock allows only one air lock door of an air lock to be opened at one time. This provision ensures that a gross breach of containment does not exist when containment is required to be OPERABLE.

Closure of a single OPERABLE door -in each air lock is sufficient to provide a leak tight barrier following postulated events. Nevertheless; both doors are kept closed when the air lock is not being used for normal entry into or exit from containment.'

Palisades Nuclear Plant B 3.6.2-2 cJ 5 -CJ.-_./

01/20/98

3.6.2-19 ASA Insert

... La : the maximum allowable containment leakage rate at the calculated maximum peak containment pressure (P J. For a LOCA, the calculated maximum peak containment pressure is approximately 53 psig. For an MSLB, the calculated maximum peak containment pressure is approximately 54 psig. However, the ensure sufficient margin and to bound all DBAs, Type B leakage rate testing is performed at or above the containment design pressure of 55.0 psig.

j 5-b

Containment Air Locks ICAtlil,(Sspheri? and Du~~

B 3 *.

BASES (conti~ued) lk J' I e.... \\:...... '\\e... r....

APPLICABLE SAFETY ANALYSES de~*"c:J,,,. \\oC:.. R So, Attt..J:~ I 171-:o-A ~s.

l:-:+r-)

..__ o+~:k..

cl_.1~ t U~fec.; ""-- ; 'S. c.. 1...ot_A, is.....se..l

For dual con ainment, the DBAs that result in a r lease of radioactive material within c ntainment are a LO A, an MSLB, and a CEA jection accident ef. 2).

In the a alysis of each of t se accidents, it s assumed that c ainment is OPERABLE uch that release f fission product to the environ nt is controlled y the rate of con inment leakage The containment was designed"wtth n allowable leakag rate of [0.50.]S f containment air eight per day

{Ref. ). This leakage rate is defined in 10 CFR 50, Appe ix J (Ref., 1), a L.: the maximu11 lowable

con.tnment 1 eakaga r a at the ca lcul at Ci maxi mum peak con ainment pressure P.) of [42.3] psi, which results from th limiting OBA, w ch is a 75S RTP M B (Ref. 2). This a owable leakage r te forms the basi for the acceptance iteria imposed o the SRs associate with the air lock.

tcont i nued)

CEOG STS B 3.6-12 Rev 1, 04/07 /95 f6r Q lac.A 1 +h( Cblc.ula.-bl ma..,.;~.........

pe~I'\\ C.S-t,i:'.unmc.f°l-t fr'r...o!J4Jfe.

G.PlroYttrQ,-k/y 53 Pst'. F~r Q.(\\ mSL&, fhe. CAli:ut.o,+rJ ma.ximuYI'"\\ peo..'I'\\

C:sniunmi;11-l-frc.rr r.Hc, t S a f P~ 111dJy S'j f.Jll, 1-lowc.\\..tfa +o ensure. /j u~ic.ie.n-\\

~m Q.nd +o. ~oond 0.11. D&A.s )

1'1 Pc. e:, kKa~c. ro..+t Lti~

/.S.

fe~formte/ _aJ* or o..bwc. +fk. ~rda.mmct1t dt~~jj ff°'t.Mvfl. elf

.. 35-~

ATTACHMENT 6 JUSTIFICATION FOR DEVIATIONS SPECIFICATION 3.6.2, CONTAINMENT AIR LOCKS Change Discussion

9.

The Palisades Nuclear Plant is considered to be an "Atmospheric" containment. The heading titles referring to either "Atmospheric" or "Atmospheric and Dual" are deleted since they add no value to the usage of the plant specific Palisades Nuclear Plant Technical Specifications. In addition, the portions of NUREG-1432 which are provided for "dual" contahunents are not applicable to the Palisades Nuclear Plant.

10.

rM~C~

+ru-Lrx..A o..rrJ*

m SL~

IYPt & i:ta+~ M

~IJ/U.I' :;?.ti f's Q.

Palisades Nuclear Plant Page 3 of 3 35-d 01/20/98

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

3.6.4 Containment Pressure 3.6.4-1 DOC A.3 CTS 3.6.2.b ITS 3.6.4 APPLICABILITY CTS 3.6.2.b specifies a limit of 1.0 psig for containment pressure when in "Power Operation or Hot Standby". ITS 3.6.4, APPLICABILITY makes this pressure limit applicable in Modes 1 and

2. The proposed ITS APPLICABILITY is acceptable; however, the DOC A.3 technical justification appears to have incorrect statements that should be corrected. Between the third and fourth sentences, it appears that the justification for MODE 2 operation is missing, while the fifth sentence does not make sense.

Comment:

Revise the DOC A.3 to provide a corrected technical justification.

Consumers Energy Response:

As described in the front matter provided with Section 3.6 Sections D and E, CTS Operating*

Conditions "Power Operation" and "Hot Standby" are defined differently than ITS MODE 1 and MODE 2. However, the changes do not result in a substantive operational effect. DOC A.3 is revised to more clearly reflect the parallel between the CTS Operating Conditions and the ITS MODEs.

Affected Submittal Pages:

Att 3, DOC 3.6.4, page 2 of 3 36

A.3 ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.4, CONTAINMENT.PRESSURE CTS 3.6.2b specifies a r t of 1.0 psig for contaimrtent press re when in "POWER OPERATION or HOTS ANDBY." The proposed ITS ch ges tills to "MODESJ and 2." The CTS HO STANDBY condition is when Ta of the CONTROL R S are withdrawn and power is le than 2 % of RA TED POWER. The CT term POWER OPERATION is de ed to be when the react A.4 CTS 3.6.2 requires that if containment pressure is not restored to within limit, that the plant be placed in HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . In the proposed ITS the CTS term HOT*

SHUTDOWN is replaced by MODE 3 and COLD SHUTDOWN is replaced by MODE 5. This is considered to be an administrative change since the effect on operations is similar. For a discussion of the change from the CTS operating condition definitions to the proposed ITS MODES refer to the information associated with Chapter 1.0. This change is consistent with NUREG-1432.

MORE RESTRICTIVE CHANGES (M)

M.1 CTS 3.6.2 specifies limits for containment internal pressure *and actions to be taken if the limits are not met. However, no surveillances are provided to verify that containment internal pressure is. within limits. The proposed ITS requires that the containment pressure be verified within limits every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This change is a more restrictive change since the CTS did not contain an explicit verification of containment pressure on a periodic basis. This change is consistent with NUREG-1432.

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

There were no "Removal of Detail" changes made to this specification.

Palisades Nuclear Plant Page 2of3 01/20/98

DOC A.3 to*3.6.4 CTS 3.6.2b specifies a limit of 1.0 psig for containment pressure when in "POWER OPERATION or HOT STANDBY." The proposed ITS changes this to "MODES 1 and 2."

The CTS term POWER OPERATION is defined to be when the reactor is critical and power is

> 2 % of RATED POWER. The proposed ITS definition of MODE 1 is with Keff ~ 0.99 and power> 53 power. The CTS HOT STANDBY condition is when Tave> 525°F, any of the CONTROL RODS are withdrawn and power is < 2 % of RA TED POWER. The proposed ITS definition of MODE 2 is ::o; 53 power and Keff is ~ 0.99. From an operational standpoint there is minimal difference between the conditions described by the CTS HOT STANDBY and POWER OPERATION and the ITS MODES 1 and 2 because the combination of MODEs 1 and 2 define conditions similar to the combined CTS limits. Therefore, this is considered to be an administrative change. This change is consistent with NUREG-1432.

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

3.6.4-2 CTS 3.6.2 ITS LCO 3.6.4 and Associated Bases CTS 3.6.2 specifies that the containment internal pressure shall not exceed 3 psig except for containment leak rate tests. An Amendment Request dated March 26, 1997, proposes to change the containment internal pressure limits to ITS LCO 3.6.4 limits of~ 1.5 psig in MODES 3 and 4 and ~ 1.0 in MODES 1 and 2. This change is under review by the staff. Even though the CTS markup is based on the Amendment Request and the CTS/ITS markups correctly show the change, acceptability of the ITS will depend on the acceptability of the change in containment pressure limits. Thus the staff considers this change to be a beyond scope of review item for the conversion.

Comment:

Acceptability of this change is dependent on resolution of the March 26, 1997, Amendment Request.

Consumers Energy Response:

Amendment 184 to the Palisades Technical Specifications was approved on February 22, 1999, and incorporated the changes described in the Amendment Request submitted on March 26, 1997.

Affected Submittal Pages:

No page changes.

37

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

3.6.5 Containment Air Temperature 3.6.5-1 JFD 1 JFD 6 CTS 3.6.3 STS B 3.6.6.5 Bases LCO ITS B 3.6.5 Bases APPLICABLE SAFETY ANALYSES AND LCO The second paragraph of the ITS B 3.6.5 Bases APPLICABLE SAFETY ANALYSES contains a new insert that states the containment building design temperature will be exceeded based upon the technical specification containment temperature limit initially assumed to exist prior to a OBA event. This statement is apparently drawn from FSAR 14.18.2.2.3 per the ITS Bases markup margin Notes. In addition, ITS B 3.6.5 Bases -LCO changes the STS words "resultant peak accident temperature" and "containment design temperature" to "resultant peak accident pressure" and "containment design pressure" respectively. It appears that the ITS B 3.6.5 Bases LCO changes are based upon exceeding the design building temperature limit. A*

Technical Specification (TS) Amendment Request dated March 26, 1997, proposes to add a new TS on containment temperature (CTS 3.6.3). The justification provided in that Amendment request does not provide sufficient information to evaluate the above Bases statements. No technical justification is provided on the effects or acceptability of exceeding the design building temperature limit or the effects to equipment within containment that may have a lower component qualification temperature. The staff considers this change to be a beyond scope of review item for this conversion.

Comment:

Provide additional discussion and justification for these changes.

Consumers Energy Response:

The Palisades FSAR provides the licensing basis and justification for the changes proposed to the proposed BASES of 3.6.5. A description of the Containment Structure at Palisades is provided in Section 5.8 of the UFSAR. Subsection 5.8.1 describes the predicted containment response that will result in peak transient temperatures exceeding the design temperature.

Section 14.18 of the FSAR provides the Containment Pressure and Temperature Analysis, including the analysis of a postulated MSLB inside the Containment. Section 14.18.2.2.3 and Table 14. 18.2-3 provide the results of the MSLB analysis. The MSLB Containment Response Maximum Temperature Profile is provided in Figure 14.18.2-2.

The 140°F Containment Temperature Limit was incorporated into CTS 3.6.3 on February 22, 1999 by Amendment 184 to the Palisades Technical Specifications. This change was accompanied by a Safety Evaluation Report, also dated February 22, 1999.

(continued) 38

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

3.6.5-1 Consumers Energy Response: (continued)

The proposed changes to the Bases of ITS 3.6.5 are consistent with the current licensing basis for the Palisades plant, including the FSAR and the CTS. These Bases changes provide plant-specific analysis detail regarding the postulated peak post-OBA containment temperature consistent with the Palisades licensing basis. Because these changes reflect the current licensing basis as described in the FSAR and CTS, Consumers Energy does not believe these changes are a beyond scope of review item for the conversion of the Palisades Technical Specifications to the ISTS format.

Affected Submittal Pages:

No page changes.

39

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

3.6.5-2 JFD 2 STS B 3.6.5 Bases - A.1 ITS B 3.6.5 Bases - A.1 STS B 3.6.5 Bases - A.1 states that when the containment air temperature is not within limit, "it must be restored to within limit within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ." ITS B 3.6.5 Bases - A.1 deletes the phrase "to within limit" from the restoration statement. The justification used for this deletion (JFD 2) is for editorial clarity, etc. The deletion does not clarify the intent of the sentence and results in the sentence not making sense, with regards to what one is restoring.

Comment: Delete this change.

Consumers Energy Response:

The change has been deleted and the text of NUREG-1432 adopted.

Affected Submittal Pages:

Att 2, ITS 3.6.5, page B 3.6.5-2 Att 5, NUREG, page B 3.6-42 40

BASES APPLICABLE SAFETY ANALYSES (continued)

LCO APPLICABILITY ACTIONS

'RA:r 3,1,.5'-,;)....

Containment Air Temperature B 3.6.5 The initial pre-accident temperature inside containment was assumed to be 140°F (Ref. 2).

The initial co.ntainment average air temperature condition of 140°F resulted in a maximum vapor temperature in containment of 399°F. Thts value represents the analytical value presented in Reference 3, rounded up to the next highest number. This exceeds the containment building design temperature of 283°F.

The effect on the containment structure is negligible due to the short period of time the temperature exceeds the design value.

Containment average air temperature satisfies Criterion 2 of 10 CFR 50.36(c)(2).

During a OBA, with an initial containment average air temperature less than or equal to the LCO temperature limit, the resultant peak accident pressure is maintained below the containment design pressure.

As a result, the ability of containment to perform its function is ensured.

In MODES 1, 2, 3, and 4, a OBA could cause a release of radioactive material to containment.

In MODES 5 and 6, the probability and consequences of these events are ~educed due to the pressure and temperature limitations of these MODES.

Therefore, maintaining containment average air temperature within the limit is not required in MODE 5 or 6.

When containment average air temperature is not within the limit of the LCO, it must be restored ithin 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

This Required Action is necessary to return operation to within the bounds of the containment analysis. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is acceptable considering the sensitivity of the analysis to variations in this parameter and provides sufficient time to correct minor problems.

Palisades Nuclear Plant B 3.6.5-2 01/20/98

{/()-()__/

Containment Air Temperature ICAtlljOspheric an( Dual)~

3.6.5 BASES (cont i n*ued)

ACTIONS SURVEILLANCE REQUIREMENTS

-n.,.... l'iOoF° \\;_:~ j~ ~

o...c...+....J- [;,_:....... ~~..... -e~

.+:~..- 4

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.... t: ..C.C....._,.....,\\1!$

CEOG STS RA-1:"

Ll 3.'-.5",z "ST"E.T t-z, ~U..ll.E'~

When containment average air tempera~e is not within;li~e

(-;-\\

limit of the LCO, it must be restorea/l!o w}thin l\\aiitlwi~hin * ~

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This Required Action is necessary to return operition to within the bounds of the containment analysis.

The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is acceptable considering the sensitivity of the analysis to variations in this parameter and provides sufficient time to correct minor problems.

B.1 and B.2 If the containment average air temperature cannot be restored to within its limit.within the required Completion Time, the plant must be.brought to a MODE in whi~h the LCO does not apply.

To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to HOOE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant cond;tions from full power conditions in an orderly manner ~nd without c~allenging plant systems

SR 3.6.S.1 Verifying that containment average air temperature is within the LCO limit ensures that containment* o eration remains

_w1t n.the limit. assumed for the containment analyses.

In ~

order to det"ermini the containment average air temperature, o:r; an arithmetic average is calculated using measurements taken at locations within the containment selected to provide a representative sample of the overall containment atmosphere.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency of this SR is considered acceptable based on the observed.slow rates of temperature increase within containment.. a.s_ a-result of environmental heat sources due to the.Ja e volume of containment

urt ermore, e

our r, quency s cons *re a equa e 1n vi of other ind1cat1 s available in t e control room, in uding alarms, ~

to aler the operator to n abnormal contain nt temperature \\..!,,!

cond1t on.

B 3.6-42 (continued)

Rev 1, 04/07/95

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

3.6.5-3 JFD 4 ITS B 3.6.5 Bases SR 3.6.5.1 ITS B 3.6.5 Bases - SR 3.6.5.1 adds the following statement: "The 140°F limit is the actual limit assumed for the accident analyses and does not account for instrument uncertainties." The intent of the STS/ITS is to be more operator/inspector friendly in that the limits and parameters specified in the TS would be those numbers as read directly from the gages and instruments. If instrument uncertainties are not taken into account, this could lead to confusion as to what is the correct limit.

Comment:

Provide additional discussion and justification for the deviation from the intent of the STS/ITS.

Consumers Energy Response:

The 140°F limit is the same as that provided in CTS 3.6.3. The proposed change to the Bases provides an accurate description of the limit as established in the current licensing basis for the plant. Any change to this limit would require a change to the licensing basis, i.e., an out-of-scope change to the Technical Specifications. Based on this, the existing limit was adopted,

and its technical basis clarified through the addition of the proposed statement. No additional change is proposed.

Affected Submittal Pages:

No page changes.

41

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

3.6. 7 Hydrogen Recombiners 3.6.7-1 DOC A.3 DOC M.2 DOC LA.1 CTS 4.2 Table 4.2.2 Item 11 b.1 ITS SR 3.6.7.1 and 3.6.7.2 DOC A.3 states that the CTS wording in CTS 4.2 Table 4.2.2 Item 11.b.1 "discussing a channel calibration of all recombiner instrumentation and controls" is replaced by a system functional test as ITS SR 3.6. 7.1, not ITS SR 3.6. 7.2 which is the visual examination for abnormal conditions SR. This same discrepancy is also applicable to DOCs M.2 and LA.1.

See Comment Numbers 3.6.7-2, 3.6.7-3 and 3.6.7-6.

Comment:

Correct this discrepancy. See Comment Numbers 3.6.7-2, 3.6.7-3 and 3.6.7-6.

Consumers Energy Response:

DOC A.3 incorrectly referred to SR 3.6.7.2, the correct reference is SR 3.6.7.1. DOC A.3 has been revised. Other issues related to SR 3.6.7.1 versus SR 3.6.7.2 are addressed in the responses to RAI Comment Nos. 3.6.7-2, -3, and -6.

Affected Submittal Pages:

Att 3, DOC 3.6.7, page 1 of 5 42

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.7, HYDROGEN RECOMBINERS ADMINISTRATIVE CHANGES (A)

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

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

During Improved Technical Specification (ITS) development certain wording preferences or English language conventions were adopted which resulted in no technical changes (either actual or implied) to the TS. Additional information has also been added to more fully describe each subsection. This wording is consistent with NUREG-1432. Since the design is already approved by the NRC, adding more details

does not result in a technical change.

A.2 CTS 3.6.4 requires that two hydrogen recombiners be OPERABLE when the plant is in "POWER OPERATION or HOT STANDBY." The proposed ITS has an Applicability of MODES 1 and 2. The CTS reactor operating conditions of POWER OPERATION and HOT ST AND BY are nominally operationally equivalent as discussed in TS A.3 Section 1.1, Definitions. Therefore, this is considered to be an administrative change to adopt the MODE definitions from NUREG-1432.

CTS Table 4.2.2 Item 11.b.l requires that a channel calibration of all recombiner instrumentation and control circuits be performed at least once per refueling cycle (18 months in ITS). There ~e no actuation circuits for the hydrogen recombiners as they are manually initiated from a control panel in the auxiliary building. The system is verified to be OPERABLE by a functional test which verifies that the heaters are working properly. Therefore, the CTS wording discussing a "channel calibration of all recombiner instrumentation and controls" is replaced by a system functional test in proposed ITS SR 3.6.7

'This is considered to be an administrative change since all of the recombiner functions will be tested to be working properly as part of the system functional test. This change 1s consistent with NUREG-1432.

Palisades Nuclear Plant Page 1 of S 01/20/98

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

3.6.7-2 DOC M.2 CTS 4.2. Table 4.2.2 Item 11.b.1 ITS SR 3.6.7.1 and Associated Bases The OPERABILITY requirements for each hydrogen recombiner as stated in ITS B 3.6. 7 Bases

- BACKGROUND requires at least one containment cooling post-OBA fan OPERABLE to perform the hydrogen mixing function. DOC M.2 describes the need for a new ITS SR 3.6.7.1 that verifies the OPERABILITY of only the post-OBA fan V-4A. The ITS markup does not show this SR. ITS SR 3.6.7.1 performs a system functional test (See Comment Number 3.6.7-1).

There appears to be some confusion and concern for the reliability of the non-safety-related Containment Air Cooler (CAC) VHX-4 that does not provide a post-OBA containment cooling function in ITS 3.6.6. The fan V-4A associated with CAC VHX-4 is taken credit for as providing a hydrogen mixing function in ITS 3.6.7; and in ITS 3.6.6, it is also credited for operating in conjunction with the two required containment spray pump trains associated with the diesel generator 1-1 to ensure the full capacity to mitigate the OBA. The presence of this DOC M.2 raises concern about which CACs are really verified in ITS SR 3.6.6.2, SR 3.6.6.4 and SR 3.6.6.8. There should be no need for the DOC M.2 new SR proposed because it should be redundant to the SR 3.6.6.2-1 See Comment Numbers 3.6.6-1, 3.6.6-2, 3.6.6-3, 3.6.6-23, 3.6.6-24, 3.6.7-1, 3.6.7-3, 3.6.7-6 AND 3.6.7-7.

Comment:

Does ITS SR 3.6.6.2 verify the OPERABILITY of the normal rated fan and the post-OBA fan in each CAC unit every 31 days?: Provide a safety basis for how ITS 3.6.6 and ITS 3.6. 7 can both rely upon the same non-safety-related CAC VHX-4 under the governing requirements provided in these proposed improved technical specifications. Provide additional discussion and justification on the need for this new SR. See Comment Numbers 3.6.6-1, 3.6.6-2, 3.6.6.-3, 3.6.6-23, 3.6.6-24, 3.6.7-1, 3.6.7-3, 3.6.7-6 and 3.6.7-7.

Consumers Energy Response:

Palisades containment design utilizes four containment air coolers. Each cooler consists of one safety related (SR) fan, one non-safety related fan, and a heat exchanger. This equipment is arranged as follows:

SR Fan V-1A V-2A V-3A V-4A Non-SR Fan V-1B V-2B V-3B V-4B Heat Exchanger VHX-1 VHX-2 VHX-3 VHX-4 Assoc. Diesel Generator 1-2 (Right Train) 1-2 (Right Train) 1-2 (Right Train) 1-1 (Left Train)

Only the safety related fans can be powered from the associated diesel generator. Non-SR fans are not in operation or credited following a postulated accident.

Following a postulated accident, the heat exchangers associated with Right Train, diesel generator 1-2, are in operation and credited in containment analyses. These three heat exchangers are aligned automatically on receipt of a Safety Injection Signal (SIS) for maximum cooling (their high capacity service water outlet valves are opened.)

43

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

3.6.7-2 Consumers Energy Response: (continued)

The Left Train VHX-4 heat exchanger is isolated from the service water system automatically upon receipt of a SIS signal. This Left Train heat exchanger is not credited for heat removal after an accident - the Containment Spray System is credited for heat removal from the containment when only the Left Train is in service. The Left Train safety related fan, V-4A is credited following a postulated accident with circulating containment atmosphere from unsprayed areas to sprayed areas, assisting in the removal of iodine and cooling of the atmosphere.

During normal plant operations, all eight fans are typically in operation, removing heat from the containment building.

Following a postulated accident, the containment atmosphere must be also mixed to assure that pockets of elevated hydrogen concentration do not accumulate. As described in the Bases Background for 3.6.7, the Palisades analyses assume that at least one fan is in operation during the entire time containment sprays are operating. For the recombiner associated with diesel generator 1-2, any one of the three SR fans (V-1A, V-2A, or V-3A) is adequate to support this function. For the recombiner associated with the 1-1 diesel generator, SR fan V-4A must be OPERABLE to support the OPERABILITY of the recombiner. Additional information is provided in the response to RAI comment 3.6.7-7.

As discussed i[I the RAI comment, SRs in Specification 3.6.6 ensure that at least one containment cooling fan associated with each diesel generator is OPERABLE to support mixing of the containment atmosphere as discussed in the Bases of ITS 3.6.7. Therefore, DOC M.2, and the associated CTS markup h~ve been deleted. The CTS markup of Specification 3.6.7 has been edited to reflect this renumbering in the cross-reference notation provided on the left side of CTS page 4-12. Additional information is provided with the responses to the listed comments associated with Specification 3.6.6.

Affected Submittal Pages:

Att 3, CTS, page 4-12 Att 3, DOC 3.6.7, page 2 of 5 44

4.2

('£!>-

Hydrogen Recombiners Each

~~;~{,~ 5~ 3.i.:1.fll, er unit re 700"F, Verify that

As 111tas red b install* or portable tem raturt measuring nstruments.

4*12 11-()__/

Amendment Ho. 811 99, 162 October 26, 1994

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.7, HYDROGEN RECOMBINERS MORE RESTRICTIVE CHANGES (M)

M.1 CTS 3.6.4 for the hydrogen recombiners requires that the inoperable recombiner be restored-to OPERABLE status within 30 days or be in at least "HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ." The proposed ITS requires that if the Required Action and Associated Completion Time not met the plant must be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

The CTS HOT SHUTDOWN is nominally operationally equivalent to the ITS M.2 MODE 3 as discussed in TS Section 1.1. However, the proposed ITS requires that MODE 3 be reached in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months as opposed to the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to reach HOT SHUTDOWN which is allowed by the CTS and therefore this change is considered to be more restrictive. This change is consistent with NUREG-1432.

.. ht "'"'-~*

The proposed ITS ds SR 3. 6. 7.1 to o rate containment c ling fan V-4A for

~ 15 minutes eve 31 days to ensure e fan is working p perly. The conta*

cooling post-D A fans are utilized performing a hydr gen mixing functio to limit the local hyd gen concentration below the flarnma ity limit. The pos associated 1th Containment Ai Coolers (CACs)

-1, VHX-2, and X-3 also provide ontainment coolin function in conjunc *on with the coolers The require ents for the cooler and fans associated ith CAC VHX-1,

-2 and VH are addressed in oposed ITS 3.6.6, " ontainment Coor Systems." Since C

VHX-4 does not ovide a post-DBA ntainment cooling nction, it is not a tlressed in LCO 3.. o. However, fan V A which is associ d with CAC VHX aken credit for as oviding a hydroge

ing function.

refore, it is includ as part of the hydro n recombiner OPE ILITY requirem ts since it helps to nsure that the hydrog

is maintained belo the flammability r *t. Proposed SR.6. 7.1 is added to prov* e verification that V-4A is functio

g properly in order o ensure it will be avai ble to perform its ing function. Sin e requirements for ntainment cooling f:

V-4A is not inclu din the CTS, its a ition in the propos ITS is conside d to a more restric

e change.

Palisades Nuclear Plant Page 2 of 5 01/20/98

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

3.6.7-3 DOC LA.1 CTS 4.2 Table 4.2-2 Item 11.a ITS SR 3.6.7.1 and Associated Bases CTS 4.2 Table 4.2-2 Item 11.a specifies the acceptance criteria for the hydrogen recombiner functional test. DOC LA.1 states that the acceptance criteria is not included in ITS SR 3.6.7.1, but will be contained in the Bases. Not all of this information has been relocated to the Bases.

The Staff cannot find the information contained in the *Footnote associated with CTS 4.2 Table 42-2 Item 11.a in the ITS Bases for 3.6.7.. See Comment Numbers 3.6.7-1 and 3.6.7-2.

Comment:

Revise the ITS markup of ITS B 3.6.7 Bases - SR 3.6.7.1 to include the information in CTS 4.2 Table 4.2-2 Item 11.a - *Footnote or provide a discussion and justification for its deletion.

Consumers Energy Response:

Footnote

to CTS 4.2, Table 4.2-2 indicates that the minimum temperature limit acceptance criteria for the functional test of the recombiner sheath temperature increase may be

"... measured by installed or portable temperature monitoring instruments." This footnote provides no substantive information related to performing the surveillance since any measurement of the temperature must occur with either installed or portable temperature monitoring instruments, i.e. no other type of temperature monitoring instrument exists. The removal of this information is described in new Description of Change L.3 and associated NSHC.

Affected Submittal Pages:

Att 3, CTS, page 4-12 Att 3, DOC 3.6.7, page 5 of 5 Att 4, NSHC 3.6. 7, page 4 of 4 45

4.2

~ Hydrogen Reeomb1ners er unit re 700'F, Verify that a 1 1

17\\

3 Ver1fy1ng the 1ntegr1ty of 111 h11ter 1l1ctr1t1l s" J.~. Ji.)

or portable tem rature measuring nstru1111nts.

4-12 Z/.!f-cv Amendment No. 811 99, 162 October 26, 1994

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.7, HYDROGEN REC.:OMBINERS L.2 CTS Table 4.2-2 Item 11.a specifies that a hydrogen recombiner unit functional test be performed at least once per 6 months for each unit. The proposed ITS SR 3.6T'Q) ~~~-<..

specifies that this test be perfortl)ed every 18 months. The change from 6 months to 18 months is acceptable because the hydrogen recombiners generally pass the surveillance when performed at the 6 month frequency. In addition, the design of the recombiner is simple in that it is simply relying on heat to recombine hydrogen and oxygen. A 100% capacity fully redundant hydrogen recombiner is also available and maintained OPERABLE. This is considered to be a less restrictive change since the hydrogen recombiner test will be performed every 18 months instead of the current every 6 months.

Palisades Nuclear Plant Page 5 of 5 01/20/98

DOC L.3 to-3.6.7 CTS Table 4.2-2, Footnote

to Item 11.a requires that the minimum recombiner heater sheath temperature increase be measured using installed or portable temperature monitoring instrumentation. This detail is being removed from proposed SR 3. 6. 7.1 and its associated Bases. This footnote provides no substantive requirement since any measurement of temperature must use either installed or portable temperature monitoring instrumentation. This change will not effect operation of the facility and is consistent with NUREG-1432.

~5 -e__

ATTAC1'ENT 4 NO SIGNIFICANT HAZARDS CONSIDERATION SPECIFICATION 3.6. 7, HYDROGEN RECOMBINERS

2.

Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change does not involve a physical alteration of the plant. No new or different type of equipment will be installed or changes made to plant parameters which govern normal plant operation. The proposed change will allow the system functional test to be performed every 18 months rather than the existing 6 month frequency. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does this change involve a significant reduction in a margin of safety?

The proposed change allows the surveillance interval for performing the system functional test on the hydrogen recombiners to be changed from 6 months to 18 months. The margin of safety afforded by the hydrogen recombiners are to ensure that the hydrogen concentration is minimized by burning the hydrogen before it reaches an explosive concentration. Extending the surveillance interval from 6 months to 18 months is based on the fact that the test is normally successful when performed at a 6 month frequency and is also expected to pass the 18 month frequency based on engineering judgement. If for some reason the hydrogen recombiner was inoperable during the 18 month interval, but the inoperability was not known, a_n OPERABLE hydrogen recombiner is still available and is:* sufficient to ensure that the hydrogen concentration does not exceed the flammability limit. Therefore, this change does not involve a significant reduction in a margin of safety.

. t. _____ _

c.... '>c...,-\\-

k... "'> C4.. w.... k~ e~

\\...~5

~~"\\.-;""- ~

\\..*" r Palisades Nuclear Plant Page 4 of 4 01/20/98 115-J

NSHC for L.3 to 3.6.7 LESS RESTRICTIVE CHANGE L.3 CTS Table 4.2-2, Footnote

to Item 11.a requires that the minimum recombiner heater sheath temperature increase be measured using installed or portable temperature monitoring instrumentation. This detail is being removed from proposed SR 3. 6. 7.1 and its associated Bases. This footnote provides no substantive requirement since any measurement of temperature must use either installed or portable temperature monitoring instrumentation. This change will not effect operation of the facility and is consistent with NUREG-1432.

1.

Does the change involve a significant increase in the probability or consequence of an accident previously evaluated?

The removal of this detail does not have an effect on the way the plant is operated. The Hydrogen Recombiners are provided for use following a postulated accident that results in generation of combustible gas in the containment building. The Hydrogen Recombiners are not an initiator for any previously analyzed accident. Therefore removing this detail from the surveillance testing requirements associated with the Hydrogen Recombiners does not effect the probability of any accident previously evaluated.

The consequences of a previously analyzed event are dependent on the initial conditions assumed for the analysis, and the availability and successful functioning of the equipment assumed to operate in response to the analyzed event. The method of performing the temperature measurement that is part of the surveillance testing for the system does not effect the ability of the Hydrogen Recombiner to perform its safety function. Therefore, the proposed change does not involve a significant increase in the consequences of an accident previously evaluated.

2.

Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change does not involve a physical alteration of the plant. No new or different type of equipment will be installed or changes made to plant parameters which govern normal plant operation. The proposed change will remove the detail provided in footnote

that indicates the sheath heater temperature increase is to be measured using installed or portable instrumentation. Any measurement of temperature requires the use of either installed or portable instrumentation, and the proposed detail does not have a substantive effect on the way the required measurements are made. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does-this change involve a significant reduction in a margin of safety?

The proposed change will remove the detail provided in footnote

that indicates the sheath heater temperature increase is to be measured using installed or portable instrumentation. Any measurement of temperature requires the use of either installed or portable instrumentation, and the proposed detail does not have a substantive effect on the way the required measurements are made. The margin of safety afforded by the hydrogen recombiners is to ensure that the hydrogen concentration is minimized by burning the hydrogen before it reaches an explosive mixture. The removal of this unnecessary detail from the Technical Specifications will not effect the way testing is performed or the availability of the required Hydrogen Recombiners. Therefore, this change does not involve a significant reduction in a margin of safety.

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

3.6.7-4 DOC LA.2 CTS 4.2 Table 4.2-2 Item 11.b.3 CTS 4.2 Table 4.2-2 Item 11.b.3 specifies that the integrity check of the recombiner heater electrical circuits is to be performed "immediately following the above functional test." This information according to DOC LA.2 is being relocated to plant procedures. It is unclear from the discussion in DOC LA.2 if the procedure change control process is covered by 10 CFR 50.59 or some other non-regulatory control process. If the procedure change control process is hot covered by 10 CFR 50.59 then the change is a Less Restrictive (L) change deletion of material rather than a Less Restrictive (LA) change. Less Restrictive (LA) changes are limited to those items which are relocated to licensee controlled documents covered by a 10 CFR 50.59 change control process.

Comment:

Provide additional discussion and justification on the plant procedure change control process.

Consumers Energy Response:

The requirement to perform an integrity check of the recombiner heater electrical circuits immediately after the functional test as described in CTS 4.2, Table 4.2-2 item 11.b.3 is being deleted. The removal of this requirement is described in new Description of Change L.4 and associated NSHC..

Affected Submittal Pages:

Att 3, CTS page 4-12 Att 3, DOC 3.6.7, page 3 of 5 Att 3, DOC 3.6.7, page 5 of 5 Att 4, NSHC 3.6. 7 46

4.2 t£!>-

Hydrogen Recomb1ners Each b* demonstrated Qperable:

er unit

As rnus red b 1nsta11t or porhblt tem raturt measuring nstruments.

Amendment No. 811 99, 162 October 26, 1994

ATTACHMENT3 DISCUSSION OF CHANGES SPECIFICATION 3.6.7, HYDROGEN RECOMBINERS LESS RESTRICTIVE CHANGES-REMOVAL OF DETAILS TO LICENSEE CONTROLLED DOCUMENTS (LA)

LA.1 LA.2 CTS Table 4.2-2 Item 11.a specifies the acceptance criteria for the hydrogen recombiner functional test. This acceptance criteria is not included in the proposed ITS SR 3.6.7.1 as it will be contained in the Bases. The proposed ITS SR 3.6.7.l will require that the functional test be performed but the Bases will contain the more detailed information with respect to performance and acceptance criteria. Changes to the Bases are made in accordance with the Bases Change Control Program which is specified in TS Chapter 5.0. This change is consistent with NUREG-1432.

\\\\Jo'° u~

CT Table 4.2-2 Item

.b.3 specifies that e integrity check a heater electrical ci cuits is to be perfo ed "immediately llowing the above quiredfunctional hese details are de ribing test conditi which must bee blished in order ti data to be valid.

s information is ore appropriate for lant procedures.

Therefore, the p posed ITS SR 3.6.3 does not includ the statement that e

integrity check :ust be performed ediately follow* g the required fun 10nal test as this informaf n will be addresse in plant procedure. Changes to plant rocedures are made i accordance with t plant procedure c ge process. This hange is consisten ith NUREG-143.

Palisades Nuclear Plant Page 3 of 5 01/20/98

L.2 ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.7, HYDROGEN REC.:OMBINERS CTS Table 4.2-2 Item 11.a specifies that a hydrogen recombiner unit functional test be performed at least once per 6 months for each unit. The proposed ITS SR 3.6.T"(D ~~~-C..

specifies that this test be performed every 18 months. The change from 6 months to 18 months is acceptable because the hydrogen recombiners generally pass the surveillance when performed at the 6 month frequency. In addition, the design of the recombiner is simple in that it is simply relying on heat to recombine hydrogen and oxygen. A 100 % capacity fully redundant hydrogen recombiner is also available and maintained OPERABLE. This is considered to be a less restrictive change since the hydrogen recombmer test will be performed every 18 months instead of the current every 6 months.

Palisades Nuclear Plant Page 5 of 5 01/20/98

DOC L.4 to-3.6.7 CTS Table 4.2-2, Item 11.b.3 requires the integrity check of the recombiner heater electrical circuits to be performed "immediately following" the system functional test of Item 11.a.

This detail is an initial condition for performing the measurements required by proposed SR 3. 6. 7. 3. As such, this detail is more suitable for inclusion in plant procedures and is proposed to be deleted from the specifications. This is consistent with other.testing where particular equipment configurations or conditions are required to be met to successfully complete the surveillance testing. This change is consistent with NUREG-1432.

ATTAC1'ENT 4 NO SIGNIFICANT HAZARDS CONSIDERATION SPECIFICATION 3.6. 7, HYDROGEN RECOMBINERS

2.

Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change does not involve a physical alteration of the plant. No new or different type of equipment will be installed or changes made to plant parameters which govern normal plant operation. The proposed change will allow the system functional test to be performed every 18 months rather than the existing 6 month frequency. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does this change involve a significant reduction in a margin of safety?

The proposed change allows the surveillance interval for performing the system functional test on the hydrogen recombiners to be changed from 6 months to 18 months. The margin of safety afforded by the hydrogen recombiners are to ensure that the hydrogen concentration is minimized by burning the hydrogen before it reaches an explosive concentration. Extending the surveillance interval from 6 months to 18 months is based on the fact that the test is normally successful when performed at a 6 month frequency and is also expected to pass the 18 month frequency based on engineering judgement. If for some reason the hydrogen recombiner was inoperable during the 18 month interval, but the inoperability was not known, a_n OPERABLE hydrogen recombiner is still available and is sufficient to ensure that the hydrogen concentration does not exceed the flammability limit. Therefore, this change does not involve a significant reduction in a margin of safety.

ks~ ~~W.:c.\\{~ e~

7 3.<..'7 -3

r.... '>u,~

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Palisades Nuclear Plant Page 4 of 4 01/20/98

NSHC for LA to 3.6.7 LESS RESTRICTIVE CHANGE L.4 CTS Table 4.2-2, Item 11. b.3 requires the integrity check of the recombiner heater electrical circuits to be performed "immediately following" the system functional test of Item 11.a. This detail is an initial condition for performing the measurements required by proposed SR 3.6.7.3. As such, this detail is more suitable for inclusion in plant procedures and is proposed to be deleted from the specifications. This is consistent with other testing where particular equipment configurations or conditions are required to be met to successfully complete the surveillance testing. This change is consistent with NUREG-1432.

1.

Does the change involve a significant increase in the probability or consequence of an accident previously evaluated?

The proposed change would remove the detail of an initial condition for performing the integrity check of the recombiner heater electrical circuit. Conditions and special equipment alignments are controlled by plant procedures which describe details of how surveillance testing is performed. The proposed change does not cause a change in the way surveillance testing is performed, it merely removes a level of detail that is unnecessary for inclusion in the specifications. The Hydrogen Recombiners are not an initiator for any previously analyzed accident. Therefore removing this detail from the surveillance testing requirements associated with the Hydrogen Recombiners does not effect the probability of any accident previously evaluated.

The consequences of a previously analyzed event are dependent on the initial conditions assumed for the analysis, and the availability and successful functioning of the equipment assumed to operate in response to the analyzed event. The method of performing the temperature measurement that is part of the surveillance testing for the system does not effect the ability of the Hydrogen Recombiner to perform its safety function. Therefore, the proposed change does not involve a significant increase in the consequences of an accident previously evaluated.

2.

Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change does not involve a physical alteration of the plant. No new or different type of equipment will be installed or changes made to plant parameters which govern normal plant operation. The proposed change will merely remove the detail of an.initial condition to perform a check of the integrity of the electrical heater circuits of the recombiners. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does*this change involve a significant reduction in a margin of safety?

The proposed change will remove the detail of an initial condition for performing the integrity check of the electrical heater circuits of the Hydrogen Recombiners. The margin of safety afforded by the hydrogen recombiners is to ensure that the hydrogen concentration is minimized by burning the hydrogen before it reaches an explosive mixture. The removal of this unnecessary detail from the Technical Specifications will not effect the way testing is performed or the availability of the required Hydrogen Recombiners. Therefore, this change does not involve a significant reduction in a margin of safety.

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

3.6.7-5 DOC LA.4 CTS 4.2 Table 4.2-2 Item 11.b.2 CTS 4.2 Table 4.2-2 Item 11.b.2 provides examples of hydrogen recombiner abnormal conditions which are identified by visual examination. This information according to DOC LA.4 is being relocated to plant procedures. It is unclear from the discussion in DOC LA.4 if the procedure change control process is covered by 10 CFR 50.59 or some other non-regulatory control process. If the procedure change control process is not covered by 1 O CFR 50.59 then the change is a Less Restrictive (L) change deletion of material rather than a Less Restrictive (LA) change. Less Restrictive (LA) changes are limited to those items which are relocated to licensee controlled documents covered by a 10 CFR 50.59 change control process.

Comment:

Provide additional discussion and justification on the plant procedure change control process.

Consumers Energy Response:

The descriptive examples of abnormal conditions listed in CTS 4.2, Table 4.2-2 item 11.b.2 are being deleted. The removal of this requirement is described in new Description of Change L.5 and associated NSHC.

Affected Submittal Pages:

Att 3, CTS, page 4-12 Att 3, DOC 3.6.7, page 4 of 5 Att 3, DOC 3.6.7, page 5 of 5 Att 4, NSHC 3.6.7, page 5 of 5 47

4.2

~ Hydrogen Reeombiners Eacn be demonstrated ~perable:

or portable tem raturt measuring nstruments.

4*12 11-0-/

Amendment No. 81 1 99, 162 October 26, 1994

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.7, HYDROGEN RECOMBINERS LA.3 CTS Table 4.2-2 Item b.3 specifies that for the electrical circuit integrity check "The resistance to ground for any hea:ter element shall be ~ 10,000 ohms." This acceptance criteria is not included in the proposed ITS and will be contained in the Bases.

Changes to the Bases are made in accordance with the Bases Change Control Program which is specified in TS Chapter 5.0. This change is consistent with NUREG-1432.

LA.4 Item 11. b.2 prov* es examples of abn ugh visual examina 'ons with the follow' wording."(i.e., loo wmng connections, depo

s of foreign materia, etc.)." Specific vi al examin on criteria are cove d in plant procedur and therefore these amples of some f the criteria are no ncluded in the prop ed ITS. Changes to lant procedures are i::ldressed as part of e plant procedure c nge process. This c nge is.consistent w* h NUREG-1432.

LESS RESTRICTIVE CHANGES (L)

L.1 In proposed ITS 3.6.7 Action A, a note is added which is not contained in the CTS.

The note states "LCO 3.0.4 is not applicable." By specifying that LCO 3.0.4 is not applicable, the plant would be allowed to change MODES while relying on an Action statement for an inoperable hydrogen recombiner. This is acceptable given the long Completion Time of 30 days if one recombiner is inoperable which indicates that this system is not of immediate importance following an accident. Another redundant hydrogen recombiner also is required to be OPERABLE. and is sufficient to maintain hydrogen below the flammability limit in the event of a design basis accident. This is considered to be a less restrictive change since in the proposed ITS, the plant would be allowed to change MODES while relying on an Action as opposed to the CTS which would not allow this. This change is consistent with NUREG-1432.

Palisades Nuclear Plant Page 4 of S 01/20/98

L.2 ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6. 7, HYDROGEN REC.:OMBINERS CTS Table 4.2-2 Item 11.a specifies that a hydrogen recombiner unit functional test be performed at least once per 6 months for each unit. The proposed ITS SR 3.6.T'(D ~~.~-Co specifies that this test be performed every 18 months. The change from 6 months to 18 months is acceptable because the hydrogen recombiners generally pass the surveillance when performed at the 6 month frequency. In addition, the design of the recombiner is simple in that it is simply relying on heat to recombine hydrogen and oxygen. A 100% capacity fully redundant hydrogen recombiner is also available and maintained OPERABLE. This is considered to be a less restrictive change since the hydrogen recombiner test will be performed every 18 months instead of the current every 6 months.

Palisades Nuclear Plant Page 5 of 5 01/20/98

DOC L.5 to 3.6.7 CTS Table 4.2-2, Item 11.b.2 lists examples of abnormal conditions that are to be sought during the visual examination of the hydrogen recombiners. These examples are neither exhaustive or explicit. These examples do not provide direction or limitations regarding the conduct of the required examination. As such, these details are more suitable for inclusion in plant procedures and are proposed to be deleted from the specifications. This change is consistent with NUREG-1432.

17-J

2.

ATTAC1'ENT 4 NO SIGNIFICANT HAZARDS CONSIDERATION SPECIFICATION 3.6.7, HYDROGEN RECOMBINERS Does the change create the. possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change does not involve a physical alteration of the plant. No new or different type of equipment will be installed or changes made to plant parameters which govern normal plant operation. The proposed change will allow the system functional test to be performed every 18 months rather than the existing 6 month frequency. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does this change involve a significant reduction in a margin of safety?

The proposed change allows the surveillance interval for performing the system functional test on the hydrogen recombiners to be changed from 6 months to 18 months. The margin of safety afforded by the hydrogen recombiners are to ensure that the hydrogen concentration is minimized by burning the hydrogen before it reaches an explosive concentration. Extending the surveillance interval from 6 months to 18 months is based on the fact that the test is normally successful when performed at a 6 month frequency and is also expected to pass the 18 month frequency based on engineering judgement. If for some reason the hydrogen recombiner was inoperable during the 18 month interval, but the inoperability was not known, ~m OPERABLE hydrogen recombiner is still available and is sufficient to ensure that the hydrogen concentration does not exceed the flammability limit. Therefore, this change does not involve a significant reduction in a margin of safety.

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I...*" r Palisades Nuclear Plant Page 4 of 4 01/20/98

NSHC for L.5 to 3.6.7 LESS RESTRICTIVE CHANGE L.5 CTS Table 4.2-2, Item 11.b.2 lists examples of abnormal conditions that are to be sought during the visual examination of the hydrogen recombiners. These examples are neither exhaustive or explicit. These examples do not provide direction or limitations regarding the conduct of the required examination. As such, these details are more suitable for inclusion in plant procedures and are proposed to be deleted from the specifications. This change is consistent with NUREG-1432.

1.

Does the change involve a significant increase in the probability or consequence of an accident previously evaluated?

The proposed change would remove examples of conditions that are to be considered during the visual examination of the Hydrogen Recombiners. These examples do not provide direction or limits that must be verified. Neither do are they an exhaustive list of conditions that should be considered. Since the examples provide no guidance or limits, removing this detail from the surveillance testing requirements associated with the Hydrogen Recombiners does not effect the testing or operability of the recombiners.

in any way. Since no effect on the recombiners will occur, the probability of any accident previously evaluated is not effected.

The consequences of a previously analyzed event are dependent on the initial conditions assumed for the analysis, and the availability and successful functioning of the equipment assumed to operate in response to the analyzed event. The presence or lack of example conditions does not effect the ability of the Hydrogen Recombiner to perform its safety function. Therefore, the proposed change does not involve a significant increase in the consequences of an accident previously evaluated.

2.

Does the change create-the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change does not involve a physical alteration of the plant. No new or different type of equipment will be installed or changes made to plant parameters which govern normal plant operation. The proposed change will merely remove the detail of example conditions to be considered during the visual inspection of the recombiners.

Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does this change involve a significant reduction in a margin of safety?

The proposed change will remove examples of conditions to be considered during the visual examination of the Hydrogen Recombiners. The margin of safety afforded by the hydrogen recombiners is to ensure that the hydrogen concentration is minimized by burning the hydrogen before it reaches an explosive mixture. The removal of this unnecessary detail from the Technical Specifications will not effect the way testing is performed or the availability of the required Hydrogen Recombiners. Therefore, this change does not involve a significant reduction in a margin of safety.

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

3.6.7-6 DOC L.2 JFD 10 CTS 4.2 Table 4.2-2 Item 11.a ITS SRs 3.6.7.1, 3.6.7.2, 3.6.7.3, 3.6.7.4, 3.6.8.1 and Associated Bases CTS 4.2 Table 4.2-2 Item 11.a specifies a hydrogen recombiner functional test be performed at least one per 6 months. DOC L.2 states that this SR is ITS SR 3.6.8.1. The CTS markup shows this SR as ITS SR 3.6.7.2 while the ITS markup shows this SR as ITS SR 3.6.7.1. In addition, the CTS and ITS markups and the DOCs do not correlate with regards to the SR numbers. See Comment Numbers 3.6.7.1 and 3.6.7.2.

Comment:

Correct these discrepancies. See Comment Numbers 3.6.7-1 and 3.6.7-2.

Consumers Energy Response:

The reference to ITS SR 3.6.8.1 in DOC L.2 has been revised to correctly refer to ITS 3.6.7.1.

The CTS markup has been revised to indicate that Table 4.2-2, Items 11.a and 11.b.1 are now addressed by 3.6.7.1. The subsequent SRs have been renumbered, and the reference to add a new SR 3.6.7.1 has been deleted.

Affected Submittal Pages:

Att 3, CTS, page 4-12 Att 3, DOC 3.6.7, page 5 of 5 48

4.2

~ Hydrogen Reeombiners Sf< 3.b.1.rj)\\

~

bt demonstrated ~perable:

er unit

~.(,,-.- L or portable tem raturt measuring nstruments.

4*12 4-f3~

Amendment Ho. 811 99, 162 October 26, 1994

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6.7, HYDROGEN REC.:OMBINERS L.2 CTS Table 4.2-2 Item 11.a specifies that a hydrogen recombiner unit functional test be performed at least once per 6 months for each unit. The proposed ITS SR 3.6.T'G) ~~~-<..

specifies that this test be perfoqned every 18 months. The change from 6 months to 18 months is acceptable because the hydrogen recombiners generally pass the surveillance when performed at the 6 month frequency. In addition, the design of the recombiner is _simple in that it is simply relying on heat to recombine hydrogen and

. oxygen. A 100% capacity fully redundant hydrogen recombiner is also available and maintained OPERABLE. This is considered to be a less restrictive change since the hydrogen reconibiner test will be performed every 18 months instead of the current every 6 months.

Palisades Nuclear Plant Page 5of5 01/20/98 l/8-b

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

3.6.7-7 JFO 9 ITS B 3.6.7 Bases - LCO ITS B 3.6.7 Bases - LCO states the following: "In addition, one safety related containment cooling fan in each train must be in operation to ensure adequate mixing of the containment atmosphere in a post-OBA environment." JFO 9 states that the fan must be OPERABLE, while the sentence in the ITS implies that the fan must be in operation, i.e., running, at all times (normal and accident conditions). This would also conflict with the requirements of ITS 3.6.6.

Comment:

Revise the ITS markup to clearly indicate what is required to be OPERABLE and what is required to be in OPERATION during normal and accident conditions.

Consumers Energv Response:

The first paragraph of ITS 3.6. 7 Bases - LCO has been revised to clarify that at least one cooling fan is needed for operation in a post-OBA environment to ensure adequate mixing of the containment atmosphere.

As described in the response to comment 3.6. 7-2, cooling fan operation is a Hydrogen Recombiner support function needed if the Hydrogen Recombiners are being used following a postulated event. In this support role, a safety related fan on each train must be in operation when containment spray is in operation.

For Containment Cooling Systems OPERABILITY, the four safety related containment air cooler fans must also be OPERABLE and in operation. The fans are required to be in operation because they only receive an automatic initiation signal from the OBA sequencer. Therefore if an accident occurs with offsite power available, the fans must be in operation to support the Containment Cooling function. This requirement is independent of, and unrelated to, the recombiner support function of one fan associated with each OPERABLE recombiner on the same train.

Affected Submittal Pages:

Att 2, ITS 3.6.7, page B 3.6.7-3 Att 5, ITS 3.6.7, page B 3.6-72 Att 5, ITS 3.6.7, page B 3.6-72 insert 49

BASES Hydrogen Recombiners B 3.6.7 APPLICABLE The hydrogen recombiners provide for controlling the bulk SAFETY ANALYSES hydrogen concentration in containment to less than the lower flammable concentration of 4.1 v/o following a OBA.

This control would prevent a containment wide hydrogen burn, thus ensuring the pressure and temperature assumed in the analysis are not exceeded and minimizing damage to safety related equipment located in containment.

The limiting ORA relative to hydrogen generation is a LOCA.

LCO RAI 3,1,.1 _, 7 Hydrogen may accumulate within containment following a LOCA as a result of:

a.

A metal steam reaction between the zirconium fuel rod cladding and the primary coolant;

b.

Radiolytic decomposition of water in the Primary Coolant System (PCS) and the containment sump;

c.

Hydrogen in the PCS at the time of the LOCA (i.e.,

hydrogen dissolved in the primary coolant and hydrogen gas in the pressurizer vapor space); or

d.

Corrosion of metals exposed to Containment Spray System and Emergency Core Cooling Systems solutions.

To evaluate the potential for hydrogen accumulation in containment following a LOCA, the hydrogen generation as a function of time following the initiation of the accident is calculated. Conservative assumptions discussed in Reference 3 are used to maximize the amount of hydrogen calculated.

The hydrogen recombiners satisfy Criterion 3 of 10 CFR 50.36(c)(2).

Two hydro en recombiners must be OPERABLE.

This ensures o ra ion o at eas one y rogen rec iner in the even f a worst case si le active failur.

In addition, on safety related c tainment cooling an in each train ust be in operatic to ensure adequat mixing of the co ainment atmosphere in a post-OBA enviro ent.

Operation with at least one hydrogen recombiner ensures that the post LOCA hydrogen concentration can be prevented from exceeding the flammability limit..

Palisades Nuclear Plant B 3.6.7-3 01/20/98

</9-~

3.6.7, LCO page B 3.6.7-3 In addition, one safety related containment cooling fan associated with each train must be in operation. These requirements ensure operability of at least one hydrogen recombiner and adequate mixing of the containment atmosphere in the event of a worst case single active failure.

Replace existing insert to ISTS Bases Page B 3.6-72 with In addition, one safety related containment cooling fan associated with each train must be in operation. These requirments ensure operability of at least one hydrogen recombiner and adequate mixing of the containment atmosphere

BASES APPLICABLE SAFETY ANALYSES (continued)

LCO Hydrogen related equipment located in containment.

The limiting DBA relative to hydrogen. generation is a LOCA.

Hydrogen may accumulate within containment. following a LOCA as a.result of:

a.

b.

c.

A metal steam reaction between the zirconium fuel rod cladding and the !fi<c@~coolant;(f,,....,_~!)

I Radiolytic decome,~sition of water in the r&<ct8fl<'[""..,,.~ [)

Coolant System (liJS) and the containment sump;

~(p)

Hydrogen in the (gC"S at the time of the LOCA (i.e.,

~

hydrogen dissolved in the r. c coolant and hydrogen l gas in the pr..:ssuri zer vapor. space ; or f,..;....,...,

d.

Corrosion of metals exposed to Containment Spray System and Emergency Core Cooling Systems solutions.

To evaluate the potential for hydrogen accumulation in containment following a LOCA, the hydrogen generation as a function of time following the initiation of the acciden.~:s...-o.*---..,,

calculated. Conservative assumptions (fijeorrmetidedl *

.l;si

.-ss~.J ~

Reference 3 are used to maxim;ze the amount of hy rogen calculated.

!6j\\

(IN~~~\\">-------~~~~~~~-~~~~-

\\.J)

Operation with at least one hydrogen recombiner ensures that the post LOCA hydrogen concentration can be prevented from exceeding the flannability limit.

APPLICABILITY CEOG STS In MODES 1 and 2, two hydrogen recombiners are required to control the post LOCA hydrogen concentration within containment below its flanmability limit of 4.1 v/o, assuming a worst case single failure.

(continued)

B 3.6-72 Rev 1, 04/07/95

.SECTION 3.6 INSERT (B 3.6.7 LCO) ontainment cooling fan

ach train must be in oper 10n, to ure adequate mixing o e containment atrnosphe ma ost-DBA environrne.

\\

R.fl..L ""3.~:1-7 "5 ee

~u'-x.d iv-.~\\.

B 3.6-72 19-J

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

3.6.7-8 CTS 3.6.4 ITS LCO 3.6. 7 and Associated Bases CTS 3.6.4 states that "Two independent containment hydrogen recombiners shall be OPERABLE... " ITS LCO 3.6.7 states that "Two hydrogen recombiners shall be OPERABLE."

The word "independent" has been relocated in converting from the CTS to the ITS to ITS B 3.6. 7 Bases - BACKGROUND. No justification is provided for this Less Restrictive (LA) change.

Comment:

Revise the CTS markup and provide a discussion and justification for this Less Restrictive (LA) change.

Consumers Energy Response:

DOC LA.5 has been generated to describe the relocation of the CTS 3.6.4 requirement for "independent" trains for containment hydrogen recombiners to be OPERABLE. This information is contained in the proposed ITS Bases in the second paragraph of the Background section. As described, the independence of the recombiners is a design feature of the system.

Affected Submittal Pages:

Att 3, CTS, page 3-40 Att 3, DOC 3.6.7; page 4 of 5 50

3.6

3. 6.

3.6.2 3.6.3 3.6.S CONTAINMENT SYSTEM

~t.e 3.t...l/

2'. c... z.

u *. 1 With one or more nta1nment isolation valves in arable (1nclud1ng during performan of valve testing), maintain least one isolation valve OPERABLE n each affected penetration t t is open and either:

a.

Restor the 1noperablt valves to OPE LE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ; or

b.

Iso t1 each affected penetration 1thin 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months by use of at least o

closed and deactivated autom ic valve, closed manual valve, or ind flange; or

c.

Bt in at least HOT SHUTDOWN thin tht next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and 1n COLO UTDOWN within the followi 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

The con a1nment internal prtssurt not exceed:

a.

.S ps1g when above COLD SHUT WN and below HOT STANDBY; b

1.0 ps1g when in POWER OPE TION or HOT STANDBY.

/ /W1th containment internal pr sure above the 11mit, rester, pressure to within the limit within 1 h r, or be in at least HOT SH DOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and 1n CO SHUTDOWN w1th1n the follo n 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

e containment purge exhau and air room supp1y 1solat1on valves shall

locked closed whenever e plant 1s above COLO SHUTDOW. With one containment purge exhaus or air room supply *isolation v ve not locked closed, lock the valve osed within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in a least HOT STANDBY w1th1n the ne 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and 1n COLO SHUTDOWN thin the foll win 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

erform e

3-40

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Amendment No. ~. ~.

L-.C. o 1.o.4 ; s no+ c...tf I :c...l.l<

. ~e.e J.1..J>

I *" f I

I Se~ J.1.p.z.)

)~c.1 eo3>

6 {)-()_./

R~ I ot 2.

LA.3 ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.6. 7, HYDROGEN RECOMBINERS CTS Table 4.2-2 Item b.3 specifies that for the electrical circuit integrity check "The resistance to ground for any heater element shall be ~ 10,000 ohms." This acceptance criteria is not included in the proposed ITS and will be contained in the Bases.

Changes to the Bases are made in accordance with the Bases Change Control Program which is specified in TS Chapter 5.0. This change is consistent with NUREG-1432.

LA.4 Item 11. b.2 prov* es examples of abn ugh visual examina 'ons with the followi wording. "(i.e., loo of structu connections, depo

s of foreign materia, etc.)." Specific vi al examin on criteria are cove d in plant procedur and therefore these amples of some f the criteria are no ncluded in the prop ed ITS. Changes to lant procedures are Cldressed as part of e plant procedure c nge process. This c nge is consistent w* h NUREG-1432.

LESS RESTRICTIVE CHANGES (L)

L.1 In proposed ITS 3.6.7 Action A, a note is added which is not contained in the CTS.

The note states "LCO 3.0.4 is not applicable." By specifying that LCO 3.0.4 is not applicable, the plant would be allowed to change MODES while relying on an Action statement for an inoperable hydrogen recombiner. This is acceptable given the long Completion Time of 30 days if one recombiner is inoperable which indicates that this system is not of immediate importance following an accident. Another redundant hydrogen recombiner also is required to be OPERABLE_ and is sufficient to maintain hydrogen below the flammability limit in the event of a design basis accident. This is considered to be a less restrictive change since in the proposed ITS, the plant would be allowed to change MODES while relying on an Action as opposed to the CTS which would not allow this. This change is consistent with NUREG-1432.

Palisades Nuclear Plant Page 4 of 5 01/20/98 5()-b

3.6.7, DOC, LA.5 LA.5 CTS 3.6.4 requires two independent containment hydrogen recombiners to be OPERABLE. Descriptive information about the design of the system is not included in the proposed ITS and is included in the Bases. Changes to the Bases are made in accordance with the Bases Change Control Program which is specified in TS Chapter 5.0. This change is consistent with NUREG-1432.

50-c_

ML18066A490

Text

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