ML18066A588

Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS

ML18066A588
Person / Time
Site:	Palisades
Issue date:	07/30/1999
From:	Haskell N CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18066A590	List: ML18066A588 ML18066A591
References
RTR-NUREG-1432 NUDOCS 9908050102
Download: ML18066A588 (4)

Text

A CMS Energy Company Palisades Nuclear Plant Tel: 616 764 2276 27780 Blue Star Memorial Highway Fax: 616 764 2490 Covert. Ml 49043 Nathan L. Haskell Director, Licensing U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS; CORRECTIONS IN RESPONSE TO NRC COMMENTS AND EDITORIAL CHANGES On January 26, 1998, Consumers Energy Company submitted a Technical Specification Change Request (TSCR) to convert the Palisades Technical Specifications to closely emulate the Standard Technical Specifications for Combustion Engineering Plants, NUREG-1432.

During their review of that submittal, the NRC staff provided several comments on the proposed Technical Specifications and the associated bases. This letter provides a revision to the instrument channel drift measurement submitted on June 11, *1999; corrections made in response to NRC comments on our RAI responses for Sections 3.3, 3.5, and 3.6; and some editorial revisions necessary for consistency within the ITS. Clean pages reflecting these changes will be provided with the certified ITS in a *later submittaL

• The following changes have been made:

1. The notes in the Surveillance Require!!'lents (SR) of several ITS Sectiof"IS have been editorially revised for consistency throughout the ITS. These changes do not alter any requirements, and are solely made to provide consistent wording of equivalent SR notes throughout the ITS. The revised wording reflects the guidance of the Writer's Guide. The changes are provided as marked-up pages in Enclosure 1.

2. Two groups of changes were made to ITS Section 3.3. These changes have been discussed with the NRC reviewer for Section 3.3.

a) The LCOs and Bases for ITS Section 3.3 have been revised to provide editorial corrections and clarifications. These changes were made in response to comments from the NRC staff review of our June 6, 1999 RAI response for ITS Section 3.3. /.A. 0\

Corrected pages, with revisions noted in the margins, are provided in Enclosure 2. f .0 9908050102 990730 'i .

! I PDR ADOCK.05000255 P ' *- .. PDR t

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b)

The marked-up of CTS page 4-77 and several DOC pages have had minor errors corrected. These pages are provided in Enclosure 2.

3. The Required Actions associated with LCO 3.5.3 have been revised to be consistent with those for a similar plant equipment condition, in LCO 3.4.6. In LCO 3.5.3, the Condition A provides Action Requirements when there are no operable Low Pressure Safety Injection (LPSI) trains; in LCO 3.4.6, Condition A provides Action Requirements when there are no operable trains of Shutdown Cooling (SOC). Since the LPSI pumps and much of the LPSI piping is used for shutdown cooling, this change makes these Action Requirements the same. Conforming changes have been made to the Bases and supporting documentation.

_ _ _ _ _ _ _T~h~i=s~c~h=a~nge was made in resRonse to a comment from the NRC staff review of ITS~------

Section 3.5. Marked-up pages, showing the changes, are provided in Enclosure 3.

4. The following changes have been made to ITS Section 3.6. A discussion of these changes is provided in Enclosure 4.

a) Several editorial changes have been made to ITS Section 3.6 in response to NRC comments from our July 1, 1999 meeting with the Staff.

b) The Service Water flow rate required by SR 3.6.6.4 for the Containment Air Coolers '.I-

. has been revised to reflect recent changes to the safety analyses and system flow balancing. A conforming change has been made to the Bases.

c) The Bases for SR 3.6.2.1 has been revised to include a clarification of the relationship between the ITS term "Containment Operability" and the Appendix J term "Containment Integrity".

Marked-up pages, showing the changes, are provided in Enclosure 4.

5. The documentation supporting several changes previously classified as "LA" changes (which moved details of requirements to procedures) have been revised and reclassified as "L" changes (which provide justification for deletion of those details). These changes have been made in response to suggestions from the NRC staff review of the ITS. The changes are provided as replacement pages in Enclosure 5.

6. The Instrument Channel Drift data submitted as Enclosure 7 to our June 11, 1999 RAI response has been revised to better explain the drift implications of our "as found" and "as left" measurements. The revised data provided in Enclosure 6 of this letter replaces the formerly submitted data in its entirety.

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SUMMARY

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

Director, Licensing C AdminlStrator, Region 111, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Enclosures 3

• CONSUMERS ENERGY COMPANY CORRECTIONS IN RESPONSE TO NRC COMMENTS AND EDITORIAL CHANGES To the best of my knowledge, the content of this submittal of corrections in response to NRC comments and editorial changes for our January 26, 1998 License Amendment request for conversion to Improved Technical Specifications, is truthful and complete.

--oirector;-ticensing--

Sworn and subscribed to before me this _ _3 0_ +-1"

._day o. f t Q.,,

= =I ? .. / 1999.

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