ML18068A583

Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432

ML18068A583
Person / Time
Site:	Palisades
Issue date:	05/03/1999
From:	Haskell N CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18068A584	List: ML18068A583 ML18068A585
References
RTR-NUREG-1432 NUDOCS 9905100132
Download: ML18068A583 (5)

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 May 03, 1999 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS -RESPONSE TO MARCH 17, 1999 REQUEST FOR ADDITIONAL INFORMATION - ITS SECTION 3.5, EMERGENCY CORE COOLING SYSTEM.

On January 26, 1998, Consumers Energy Company submitted a Technical Specifications Change Request (TSCR) to revise the Palisades Technical Specifications to closely emulate the Standard Technical Specifications for Combustion Engineering Plants, NUREG-1432. On March 17, 1999, the NRG requested additional information regarding Section 3.5, Emergency Core Cooling Systems, of that TSCR. This letter provides both responses to the NRG questions and editorial revisions for ITS Section 3.5 of our January 26, 1998 submittal. In addition to the response and editorial revisions concerning Section 3.5, this letter also provides a revision to Section 3.8, Electrical Power Systems, made in response to additional discussion with the NRG staff concerning that section.

The following Enclosures to this letter have been provided:

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

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

Enclosure 3 contains revised pages for Section 3.5, along with a list of revised pages and instructions for page replacement. These revised pages reflect changes resulting from our response to the RAI questions and the changes identified in Enclosure 2. Each revised page is dated for identification.

Enclosure 4 contains revised pages for Section 3.8, along with a list of revised pages and instructions for page replacement. These revised pages reflect changes resulting from additional discussions with the NRG staff concerning Section 3.8. Each revised page is dated for identification.

The changes being submitted herein do not alter the conclusions of the No Significant Hazards 1

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Considerations contained in our January 26, 1998 submittal. :i r ~6~51 28AE~ 6~8&8~ss l -P(C!f.) \ :~ t l P PDR I

SUMMARY

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

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

CONSUMERS ENERGY COMPANY RESPONSE TO MARCH 17, 1999 RAI To the best of my knowledge, the content of this response to the NRC Request for Additional Information dated March 17, 1999 concerning Section 3.5 and the response to NRC verbal inquiries concerning Section 3.8 of our January 26, 1998 License Amendment request for conversion to Improved Technical Specifications, is truthful and complete.

Director, Licensing Sworn and subscribed to before me this 3ddayof ~ 1999.

~~ (;,u~

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

My commission expires February 16, 2000

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ENCLOSURE 1 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255

• CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO MARCH 17 , 1999 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO NRC QUESTIONS SECTION 3.5, EMERGENCY CORE COOLING SYSTEMS

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO THE MARCH 17, 1999 REQUEST FOR ADDITIONAL INFORMATION SECTION 3.5, EMERGENCY CORE COOLING SYSTEMS NRC REQUEST:

3.5, ECCS-Generic 3.5.G-1 CTS 3.3.l, 4.6.3.a, & 4.6.4.a DOCs 3.5.1-LA.1 & LA.2, 3.5.2-LA.1 & LA.2, LA.l Comment: Generally, requirements moved to licensee-controlled documents should be moved to documents that are covered by some type of regulatory control such as 10 CFR 50.59, 10 CFR 50.54a, or the ITS Bases Control Program. The DOCs noted above state that the subject requirements are being moved to plant procedures.

The staff considers CTS requirements moved to plant procedures to be essentially deleted requirements since there is no longer a regulatory control mechanism associated with the requirements. Therefore, please review the subject changes and move the requirements to licensee-controlled documents covered by some type of regulatory control or reclassify the changes as less restrictive changes describing deletion of CTS requirements.

Consumers Energv Response:

CTS 4.6.3a, CTS 4.6.4a and CTS 4.2, Table 4.2.2 item 10 (DOC 3.5.1, LA.l, LA.2, LA.3, and DOC 3.5.2, LA.2, LA.3) contain details that are not necessary to describe, or are not pertinent to, any actual regulatory requirement. Thus, it is not necessary to maintain these details in documents subject to regulatory controls such as 10 CFR 50.59, 10 CFR 50.54a, or the ITS Bases Control Program.

Therefore, these details have been reclassified as less restrictive" and excluded 11 from the ITS.

Affected Submittal Pages:

Att 3, CTS pg 4-11 (ITS 3.5.1, pg 4 of 5)

Att 3, CTS pg 4-24 (ITS 3.5.1, pg 5 of 5)

Att 3, CTS pg 4-24 (ITS 3.5.2, pg 4 of 5)

Att 3, DOC 3.5.1, pg 4 of 5 Att 3, DOC 3.5.1, pg 5 of 5 Att 3, DOC 3.5.2, pg 6 of 7 Att 3, DOC 3.5.2, pg 7 of 7 Att 4, NSHC 3.5.1, pg 3 of 3 Att 4, NSHC 3.5.2, pg 4 of 4 1

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