Text

Proposed Tech Specs Converting to Improved Tss, Consistent with NUREG-1432,Rev 1
	ML20151Z811
Person / Time
Site:	Palisades
Issue date:	09/14/1998
From:	; CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	;
Shared Package
ML18068A437	List: ML20151Z811;
References
	RTR-NUREG-1432 NUDOCS 9809220130
	Download: ML20151Z811 (100)
	v • d • e

. ~. . _-_ _. _. _ - _ -

AC Sources - Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS j

3.8.1 AC Sources-- Operating LCO 3.8.1 The following AC electrical sources shall be OPERABLE:

a. ' Two qualified circuits between the offsite transmission network and the onsite Class E AC E l Electrical Power Distribution System; andk 1 #

b. Two-Diesel Generators (DGs) each capable of supplying i one train of the onsite Class 1E AC Electrical Power Distribution System.

APPLICABILITY: MODES 1, 2, 3, and 4.

i ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ;

A. One offsite circuit A.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. (offsite source check) for OPERABLE AND offsite circuit.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months eSQ thereafter A.2 Restore offsite i

circuit to OPERABLE status. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months "f AHQ 10 days from discovery of failure to meet LCO Palisades Nuclear Plant 3.8.1-1 Amendment No. 01/20/98 9809220130 980914 l 6k f D PDR ADOCK 05000255 p PDR

l AC Sources - Operating {

3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. One DG inoperable. 8.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (offsitesource check) for the M OPERABLE offsite ci rcui t(s) . Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter M

B.2 Declare required feature (s) supported 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from 5 by the inoperable OG inoperable when its discovery of Condition B j '.

redundant required concurrent with feature (s) is inoperability of ,

inoperable. redundant requi red M feature (s) 8.3.1 Determine OPERABLE DG 1 is not inoperable.due 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months y

to common cause failure.

08 B.3.2 Perform SR 3.8.1.2 i (start test) for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months t OPERABLE DG, M

B.4 Restore DG to 7 OPERABLE status. 7 days y l

M 10 days from discovery of failure to meet LC0 l

l

Palisades Nuclear Plant 3.8.1-2 Amendment No. 01/20/98 cR ofl0

L DC Sources - Operating l

3.8.4 SURVEILLANCE REQUIREMENTS ,

SURVEILLANCE FREQUENCY SR 3.8.4.8 -------------------NOTE--------------------

This Surveillance shall not be performed in MODE 1, 2, 3, or 4.

L Verify battery capacity is 2 80% of the 60 months 4 l manufacturer's rating when subjected to a AMD performance discharge test or a modified performance discharge test. 12 months when battery shows degradation or has reached 85%

l

' of the expected life with capacity

< 100% of manufacturer's rating AHQ 24 months when battery has reached 85% of i

' the expected life with capacity 2 100% of manufacturer's i rating i

l l

l.

d 4

Palisades Nuclear Plant 3.8.4-4 Amendment No. 01/20/98 l

l 3 of 10

i AC Sources - Shutdown B 3.8.2 j BASES SURVEILLANCE SR 3.8.2.1 REQUIREMENTS .

(continued) SR 3.8.2.1 requires the SRs from LC0 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in MODES 5 and 6.

The SRs from LCO 3.8.1 w are required ar those which both support a feature equired in MODES 5 an 6 and which , ,j {

l can be performed with ut .6ffecting the OPERABI ITY or u reliability of the re uiredgsources.

Yttaw1V With only one DG avat able, many. tests ca t be performed since their performan would render t DG inoperable during the test. This 1 Fui c a _ r tests which require DG loading: SRs 3.8.1.3, 3.8.1.5, 3.8.1.6, 3.8.1.7, 3.8.1.8 3.8.1.9, 3.8.1.10, and 3.8.1.11. !

f REFERENCES None Palisades Nuclear Plant B 3.8.2 4 01/20/98 Yof/D

DC Sources - Operating B 3.8.4 BASES SURVEILLANCE SR .3.8.4.8 REQUIREMENTS (continued) A battery performance discharge test is a test of constant current capacity of a battery, normally done in the "as found" condition, after having been in service, to detect any change in-the capacity determined by the acceptance test. The test is intended to determine overall battery degradation due to age and usage.

The modified performance discharge te simulated duty cycle consisting of just two rate - e one m fute rate published for the battery or th argest curreht load of the I duty cycle, followed by the test rate employed for the performance test, both of which nvelopfthedtycycleof {ef the service test. Since the ampere-hours rem ed by a rated one minute discharge represents a very small portion of the battery capacity, the test rate an be ch ed to that for the performance test without comp the results of the performance discharge test. The battery terminal voltage for the modified performance discharge test should remain above the minimum battery terminal voltage specified in the battery service test for the duration of time equal to that of the service test.

A modified performance discharge test is a test of the battery capacity and its ability to provide a high rate, short duration load (usually the highest rate of the duty cycle). This will often confirm the battery's ability to meet the critical period of the load duty cycle, in addition to determining its percentage of rated capacity. Initial conditions for the modified performance discharge test should be identical to those specified for a service test.

Either the battery performance discharge test or the modified performance discharge test is acceptable for satisfying SR 3.8.4.8; however, only the modified performance discharge test may be used to satisfy SR 3.8.4.8 while satisfying the requirements of SR 3.8.4.7 at the same time.

The acceptance criteria for this Surveillance are consistent with the recommendations of IEEE-450 (Ref. 4) and IEEE-485 (Ref. 3). These references recommend that the battery be replaced if its capacity is below 80% of the manufacturer rating. A capacity of 80% shows that the battery rate of deterioration is increasing, even if there is ample capacity to meet the load requirements.

Palisades Nuclear Plant B 3.8.4-10 01/20/98 GofIb

DC Sources - Operating B 3.8.4 BASES 1

SURVEILLANCE SR 3.8.4 1 (continued)

REQUIREMENTS The Surveillance Frequency for this test is normally 60 months. If the battery shows degradation, or if the battery has reached 85% of its expected life and capacity is

< 100% of the manufacturer's rating, the Surveillance Frequency'is reduced to 12 months. However, if the battery shows no degradation but has reached 85% of its expected life, the Surveillance Frequency is only reduced to 24 months for. batteries that retain capacity 2 100% of the manufacturer's rating. Degradation is indicated, according to IEEE-450 (Ref. 4), when the battery capacity drops by more than 10% relative to its capacity on the previous performance-test or when it is 2 10% below the manufacturer's rating. These Frequencies are consistent with the recommendations in IEEE-450 (Ref. 4).

The reason for the restriction that the plant be' outside of !

MODES 1, 2, 3, and 4 is that performing the Surveillance requires disconnecting the battery from the DC distribution buses and connecting it to a test load resistor bank. This action makes the battery inoperable and completely unavailable for u .

\

7 REFERENCES 1. 10CFQO,AppendixA,GDC17 X6/

2. FSAR, Chapter 8

3. IEEE-485-1983, June 1983

4. IEEE-450-1995

5. Letter; Graham Walker, C&D Charter Power Systems, Inc to John Slinkard, Consumers Power Company, 12 July 1996

6. Regulatory Guide 1.32, February 1977

7. Regulatory Guide 1.129, December 1974 Palisades Nuclear Plant B-3.8.4-11 01/20/98 to dio

l DC Sources - Shutdoen l B 3.8.5

! BASES l

l APPLICABILITY This LCO is applicable during movement of irradiated fuel (continued) assemblies even if the plant is in a condition other than MODE 5 or 6. This LC0 provides the necessary ACTIONS if the

' DC electrical power sources required by this LCO become unavailable during movement o tradiated fuel assemblies.

l The DC source requirement fgp M0 ES 1, 2, 3, and 4 are addressed in LCO 3.8.4, DCpur s - Operating."

ACTIONS L1 Since the required DC source is only required to support features required by other LCOs, the option to declare those required features with no DC power available to be inoperable, assures that appropriate ACTIONS will be implemented in accordance with the affected LCOs.

A.2.1. A.2.2. A.2.3. and A.2.4 l

Required Action A.1 may involve undesired and unnecessary administrative efforts, therefore, Required Actions A.2.1 through A.2.4 provide alternate, but sufficiently conservative, actions.

Required Actions A.2.1 th: ough A.2.4 require suspension of CORE ALTERATIONS, moven,er.t of irradiated fuel assemblies, and operations involving oositive reactivity additions. The suspension of CORE ALTERATIONS and movement of irradiated fuel assemblies does not preclude actions to place a fuel assembly in a safe location; the suspension of oositive reactivity additions does not preclude actions to maintain or increase reactor vessel inventory provided the requireo SHUT 00WN MARGIN is maintained.

These ACTIONS minimize the probability or the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC sources (and to continue this action until restoration is accomplished) in order to provide the necessary DC power to the plant safety systems.

l l Palisades Nuclear Plant B 3.8.5-2 M ofib , ,

DC Sources - Shutdown B 3.8.5 l

~

BASES ACTIONS A.2.1. A.2.2. A.2.3. and A.2.4 (continued) l The Completion Time of "immediately" is consistent with the required times for actions requiring prompt attention. The restoration of the required DC power sources should be completed as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient control and Preferred AC power.

SVRVEILLANCE SR 3.8.5.1 REQUIREMENTS SR 3.8.5.1 requires the s from LCO 3.8.4 hat are necessary for ensurin he OPERABILITY of the AC sources in MODES 5 and 6.

The SRs from LCO 3.,.4 whi kF f t4 *&

e re.guired re those which )(

can be performed wi thout fecting RABILITY or gc/

reliability of the equi d DC-soGr,the O only one ee. With battery available, oading tests ca t be performed since their performance wo ld render t battery inoperable during the test. This ' ase for SRs 3.8.4.7 and 3.8.4.8.

REFERENCES None l

F lisades Nuclear Plant B 3.8.5-3 Bof/b

Distribution Systems - Shutdown B 3.8.10 BASES APPLICABILITY This LCO is applicable during movement of irradiated fuel (continued) assemblies even.if the plant is in a condition other than MODE 5 or 6. This LCO.provides the necessary ACTIONS if the electrical power distribution subsystems required by this LCO become unavailable during movement of irradiated fuel assemblies.

The electrical power distribution subsystem requirements for MODES 1, 2, 3, and 4 are addressed in LC0 3.8.9,

" Distribution Systems - Operating."

/ / h ACTIONS a.d /

l Since the distribution systems are on1 required9to suppo t features required by other.LCOs, the ption ' declare ose s affected required features to be in erabl assures t at Aj appropriate ACTIONS will be impleme ted ir, ccordan with 6v the affected LCOs.

A.2.1. A.2.2. A.2.3. A.2.4. and A.2.5 Required Action A.1 may involve undesired and unnecessary administrative efforts, therefore, Required Actions A.2.1 through A.2.5 provide alternate, but sufficiently conservative, actions.

Required Actions A.2.1, A.2.2, A.2.3:. and A.2.5 require suspension of CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions, and declaration that affected shutdown cooling trains are inoperable. The suspension of CORE ALTERATIONS and movement of irradiated fuel assemblies does not preclude actions to place a fuel assembly in a safe location; the suspension of positive reactivity additions does not preclude actions to maintain or increase reactor vessel inventory provided the required SHUTOOWN MARGIN is maintained.

These ACTIONS minimize the probability or the occurrence of postulated events. It is further required (Required Action A.2.4) to immediately initiate action to restore the required distribution subsystems (and to continue this action until restoration is accomplished) in order to provide the necessary electrical power to the plant safety systems.

i Palisades Nuclear Plant B 3.8.10-2 01/20/98 94/o

~

ATTACIBfENT 8 JUSTIFICATIONS FOR DEVIATIONS SECTION 3.8, ELECTRICAL POWER SYSTEMS - BASES Chnnoe Discuccion Note: The CTS Bases for Electrical Power Systems are unique in they have been upgraded to incorporate the format, and much of the content, of NUREG-1432.

These Bases have previously been reviewed and found acceptable by the NRC l6D ~in support of amendmenf### to the Palisades Technical Specifications dated p g gg XXXX ##, ####}. To facilitate the review of the proposed Bases for ITS ection 3.8, a markup of the CTS Electrical Power Systems Bases has been g

provided which denotes only those differences between the previously approved CTS Bases and the proposed ITS Bases. In addition, a separate

" red-line & strikeout" version of NUREG-1432, has been provided and will serve as a comparison between the CTS and NUREG-1432.

A brief discussion of the deviations from the CTS Bases is provided below.

- The Change Numbers correspond to the respective deviation shown on the

" CTS MARKUPS" The first five justifications were used generically throughout the markup of the CTS Bases.

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

2. 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 intent.

3. 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.

4. 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.

l

~

\

Palisades Nuclear Plant Page 1 of 3 01/20/98 f-L /O of/o e

. . . . . . - . - . . . . . . - - _ . - . .- = . .. ... ... . . - . .. - . ...-.. .

i.

l i

ATTACHMENT 3 i

CONSUMERS ENERGY COMPANY 4

.. PALISADES PLANT DOCKET 50-255 CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27,1998 REQUEST FOR ADDITIONAL INFORMATION REVISED PAGES FOR SECTION 3.8 l

l l

i I

l i

1 CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27,1998 REQUEST FOR ADDITIONAL INFORMATION l

REVISED PAGES FOR SECTION 3.8 '

Pace Chanae lnst ucdons Revise the Palisades submittal for conversion to improved Technical Specifications by removing the pages identified below and inserting the attached pages. The revised pages are identified by date and contain vertical lines in the margin indicating the areas of change.

REMOVE PAGES INSERT PAGES REV DATE NRC COMMENT # l lNTRODUCTION ATTACHMENT 1 TO ITS CONVERSION SUBMITTAL 3.8.1 -1 3.8.1-1 09/04/98 N/A editorial 3.8.1 -2 3.8.1-2 09/04/98 N/A editorial 3.8.3-1 3.8.3-1 09/04/98 RAI 3.8.3-02 3.8.3-2 3.8.3-2 09/04/98 RAI 3.8.3-02 3.8.4-4 3.8.4-4 09/04/98 N/A editorial 3.8.9-1 3.8.9-1 09/04/98 RAI 3.8.9-01 RAI 3.8.9-02 RAI 3.8.9-03 ATTACHMENT 210 ITS CONVERSION SUBMITTAL B 3.8.2-1 B 3.8.2-1 09/04/98 N/A editorial B 3.8.2-2 B 3.8.2-2 09/04/98 RAI 3.8.2-01 B 3.8.2-4 B 3.8.2-4 09/04/98 N/A editorial B 3.8.3-1 B 3.8.3-1 09/04/98 RAI 3.8.3-06 RAI 3.8.3-07 B 3.8.3-2 B 3.8.3-2 09/04/98 RAI 3.8.3-05 RAI 3.8.3-06 RAI 3.8.3-07 RAI 3.8.3-02 i

B 3.8.3-4 B 3.8.3-4 09/04/98 RAI 3.8.3-08 RAI 3.8.3-02 B 3.8.4-2 B 3.8.4-2 09/04/98 RAI 3.8.4-02 B 3.8.4-10 B 3.8.4-10 09/04/98 N/A editorial B 3.8.4-11 B 3.8.4-11 09/04/98 N/A editorial B 3.8.5-1 B 3.8.5-1 09/04/98 RAI 3.8.5-02 RAI 3.8.5-03 B 3.8.5-2 B 3.8.5-2 09/04/98 N/A editorial B 3.8.5-3 B 3.8.5-3 09/04/98 N/A editorial B 3.8.6-1 B 3.8.6-1 09/04/98 RAI 3.8.6-01 B 3.8.7-1 8 3.8.7-1 09/04/98 RAI 3.8.7-01 B 3.8.7-3 B 3.8.7-3 09/04/98 RAl 3.8.7-02 B 3.8.8-1 B 3.8.8-1 09/04/98 RAI 3.8.8-01 RAI 3.8.8-02 1

l l

REMOVE PAGES INSERT PAGES REV DATE NRC COMMENT #

l ATTACHMENT 2 TO ITS CONVERSION SUBMITTAL (continued)

B 3.8.9-1 B 3.8.9-1 09/04/98 RAI 3.8.9-08 8 3.8.9-3 B 3.8.9-3 09/04/98 RAI 3.8.9-05 B 3.8.9-5 .B 3.8.9-5 09/04/98 RAI 3.8.9-04 8 3.8.9-6 B 3.8.9-6 09/04/98 RAI 3.8.9-06 RAI 3.8.9-07 B 3.8.10-1 B 3.8.10-1 09/04/98 RAI 3.8.10-02 RAI 3.8.10-03 B 3.8.10-2 B 3.8.10-2 09/04/98 N/A editorial ATTACHMENT 3 TO ITS CONVERSION SUBMITTAL DOC 3.8.1 pg 3 of 4 3.8.1 pg 3 of 4 09/04/98 N/A editorial DOC 3.8.1 pg 4 of 4 09/04/98 RAI 3.8.1-03 CTS 3.8.1 pg 4 of 5 3.8.1 pg 4 of 5 09/04/98 RAI 3.8.1-10 DOC 3.8.3 pg 1 of 1 3.8.3 pg 1 of 2 09/04/98 RAI 3.8.3-01 RAI 3.8.3-04 DOC 3.8.3 pg 1 of 1 3.8.3 pg 2 of 2 09/04/98 RAI 3.8.3-03 CTS 3.8.3 pg 2 of 4 3.8.3 pg 2 of 4 09/04/98 RAI 3.8.3-01 CTS 3.8.3 pg 2 of 4 3.8.3 pg 2 of 4 09/04/98 RAI 3.8.3-03 CTS 3.8.3 pg 4 of 4 3.8.3 pg 4 of 4 09/04/98 RAI 3.8.3-04 DOC 3.8.4 pg 2 of 3 3.8.4 pg 2 of 3 09/04/98 RAI 3.8.4-01

. DOC 3.8.9 pg 1 of 2 3.8.9 pg 1 of 2 09/04/98 RAI 3.8.9-06 CTS 3.8.9 pg 1 of 3 3.8.9 pg 1 of 3 09/04/98 RAI 3.8.9-06 DOC 3.8.10 pg 1 of 1 3.8.10 pg 1 of 2 09/04/98 RAI 3.8.10-01 CTS 3.8.10 pg 1 of 2 3.8.10 pg 1 of 2 09/04/98 RAI 3.8.10-01 DOC 3.8.10 pg 1 of 1 3.8.10 pg 2 of 2 09/04/98 N/A editorial DOC 3.8.9 pg 2 of 2 3.8.9 pg 2 of 2 09/04/98 N/A editroial ATTACHMENT 4 TO ITS CONVERSION SUBMITTAL No change ATTACHMENT 5 TO ITS CONVERSION SUBMITTAL 3.8.7 ^*7 09/04/98 RAI 3.8.1-07 3.8.9 s. 1 09/04/98 RAI 3.8.1-08 RAI 3.8.1-09 3.8.22 3.8.22 09/04/98 RAI 3.8.3-02 3.8.23 3.8.23 09/04/98 RAI 3.8.3-02 3.8.39 3.8.39 09/04/98 RAI 3.8.9-01 RAI 3.8.9-02 RAI 3.8.9-03 i

l I

l 2

l

' ATTACHMENT 6 TO ITS CONVERSION SUBMITTAL 3.8.1 pg 1 of 3 3.8.1 pg 1 of 4 09/04/98 N/A editorial 3.8.1 pg 2 of 3 3.8.1 pg 2 of 4 09/04/98 RAI 3.8.1-05

( 3.8.1 pg 3 of 3 3.8.1 pg 3 of 4 09/04/98 RAI 3.8.1-07 RAI 3.8.1-08 RAI 3.8.1-09 3.8.1 pg 4 of 4 09/04/98 N/A editorial

, 3.8.4 pg 1 of 1 3.8.4 pg 1 of 2 09/04/98 N/A editorial l 3.8.4 pg 1 of 1 3.8.4 pg 2 of 2 09/04/98 RAI 3.8.4-01 3.8.5 pg 1 of 1 3.8.5 pg 1 of 1 09/04/98 RAI 3.8.5-01 l

ATTACHMENT 7 TO ITS CONVERSION SUBMITTAL B 3.7.2-2 B 3.7.2-2 09/04/98 RAI 3.8.2-01 B 3.7.3-1 B 3.7.3-1 09/04/98 RAI 3.8.2-05 B 3.7.3-1 Insert B 3.7.3-1 Insert 09/04/98 RAI 3.8.3-07 B 3.7.3-2 B 3.7.3-2 09/04/98 RAI 3.8.3-02 B 3.7.3-2 Insert B 3.7.3-2 Insert 09/04/98 RAI 3.8.3-06 B 3.7.3-3 B 3.7.3-3 09/04/98 RAI 3.8.3-02 RAI 3.8.3-08 B 3.7.3-4 B 3.7.3-4 09/04/98 RAI 3.8.3-04 l

B 3.7.4-2 B 3.7.4-2 09/04/98 RAI 3.8.4-02 B 3.7.5-1 B 3.7.5-1 09/04/98 RAI 3.8.5-02 RAI 3.8.5-03

. B 3.7.6-1 B 3.7.6-1 09/04/98 RAI 3.8.6-01 B 3.7.7-1 B 3.7.7-1 09/04/98 RAl 3.8.7-01 B 3.7.7-3 B 3.7.7-3 09/04/98 RAI 3.8.7-02 B 3.7.8-1 B 3.7.8-1 09/04/98 RAI 3.8.8-01 RAI 3.8.8-02 B 3.7.9-1 B 3.7.9-1 09/04/98 RAI 3.8.9-08 B 3.7.9-2 B 3.7.9-2 09/04/98 RAI 3.8.9-05 B 3.7.9-4 B 3.7.9-4 09/04/98 RAI 3.8.9-04 RAI 3.8.9-06 B 3.7.9-5 B 3.7.9-5 09/04/98 RAI 3.8.9-07 8 3.7.10-1 B 3.7.10-1 09/04/98 RAI 3.8.10-02 RAI 3.8.10-03 ATTACHMENT 8 TO ITS CONVERSION SUBMITTAL 3.8 pg 1 of 3 3.8 pg 1 of 3 09/04/98 N/A editorial 3.8 pg 2 of 3 3.8 pg 2 of 3 09/04/98 RAI 3.8.01-11 3.8 pg 3 of 3 3.8 pg 3 of 3 09/04/98 N/A editorial ATTACHMENT 9 TO ITS CONVERSION SUBMITTAL No change 3

1 AC Sources - Operating 3.8.1 j l

3.8 ELECTRICAL POWER SYSTEMS

-3.8.1 AC Sources - Operating I

LCO 3.8.1 The followig AC electrical sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the onsite Class 1E AC l Electrical Power Distribution System; and ,

b. Two Diesel Generators (DGs) each capable of supplying one train of the onsite Class 1E AC Electrical Power Distribution System.

APPLICABILITY: MODES 1, 2, 3, and 4.

1

-ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME I

A. One offsite circuit A.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable.. (offsitesource check) for OPERABLE AND offsite circuit, Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months AN1 thereafter I

A.2 Restore offsite 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months circuit to OPERABLE status. AND 10 days from discovery of failure to meet LC0 Palisades Nuclear Plant 3.8.1-1 Amendment No. 09/04/98

!_ )

AC Sources - Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. One DG inoperable. B.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (offsitesource check) for the AND i OPERABLE offsite !

circuit (s). Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ;

thereafter i MQ '

l B.2 Declare required 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from feature (s) supported discovery of by the inoperable DG Condition B inoperable when its concurrent with redundant required inoperability of feature (s) is redundant inoperable. required feature (s)

AND I

. B.3.1 Determine OPERABLE DG 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is not inoperable due to common cause failure.

03 I

B.3.2 Perform SR 3.8.1.2 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (start test) for OPERABLE DG.

MQ l

B.4 Restore DG to 7 days -

OPERABLE status.

AND 10 days from discovery of failure to meet LC0 Palisades Nuclear Plant 3.8.1-2 Amendment No. 09/04/98

l' 1

l-Diesel Fuel, Lube Oil, and Starting Air 3.8.3 L

3.8 ELECTRICAL POWER SYSTEMS i

3.8.3 Diesel Fuel, Lube Oil, and Starting Air

l. .LC0 3.8.3 For each Diesel Generato" (DG):

a. The stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits, and

b. Both diesel fuel oil transfer systems shall be i OPERABLE.

APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS :

NOTE-------------------------------------

Separate Condition entry is allowed for each DG. ;

CONDITION REQUIRED ACTION COMPLETION TIME i

A. Fuel oil inventory A.1 Restore fuel oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months l l < 23,700 gallons and inventory to within

> 20,110 gallons in limits. j storage tank. ^

B. Stored lube oil B.1 Restore stored lube 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months inventory oil inventory to i < 200 gallons and within limits.

> 160 gallons.

C. Fuel transfer system C.1 Restore fuel trarisfer 15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months

{P-18A) inoperable, system to OPERABLE status.

p l

l D. Fuel transfer system D.1 Restore fuel transfer 7 days (P-188) inoperable. system to OPERABLE

. status.

i

~ Palisades Nuclear Plant 3.8.3-1 Amendment No. 09/04/98

Diesel Fuel, Lube Oil, and Starting Air 3.8.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. Both fuel transf~er E.1 Restore'one-fuel 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months

-systems inoperable. transfer system to OPERABLE status.

1 1

F. Fuel oil properties F.1 Restore stored fuel 30 days other than viscosity, oil properties to and water and within limits.

sediment, not within limits.

G. Required Action and G.1 Declare associated Immediately associated Completion. DG(s) inoperable. l Time not met.

QB Stored diesel fuel oil, lube oil, or starting air subsystem

.not within limits for reasons other than Condition A, B, or F.

1 I

i 4

4

. Palisades Nuclear Plant 3.8.3-2 Asendment No. 09/04/98

. DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

-SR 3.8.4.8 --------------------NOTE--------------------

This Surveillance shall not be performed in MODE 1, 2, 3, or 4.

Verify battery capacity is.2 80% of the 60 months manufacturer's rating when subjected to a performance discharge test or a modified AND performance discharge test.

12 months when battery shows degradation or has reached 85%

of the expected life with capacity

< 100% of manufacturer's rating i

24 months when battery has reached 85% of the expected life with capacity 2 100% of manufacturer's rating l

l l

l Palisades Nuclear Plant 3.8.4-4 Amendment No. 09/04/98

Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 Left Train'and Right Train AC, DC, and Preferred AC bus electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC A.1 Restore AC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months electrical power power distribution distribution subsystem (s) to AND subsystems in one OPERABLE status.

train inoperable. 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LC0 B. One Preferred AC bus B.1 Restore Preferred AC 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable. bus to OPERABLE status. AND 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LC0 C. One or more C.1 Restore DC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months DC electrical power power distribution distribution subsystem (s) to AND subsystems in one OPERABLE status.

train inoperable. 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LC0 Palisades Nuclear Plant- 3.8.9-1 Amendment No. 09/04/98

i AC Sources - Shutdown B 3.8.2 BASES L

l l

LCO An OPERABLE DG, associated with a distribution subsystem (continued) required'to be OPERABLE by LC0 3.8.10, ensures a diverse power source is available to provide electrical power support, assuming a loss of the offsite circuit.

Together, OPERABILITY of the required offsite circuit and DG ensures the availability of sufficient AC sources to operate the plant in a safe manner and to miti of postulated events during shutdown e.g., (gatefuel the handling consequences accidents and loss of shutdown cooling).

The DG must be capable of starting, accelerating to rated speed and voltage, connecting to its respective 2400 V bus on detection of bus undervoltage, and accepting required loads. Proper " Normal Shutdown" loading sequence, and tripping of nonessential loads, is a required function for DG OPERABILITY. A Service Water Pump must be started soon after the DG to assure continued DG operability. The DBA loading sequence is not required to be OPERABLE since the Safety Injection Signal is disabled during MODES 5 and 6.

APPLICABILITY The AC sources required to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies provide assurance that equipment and instrumentation is available to:

a. Provide coolant inventory makeup,

b. Mitigate a fuel handling accident,

c. Mitigate shutdown events that can lead to core damage, and

d. Monitor and maintain the plant in a cold shutdown condition or refueling condition.

This LC0 is applicable during movement of irradiated fuel assemblies even if the olant is in a condition other than MODES 5 and 6. This LCO provides the necessary ACTIONS if the AC electrical power sources required by this LC0 become l- unavailable during movement of irradiated fuel assemblies.

The AC source requirements for MODES 1, 2, 3, and 4 are l addressed in LCO 3.8.1, "AC Sources - Operating."

l l

l Palisades Nuclear Plant B 3.8.2-2 09/04/98

AC Sources - Shutdown B 3.8.2 BASES SURVEILLANCE SR 3.8.2.1 i REQUIREMENTS (continued) SR 3.8.2.1 requires the SRs from LC0 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in MODES 5 and 6.

The SRs from LC0 3.8.1 which are required are those which both support a feature required in MODES 5 and 6 and which can be performed without affecting the OPERABILITY or l reliability of the required sources.

With only one DG available, many tests cannot be performed since their performance would render that DG inoperable during the test. This is the case for tests which require ;

DG loading: SRs 3.8.1.3, 3.8.1.5, 3.8.1.6, 3.8.1.7, 3.8.1.8, !

3.8.1.9, 3.8.1.10, and 3.8.1.11.

REFERENCES None I

l Palisades Nuclear Plant B 3.8.2-4 09/04/98 i

i L

l Diesel Fuel, Lube Oil, and Starting Air B 3.8.3 j 3.8 ELECTRICAL POWER SYSTEMS l l

B 3.8.3 Diesel Fuel, Lube Oil, and Starting Air BASES l l l

l l BACKGROUND The Diesel Generators (DGs) are provided with a storage tank <

having a required fuel oil inventory sufficient to operate I j

one diesel for a period of 7 days, while the DG is supplying maximum post-accident loads. This onsite fuel oil capacity is sufficient to operate the DG for longer than the time to l replenish the onsite supply from offsite sources.

l

' Fuel oil is transferred from the Fuel Oil Storage Tank to !

either day tank by either of two Fuel Transfer Systems. The j fuel oil transfer system which includes fuel transfer pump P-18A can be powered by offsite power, or by either DG. l However, the fuel oil transfer system which includes fuel !

transfer pump P-18B can only be powered by offsite power, or l by DG 1-1.

For proper operation of the standby DGs, it is necessary to ensure the proper quality of the fuel oil. Regulatory Guide (RG) 1.137 (Ref.1) addresses the recommended fuel oil practices as supplemented by ANSI N195-1976 (Ref. 2). l The DG lubrication system is designed to provide sufficient lubrication to permit proper operation of its associated DG urder all loading conditions. The system is required to circulate the lube oil to the diesel engine working surfaces and to remove excess heat generated by friction during operation. The onsite storage in addition to the engine oil sump is sufficient to ensure 7 days of continuous operation.

This supply is sufficient supply to allow the operator to l replenish lube oil from offsite sources. Implicit in this LC0 is the requirement to assure, though not necessarily by i testing, the capability to transfer the lube oil from its storage location to the DG oil sump, while the DG is running.

Each DG is provided with an associated starting air subsystem to assure independent start capability. The starting air system is required to have a minimum capacity with margin for a DG start attempt without recharging the '

air start receivers.

(

Palisades Nuclear Plant B 3.8.3-1 09/04/98

- - _ . _ , .. .- ---~_--.-.- -- - --..--.- -

Diesel Fuel, Lube Oil, and Starting Air B 3.8.3 BASES APPLICABLE A description of the Safety Analyses applicable in MODES 1

! . SAFETY ANALYSES 2, 3, and 4 is provided in the Bases for LCO 3.8.1, "AC l Sources - Operating"; during MODES 5 and 6, in the Bases 'for LCO 3.8.2, "AC Sources - Shutdown." Since diesel fuel, lube ,

oil, and starting air subsystems support the operation of the standby AC power sources, they satify Criterion 3 of 10 CFR 50.36(c)(2).

LCO Stored diesel fuel oil is required to have sufficient supply for.7 days of full accident load operation. It is also ,

required to meet specific standards for quality. The specified 7 day requirement and the 6 day quantity listed in Condition A are taken from_the Engineering Analysis associated with Event Report E-PAL-93-026B. Additionally, the ability to transfer fuel oil from the storage tank to <

each day tank is required from each of the two transfer j pumps. l Additionally, sufficient lube oil supply must be available to ensure the capability to operate at full accident load for 7 days. This requirement is in addition to the lube oil cor.tained in the engine sump. The specified 7 day-requirement and the 6 day quantity listed in Condition B are based on an assumed lube oil consumption of 0.8 to 1.0% of fuel oil consumption.

The starting air subsystem must provide, without the aid of the refill compressor, sufficient air start capacity, including margin, to assure start capability for its )

associated DG. 1 These requirements, in conjunction with an ability to obtain replacement supplies within 7 days, support the availability of the DGs. DG day tank fuel requirements are addressed in LCOs 3.8.1 and 3.8.2.

APPLICABILITY DG OPERABILITY is required by LCOs 3.8.1 and 3.8.2 to ensure the availability of the required AC power to shut down the reactor and maintain it in a safe shutdown condition following a loss of off-site power. Since diesel fuel, lube oil, and starting air support LCOs 3.8.1 and 3.8.2, stored l diesel fuel oil, lube oil, and starting air are required to l

be within limits, and the fuel transfer system is required

! to be OPERABLE, when either DG is required to be OPERABLE.

1 Palisades Nuclear Plant B 3.8.3-2 09/04/98 )

e --m-~ - - . , . . ,

Diesel Fuel, Luhe Oil, and Starting Air B 3,8.3 BASES ACTIONS f_d (continued)

With the stored fuel oil properties, other than viscosity, and water and sediment, defined in the Fuel Oil Testing Program not within the required limits, but acceptable for short term DG operation, a period of 30 days is allowed for restoring the stored fuel oil properties. The most likely cause of stored fuel oil becoming out of limits is the addition of new fuel oil with properties that do not meet all of the limits. This 30 day period provides sufficient time to determine if new fuel oil, when mixed with stored fuel oil, will produce an acceptable mixture, or if other methods to restore the stored fuel oil properties are requi red. This restoration may involve feed and bleed procedures, filtering, or combinations of these procedures.

Even if a DG start and load was required during this time interval and the fuel oil properties were outside limits, there is a high likelihood that the DG would still be capable of performing its intended function.

G_d With a Required Action and associated Completion Time not met, or with diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than addressed ,

by Conditions A, B, or F, the associated DG may be incapable i of performing its intended function and must be immediately declared inoperable. ;

In the event that diesel fuel oil with viscosity, or water and sediment is out of limits, this would be unacceptable for even short term DG operation. Viscosity is important primarily because of its effect on the handling of the fuel by the pump and injector system; water and sediment provides an indication of fuel contamination. When the fuel oil stored in the Fuel Oil Storage Tank is determined to be out of viscosity, or water and sediment limits, the DGs must be declared inoperable, immediately.

Palisades Nuclear Plant B 3.8.3-4 09/04/98

DC Sources - Operating .

B 3.8.4 l I

BASES ;

i BACKGROUND The' batteries for the DC power sources are sized to produce (continued) required capacity at 80% of nameplate rating, corresponding i to warranted capacity at end of life cycles and the 100% i design demand. The voltage limit is-2.13 V per cell, which i corresponds to a total minimum voltage output of 125.7 V per battery discussed in the FSAR, Chapter 8 (Ref. 2). The criteria for sizing large lead storage batteries are defined l in IEEE-485 (Ref. 3). 1 Each DC electrical power source has ample power output I capacity for the steady state operation of connected loads i during normal operation, while at the same time maintaining l its battery fully charged. Each battery charger also has ;

sufficient capacity to restore the battery from the design minimum charge to its fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months while supplying normal steady state loads discussed in the FSAR, Chapter 8 (Ref. 2).

APPLICABLE A description of the Safety Analyses applicable in MODES 1, SAFETY ANALYSES 2, 3, and 4 is provided in the Bases for LC0 3.8.1, "AC i Sources - Operating." '

The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2). l l LC0 The DC pnwer sources, each consisting of one battery, one i directly onnected battery charger and the corresponding control e4.ipment and interconnecting cabling supplying power to the associated bus within the train are required to be OPERABLE to ensure the availability of DC control power and Preferred AC power to shut down the reactor and maintain it in a safe condition.

An OPERABLE DC electrical power source requires its battery to be OPERABLE and connected to the associated DC bus. In order for the battery to remain OPERABLE, one charger must be in service.

Palisades Nuclear Plant B 3.8.4-2 09/04/98

DC Sources - Operating B 3.8.4 BASES SURVEILLANCE SR 3.8.4.8 REQUIREMENTS-(continued) A battery performance discharge test is a test of constant current capacity of a battery, normally done in the "as found" condition, after having been in service, to detect any change in the capacity determined by the acceptance test. The test is intended to determine overall battery degradation due to age and usage.

The modified performance discharge test is a simulated duty cycle consisting of just two rates; the one minute rate published for the battery or the largest current load of the duty cycle, followed by the test rate employed for the performance test, both of which envelop the duty cycle of l the service test. Since the ampere-hours removed by a rated one minute discharge represents a very small portion of the battery capacity, the test rate can be changed to that for the performance test without compromising the results of the performance discharge test. The battery terminal voltage for the modified performance discharge test should remain above the minimum battery terminal voltage specified in the battery service test for the duration of time equal to that of the se.vice test.

A modified performance discharge test is a test of the battery capacity and its ability to provide a high rate, short duration load (usually the highest rate of the duty cycle). This will often confirm the battery's ability to meet the critical period of the load duty cycle, in addition to determining its percentage of rated capacity. Initial conditions for the modified performance discharge test should be identical to those specified for a service test.

Either the battery performance discharge test or the modified performance discharge test is acceptable for satisfying SR 3.8.4.8; however, only the modified performance discharge test may be used to satisfy SR 3.8.4.8 while satisfying the requirements of SR 3.8.4.7 at the same time.

The acceptance criteria for this Surveillance are consistent with the recommendations of IEEE-450 (Ref. o) and IEEE-485 (Ref. 3). These references recommend that the battery be replaced if its capacity is below 80% of the manufacturer rating. A capacity of 80% shows that the battery rate of deterioration is increasing, even if there is ample capacity to meet the load requirements.

Palisades Nuclear Plant B 3.8.4-10 09/04/98

DC Sources - Operating B 3.8.4 BASES SURVEILLANCE SR 3.8.4.8 (continued)

REQUIREMENTS The Surveillance Frequency for this test is normally 60 months. If the battery shows degradation, or if the battery has reached 85% of its expected life and capacity is

< 100% of the manufacturer's rating, the Surveillance Frequency is reduced to 12 months. However, if the battery shows no degradation but has reached 85% of its expected life, the Surveillance Frequency is only reduced to 24 months for batteries that retain capacity 2 100% of the manufacturer's rating. Degradation is indicated, according to IEEE-450 (Ref. 4), when the battery capacity drops by more than 10% relative to its capacity on the previous performance test or when it is a 10% below the manufacturer's rating. These Frequencies are consistent with the recommendations in IEEE-450 (Ref. 4).

The reason for the restriction that the plant be outside of MODES 1, 2, 3, and 4 is that performing the Surveillance requires disconnecting the battery from the DC distribution buses and connecting it to a test load resistor bank. This action makes the battery inoperable and completely unavailable for use.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 17 l

2. FSAR, Chapter 8

3. IEEE-485-1983, June 1983

4. IEEE-450-1995

5. Letter; Graham Walker, C&D Charter Power Systems, Inc to John Slinkard, Consumers Power Company, 12 July 1996

6. Regulatory Guide 1.32, February 1977

7. Regulatory Guide 1.129, December 1974 Palisades Nuclear Plant B 3.8.4-11 09/04/98

DC Sources - Shutdown B 3.8.5 3.8 ELECTRICAL POWER SYSTEMS B 3.8.5 DC Sources - Shutdown BASES BACKGROUND A description of the DC sources is provided in the Bases for LC0 3.8.4, "DC Sources - Operating."

l APPLICABLE A description of the Safety Analyses applicable during SAFETY ANALYSES MODES 5 and 6 is provided in the Bases for LC0 3.8.2, "AC 1 Sources - Shutdown." '

The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2). l LC0 This LC0 requires those, and only those, DC power sources which supply the DC distribution subsystems required by LC0 3.8.10, to be OPERABLE. Each DC source consists of one battery, one battery charger, and the corresponding control l equipment and interconnecting cabling. This ensures the l availability of sufficient DC power sources to maintain the l plant in a safe manner and to mitigate the consequences of l postulated events j accidents and loss ofduring shutdown shutdown cooling (e.g).,

. fuel handling APPLICABILITY The DC power sources required to be OPERABLE in MODES 5 and l 6, and during movement of irradiated fuel assemblies provide l assurance that equipment and instrumentation is available to:

a. Provide coolant inventory makeup,

b. Mitigate a fuel handling accident,

c. Mitigate shutdown events that can lead to core damage, and

d. Monitoring and maintaining the plant in a cold shutdown condition or refueling condition.

Palisades Nuclear Plant B 3.8.5-1 09/04/98

l l

DC Sources - Shutdown B 3.8.5 BASES APPLICABILITY This LC0 is applicable during movement of irradiated fuel I (continued) assemblies even if the plant is in a condition other than

! MODE 5 or 6. This LC0 provides the necessary ACTI0FS if the

( DC electrical power sources required by this LC0 become

unavailable during movement of irradiated fuel assemblies.

The DC source requirements for MODES 1, 2, 3, and 4 are l addressed in LC0 3.8.4, "DC Sources - Operating." l l

ACTIONS 6_d i Since the required DC source is only required to support features required by other LCOs, the option to declare those required features with no DC power available to be inoperable, assures that appropriate ACTIONS will be implemented in accordance with the affected LCOs.

A.2.1. A.2.2. A.2.3. and A.2.4 Required Action A.1 may involve undesired and unnecessary administrative efforts, therefore, Required Actions A.2.1 through A.2.4 provide alternate, but sufficiently conservative, actions.

Required Actions A.2.1 through A.2.4 require suspension of CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions. The suspension of CORE ALTERATIONS and movement of irradicted fuel assemblies does not preclude actions to place a fuel assembly in a safe location; the suspension of positive reactivity additions does not preclude actions to maintain or increase reactor vessel inventory provided the required SHUTDOWN MARGIN is maintained.

These ACTIONS minimize the probability or the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC sources (and to continue this action until restoration is accomplished) in

! order to provide the necessary DC power to the plant safety l systems.

! Palisades Nuclear Plant B 3.8.5-2 09/04/98 l

I~

DC Sources - Shutdown B 3.8.5 BASES ACTIONS A.2'.1. A.2.2. A.2.3. and A.2.4 (continued)

The Completion. Time of "immediately" is consistent with the

' required times for actions requiring prompt attention. The restoration of the required DC power sources should be completed as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient control and Preferred AC power.

SURVEILLANCE SR 3.8.5.1 REQUIREMENTS SR 3.8.5.1 requires the SRs from LC0 3.8.4 that are necessary for ensuring the OPERABILITY of the AC sources in MODES 5 and 6.

The SRs from LC0 3.8.4 which are required are those which can be performed without affecting the OPERABILITY or l reliability of the required DC source. With only one battery available, loading tests cannot be performed since their performance would render that battery inoperable during the test. This is the case for SRs 3.8.4.7 and 3.8.4.8.

REFERENCES None l-l l

Palisades Nuclear Plant B 3.8.5 09/04/98

Battery Cell Parameters B 3.8.6 3.8 ELECTRICAL POWER SYSTEMS B 3.8.6 Battery Cell Parameters BASES BACKGROUND This LC0 delineates the limits on electrolyte temperature, level, float voltage, and specific gravity for the DC power source batteries. A discussion of these batteries is provided in the Bases for LC0 3.8.4, "DC Sources -

Operating."

APPLICABLE A description of the Safety Analyses applicable for SAFETY ANALYSES MODES 1, 2, 3, and 4 is provided in the Bases for LC0 3.8.1, "AC Sources - Operating"; during MODES 5 and 6, in the Bases for LC0 3.8.2, "AC Sources - Shutdown."

Battery cell parameters satisfy Criterion 3 of 10 CFR 50.36(c)(2).

LC0 Battery cell parameters must remain within acceptable limits to ensure availability of the required DC power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA.

Battery cell limits are conservatively established, allowing continued DC electrical system function even when Category A and B limits are not met.

The requirement to maintain the average temperature of representative cells above 70 F assures that the battery temperature is within the design band. Battery capacity is a function of battery temperature.

APPLICABILITY The battery cell parameters are required solely for the support of the associated DC power sources. Therefore, they are only required when the DC power source is required to be OPERABLE. Refer to the Applicability discussions in the Bases for LC0 3.8.4 and LC0 3.8.5, "DC Sources - Shutdown." !

l I

i Palisades Nuclear Plant B 3.8.6-1 09/04/98 l

l

Inverters - Operating B 3.8.7 3.8 ELECTRICAL POWER SYSTEMS B 3.8.7 Inverters - Operating BASES BACKGROUND The inverters (ED-06, ED-07, ED-08, and ED-09) are the normal source of power for the Preferred AC buses. The function of the inverter is to provide continuous AC electrical power to the Preferred AC buses, even in the event of an interruption to the normal AC power distribution system. A Preferred AC bus can be powered from the AC power distribution system via the Bypass Regulator if its associated inverter is out of service. An interlock prevents supplying more than one Preferred AC bus from the bypass regulator at any time. The station battery provides an uninterruptable power source for the instrumentation and controls for the Reactor Protective System (RPS) and the Engineered Safety Features (ESF).

APPLICABLE A description of the Safety Analyses applicable in SAFETY ANALYSES MODES 1, 2, 3, and 4 is provided in the Bases for LC0 3.8.1, "AC Sources - Operating."

inverters are part of the distribution system and, as such, satify Criterion 3 of 10 CFR 50.36(c)(2).

LC0 The inverters ensure the availability of Preferred AC power for the instrumentation required to shut down the reactor and maintain it in a safe condition after an anticipated

, operational occurrence or a postulated DBA.

Maintaining the inverters OPERABLE ensures that the redundancy incorporated into the RPS and ESF instrumentation and controls is maintained. The four inverters ensure an uninterruptable supply of AC electrical power to the Preferred AC buses even if the 2400 V safety related buses are de-energized.

An inverter is considered inoperable if it is not powering the associated Preferred AC bus, or if its output voltage or frequency is not within tolerances.

Palisades Nuclear Plant B 3.8.7-1 09/04/98

_ . _ . __ . . ... . - _ _ _ _ _ ~ _ _ _ _ _ . _ _ _ _ . . _ _ _ . _ _ _ . - . _ _ . _ _ _ . _ _ . . _ _ . . _ _

Inverters - Operating B 3.8.7 i

BASES i.

SURVEILLANCE SR *3.8.7.1

. REQUIREMENTS This Surveillance verifies that the inverters are functioning properly and energizing the Preferred AC buses. l The verification of proper voltage and frequency output ensures that the required power is readily available for the l instrumentation of the RPS and ESF connected to the Preferred AC buses. The 7 day Frequency takes into account indications available in the control room that alert the '

operator to inverter malfunctions.

REFERENCES Non.e I

l I

t i-

. Palisades Nuclear Plant B 3.8.7-3 09/04/98

--1 -r . - -~ . -- - -- , - - r- -ra*r y

Inverters - Shutdown B 3.8.8 3.8 ELECTRICAL POWER SYSTEMS B 3.8.8 Inverters - Shutdown BASES BACKGROUND A description of the inverters is provided in the Bases for LC0 3.8.7, " Inverters - Operating."

APPLICABLE A description of the Safety Analyses applicable during SAFETY ANALYSES MODES 5 and 6 is provided in the Bases for LCO 3.8.2, "AC Sources - Shutdown."

Inverters are part of the distribution system and, as such, satisfy Criterion 3 of 10 CFR 50.36(c)(2).

LC0 This LC0 requires those, and only those, inverters necessary to support the Preferred AC buses required by LC0 3.8.10, l

" Distribution Systems - Shutdown," to be OPERABLE.

This ensures the availability of sufficient Preferred AC electrical power to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents and loss of shutdown cooling).

An inverter is considered inoperable if it is not powering the associated Preferred AC bus, or if its voltage or I frequency is not within tolerances.

APPLICABILITY The inverters required to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies provide assurance that equipment and instrumentation is available to:

a. Provide coolant inventory makeup,

b. Mitigate a fuel handling accident,

c. Mitigate shutdown events that can lead to core damage, and

d. Monitoring and maintaining the plant in a cold shutdown condition or refueling condition.

Palisades Nuclear Plant B 3.8.8-1 09/04/98

.. . _ . . . . . . . _ _ . _ . _ . _ . . . _ _ _ _ _ . _ _ _ _ _ _ __._____-__.m__.

Distribution Systems - Operating B 3.8.9 3.8 ELECTRICAL POWER SYSTEMS B 3.8.9 Distribution Systems - Operating BASES

-BACKGROUND The onsite Class 1E AC, DC, and Preferred AC bus electrical power distribution systems are divided into two redundant and independent electrical power distribution trains. Each

! electrical power distribution train is made up of several L subsystems which include the safety related buses, load l' centers, motor control centers, and distribution panels shown in Table,B 3.8.9-1.

The Class 1E 2400 V safety related buses, Bus 1C and Bus 10, i are normally powered from offsite, but can be powered from i the DGs, as explained in the Background section of the Bases L

' for LCO 3.8.1, "AC Sources - Operating." Each 2400 V safety related bus supplies one train of the Class 1E 480 V l distribution system.

The 120 V Preferred AC buses are normally powered from the l inverters. The' alternate power supply for the buses is a

!- constant voltage transformer, called the Bypass Regulator.

Use of the Bypass regulator is governed by LC0 3.8.7,

" Inverters - Operating." The bypass regulator is powered from the non-Class 1E instrument AC bus, Y-01. The L Instrument AC bus is normally powered through an automatic bus transfer switch, an instrument AC transformer, and isolation fuses. Its normal power source is MCC-1. Loss of power to MCC-1 will cause automatic transfer of the >

Instrument AC bus to MCC-2. 7 l -There are two independent 125 V DC electrical power distribution subsystems.

APPLICABLE A description of the Safety Analyses applicable in SAFETY ANALYSES MODES 1, 2, 3, and .4 is provided in the Bases for LCO 3.8.1.

The distribution systems satisfy Criterion 3 of 10CFR50.36(c)(2).

P 1

Palisades Nuclear Plant B 3.8.9-1 09/04/98 l

l

. , . , , , ., , ., - +- . - - - - --- .. , , ,-

L Distribution Systems - Operating B 3.8.9 BASES l APPLICABILITY The electrical power distribution subsystems are required to -

be OPERABLE in MODES 1, 2, 3, and 4 to ensure that AC, DC, 1 and Preferred AC power is available to the redundant trains and channels.of safeguards equipment, instrumentation and ,

controls required to support engineered safeguards equipment I in the event of an accident or transient. i Electrical power distribution subsystem requirements for MODES 5 and 6, and during movement of irradiated fuel assemblies are addressed in LC0 3.8.10. " Distribution Systems - Shutdown."

ACTIONS 6.d With one or more required AC buses, load centers, motor !

control centers, or distribution panels, except Preferred AC l buses, in one train inoperable, the redundant AC electrical power distribution subsystem in the other train is capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because an additional failure'in the power distribution systems could result in the minimum required ESF functions not being supported.

Therefore, the required AC buses, load centers, motor control centers, and distribution panels must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The second Completion Time for Required Action A.1 establishes a limit on the maximum time allowed for any combinations of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition A is entered while, for instance, a DC bus is inoperable and subsequently restored OPERABLE, the LC0 may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This could lead to a total of 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months , since initial failure of the LCO, to restore the AC distribution system. At this time, a DC circuit could again become inoperable, and AC distribution resto*ed OPERABLE.

This could continue indefinitely.

i Palisades Nuclear Plant B 3.8.9-3 09/04/98

Distribution Systems - Operating B 3.8.9 BASES I ACTIONS' (_d

!' .(continued)

! With one or more DC bus in one train inoperable, the l i remaining DC electrical power distribution subsystems are-capable of~ supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliaoility is reduced, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF functions not being supported. Therefore the required DC buses must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months by powering the bus from the associated battery or charger.

This 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months limit is more conservative than Completion Times allowed for the vast majority of components which would be without power and is a feature of the original Palisades licensing basis.

The second Completion Time for Required Action C.1 t

establishes a limit on the maximum time allowed for any combination of required. distribution subsystems to be !

inoperable.during any single continuous occurrence of failing to meet the LCO. If Condition C is entered while, for instance,.an AC bus is inoperable and subsequently restored OPERABLE, the LCO may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This could lead to a total of 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months , since initial failure of the LCO, to restore the Preferred DC distribution system. At this time, a AC bus could again become inoperable, and Preferred ~AC distribution restored OPERABLE. This could continue indefinitely.

The Completion Time allows for an exception to the normal

" time zero" for beginning the allowed outage time " clock."

This will result in establishing the " time zero" at the time the LCO was initially not met, instead of the time Condition C was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an-acceptable limitation on this potential to fail to meet the LCO indefinitely.

L f.

Palisades Nuclear Plant B 3.8.9-5 09/04/98

Distribution Systems - Operating 8 3.8.9 BASES ACTIONS D.1 and D.2 (continued)

.If the inoperable distribution subsystem cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to an operating condition in which the LC0 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.

f_d Condition E corresponds to a degradati in the electrical distribution system that causes a requi.ed safety function to be lost. When more than one Condition is entered, and this results in the loss of a required function, the plant M in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation.

LC0 3.0.3 must be entered immediately to commence a controlled shutdown.

SURVEILLANCE SR 3.8.0.1 REQUIREMENTS This surveillance verifies that the required AC, DC. and Preferred AC bus electrical power distribution subsystems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained.

For those buses which have undervoltage alarms in the l control room, correct voltage may be verified by the absence of an undervoltage alarm.

For those buses which have only one possible power source and have undervoltage alarms in the control room, correct breaker alignment may be verified by the absence of an undervoltage alarm.

Palisades Nuclear Plant B 3.8.9-6 09/04/98

Distribution Systems - Shutdown B 3.8.10 3.8 ELECTRICAL POWER SYSTEMS B 3.8.10 Distribution Systems - Shutdown BASES -

BACKGROUND A description of the AC, DC, and Preferred AC bus electrical power distribution systems is provided in the Bases for LC0 3.8.9, " Distribution Systems - Operating."

APPLICABLE A description of the Safety Analyses applicable SAFETY ANALYSES during MODES 5 and 6 is provided in the Bases for LCO 3.8.2, "AC Sources - Shutdown."

The distribution system satisfy Criterion 3 of 10 CFR 50.36(c)(2).

LC0 This LC0 requires those, and only those, AC, DC, and Preferred AC distribution subsystems to be OPERABLE which are necessary to support equipment required by other LCOs.

Maintaining these portions of the distribution system energized ensures the availability of sufficient power to operate the plant in a safe manner to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).

APPLICABILITY The electrical power distribution subsystems required to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies, provide assurance that equipment and instrumentation is available to:

a. Provide coolant inventory makeup,

b. Mitigate a fuel handling accident,

c. Mitigate shutdown events that can lead to core damage, and

d. Monitoring and maintaining the plant in a cold shutdown condition and refueling condition.

Palisades Nuclear Plant B 3.8.10-1 09/04/98

Distribution Systems - Shutdown B 3.8.10 BASES APPLICABILITY This LC0 is applicable during movement of irradiated fuel assemblies even if the plant is in a condition other than (continued)

MODE 5 or 6. This LC0 provides the necessary ACTIONS if the electrical power distribution subsystems required by this LC0 become unavailable during movement of irradiated fuel assemblies.

The electrical power distribution subsystem requirements for MODES 1, 2, 3, and 4 are addressed in LC0 3.8.9,

" Distribution Systems - Operating."

ACTIONS A1 Since the distribution systems are only required to support features required by other LCOs, the option to declare those affected required features to be inoperable assures that l appropriate ACTIONS will be implemented in accordance with the affected LCOs.

O A.2.1. A.2.2. A.2.3. A.2.4. and A.2.5 Requireo Action A.1 may involve undesired and unnecessary administrative efforts, therefore, Required Actions A.2.1 through A.2.5 provide alternate, but sufficiently conservative, actions.

Required Actions A.2 1, A.2.2, A.2.3, and A.2.5 require suspension of CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions, and declaration that affected shutdown cooling trains are inoperable. The suspension of CORE ALTERATIONS and movement of irradiated fuel assemblies does not preclude actions to place a fuel assembly in a safe location; the suspension of positive reactivity additions does not preclude actions to maintain or increase reactor vessel inventory provided the required SHUTDOWN MARGIN is maintained.

The.se ACTIONS minimize the probability or the occurrence of postulated events. It is further required (Required Action A.2.4) to immediately initiate action to restore the required distribution subsystems (and to continue this action until restoration is accomplished) in order to provide the necessary electrical power to the plant safety systems.

Palisades Nuclear Plant B 3.8.10-2 09/04/98

3. 8 . i ELECTRICAL POWER SYSTEMS TESTS 4g AC Power Sources Ooeratino (continued)

H3.5 h6 4.7.1.8 Verify that each DG, operating at a power factor s 0.9, does not trip, and voltage is maintained 5 4000 V during and following a load rejection of 2 2300 and 5 2500 kW; each 18 months.

(R 3.8.i. 7 4.7.1.9* Verify; each 18 months; on an actual or simulated loss of offsite power:

a. De energization of emergency buses;

b. Load shedding from emergency ouses;

c. DG auto-starts from standby condition and: I

1. Energizes permanently connected loads in s 10 seconds,

2. Energizes auto-connected shutdown loads through the automatic i load sequencer,

3. Maintains steady state voltage 2 2280 and s 2520 V,

'4. Maintains steady state frequency 2 59.5 and 5 61.2 Hz, and gg 5. Supplies permanently connected loads for 2 5 minutes, g 3, y,l ,9 4.7.1.10 Verify, each 18 months, that each DG operates at a power factor s 0.9 for 2 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s:

a. For 2 100 minutes loaded above its peak accident loading, and 1

b. For the remainder of the test loaded 2 2300 and 5 2500 kW.

M'5.1 b9 4.7.1.11* Verify; each 18 months; that each DG:

a. Can be synchronized with offsite power while supplying its associated 2400 volt bus upon a simulated restoration of offsite power;

b. Can transfer loads to an offsite power source; and

c. Can be returned to ready-to-load operation.

g3,g ,1, to 4.7.1.12* Verify the time of each sequenced load is within 10.3 seconds of the design timing for each automatic load sequencer; each 18 months.

54 g These tests must be performed in COLD SHUTOOWN or REFUELING SHUTDOWN.

4 43 Amendment No. 66, M, MB, M6, 4 bh $

esmems

3. 7. 3 3.8 # ELECTRICAL POWER SYSTEMS g,g,3 -aft DG Fuel Oil and Lube Oil Soecifications lf D The stored DG fuel oil and DG lube oil shall be within limits.

ADb 'hl od. fruark Sysd and Aoolicability Sf*% # I M LC-O .

Specification 3.7.3 applies when any DG is required to be OPERABLE.

Action ADO AcTloN3 f)DWh -f,1 (en) A 3.7.3.A With stored fuel oil inventory < 23,700 and 2 20,110 gallons:

1. Restore stored fuel oil inventory to within limits; within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , ggg 3.7.3.B With stored lube oil inventory < and gallons:

1. Restore the lube oil inventory to within limits; within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

Qq 3.7.3.C With stored fuel oil viscosity, or water and sediment not within limits:

1. Declare both DGs inoperable, immediately.

Qp 3.7.3.D With stored fuel oil properties other than viscosity, and water and sediment not within limits:

1. Restore stored fuel oil properties to within limits; within 30 days.

Cond G 3.7.3.E If any action required by 3.7.3.A through 3.7.3.0 is not met and the associated completion time has expired, or if Specification 3.7.3 is not met for reasons other than those addressed in 3.7.3.A. through 3.7.3.0:

1. Declare both DGs inoperable; immediately.

3 44 Amendment No.

FEVISED temems

[O

I I

s 3.1. 3 ELECTRICAL POWER SYSTEMS TESTS

'~T.7.2 AC Pode Source Tests - Shutdown -

3 4.7.2.1 Ver fy each AC power source requir by Specification 3.7.2 is PERABLE 4 the following surveillance. C edit may be taken for unpla ed events hat ~ satisfy a surveillance req rement.

4.7.1.1, Offsite source chec 4.7.1.2, DG starting test 4.7.1.4, DG starting a check y

4.7.1.5, DG day tan level check k- 4.7.1.6. Fuel tr sfer check D DG Fuel Oil and Lube Oil Verify that the fuel oil and lube oil for each required DG is adequate by the following surveillance:

g 3.3 3 1 4.7.3.1 Verify that the Fuel Oil Storage Tank contains 2 23,700 gallons of fuel; each 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . g g 3 3.3.1 4.7.3.2 Verifystoredlubeoilinventoryis2hgallons;each31 days.

r A 3 ,F.3 3 4.7.3.3 Verify properties of new fuel oil and stored fuel oil are tested in accordance with, and maintained within the limits of, the fuel Oil Testing Program, Specification 6.5.11.

~ 4.7.3.4 Check for and remove excess accumulated water from the Fuel 011 Storage 54 3.U. 7 Tank; each 92 days.

4-43b Amendment No.

REVISED se4Wes f 0f Y

.3. I W ELECTRICAL POWER S" STEMS 3,F.9 W Distribution Systems - Ooeratina Scecifications Lt 0 3'f'T The left and right trains of AC, DC, and Preferred AC power distribution SubsystemsMsted ia

. hall be OPERABLE. !

L Acolicability QLA.I Specification 3.7.9 applies when the PCS is "c.; COLC SM','"^""

Action _b '

MA 3.7.9.A With one or more subsystems of one AC electrical power distribution train inoperable:

-1. C;.pi, ;th 2.7.^.C, ;f applis.L ;, ;..J I

2. Restore the electrical power distribution train to OPERABLE s tus; within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . W O (g su.be(o @

g,z bdO 3.7.9.B With one Preferred AC bus inoperY

/.'2.

1 C g ly with 1 7.9.E. if annlicable an

2. Restore the Preferred AC bus to BlF e+'+"e- uithin A hours AM v. Ca. 64 IND 2, h)C 3.7.9.C With one or more subsystems of one DC e ecthcas power oistribution train inoperable:

1. Co. ,1., ith 0.7.^. , if .ppi';;bl., oo f

2. Restore the DC electrical rdistributiograintoOPERABL status; within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

Ag ~s 4<below g- -

/I. 2.

y 9 3.7.9.0 If the action required by 3.7.9.A, through 3.7.9.C is not met and the associated completion time has expired:

4

1. The reactor shall be placed in HOT SHUTDOWN; within hours, an

[Tg g 2. The reactor shall be placed in COLD SHUTDOWN: within rs.

Q G 3.7.9.E WitVan3inoperabledistributionsubsystemthatresultsina oss of a santy function:

1. Enter Specification 3.0.3; immediately.

(Insu4 p_ab1?:) - _ -- p.L 4 /b hwrs km d;siswy)' M

>f (*5Iwt -/v meef LLD 3 45f Amendment No.

[4 eenelse

i

3. ? --) ELECTRICAL POWER SYSTEMS 3.7,ID f.7./O W Distribution Systems - Shutdown A.\ .

I Soecifications gg 3, p, fo The necessary portion of AC, DC, and Preferred AC electrical power distribution subsystems listed in Table 3.7.9-1 shall be OPERABLE to support equipment required to be OPERABLE.

Aeolicability l

e/Ho0Er5 F5rd C '

Specification 3.7.10 applies when the plant is J- m . , . . . . - -

l REFU U NC CMUT00 n wiin Two'. ... tr.; . ;.; u r, and during movement of l irradiated fuel assemblies.

l Action !

3.7.10.A With one or more required AC, DC, or Preferred AC electrical po'wer QA distribution subsystems inoperable, immediately initiate action to: l l

1. Declare affected required features supplied by an inoperable l distribution subsystem to be inanorahlp, ar-2.1. Suspend RiiUCUNG CFC:"T!^"S7 imcr kILE[At.T5YItTt8N -

,l 2.2. Suspend movement of irradiated fuel assemblies, and l 2.3. Suspend operations involving positive reactivity additions, and 2.4. Restore the required AC, DC, and Preferred AC electrical' power distribution subsystems to OPERABLE status, and 2.5. Declare affected required shutdown cooling trains inoperable.

ADW M M

/AlO%.rQhon i

t 3-45h l

Amendment No.

/ af Z.

-ie.

. eenene

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.8.1, AC SOURCES - OPERATING LESS RESTRICTIVE CHANGES - REMOVAL OF DETAILS TO LICENSEE CONTROLLED DOCUMENTS (LA) l LA.1 CTS Action 3.7,1.F requires inoperable automatic DG load sequencers to immediately result in considering the associated DG inoperable. This statement of operability is not required to be explicitly within the ITS actions. Attributes of operability are relocated to the ITS LCO Bases for LCO 3.8.1. This detail of a support system required for DG operability can be adequately controlled within the Bases where revisions are governed by the Administrative Controls Section for Bases Control Program and 10 CFR 50.59. This level of detail remaining being located within the Bases in lieu of an explicit ITS Action is consistent with NUREG-1432.

LA.2 CTS 4.7.1 presents a Surveillance Note (" Credit may be taken for unplanned events...") that applies globally to AC power source tests. The CTS Note is specifically needed only for those Surveillance that have restrictions associated with the operations Modes in which they are allowed to be performed. Since CTS 4.7.2.1 contains no restrictions, the fundamental allowance is applicable without any necessity for an explicitly statement. This fundamental allowance is stated in the ITS Bases for SR 3.0.1. This detail for the method of application can be adequately controlled within the Bases where revisions are governed by the Administrative Controls Section for Bases Control Program and 10 CFR 50.59. This level of detail remaining being located within the Bases in lieu of an explicit ITS SR is consistent with NUREG-1432.

LESS RESTRICTIVE CHANGES (L)

L.1 CTS Action 3.7.1.B.4 requires restoration of an inoperable DG within 7 days l cumulative time in any calendar month. ITS Required Action B.4 limits the l restoration time of any inoperability to 7 days (except as further restricted by the l Completion Time added in accordance with Discussion of Change M.1), without j tracking cumulative time. This change imposes both more restrictive possibilities as l well as less restrictive. CTS actions have the potential to allow a 14-day continuous l DG outage in the event the inoperability begins with 7 days remaining in a calendar j month; allowing those 7 days followed by the first 7 days in the next calendar month. l Eliminating this allowance in the ITS is considered more restrictive. The less l restrictive aspect of the ITS is the allowance to have two or more separate DG l l inoperabilities in any one calendar month that cumulatively could exceed 7 days which l l is not allowed by the CTS. l i I I

i Palisades Nuclear Plant Page 3 of 4 09/04/98

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.8.1, AC SOURCES - OPERATING LESS RESTRICTIVE CHANGES (L) l l

L.1 (continued) l l

Tracking cumulative outage time is not included in the ISTS since it is not a function l of Operability. Instead, tracking cumulative outage time is a function of l

" availability." Early custom technical specifications attempted to limit the time diesel l generators were unavailable by specifying cumulative outage time in the l specifications. Conversely, a literal application of standard technical specifications l would allow extended periods of diesel generator unavailability by an iterative process l of declaring an inoperable diesel " Operable" followed by another period of l inoperability. Subsequent to the issuance of standard technical specifications, the l NRC promulgated two rules (10 CFR 50.63, " Loss of all Alternating Current Power" l and 10 CFR 50.65, " Requirements for Monitoring the Effectiveness of Maintenance l at Nuclear Power Plants") which mandated (in part) that controls be instituted to limit j the time diesel generators are unavailable. In response to 10 CFR 50.63, the l Palisades plant established an Emergency Diesel Generator Reliability Program to l ensure diesel reliability is monitored and maintained above a reliability target level of l 0.95. This value is also used as a performance goal for diesel generator reliability l under the requirements of 10 CFR 50.65. The elements of Emergency Diesel l Generator Reliability Program are consistent with the guidance of Regulatory Guide l 1.155, " Station Blackout" and NUMARC 87-00, " Guidelines and Technical Bases for l NUMARC Initiatives Addressing Station Blackout at Light Water Reactors." l The 7 day cumulative time in any calendar month requirement in the CTS would l permit a maximum diesel generator unavailability of approximately 0.77. However, I due to the commitments associated with the requirements of 10 CFR 50.63 and l 10 CFR 50.65 to maintain a diesel generator reliability target level of 0.95, the l overall availability of the Palisades plant diesel generators is significantly greater than l 0.77 (the current availability for the emergency diesel generators is 99.0% for one l diesel, and 99.1% for the other). Since the requirements of the CFRs mandate higher l levels of diesel generator availibility than the CTS, excluding cumulative outage time l in the ITS can be made without a significant impact on the health and safety of the l public. Elimination of tracking outage time against a cumulative limit is consistent l with NUREG-1432. I Palisades Nuclear Plant Page 4 of 4 09/04/98

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR 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 j understandable by plant operators as well as other users. The reformatting, renumbering, and rewording process involves no technical changes to existing Technical Specifications.

I 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 l

details does not result in a technical change. i i

A.2 A Note is added to ITS 3.8.3 Actions allowing separate entry for each DG, This !

provides explicit instructions for proper application of the Actions for Technical Specifications compliance. In conjunction with proposed Specification 1.3,

" Completion Times," the Note provides direction consistent with the intent of CTS.

These changes are presentation preferences consistent with the NUREG-1432.

Therefore, this is an administrative change with no impact on safety. !

A.3 CTS 3.7.3 has been modified to include the " fuel oil transfer system" and " starting l 1

air subsystem" in the text of the " Specification". This change has been made to l establish a format consistent with the ISTS by specifying, in the LCO, the functional l l

capability of DG support systems required for the safe operation of the facility. Titis l change does not add or delete any requirement to the CTS, but simply adopts a j standard convention for specifying limiting conditions for operations. Therefore, this l ,

change is considered administrative in nature. l l I

Palisades Nuclear Plant Page 1 of 2 09/04/98 I

ATTACHhtENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR TECHNICAL CHANGES - AIORE RESTRICTIVE (51)

M.1 CTS 4.7.3.2 verifies the inventory of stored lube oil is 2175 gallons each 31 days. l CTS 3.7.3.B requires that actions be taken when the inventory of stored lube oil is < 175 l and 2150 gallons. Proposed ITS SR 3.8.3.2 verifies the inventory of stored lube oil is l 2 200 gallons. Proposed ITS 3.8.3 Condition B requires that actions be taken when the l inventory of stored lube oil is < 200 and > 160 gallons. The quantity of stored lube oil in l the ITS has been revised from the quantity required in the CTS as a result of data recently l obtained related to diesel generator lube oil consumption. The inventory of stored lube l oil is based on amount of tube oil necessary to support full load diesel generator i operation for at least 7 days. The CTS value of 175 gallons was based on an estimated l consumption rate of I gallon per hour which is representative oflarge type diesel l engines. Empirical data derived during a recent test of a Palisades plant diesel engine test I concluded that the actual lube oil consumption rate was approximately 0.83%. Values I between 0.8% and 1.0% have been confirmed to be acceptable by the engine vendor. As l a result of this test, and to ensure an adequate inventory oflube oil is available to support I diesel engine operations, the quantity of stored lube oil required in the ITS has been l increased to 200 gallons. A stored inventory of 200 gallons, together with the lube oil in I the engine sump, will ensure an adequate amount of tube oil will be available to support I full load diesel generator operation for at least 7 days in the event of an accident. This l change has been characterized as "more restrictive" and is considered acceptable since it l continues to preserve the original basis for stored tube oil contained in the CTS. l LESS RESTRICTIVE CHANGES - REhlOVAL OF DETAILS TO LICENSEE CONTROLLED DOCUh1ENTS (LA)

There were no " Removal of Detail" changes associated with this specification.

LESS RESTRICTIVE CHANGES (L)

There were no "Less Restrictive" changes associated with this specification.

Palisades Nuclear Plant Page 2 of 2 09/'RT95

ATTACIB1ENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.8.4, DC SOURCES - OPERATING LESS RESTRICTIVE CHANGES - REMOVAL OF DETAILS TO LICENSEE

CONTROLLED DOCUMENTS (LA)

LA.1 CTS 3.7.4 and 4.7.4.6 detail the plant equipment designators for the DC electrical power trains. ITS 3.8.4 simply requires the operability of the DC electrical power trains, and relocates the details of what comprises the trains to the Bases and FSAR.

Since these details are not necessary to adequately describe the actual regulatory requirement, they can be moved to a licensee controlled document without a significant impact on safety. Placing these details in the Bases of ITS 3.8.4 and the FSAR provides adequate assurance that they will be maintained. The Bases are controlled by the Bases Control Proces; in Chapter 5 of the proposed Technical Specifications, and the FSAR is controlled by 10 CFR 50.59. This change is consistent with NUREG-1432.

LESS RESTRICTIVE CHANGES (L)

L.1 CTS 3.7.4 specifies the requirements for DC source when the plant is above Cold l Shutdown. CTS 3.7.4 Actions A.1 require the cross-connected charger (s) for the l affected battery be placed in service immediately whenever one required charger is l l

inoperable. CT5 3.7.4 Action B.1 requires both chargers for the affected battery be l placed in service immediately whenever one battery is inoperable. The CTS does not l specify an Action when one charger and one battery in one train are inoperable l concurrently. Thus, the provisions of LCO 3.0.3 are applied. In the ITS, the l inoperability of a charger, a battery, and a charger and battery in one train l concurrently, are addressed by Conditions A, B, and C, respectively. The l Completion Times for Conditions A, B, and C are equally stated at 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months since l these conditions are ones where DC power continues to remain available to the bus, l albeit with inoperable sources. Selection of the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is consistent l with that previously approved for the more degraded condition of one de-energized l DC electrical distribution train allowed by CTS 3.7.9.c. With one DC electrical l distribution train de-energized, the remaining DC electrical train is capable of l l supporting the minimum safety functions necessary to shut down the reactor and l maintain it in a safe condition. Since ITS 3.8.4 represcats a configuration of the DC l i

electrical system that is less severe and presents less risk for a loss of function than that l

allowed by CTS 3.7.9.c (proposed ITS 3.8.9), an extension of the Completion Times to l l 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months can be made without a significant risk to public health and safety. An extension l of the Completion Times for "DC Source-Operating" to match the Completion Times for l (DC)" Distribution Systems-Operating"is consistent with the philosophy presented in l NUREG-1432. I Palisades Nuclear Plant Page 2 of 3 09/04/98 l

\

l ATTACHMENT 3 t

DISCUSSION OF CHANGES ,

l SPECIFICATION 3.8.9, DISTRIBUTION SYSTEM - OPERATING l

( 1 ADMINISTRATIVE CHANGES (A) l A.1 All reformatting and renumbering are in accordance with NUREG-1432. As a result, l i

the Technical Specifications (TS) shculd be more readily readable, and therefore l understandable by plant operators as well as other users. The refonnatting, renumbering, and rewording process invol'ms no technical changes to existing :

Technical Specifications. l 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.

I A.2 CTS 3.7.9.A.1, B.1, and C.1 specify an action that informs the operator to comply with other required actions is necessary. Since these other required actions are !

required to be met regardless of this statement, this statement does not provided !

specific action. It therefore serves solely as an informational note, which does not

{

appear in ITS. As such, its removal is an administrative editorial presentation -

preference with no technical change or change in intent. This change is consistent with NUREG-1432.

A.3 CTS 3.7.9.E requires immediate entry into specification 3.0.3 "with any inoperable l distribution subsystem that results in a loss of a safety function." ITS 3.8.9 l Condition E requires immediate entry into LCO 3.0.3 when "two or more inoperable l subsystems result in a loss of function." The requirements of the CTS and ITS are l essentially equivalent. That is, both specifications require a plant shutdown when a l loss of safety function exists due to degradation of the electrical distribution system. l The difference in language between CTS 3.7.9.E and ITS 3.8.9 Condition E is due to l the application of the technical specification usage rules and treatment for a loss of l safety function. (See Chapter 3.0 of the Palisades ITS conversion submittal for a l 1 discussion related to the inclusion of ITS LCO 3.0.6) Since the proposed wording l does not alter the original intent of the CTS, this change has been characterized as 1 administrative in nature. l l

Palisades Nuclear Plant Page 1 of 2 09/04/98

l l

ATTACHMENT 3 DISCUSSION OF CHANGES l SPECIFICATION 3.8.9, DISTRIBUTION SYSTEM - OPERATING TECHNICAL CHANGES - MORE RESTRICTIVE (M)

M.1 CTS 3.7.9.D requires that if inoperable components are not restored to OPERABLE status then the reactor shall be placed in a hot shutdown condition within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and cold shutdown within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . In the proposed ITS, the requirement is to place the plant in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The CTS HOT SHUTDOWN is nominally equivalent to the proposed ITS MODE 3 as discussed in Section 1.1 and therefore, there is little effect in adopting the proposed ITS MODE 3 parameters. However, adopting the proposed ITS shutdown times is considered to be more restrictive, but continues to allow sufficient time to shutdown the plant in a safe and controlled manner. This change is consistent with NUREG-1432.

M.2 CTS 3.7.9 Actions for restoration of an inoperable power distribution subsystems, do not impose limitations for overlapping combinations of inoperable AC, DC and Preferred AC subsystems. ITS Required Actions A.1, B.1 and C.1 include a requirement for restoration of all subsystems to operable status within 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months of initial failure to meet the LCO requirement. These added Completion Times assure that alternating inoperabilities in AC, DC and/or Preferred AC subsystems will not continue indefinitely without complete restoration to compliance with the LCO. The 16-hour Completion Time is reasonable to assure timely restoration. This Completion Time is consistent with the NUREG-1432.

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

LA.1 CTS 3.7.9 , and Table 3.7.9-1, detail the plant equipment designators for the AC, DC and Preferred AC distribution subsystems. ITS 3.8.9 simply requires the operability of the subsystems, and relocates the details of the plant-specific designators to the Bases and FSAR. Since these details are not necessary to adequately describe the actual regulatory requirement, they can be moved to a licensee controlled document without a significant impact on safety. Placing these details in the Bases of ITS 3.8.9 and the FSAR provides adequate assurance that they will be maintained. The Bases are controlled by the Bases Control Process in Chapter 5 of the proposed Technical Specifications, and the FSAR is controlled by 10 CFR 50.59. This change is consistent with NUREG-1432.

l- LESS RESTRICTIVE CHANGES (L)

There were no "Less Restrictive" changes associated with this specification.

Palisades Nuclear Plant Page 2 of 2 09/f'4/95

ATTACHMENT 3 DISCUSSION OF CHANGES SPECIFICATION 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN 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 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.

A.2 CTS 3.7.10.A contains the actions to be taken when one or more required AC, DC, l or Preferred AC electrical power distribution subsystems are inoperable. CTS l 3.7.10.A action 2.5 states to " declare affected required shutdown cooling trains l inoperable." In the ITS, the corresponding action is Required Action A.2.5 which l states " declare associated required shutdown cooling train inoperable and not in l operation." Required Action A.2.5 contains the ph and in operation" which is l not in the CTS. The inclusion of this phrase assures the appropriate actions are taken l in the event primary coolant circulation and heat removal functions are lost as a result l of an electrical distribution system inoperability. In this instance, reliance on l LCO 3.0.6 would be inappropriate. This change is considered administrative in l nature since it does not alter an existing requirement in the CTS, but simply addresses l each aspect (i.e., Operable, and in operation) related to a loss of the shutdown j cooling function. l TECHNICAL CHANGES - MORE RESTRICTIVE (M)

There were no "More Restrictive" changes associated with this specification.

Palisades Nuclear Plant Page 1 of 2 09/04/98

l I

i ATTACHMENT 3 DISCUSSION OF CHANGES ,

SPECIFICATION 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN I LESS RESTRICTIVE CHANGES - REMOVAL OF DETAILS TO LICENSEE CONTROLLED DOCUMENTS (LA)

There were no " Removal of Details". changes associated with this specification.

LESS RESTRICTIVE CHANGES (L) ,

l There were no "less Restrictive" changes associated with this specification.

i l

l Palisades Nuclear Plant Page 2 of 2 09/04/98 l

l l

l

AC Sources-Operating

_, 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVE!LLANCE FREQUENCY SR 3.8.1.3 -- -------- -- --NOTES -- ------------ --

cy5 1- G I 'd'"S **Y '" ' Sr'd" I ding a recommen d by th 47.l.3 nufactu er. -

. Momentary transients outside the load range do not invalidate this test.

V This Surveillance shall be conducted on only one OG at a time.

4. This SR shall be preceded by and

./ immediately follow without shutdown a successful, performance of SR 3.8.1.2

_ -- co 3 a ,-

f

:'--- : L - ------------ -- ----------

9. For 1 'G m MM -

loaded 4 greak 3 \ do

% orepo.1/p Peak Verify each DG is synchronized and loaded, As op.ciff d -

i etcci dswi lo ad, and i agoggratesfora60minutestataload Tel 3 ".1 1 2 6,,.. kW and s kW.

. b . Fvr h l M M ain) ts 2300 ~

2.900 ofM

+ts e SR 3.8.1.4 Verify each day tank ' :=t;t 31 days t* *} contains 2 M- 2M) ud : of;in:fuel oil.

CTS

+1.I f QS00 @Q SR 3. 8. .'S Chec for and remov accumulated water rom (31] days eac day tank (and ngine mounted ta ).

SR 3. .l.6 Verify e fuel oil tran fer system (92) days operat to (automatic ly) transfer fu oil f storage tank' ] to the day ta (and ngine ecunted ink).

(continued)

CEOG STS 3.8-7 Rev 1, 04/07/95 REMSED ee44 tee l

)

i AC Sources-Operating 3,8,1 l

SURVEILLANCE REQUIREMENTS (continued) l SURVEILLANCE FREQUENCY 1

- - 1 SR 3.8.1 - --- -- ---- OTES ------ ---------- ,

cT3 ' his Surveil ance shall n be y,7, f,7

{ l.

performed i MODE 1 or 2 However, credit ma be taken for nplanned events t t satisfy th s SR.

g 2. If pe ormed with t with offsite power it shall be DG synchro zod j per ormed at a po r factor s

.9].

Verify each DG rejects a load greater than gl8 months {

or equal to its associated single largest i post-accident load, and: i

a. Following load rejection, the l frequency is s Hz; I b. Within (3k seconT following load rejection, the voltage is 2 V and s ; and 2'240

c. Within seconds following load rejecti , the frequency is 2 Hz and s Hz.

TI. (sl .

SR 3.8.1. ----/-- ---- -- - NOTE-- --- ------ --

t be perfo d g7) g Th 4 Surveill ce shall MODE 1 or . Howeve , credit may e taken for planned e nts that sa sfy /

y.7,[. $

/ .this

.......SR.

lLf - 000 -

Verify each DG, pera ing at a power factor 418 months {

. sfp.9k,doesno trip, and voltage is maintained s V during and following a load rejection of 2 ,GG^ kW and s kW.

(continued)

CEOG STS 3.8 9 Rev 1, 04/07/95 REVISED esfeelBe

Diesel Fuel @, Lube Otl, and Startin Air 3.8 ELECl?' CAL POWER SYSTEMS KAl g3 07 3.8.3 OleselFuel%LubeOil,andStartingAir . -

/

LCO 3.8.3 fm- i i ,

e Atored diesfi fuel oil. Itatfe oil narung aux i

sutdvsta= chill be within lindtfor each req'uired fiesel X

i generator a.. The c+ arid dio.L (OGJgl bL eil,lA oil Sed 3MAh &e J41/

k< t,9 th /.m itt v 4

L *M IVf* al All h0 ll*'

t APPLICA81LITY: When 86td dit assoc.!t Iated OG is requiredC4Lto C'd +ord be OPERA 8LE.

. ACTIONS l ..................................... NOTE.....................................

I Separate Condition entry is allowed for each DG.

W CONDITION REQUIRED ACTION COMPLETION TIME ,

j cr3 ae

3,7,J, A A. Q_n (.o%

c ..betorg)A-L L A. l_ Restore fuel oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months

'=! L.. L 4 27.7on_ @ws) to within

< g ,._ ,_ , nerj ena

~

limits, h >-er or 1 in storage tank.

fgyeohsN]

a L-(20, Ilo @5) j C r$ 8.lubea ft -- _ M : ith oil inventory 8.1

($-hW'&

Restore ubeFo11 inventory to within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 3'7,g g <CJOEAl nd limits.

.' >i M 9Arg 200 ga%

U40 tallM7

+

IFuel fra.u Msysitw N(,

C. ' ^-- - f _ "" _ 7 ' " C.1 Restore fuel \ett.

dt-3 3,7.1.G T..i '.'I.'.'. ' : O!!!I55_ U 'd:y:k lC ho 6 s.p+m +a oferus ^~E ~-

OwnMwA+m+se.P-1sqs4%om.6 +n4bsy --

CTS D. f4) hams (Wsfshyt Al Ars k e..fw l k us k (continued) 7 day 5 3 9.\ H (p-1gg)as9una. & b oPERMSW 5134v5, g5 6. 3M MM(ev' E.1 Reske one M 2 herrs

,g' g , y i stfiets ie4ofu AM, tr*K3 b 675YSA -

M .8 22^ fo ONRh6tE Rev 1, 04/07/95 CEOG STS _

$%493 e newsen SWOWee a

Die >vi Fuel 011. Lube Oil, and Starting Air 3.8.3 l

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME CTS p .

Or.; :- -~ ~ ^^

Restore stored fuel 30 days aem el il oil properties to I/.3'D properties not within within ilmits.

O Wh Viscasi6f. h ol_W a O G+*N One or ao DGs with Restore s ting air 48 hou starti air receiver receiver ressure to press < (225] psi 2 (22 psig. l and (125].psig.

' Required Action and Declare associated DG Imediately associated Completion inoperable.

CTS Time not met.

37.3.C g One or more DGs with +

diesel fuel oil, lube oil, or starting air subsystes not within limits for reasons other than v Condition A, 8, @ ,c,4 # A F. 113*A SURVEILLAE1 aus! ROUTS SURVEILLANCE FhEQUENCY CTS SR 3.8.3.1 Verify fuel oil storage tank contains O - ,2 2 n ._ _ r a ,1)of fuel.

4.T31 ,

( 2 3.100 pJeaB (continued) 3.8 23 Rev 1, 04/07/95 CEOG STS l

I RESASED semese

Distribution Systems-Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems-Operating Q

LM Prduk LCO 3.8.9 A Train X and rain X AC, DC, and AC ftte4 bus electrical power distribution subsystems shall be OPERABLE.

CT$

3.1,9 APPLICA81LITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME l 1

c75 [ A. f_QWD One AC electrical A.1 Restore AC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ,qA 3,7,q,4 power distribution power distribution yg.v.3; subsyst erable. subsystem t OPERA 8LE E status, o in m imca 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from y discovery of failure to meet LCO

- wx --

(cy9 Cr.e Of M3 9 Nrl.o

. A0 P<MkGwO 455Ftfu .- 8.1 RestoreMC w$4e%'gi

@ hours inoperable. 7..L ,.. to OPERABLE I c73 status. M

,g 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO

'~

dH&

One K elastrical C.1 Restore DC electrical ours /IM cr5 power distributton power distribution $g94 J.7 1,C subsyst perable, subsystem o OPERABLE E status.

16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from )(

in ON Mm discovery of failure to meet LCO (continued)

I 3.8-39 Rev 1, 04/07/95 CEOG STS i

sede4 tee

.n -. - .. - - _ _ . - - - . _ - - -- -

i l' ATTACHMENT 6 JUSTIFICATIONS FOR DEVIATIONS SPECIFICATION 3.8.1 AC SOURCES - OPERATING Chance Discussion NOTE: This anachment provides a brief discussion of the deviations from the Technical Specifications of NUREG-1432 that were made to support the development of the Palisades Nuclear Plant ITS. Due to the recent CTS amendment request, which proposed NUREG - like Bases for Section 3.8, three additional attachment have been provided. Attachment 7 is a markup of the CTS Bases showing the difference between CTS and proposed ITS Bases.

Attachment 8 provides an explanation of these differences. Attachment 9 provides a markup of NUREG-1432, Section 3.8 Bases. Therefore, the JFDs are provided against changes to the CTS Bases, rather than as typically done against the NUREG Bases.

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.

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

2. Editorial change for clarity or for consistency with the Improved Technical Specifications (ITS) Writer's Guide.

3. 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.

4. 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.

5. This change reflects the current licensing basis / technical specifications.

4 4

4 Palisades Nuclear Plant Page 1 of 4 09/04/98

~

l- 1 l

l i

l ATTACHMENT 6 i JUSTIFICATIONS FOR DEVIATIONS I SPECIFICATION 3.8.1, AC SOURCES - OPERATING I

1 Channe Discussion l

6. The option to specifically list automatic load sequencers as a third type of AC Source, and provide a separate Action, is not adopted. Sequencers are not a separate source of AC power; rather they are a support component for the DG function. As such they are implicitly required to be Operable by the iequirement for DG Operability (as detailed in the ITS Bases). Similarly, when discovered inoperable, the Actions for an inoperable DG apply without having to state so explicitly.

I NUREG-1432 Bases support this. The Reviewer's Note in the Bases for Required Action F.1 indicates that the specific condition related to the sequencer may be deleted "if the unit design is such that any sequencer failure mode will only affect the ability of the associated DG to power its respective safety loads under any conditions." In the design of the Palisades plant, failure of an automatic load I sequencer does not result in the inability to start all or part of the safety loads from l the offsite power circuits when required, or result in overloading the offsite power l circuits to a safety bus during an event. The automatic load sequencers are not shared l with the offsite power circuits, nor are they required to support the loading of the i 2400 V Class IE buses when those buses are being supplied by offsite power. l Therefore, inclusion of an explicit Condition, Required Action, and Completion Time l for an inoperable automatic load sequencer is not required in the Palisades ITS, l

7. The maximum time allowed to fail to meet the LCO is revised from 6 days to 10 days. The accepted NUREG-1432 practice for limiting successive alternating inoperabilities with this type of maximum time Completion Time, is to allow one full Complete Time for each of the associated component types. In this case, with the proposed Completion Times of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for an offsite circuit and 7 days for a DG, the maximum time is appropriately specified as 10 days.

8. The Palisades DG design does not incorporate " gradual acceleration" on a DG start.

NUREG-1432 presentation of SR 3.8.1.2 Notes 1 and 3, and SR 3.8.1.7, are addressing this design feature. The proposed modifications to eliminate these Notes and the SR provides the appropriate presentation for the Palisades DG design.

9. The Palisades DG design does not incorporate " gradual acceleration" on a DG start.

Similarly, NUREG-1432 SR 3.8.1.3 Note 1 states an allowance for " gradual loading." However, since there is no stated prohibition to gradual loading, and the surveillance itself does not impose and loading-rate criteria, this Note is informational only, and should be removed as a Technical Specification requirement.

t l Palisades Nuclear Plant Page 2 of 4 09/04/98

l ATTACHMENT 6 JUSTIFICATIONS FOR DEVIATIONS SPECIFICATION 3.8.1, AC SOURCES - OPERATING Channe Discussion

10. ISTS 3.8.1 Required Action A.2 is not retained; consistent with CTS. The Palisades design and requirements for operable offsite circuits ensures that each ESF bus will be energized if at least one circuit is operable. If any bus can not be energized, then both required offsite circuits would be declared inoperable.

The qualified offsite circuits required by ITS LCO 3.8.1 are Safeguards Transformer l 1-1 and Startup Transformer 1-2. For an offsite circuit to be considered operable, it l must be capable of supplying electrical power to both class 1E electrical trains. l Inclusive in the requirement for operability is that the associated cables, instruments l and breakers, necessary to provide a complete circuit from the switchyard to the l onsite safety-related AC distribution system, are capable of performing their intended l ,

function. The normal lineup at Palisades, both during plant operation and shutdown, l has both safety related 2400 volt AC buses supplied from Safeguards Transformer 1- l

1. If protective relay actuation occurs for the Safeguards Transformer, both buses are l automatically transferred to the alternate required offsite source, Startup Transformer l 1-2. l I

As part of the Palisades plant design, with one offsite circuit inoperable, electrical l power is still available to both class 1E electrical trains since either the Safeguard l l Transformer 1-1, or the Startup Transformer 1-2 can be aligned to both safety-related l I 2400 V buses. Therefore, for either safety related 2400 volt bus to have "no offsite l power available" as discussed under ISTS 3.8.1 Required Action A.2, both offsite l circuits would have to be inoperable. The condition of both offsite circuits being l 1 inoperable is covered under ISTS and ITS 3.8.1 Condition C, which includes the l l

subject Required Action C.1, but with a reduced Completion Time. As such, l Required Action A.2 of ISTS 3.8.1, which only applies when one electrical train l cannot be powered from an offsite source, is not applicable to the Palisades ITS. l

11. ISTS SR 3.8.1.6 relates to surveilling the DG fuel oil transfer pumps. Palisades provides the appropriate plant specific fuel oil transfer pump surveillance in ITS 3.8.3, SR 3.8.3.6. This presentation preference is dictated by the plant specific current licensing basis allowing specified allowed Completion Times to repair i inoperable transfer pumps prior to declaring a DG inoperable.

12. TSTF 8, Rev. 2 deleted the 3.8 SR Notes "However credit may be taken..." and addressed that issue globally in the 3.0 Bases. This presentation is consistent with NUREG-1432.

Palisades Nuclear Plant Page 3 of 4 09/04/98 w, w

- - -. - -- .- . .- ---. .. .= , - . -

l' ATTACHMENT 6 JUSTIFICATIONS FOR DEVIATIONS SPECIFICATION 3.8.1, AC SOURCES - OPERATING j Change . l Discussion '

13. This change reflects the current licensing basis / technical specifications. The l surveillance requirement for checking and removing accumulated water from each l diesel generator fuel oil day tank was not adopted in the ITS (or the CTS) due to the l design of these tanks. The tanks are constructed with flat bottoms and do not provide l a sump for water collection or removal. Historic performance has shown that water I accumulation in these tanks has not been a problem. A similar surveillance I requirement for the Diesel Fuel Oil Storage Tank was incorporated in the CTS l following replacement of the original storage tank with a new storage tank. The new l Diesel Fuel Oil Storage Tank contains an integral sump for water collection and l removal. Thus, the surveillance requirement to check and remove accumulative water l was retained in the ITS for the Diesel Fuel Oil Storage Tank only. l l

14. This change reflects the current licensing basis / technical specifications. On April 29, l 1998 the NRC issued Amendment 180 to the Palisades Plant operating license. The l amendment revised the Technical Specification requirements and associated bases l regarding the electrical power systems to closely emulate the Standard Technical l Specifications for Combustion Engineering Plants, NUREG-1432, Revision 1. As l J part of this revision, new diesel generator surveillance tests were adopted including l the tests which verify each diesel generator is capable of a load reject greater than or l equal to its associated single largest post-accident load (ISTS SR 3.8.1.9), and that l each diesel generator is capable of a full load reject (ISTS SR 3.8.1.10). These new l surveillance requirements (CTS 4.7.1.7 and CTS 4.7.1.8) were issued without the l note which states that the surveillance "shall not be performed in Mode 1 or 2. l Omission of this note was found acceptable by the NRC staff in their Safety l Evaluation related to Amendment 180 which concluded that " performance of these l SRs (4.7.1.7,4.7.1.8, and 4.7.1.10) at power would not cause any undue transients l on the Class 1E distribution system." As such, Note 1 in ISTS SR 3.8.1.9 and ISTS l SR 3.1.8.10 was not incorporated in the Palisades ITS. l I

l l

l Palisades Nuclear Plant Page 4 of 4 09/04/98

l I

l l

ATTACHMENT 6 JUSTIFICATION FOR DEVIATIONS SPECIFICATION 3.8.4, DC SOURCES - OPERATING Channe Discussion i NOTE: This attachment provides a brief discussion of the deviations from the l Technical Specifications of NUREG-1432 that were made to support the development of the Palisades Nuclear Plant ITS. For Section 3.8 ONLY, three additional attaclunent have been provided. Attachment 7 is a markup of the CTS Bases showing the difference between CTS and proposed ITS Bases.

Attachment 8 provides an explanation of these differences. Attachment 9 provides a markup of NUREG-1432, Section 3.8 Bases.

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.

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

2. Editorial change for clarity or for consistency with the Improved Technical Specifications (ITS) Writer's Guide.

3. 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.

4. 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.

Palisades Nuclear Plant Page 1 of 2 09/04/98 l

l

ATTACHMENT 6 }

JUSTIFICATION FOR DEVIATIONS '

SPECIFICATION 3.8.4, DC SOURCES - OPERATING

5. This change reflects the current licensing basis / technical specifications as modified by l DOC L.I. ITS 3.8.4 has been developed to preserve the operational flexibility of the l CTS while maintaining a parallel structure to the ISTS. The design of the Palisade l plant DC electrical power system is such that each station battery has two associated l battery chargers, one powered by the associated AC power distribution system (the l l directly connected charger), and one powered from the opposite AC power l distribution system (the cross connected charger). CTS 3.7.4 provides the actions l necessary to cope with a degraded DC electrical power system which results from an l inoperable charger or an inoperable battery using the design features (i.e., cross l connect capabilities) of the system. These same actions have been incorporated in l ITS 3.8.4. However, in NUREG-1432, ISTS 3.8.4 is structured such that the l restoration time for an inoperable DC electrical power subsystem (e.g., charger, or l battery, or charger and battery) is equivalent to the allowed outage time for an l inoperable DC electrical power distribution system. The basis for this structure is the l recognition that a degraded DC electrical power source presents no more risk than an l inoperable DC bus. Thus, to maintain this same logical structure in the Palisade's l ITS, Condition C has been added to address the concurrent inoperabilities of a l charger and battery in the same electrical train (in the ISTS, this same configuration l would be addressed by Condition A). l

6. TSTF-8, Rev. 2 deleted the 3.8 SR Notes "However credit may be taken..." and addressed that issue globally in the 3.0 Bases. This pr::sentation is consistent with NUREG-1432.

7. Incorporate TSTF-38 into SR 3.8.4.3 to specify the surveillance is to identify conditions which could degrade battery performance.

l l

Palisades Nuclear Plant Page 2 of 2 09/04/98

I ATTACHMENT 6 i JUSTIFICATION FOR DEVIATIONS SPECIFICATION 3.8.5, DC SOURCES - SHUTDOWN Channe Discussion NOTE: This attachment provides a brief discussion of the deviations from the !

Technical Specifications of NUREG-1432 that were made to support the development of the Palisades Nuclear Plant ITS. For Section 3.8 ONLY, three additional attachment have been provided. Attachment 7 is a markup of the CTS Bases showing the difference between CTS and proposed ITS Bases.

Attachment 8 provides an explanation of these differences. Attachment 9 provides a markup of NUREG-1432, Section 3.8 Bases.

The Change Numbers correspond to the respective deviation shown on the "NU. REG MARKUPS." The first five justifications were used generically throughout ilic markup of the NUREG. Not all generic justifications are used in each Specification.

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

2. Editorial change for clarity or for consistency with the Improved Technical Specifications (ITS) Writer's Guide.

3. 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.

4. 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.

5. This change reflects the current licensing basis / technical specifications. Only those l SRs from specification 3.8.4 which can be performed without affecting the l Operability or reliability of the only required DC source are specified. Since the l performance of SR 3.8.4.7 and SR 3.8.4.8 would cause the only required battery to l be inoperable during the test, these SRs have been excluded from SR 3.8.5.1. l i Palisades Nuclear Plant Page 1 of 1 09/04/98 l

l

! 1 I

AC Sources - Shutdown {

B 3.7.2 and 4.7.2 l

BASES

( 1 An OPERABLE DG, 5 ociated with a distribution subsystem required to be OPERABLE by LCO 3. 10, ensures a diverse power source is available to provide electrical power support, assuming a loss of the offsite circuit.

Together. OPERABILITY of the required offsite circuit and OG ensures the availability of sufficient AC sources to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g.,

fuel handling accidents and loss of shutdown cooling).

The DG must be capable of starting, accelerating to rated speed and voltage, connecting to its respective 2400 volt bus on detection of bus undervoltage, and accepting required loads. Proper " Normal Shutdown" loading sequence, and tripping of nonessential loads, is a required function for DG OPERABILITY, A Service Water Pump must be started soon after the DG to assure continued DG operability. The DBA loading sequence is not required to be OPERABLE since the Safety injection Signal is disabled during '^p-(Ino 0EI {ond APPLICABILITY g

The AC sources required to be OPERABLE in COLD anvisu ., Taiu R;;,0 ::fiCOU9, g and during movement of irradiated fuel assemblies provide assurance that p \ yDI equipment and instrumentation is available to: .T'

a. Provide coolant inventory makeup, h

b. Mitigate a fuel handling accident, -

c.

d.

Mitigate shutdown events that can lead to cop da p n g and maintainC 3 the plant in ny_w Uf a h y g condition.

c This LC0isisinapplicable the plant a conditionduring other movement than COLO of irradiated

lUTC'"!'! fuel assemblies c' oEP'.'!L:':0 even ip S';UTOOL (CM

, This LCO provides the necessary ACTIONS if the AC electrical power sources i required by this LCO become unavailable during movement of irradiated fuel

""'* 8*

o ars I, 2,3, o The AC source requirements for der C.L 0'"n0""are addressed in LCO 3. 1, "AC Sources - Operating".

1 PALISADES B 3.7.2-2 Amendment No.

REVISED eenetee

i l

1 l

3 cmc I Ws4 9l h Diesel Fu B

j Lube Oil

.3 m , ' 4 Nr l

ELECTRICAL POWER SYSTEMS ,

d '

B 3.7.3 6 Diesel Fu , sa44ube 01 [ dM Y4cwf;<sy 4, BASES l

BACKGROUND Thejiesel/Inerators(DGs)areprovidedwithastoragetankhavingarequired fuel oil inventory sufficient to operate one diesel for a period of 7 days, while the DG is supplying maximum post accident loads. This onsite fuel oil capacity is sufficient to operate the DG for longer than the time to replenish the onsite supply from offsite sources.

Fuel oil is transferred from the Fuel 011 Storage Tank to either day tank by l O2 either of two Fuel Transfer (R9F(3g.,4 %_Td5ff.T1) @ f, 0 l For proper operation of the standby DGs, it is necessary to ensure the proper quality of the fuel oil. Regulatory Guide (RG) 1.137Iaddresses the

@ recommended fuel oil practices as supplemented by ANSI N195-1376 The DG lubrication system is designed to provide sufficient lubrication to l permit proper operation of its associated DG under all loading conditions. '

The system is required to circulate the lube oil to the diesel engine working surfaces and to remove excess heat generated by friction during operation.

The onsite storage in addition to the engine oil sump is sufficient to ensure 7 days of continuous operation. This supply is sufficient supply to allow the operator to replenish lube oil from offsite sources. Implicit in this LCO is the requirement to assure, though not necessarily by testing, the capability to transfer the lube oil from its storage location to the DG oil sump, while the DG is running.

APPLICABLE SAFETY ANALYSES gggg g A description of the Safety Analyses applicable _._ ____ ....,_ nT provided in the Bases for LCO 3.W.1 "AC Sources - Operating"; during -GOW

-.wm one .m. _ _ _ _ . _ . - . . - . . . . . , in the Bases for LC0 3. 2 "AC Sources -

Shutdown".

A

$ N ,oS ha &c.id. ExL Odm. i ML, 0.4 04 edin 04 /)lA0y3 bed /Jopp,p+ 36, 6khsrt 04 4hr. hkedbj A( pew couney keytaa $) g RikrO 3 Ok 10 CM 30.3(a (CYb.

PAllSADES B 3.7.3-1 Amendment No.

REMSED 8844/9e

l SECTION 3.8 l INSERT 1 The fuel oil transfer system which includes fuel transfer pump P-18A can be powered by offsite power, or by either DG. However, the fuel oil transfer system which includes fuel transfer pump P-18B can only be powered by offsite power, or by DG 1-1.

l . INSERT 2 Ql333-6'1 Each DG is provided with an associated starting air subsystem to assure independent start l capability. The starting air system is required to have a minimum capacity with margin for a l DG start attemp without recharging the air start receivers. l 1

)

l l

1 B 3.7.3-1 mnase

, avd

\

> s,w sg Diesel Fuel Lube 011-B 3.7.3 and 4.7.3 BASES LCO fZAnck7.Ll Stored diesel fuel oil is ' required to have sufficient supply for 7 days of I full accident load operat'on. It is also required to meet specific standards for quality. The specified 7 day requirement and the 6 day quantity listed in Condition 4ct:ft A are taken from the Engineering Analysis associated with QQ Event Report E-PAL-93 0268. Additionally, sufficient lube oil supply must be available to ensure the capability to operate at full accided load for 7 days. This requirement is in addition to the lube oil contained in the engine sump. The specified 7 day requirement and the 6 day quantity listed in O S Condition %B are based on an assumed lube oil consumption of LPwiopper)

( TMEP'1' f (OE ** # %_

f *\*^ '"PU"'*?

)

These requirements, in conjunction with an ability to obtain replacement supplies within 7 days, support the availability of the DGs. DG day tank fuel requirements .ow Tuul ti.a d c'"'M1"y " c '"?':0 + 2 " *"d 7

h % are addressed in LCOs 3 1 and 3 2.

APPLICABILITY g g

. DG OPERABILITY is required by LCOs 3. .I and 3. 2 to ensure the availability of the required AC power to shut down the reactor and maintain it in a saf 7 shutdown condition following a loss of off site power. Since diesel fuel N +*d lube oilasupport LCOs 3. . an 3.1.2, stored diesel fuel oilfa@ lube o e are required to be within limit either DG is required to be*0PERABLE.

7 D 4l ACTIONS

[ $ ^1 l$$$t s! 0 In this Condition, the available DG fuel oil supply is less than the required 7 day supply, but enough for at least 6 days. This condition allows sufficient time to obtain additional fuel and to perform the sampling and analyses required prior to addition of fuel oil to the tank. A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration of the required inventory prior to declaring the DGs inoperable.

[ B.1 ,- }

In this Condition, the available DG lube oil supply is Tess than the required jj 7 day supply, but enough for at least 6 days. This condition allows 7 sufficient time to obtain additional lube oil. A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration of the required inventory prior to declaring the DGs inoperable.

PALISADES B 3.7.3-2 Amendment No.

REMSED esfe4tes

SECTION 3.8 INSERT 1 Q Ai 3'g'S- @

I

~ Additionally, the ability to transfer fuel oil from the storage tank to each day tank is required l from each of the two transfer pumps. l INSERT 2 The starting air subsystem must provide, without the aid of the refill compressor, sufficient

., air start capacity, including margin, to assure start capability for its associated DG.

B 3.7.3-2 nevisen eeMine

4 Diesel Fuel and tube Oil ,

B 3.7.3 and 4.7.3 BASES

,. .>.u.k 5 roiesei unacceptable f#eiforoii evenwita shortviscositx. or witer term DG operation.

ou e#d Viscesity sedimeete is import nt m t of iim l

primarily because of its effect on the handling of the fuel by the pump and '

injector system; water and sediment provides an indication of fuel contamination. When the fuel oil stored in the Fuel Oil Storage Tank is

/ SN determined to be out of viscosity, or water and sediment limits, the DGs eu i p(tor 6 te_ declared inonerable, immediately.

N 'S ?.'.?_?_1 y l (D With the stored water and u- , sediment, definedfuel oil Fuel in the propefties, other il Testing than viscosity Program not within the required limits, but acceptable for short term DG operation, a period of 30 days is allowed for restoring the stored fuel oil properties. The most likely cause of stored fuel oil becoming out of limits is the addition of new fuel oil with {

properties that do not meet all of the limits. This 30 day period provides i sufficient time to determine if new fuel oil, when mixed with stored fuel oil, '

will produce an acceptable mixture, or if other methods to restore the stored fuel oil properties are required. This restoration may involve feed and bleed l

procedures, filtering, or combinations of these procedures. Even if a DG -

start and load was required during this time interval and the fuel oil properties were outside limits, there is a high likelihood that the DG would

@ still be capable of performing its intended function.

[ril W 08 ,,e s.,..._._

j or St*M /WithaR uire and asscciated Completion Time not met, or with diesel airSa fuel oil or 1 t within limits for reasons other than addressed by

. C_ondit ons rA the associated DG may be incapable of performing its ena= '"ncunn and must te immediately declared inoperable.

[5.o}or /i [r1O&WM+ M k ' -- - --

SU LANCE REQUIREMENTS SR .1 'c=1 i woniib id' " -

This SR provides verification that there is an adequate inventory of fuel oil in the storage tank to support E.ither DG's operation for 7 days at full post-accident load. The 7 day period is sufficient time to place the plant in a safe shutdown condition and to bring in replenishment fuel from an offsite location.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is specified to ensure that a sufficient supply of fuel oil is available, since the Fuel Oil Storage Tank is the fuel oil supply for the diesel fire pumps, heating boilers, and rad waste evaporators, in addition to the DGs.

PALISADES B 3.7.3-3 Amendment No.

L REMSED 08 44100

Diesel Fuel and Lube Oil B 3.7.3 and 4.7.3 BASES

_m

% SR .2-(Ld; :t' qu:etit,; d:d) S g This Surveillance' ensures that sufficient lube oil inventory is available to 0' 4 ,

port at least 7 days of full accident load operation for one DG. The nW requirement is based on an estimated consumption ofIIxfilMD

@ gallons (o,9 % .og of Li ,a cysy,4%m.} $

A 31 day frequency is adequate to ensure that a sufficient lube oil supply is onsite, since DG starts and run times are closely monitored by the plant staf

% SR + w.3.3 (N:1 c!' qu:lity W :E)a The tests listed below are a means of determining whether new fuel oil and stored fuel oil are of the appropriate grade and have not been contaminated with substances that would have an immediate, detrimental impact on diesel engine combustion.

Testing for viscosity, specific gravity, and water and sediment is completed for fuel oil delivered to the plant prior to its being added to the Fuel Oil Storage Tank. Fuel oil which fails the test, but has not been added to the Fuel Oil Storage Tank does not imply failure of this SR and requires no specific action. If re:ults from these tests are within acceptable limits, the fuel oil may be added to the storage tank without concern for contaminating the entire volume of fuel oil in the storage tank. (M. 3)

[ Fuel oil is tested for other of the parameters specified in ASTM 0975 in .$. \

g accordance with the Fuel Oil Testing Program required by Specificationl6.5.11)

Fuel oil determined to have one or more measured parameters, other than viscosity or water and sediment, outside acceptable limits will be evaluated for its effect on DG operation. Fuel oil which is determined to be acceptable for short term DG operation, but outside limits will be restored to within limits in accordance with LCO 3. 3 Condition .

8 F SR 5.g.3M T 1 I NSEfLT A

% 3&l Baus (fjlO PALISADES B 3.7.3-4 Amendment No.

9044tge

I 1 l 1

l OC Sources Operating B 3.7.4 and 4.7.4 l

BASES The batteries for the DC power sources are sized to produce required capacity at 807. of nameplate rating, corresponding to warranted capacity at end of life cycles and the 1007. design demand. The voltage limit is 2.13 volts per cell, which corresponds to a total minimum voltage output of 125.7 volts per battery discussed in the FSAR, Chapter 8 The criteria for sirino large lead storage batteries are defined in IEEE 485n Wd C Qe.+. st')

Each DC electrical power source has ample power out'put capacity for the steady state operation of connected loads during normal operation, while at the same time maintaining its battery fully charged. Each battery charger also has sufficient capacity to restore the battery from the design minimum charge to its fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months while supplying normal steady state loads discussed in the FSAR, Chapter 8 gg APPLICABLE SAFETY ANALYSES do#ES 1,2., '3, a vtd 4 A description of the Safety Analyses applicable ^ ~ e m n e u-m g provided in the Bases for LCO J 1 "AC Sources - Operating".

~~~

h A

~4 BC. /Motte.5 cddff CMoon 3 d to CR s4.z 6.iM ,

41 SSN >

LC0 The DC power sources, each consisting of one battery, one directly connected battery charger and the corresponding control equipment and interconnecting cabling supplying power to the associated bus within the train are required to ,

be OPERABLE to ensure the availability of DC control power and Preferred AC .

power to shut down the reactor and maintain it in a safe condition.

{

An OPERABLE DC electrical power source requires its battery to be OPERABLE and connected to the associated DC bus. In order for the battery to r ain OPERABLE, one rhar er must be in service.

gg 5 The LCO B8.c.a. i"e argers ED-15 and ED 16 because those chargers are powered by the AC power distribution system and OG associated with the battery they Og supply, if only the cross connected chargers were OP=E, and a loss of off-site power should occur concurrently with the loss of one DG, both safeguards trains would eventually become disabled. One train would be disabled by the lack of AC motive power; the other would become disabled when the battery, whose only OPERABLE charger is fed by the failed OG, became depleted.

PAllSADES .B 3.'.4-2 Amendment No.

REMSED ee H ee

i 1

! DC Sources - Shutdown !

B 3. 5 ELECTRICAL POWER SYSTEMS k B 3. .nu ,.7.5.' DC Sources - Shutdown BASE BACKGROUND T

A description of the DC sources is provided in the Bases for LC0 3. 4, "DC Sources - Operating."

APPLICABLE SAFETY ANALYSES

[fdd A description of the Safety Analyses applicable during mD 3;;UT006 onu R Tu G NO ;;.J!;0W" is provided in the Bases for LC0 3. "AC Sources -

Shutdown".

pf "Ikt ti/htte.sfnMSff(ftih. con 3cdr 16 CR fo E [ CMP- , 3 4.S~0b LCO 8

This LCO requires those, and only those, D power sources which supply the DC distribution subsystems required by LCO 3. 10, to be OPERABLE. Each DC

source consists of one battery, one battery charger, and the corresponding .

control equipment and interconnecting cabling. This ensures the availability of sufficient DC power sources to maintain the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents and loss of shutdown cooling).

APPLICABILITY -

1% n0 6 6 ( a ss d G The DC power sources required to be OPERABLE in M O 'innuu ocenei y 5"UID06, and during movement of irradiated fuel assemblies provide assurance that equipment and instrumentation is available to:

a. Provide coolant inventory makeup,

b. Mitigate a fuel handling accident, N',c-N

c. Mitigate shutdown events that can lead to core damage, M C d. Monitoring and maintaining the plant in e 'n' 0 @'T00'..'" :. :iUI' "'C Cod S4Mua SAi3GQWMcinditionAorp,Q gym i. L PALISADES B 3.7.5-1 Amendment No.

I nevneo eenelse

T:

J Battery Cell Para eters :

B 3. 6 am , 7 . ,--

l ELECTRICAL POWER SYSTEMS _ '\f/ I b B 3.7.6 .r.d 0.7 ?: Battery Cell Parameters BASES BACKGROUND

.This LCO delineates the limits on electrolyte temperature, level, float voltage, and specific gravity for the DC power soarce batteries. A discussion of these batteries is provided in the Bases for LC0 3. 4, "DC Sources -

Operating". g l

APPLICABLE SAFETY ANALYSES (ggs {

A description of the Safety Analyses applicable da 0 !"""OU'"is MODES provided in the Bases for LCO 3. 1 "AC Sources - Operating"; during W ggy SouTUUnn .nu ;i;iU U' :::UTOC"':, in the Bases for LC0 3. 2 "AC Sources -

Shutdown".

4 d4/

3,s 4-ol g LCO fhW q cc.LL hrsrh* terr h4T 4 7 Cr.hr.- 5 of to t/A 50.4 (cKQ, Battery cell parameters must remain within acceptable limits to ensure availability of the required DC power to shut down the reactor and maintain it in a' safe condition after an anticipated operational occurrence or a postulated DBA. Battery cell limits are conservatively established, allowing continued DC electrical system function even when Category A and B limits are not met.

The requirement to maintain the average temperature of representative cells above 70*F assures that the battery temperature is within the design band.

Battery capacity is a function of battery temperature.

APPLICABILITY The battery cell parameters are required solely for the support of the associated DC power sources. Therefore, they are only required when the DC power source is required to be OPERABLE. Refer to the Applicability discussions in the Bases for LCO 3. W 5amtest /onntatoruff and

)/ LCO 3 5, "DC Sources - Shutdown". g PALISADES B 3.7.6-1 Amendment No.

l N

0044/08

. =. -. _ - . . .- .

1 l

1 l j l Inverters - Operating B3. 7ri __

ELECTRICAL POWER SYSTEMS E 8 3. xd 0.7.': Inverters - Operating BASE 5 U BACKGROUND [go.og F0-O't, EO -01, ad ED -09)

The inverters e the normal seurce of power for the Preferred AC buses. The function of the inverter is to provide continuous AC electrical power to the Preferred AC buses, even in the event of an interruption to the normal AC power distribution system. A Preferred AC bus can be powered from the AC '

power distribution system via the Bypass Regulator if its associated inverter ,

is out of service. An interlock prevents supplying more than one Preferred AC !

bus from the bypass regulator at any time. The station battery provides an uninterruptable power source for the instrumentation and controls for the Reactor Protective System (RPS) and the Engineered Safety Features (ESF).

APPLICABLE SAFETY ANALYSES -

gg g 7, zg A description of the Safety Analyses applicable t;.; 20 ==L is provided in the Bases for LCO 3 1.1 "AC Sources - Operating".

1 [4I 34EDl LCO subir

%W)' actOnkm c feetb o+ Ok A f6 d&4oke ag(ob e4 ao au h; $

CM 50.16 c )CL).

The inverters ensure the availability of Preferred AC power for the instrumentation required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA.

Maintaining the inverters OPERABLE ensures that the redundancy incorporated into the RPS and ESF instrumentation and controls is maintained. The four inverters ensure an uninterruptable supply of AC electrical power to the Preferred AC buses even if the 2400 volt safety related buses are I de-energized. I An inverter is considered inoperable if it is not powering the associated Preferred AC bus, or if its output voltage or frequency is not within tolerances.

PALISADES B 3.7.7-1 Amendment No.

l REWSED ee H ee

Inverters - Operating B 3.7.7 and 4.7.7 BASES SU CE REQUIRENENTS /lAl ga.on h SR 7.1 (Inverter checks)

GN I (N6 N This Surveillance verifies that the inverters are functioning pr ly and Preferred AC buses ..... ..vu ..............m. The verification of proper y voltage and frequency output ensures that the required power is readily available for the instrumentation of the RPS and ESF connected to the Preferred AC buses. The 7 day Frequency takes into account indications available in the control room that alert the operator to inverter malfunctions.

REFERENCES None ,

l l

[

i PAllSADES B 3.7.7-3

f

Inverters Shutdown B 3. 8 r d ' '.

ELECTRICAL POWER SYSTEMS 8 l

B 3. 8 x d 0.7.0: Inverters - Shutdown BASE BACKGROUND 8

A description of the inverters is provided in the Bases for LCO 3. 7,

" Inverters - Operating".

APPLICABLE SAFETY ANALYSES l moOES Sd d G A description of the Safety Analyses applicable during 60 :NUTCC:" at !

REFUEuiui :::UTC^'" is provided in the Bases for LCO 3. 2 "AC Sources - '

Shutdown". g S./d /

?p,.g

/

Lverhrt ar' fact a f A d6%4n IFt* and, o s x , auf,dy h , k,,,, j C F t o o FK .~0. M C)C7 ) . Y l LCO ['% ELJ;m iphos - ANewg )

This LCO requires those, and only those, nyerters necessary to support to Preferred AC buses required by LCO 3 0, to be OPERABLE. ;

l This ensures'the availability of suf ient Preferred AC electrical power to 1 operate the plant in a safe manner and to mitigate the consequences of l postulated events during shutdown (e.g., fuel handling accidents and loss of shutdown cooling).

An inverter is considered inoperable if it is not powering the associated Preferred AC bus, or it its voltage or frequency is not within tolerances.

APPLICABILITY

$~ a d

'^

/n o 9ers The inverters required to be OPERABLE in {0LD " " u". oreijgt:::: :,;7:j:u ,

and during movement of irradiated fuel assemblies provide assurance that equipment and instrumentation is available to: !

1

a. Provide coolant inventory makeup, (ca n aJ U t V b. Mitigate a fuel handling accident, ucc 1mu-c.ae 4.

c. .g m

d. Mitigate Mc,itoringshutdown events and maintaining thethat plantcan in alead CEOto::""O^""

core damage

~ @ PEr'JEL:!

4HtM90Mt condition.

{tw Q j 3.$ -02.-

PALISADES B 3.7.8 1 Amendment No.

[

l

Distribution Systems 0:erating 8 3. 9 :.d ' '.;

ELECTRICAL POWER SYSTEMS I B 3. 9 r d 0.7.S: Distribution Systems - Operating BASEY BACKGROUND The onsite Class IE AC, DC, and Preferred AC bus electrical power distribution systems are divided into two redundant and independent electrical power distribution trains. Each electrical power distribution train is made up of several subsystems which include the safety related buses, load centers, motor control centers, and distribution panels shown in T 3 1.

The Class IE 2400 volt safety related buses, Bus It and Bus 10, are normally powered from offsite, but can be powered from the DGs, as explained in the Background section of the Bases for LC0 3. 1, "AC Sources - Operating". Each 2400 volt safety related bus supplies one in of Class IE the 480 volt distribution system. g y The 120 volt Preferred AC buses are normally powered from the inverters. The alternate power supply for the buses is a constant voltage transformer, called the Bypass Regulator. Use of the Bypass regulator is governed by LCO 3. 7,

" Inverters - Operating." The bypass regulator is powered from the non-Class IE instrument AC bus, Y-01. The Instrument AC bus is normally powered through an automatic bus transfer switch, an instrument AC transformer, and isolation fuses. Its normal power source is MCC-1. Loss of power to MCC-1 will cause automatic transfer of the Instrument AC bus to MCC-7 There are two independent 125 volt DC electrical power distribution subsystems.

APPLICABLE SAFETY AiiALYSES ,- gg h,3, A description of the Safety Anal ses applicable 5:: =C ::,;;Cd is provided in the Bases for LCO 3. .lf "A Murofs /0p#apirgJ' . gy 3 3. h 9.op-

' %dostm Symse S%ffy Vok ~ 3 o' locm l0.RCckt),

LCO The AC, DC and Preferred AC bus electrical power distribution subsystems are required o be OPERABLE. The required power distribution subsystems listed in

/ Table.3. 9-1 ensure the availability of AC, DC, and Preferred AC bus electrical power for the systems required to shut down the reactor and

~

maintain it in a safe condition after an anticipated operational occurrence or a postulated ~ DBA.

1

! PALISADES B 3.7.9-1 Amendment No.

I

f Distribt.

Systems - - perating B 3. 9 d ' u BASES 8 Maintaining both trains of AC, DC, and Preferred AC bus electrical power i distribution subsystems OPERABLE ensures that the redundancy incorporated into the plant design is not defeated. Therefore, a single failure within any electrical power distribution subsystem will not prevent safe shutdown of the reactor. ,

OPERABLE electrical power distribution subsystems require the buses, load Og centers,. motor control centers, and distribution panels listed in Iableb3.t.91tobeenergizedtotheirpropervoltages. In addition, tie breakers between redundant safety related AC power distribution subsystems must be open when a 2400 volt source is OPERABLE for each train. This prevents any electrical malfunction in any power distribution subsystem from propagating to the redundant subsystem. If any tie breake.'s are closed, the affected redundant electrical power distribution subsystems are considered inoperable. This applies to the onsite, safety related redundant electrical power distribution subsystems. It does not, however, preclude redundant Class IE 2400 volt buses from being powered from the same offsite circuit or preclude cross connecting Class IE 480 volt subsystems when 2400 volt power is available for only one train.

This LCO does not address the power source for the Preferred AC buses. The Preferred AC buses are normally powered from the associated inverter. An alternate source, the Bypass Regulator, is available to supply one Preferred bus at a time, to allow maintenance on an inverter. The proper alignment of the inverter output breakers is addressed under the inverter LCOs. Therefore a Preferred AC Bus may be considered [ operable]when powered from either the Ok<

associated inverter or the Bypass Reguta wrlas long as the voltage and frequency of the supply is correct. ,, g APPLICABILITY rstp,3,a The electrical power distribution subsystems are required to be OPERABLE-ebde-

{0LO !"'.'T005 to ensure that AC, DC, and Preferred AC power is available to the redundant trains and channels of safeguards equipment, instrumentation and controls required to support engineered safeguards equipment in the event of M}l an accident

M%4. gg AC source equiraments for Te~addressedintro .2, "AC Sources -

p.. ,

M00E.5 5 And(*

Electrical power distribution subsystem requirements for LLO !"L'TS_

GUURim anus =, and during movement of irradiated fuel assemblies are addressed in LCO 3. 10. " Distribution Systems - Shutdown".

8

/ -

PALISADES B 3.7.9-2 Amendment No. l r

l l

Distribution Systems - Operating B 3.7.9 and 4.7.9 BASES

)

9.7.9/k An operable DC distribution subsys m can cause engineered safety fe ures '

t e inoperable. If a redundant fety feature in the other train i ncurrently inoperable, a loss of safety function could occur. AC ON C.1 equires compliance with Conditi i

3.7.9.E to assure that the pla is kutdownifasafetyfunctioni lost. f

~

l

~3.'.2.C.: C.

With m h us61n one train inope,able, the remaining DC electrical power y 4 distr ution subsystems are capable of supporting the minimum safety functions I necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF functions not being supported. Therefore, the required DC buse; must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months by powering the bus from the associated battery or charger.

This 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months limit is more conservative than Completion Times allowed for the vast majority of components which would be without power and is a feature of the original Palisades licensing basis, M D.1 and 0.2 pSOT b ~

OF (, 00i}l If the inoperable distribution cannot be restored to OPtKABLE status within the required Completion ime, the plant ..ust be brought to an operating condition in which the LCO doe not apply. To chieve this status, the plant must be brought to at least ;;07 :;WT;= althin hours and to COL. !""E0""

within hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power condition i n orderly manner and without challenging plant systems.

E.1 Condition E corresponds to a degradation in the electrical distribution system M tha loaemarw"^ re"=' **1 st ina eam oment ra wurrncauses a required safe 1M unction t'o be lost. When more than one Condition is entered, and this results in the loss of a required function, e plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation. LC0 3.0.3 must be entered immediately to commence a controlled shutdown.

PAllSADES B 3.7.9 4 l Amendment No.

l

. . ... - - . . . . - - - _ . - . - . ~ . . - _ . _

Distribution Systems - - Operating l B 3.7.9 and 4.7.9 BASES SUR LANCE REQUIREMENTS h SR .9.1 (^.C h: ;iiam;nt d;d}"

This surveillance verifies that the required AC, DC, and Preferred AC bus electrical power distribution subsystems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained.

For those buses which have undcrvoltage alarmed in the control room, correct voltage may be verified by the absence of an undervoltage alarm.

p For those buses which have only one possible power source and have -

undervoltage alarmed in the control room, correct breaker alignmen by the absence of an undervoltage alarm.

pc.j b. MJ A Preferred AC Bus may be considered correctly aligned when powered from either the associated inverter or from the bypass regulator. A mechanical interlock prevents connecting two or more Preferred AC Buses to the 8ypass Regulator. LC0 .7 and SR .7.1 address the condition of supplying a i

Preferrad AC B rom the bypas ulator.

The 7 day Freq y takes into nt the redundant capability of the AC, DC, and Preferred AC bus electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions.

REFERENCES None l

ggy CTS 7%GLE 5,2,9-/

.5 > pS 8)ggs TA6tE 6 3.7.9-1 PALISADES B 3.7.9-5 Amendment No.

[

~ . _ - _ . - - _ _ _ - - .-. -. - . . --.

I l l

Distribution Systems - Shutdown l B 3. 10 xd ' ' 10-i h ELECTRICAL POWER SYSTEMS 8

83. O M ' ' t": Distribution Systems - Shutdown BASER I BACXGROUND A description of the AC, DC, and Preferred AC bus electrical power distribution systems is provided in'the Bases for LCO 3. 9, " Distribution Systems - Operating".

APPLICABLE SAFETY ANALYSES A description of the Safety Analyses applicable durin ;0iG MT 0= .c,d

-RtfUttTNtMtHtR90WN' is provided in the Bases for LCO 3. 2 "AC Sources - g/

Shutdown". g g' g -o*

O5 b. derm 4ax r,vtbe faltff $te.,n ! of /6 A 50 56 (d(2.).

LCO This LCO requires those, and only those, AC, DC, and Preferred AC distribution subsystems to be OPERABLE which are necessary to support equipment required by other LCOs.

Maintaining these portions of the distribution system energized ensures the availability of sufficient power to operate the plant in a safe manner to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).

APPLICABILITY h ES f 4+< d G 6The, electrical and duringpower distribution movement subsystems of irradiated required to be OPERABLE in COLO fuel / @I assemblies, provide assurance that equipment and instrumentation is available Mh03 to:

D if

a. Provide coolant inventory makeup, g b. Mitigate a fuel handling accident, 00t fe w c w

c. Mitigate shutdown events that can lead to core damage, gf

d. . c

,m"n m Monitoring SRTTDO and maintaining W condition. the plant in a CC'0 TFe=[g #

_g PALISADES B 3.7.10-1 i

- .=. - - . .-

l ATTACHMENT 8 JUSTIFICATIONS FOR DEVIATIONS SECTION 3.8, ELECTRICAL POWER SYSTEMS - BASES Channe Discussion Note: The CTS Bases for Electrical Power Systems are unique in they have been upgraded to incorporate the format, and much of the content, of NUREG-1432. These Bases have previously been reviewed and found acceptable by the NRC in support of Amendment 180 to the Palisades l Technical Specifications dated April 29,1998. To facilitate the review of the l proposed Bases for ITS Section 3.8, a markup of the CTS Electrical Power Systems Bases has been provided which denotes only those differences between the previously approved CTS Bases and the proposed ITS Bases. In addition, a separate " red-line & strikeout" version of NUREG-1432, has been provided and will serve as a comparison between the CTS and NUREG-1432.

A brief discussion of the deviations from the CTS Bases is provided below.

The Change Numbers correspond to the respective deviation shown on the

" CTS MARKUPS". The first five justifications were used generically

, throughout the markup of the CTS Bases.

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

2. 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 intent.

3. 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.

4. 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.

Palisades Nuclear Plant Page 1 of 3 09/04/98 i

l 4

ATTACHMENT 8 JUSTIFICATIONS FOR DEVIATIONS :

, SECTION 3.8, ELECTRICAL POWER SYSTEMS - BASES !

i Channe Discussion

5. These changes are made to reflect Palisades licensing basis, including any associated changes proposed in this submittal (which are justified by DOCS and NSHCs .

elsewhere), as presented in the associated ITS Specifications. Additional changes are I

also proposed to establish conformance with NUREG-1432 Bases. Rewording, reformatting, and revised numbering is made to incorporate these changes consistent with Writer's Guide conventions.

6. The B 3.8.1 and B 3.8.4 Bases for those Surveillances that are associated with restrictions on which operational Modes they are allowed to be performed in, already address the issue that " credit may be taken for unplanned events that satisfy a surveillance requirement." In addition, the " credit may be taken..." concept applies to all surveillances, and is also addressed in the ITS Bases for SR 3.0.1. Therefore elimination of this discussion above all 3.8.1 Surveillance Bases is administrative only, with no technical change or change in intent. This presentation is consistent with NUREG-1432 and TSTF-8, Rev. 2.

7. The B 3.8.1 Bases discussion of " standby conditions" for the DGs is enhanced to include the existing procedural limitations regarding time after air roll. The intent of l this statement is to establish a minimum time at which a diesel generator is at rest l prior to commencing the surveillance test. ITS SR 3.8.1.2 provides assurance that a l diesel generator would start and be ready for loading in the time period assumed in l the safety analysis. Prior to starting a diesel generator for SR 3.8.1.2, a cylinder l leakage test is performed by briefly (minimum of 5 seconds) cranking the diesel l engine and observing the test cocks for the expulsion of water or oil. To avoid l invalidating the test results of SR 3.8.1.2 by " preconditioning" a diesel engine, an l elapse time of 20 minutes has been specified since the diesel engine was last air l rolled. The specified time is based on engineering judgement considering vendor l recommendations. Although this information is presently contained in plant l procedures and imposes an additional restriction on the performance of the test, l inclusion of this information in the Bases of SR 3.8.1.2 is appropriate since it l preserves the original intent of the surveillance test. l

8. CTS requirements and Actions (and associated Bases) for DG fuel transfer pumps and DG starting air, are presented in the AC Sources-Operating Specification. ITS administratively relocates these requirements and Actions to a separate Specification (3.8.3): Diesel Fuel, Lube Oil, and Starting Air. This relocation is appropriate for j those support system with a justified restoration time that is allowed prior to applying the restoration time for an inoperable DG.

Palisades Nuclear Plant Page 2 of 3 09/04/98

ATTACHMENT 8 JUSTIFICATIONS FOR DEVIATIONS j SECTION 3.8, ELECTRICAL POWER SYSTEMS - BASES Channe Discussion

9. TSTF-38 adds clarifying statements to the Bases of the battery inspection surveillance, which are adopted in the Palisades ITS Bases. Since this change only clarifies the existing intent, the change is acceptable.

10. This CTS Bases statement is in conflict with the CTS (and proposed ITS) requirements. The statement was mistakenly included with the recent amendment.

Elimination of the statement corrects an obvious error.

11. Clarification added to indicate the source of information relating resistance to voltage drop.

12. The CTS Bases associated with assumed lube oil consumption have been revised based on recently aquired information from the manufacturer which has been verified by plant specific testing.

Palisades Nuclear Plant Page 3 of 3 09/04/98

l I

l l

l ATTACHMENT 4 CONSUMERS ENERGY COMPANY PALISADES i-LANT l DOCKET 50-255 CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27,1998 REQUEST FOR ADDITIONAL INFORMATION REVISED PAGES FOR SECTION 5.0 r

l

.a

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS RESPONSE TO JULY 27,1998 REQUEST FOR ADDITIONAL INFORMATION REVISED PAGES FOR SECTION 5.0 Paae Chance Instructions Revise the Palisades submittal for conversion to improved Technical Specifications by removing the pages identified below and inserting the attached pages. The revised pages are identified by date and contain vertical lines in the margin indicating the areas of change.

REMOVE PAGES INSERT PAGES REV DATE NRC COMMENT #

!NTRODUCTION ATTACHMENT 1 TO ITS CONVERSION SUBMITTAL 5.0-10 5.0-10 09/04/98 N/A editoriai 5.0-11 5.0.11 09/04/98 N/A TSTF 270 ATTACHMENT 2 TO ITS CONVERSION SUBMITTAL No page change ATTACHMENT 3 TO ITS CONVERSION SUBMITTAL CTS 5.0 pg 13 of 29 CTS 5.0 pg 13 of 29 09/04/98 N/A TSTF-279 DOC 5.0 pg 2 of 6 5.0 pg 2 of 6 09/04/98 RAI 5.6-02 DOC 5.0 pg 5 of 6 5.0 pg 5 of 6 09/04/98 N/A editorial DOC 5,0 pg 6 of 6 5.0 pg 6 of 6 09/04/98 TSTF-279 ATTACHMENT 4 TO ITS CONVERSION SUBMITTAL No page change ATTACHMENT 5 TO ITS CONVERSION SUBMITTAL NUREG 5.0-8 NUREG 5.0-8 09/04/98 RAI 5.5-01 NUREG 5.0-10 NUREG 5.0-10 09/04/98 N/A editorial NUREG 5.0-11 NUREG 5.0-11 09/04/98 N/A TSTF-279 ATTACHMENT 6 5.0 pg 6 of 6 5.0 pg 6 of 6 09/04/98 N/A TSTF 279 1

Programs and Manuals 5.5 5.5- Programs and Manuals 5.5.4 Badigactive Effluent Controls Proaram '(continued)-

h. ' Limitations on the annual doses or dose consnitment to any.

member of. the public GJe to releases of radioactivity and to radiation from uranium fuel cycle. sources conforming to 40 CFR 190.

5.5.5 Containment Structural Intearity Surveillance Procram This program provides controls for monitoring any tendon degradation in pre-stressed concrete containments, including.

effectiveness of its corrosion protection medium, to ensure containment structural integrity. The program shall include baseline measurements prior to initial operations. The Containment Structural Integrity Surveillance Program, inspection-frequencies, and acceptance criteria shall be in accordance with ASME Boiler and Pressure Vessel Code,Section XI, Subsection iWE and IWL.

If, as a result of a tendon inspection, corrective retensioning of

. five percent (8) or more of the total number of dome tendons is necessary to restore their liftoff forces to within the limits, a dome delamination inspection shall be performed within 90 days

.following such' corrective retensioning. The results of this inspection shall be reported to the NRC in accordance with Specification 5.6.7, " Containment Structural Integrity Surveillance Report."

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the '

. Containment Structural Integrity Surveillance Program inspectian frequencies.

5.5.6 ' Primary Coolant Pumo Flywheel Surveillance Procram

a. Surveillance of the primary coolant pump flywheels shall consist of a 100% volumetric inspection of the upper flywheels each 10 years,

b. The provisions of SR 3.0.2 are no. applicable to the l Flywheel Testing Program, i

a

. Palisades Nuclear Plant 5.0-10 Amendment No. 09/04/98 W - y y y-.e- h. y .- .-u -gs-.-y- e yh'

Programs and Manuals 5.5 5.5' Programs and Manuals 5.5.7 Inservice Testina Proaram This' program provides controls for inservice testing of ASME Code Class.1, 2, and 3 components. The' program shall include the j following:

a. Testing frequencies specified in Section XI of the ASME t Boiler and Pressure Vessel Code and applicable Addenda (B&PV L

Code) as follows:

!^

Required interval

! - B&PV' Code tenninology i for inservice testing for performing inservice l activities testino activities Weekly s .7 days l Monthly s 31 days

! Quarterly or every 3 months s 92 days t

Semiannually or every 6 months s 184 days Every 9 months s 276 days Yearly or annually -s 366 days Biennially or every 2 years s 731 days-L b. The provisions of SR 3.0.2 are applicable to the above required intervals for performing inservice testing activities;

c. The provisions of SR 3.0.3 are applicable to. inservice testing activities; and t d. Nothing in the B&PV Code shall be construed to supersede the requirements of any Technical Specification.

5.5.8 Steam Generator Tube Surveillance Proaram This program provides controls for surveillance testing of the

, Steam Generator (SG) tubes to ensure that the structural integrity of this portion of the' Primary Coolant System (PCS) is maintained.

The program shall contain controls to ensure:

a. Steam Generator Tube Samole Selection and Insoection The inservice inspection may be limited to one SG on a rotating schedule encompassing 6% of the tubes if the results of previous inspections indicate that both SGs are performing in a like manner. If the operating conditions in one SG are found to be more' severe than those in the other SG, the sample sequence shall be modified to inspect the I, most severe conditions.

J i Palisades Nuclear Plant 5.0-11 Amendment No. 09/04/98

. . . ._ -__ _ . . .- _ c_. .

f, C Ap r4 N (odno6 6.0 ADMINISTRATIVE CONTR01.5 _ ._

g,f.f' 6.5.5 Qate/vedl hva ed M bdr [radevurt A L 3~dTD 4 *1[somiti. Adec. .

..- . 15; 4 Abb W % Nuk- MD ~

f,f;(, 6.5.6 Primary Coolant Pumo Flywheel Surveillance Prnaram

a. Surveillance of the primary coolant pump flywheels shall consist of a 100% volumetric inspection of the upper flywheels each 10 years,

b. TheprovisionsofSurveillanceRequirement4.0.2arefpplicableto the Flywheel Testing Program.

M

[f7 6.5.7 Inservice finstectio# anchTestina Proaram This program provides controls for inservice fnstectAn ari@ testing of ASME Code Class 1, 2, and 3 components 6__nclua ng are icabve suociert sT.

The program shall include the following:

a. Testing frequencies specified in Section XI of the ASME Boiler and ;

Pressure Vessel Code ano applicable Addenda (B&PV Code) as follows: l B&PV Code terminology Required interval i for inservice testing for performing inservice l activities testina activities Weekly 5 7 days Monthly 5 31 days Quarterly or every 3 months s 92 days Semiannually or every 6 months s 184 days Every 9 months s 276 days Yearly or annually s 366 days Biennially or every 2 years (5ft 3,o,Y) s 731 days 4 j,

b. The provisions offsuro111ancedeauiremfoF 4 Mare applicable to the above required interv'ais for performing inservice testing activities;

_ (fR 3,0$ 4. I.

c. The provisions of &lrveituti_ce Realpremgg p g are applicable to inservice testing activities; and

d. Nothing in the B&PV Code shall be construed to supersede the requirements of any Technical Specification.

6-8 Amendment No. W4, W6, h l$ of 2.9 Dele 4les

. -ATTACHMENT 3 DISCUSSION OF CHANGES CHAPTEP. 5.0, ADMINISTRATWE CONTRO_LS, A.5 CTS 6.4.1 requires that written procedures shall be established, implemented, and maintained for the activities listed. In this list, the CTS contains item b., " Refueling operations, and item c., " Surveillance and test activities of safety-related activities."

These items are included in the procedures recommended in Appendix "A" of ,

Regulatory Guide 1.33, Revision 2, February 1978 which is referenced in CTS 6.4.la and included in the proposed ITS 5.4.la. Therefore, since these procedures are already required by the reference to Regulatory Guide 1.33, Revision 2, February 1978, they are not included in the proposed ITS. This change is an administrative change since no l requirements have changed. This change maintains consistency with NUREG-1432. l l

A.6 CTS 6.4.1 requires that written procedures shall be established, implemented, and maintained for the activities listed. In this list, the CTS contains item f., " Site Security Plan implementation" and item g.," Site Emergency Plan implementation.." These items were recommended to be removed from the Technical Specifications in NRC Generic Letter 93-07 since they are duplicative of regulations contained in the Code of Federal Regulations part 50 and 73. This change is considered to be an administrative change since these requirements must still be met as required by the Code of Federal Regulations. This change maintains consistency with NUREG-1432.

A.7 CTS 6.5.7 is entitled " Inservice Inspection and Testing Program." In the proposed ITS 5.5.7, the title is changed to the " Inservice Testing Program." This change is considered to be an administrative change since the requirements of the program are unchanged. This change maintains consistency with NUREG-1432. '

A.8 CTS 6.6.5b.1 lists, among referenced LCOs, "3.10.1." That item is unnecessary and l has been deleted. Neither CTS 3.10.1, nor its ITS replacement reference the COLR. l CTS 6.6.5 a. lists the core operating limits that are established and documented in the l COLR prior to each core reload. Specifically, these limits are: ASI Limits l (CTS 3.1.1), Regulating Group Insertions Limits (CTS 3.10.5), Linear Heat Rate l Limits (CTS 3.23.1), and Radial Peaking Factor Limits (CTS 3.23.2). CTS 6.6.5 b. I list the documents approved by the NRC that describe the analytical methods used to l determine the core operating limits. As part of this listing, cross references are made l to the LCOs pertaining to the affected limit (e.g., ASI Limits, Regulating Group l Insertion Limits, etc...). In error, CTS 6.6.5 b.l. lists CTS 3.10.1 (Shutdown Margin l

, Requirements) as an LCO related to a document that describes analytical methods used l j to determine the core operating limits. Since Shutdown Margin is not a cycle l l dependent limit (the limit is contained in the technical specifications and not in the l 7

COLR), referencing CTS 3.10.1 in CTS 6.6.5 b.1 is inappropriate and has been l deleted. This change has been characterized as administrative in nature since it does l not alter any requirement of the CTS, but simply corrects an administrative oversight. l Palisades Nuclear Plant Page 2 of 6 09/04/98

ATTACITMENT 3 DISCUSSION OF ClfAJNGES CHAPTER 5.0, ADMINISTRATIVE CON 113OLS M.4 The CTS does not contain a Safety Functions Determination Program. Proposed ITS 5.5.13 includes this program. This program is added to work in conjunction with the proposed ITS in identifying any loss of safety function which might exist. Because the CTS did not contain this program, and its implementation requires additional evaluations to identify a loss of safety function than what is required in the CTS, this change is considered to be a more restrictive change. This change maintains consistency with NUREG-1432.

M.5 CTS 6.6.7 con *.ains the reporting requirements for specific accident monitoring instrument channels that are not restored to an Operable status within the required Completion Time. CTS 6.6.7 requires that a report be submitted within 30 days.

Proposed ITS 5.6.6 also contains reporting requirements for specific accident monitoring instrument channels that are not restored to an Operable status within the required Completion Time. However, the ITS requires that a report be submitted within 14 days. As such, the proposed change imposes an additional restriction on plant operations since the time period allowed to submit the report has been shortened from 30 days to 14 days. This change has been proposed to establish consistency with NUREG-1432 and is deemed acceptable since it only involves a change to administrative requirements and does not alter the way in which the plant is operated.

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

LA.1 CTS Specification 4.5.4, Surveillance for Prestressing System (page 4-21a) and 4.5.5, End Anchorage Concrete Surveillance (page 4-21c) were replaced by proposed ITS Specification 5.5.5, the Containment Structural Integrity Surveillance Program. The proposed specification emulates the ISTS treatment of containment structural integity surveillance requirements. The details associated with containment tendon inspections have been removed from the technical specification and reference has been included in ITS 5.5.5 to ASME Boiler and Pressure Vessel Code,Section XI, Subsections IWE and IWL which establishes the applicable test methods, acceptance criteria and testing frequencies. Removal of these details is acceptable since testing of containment tendons in accordance with ASME Boiler and Pressure Vessel Code,Section XI, Subsections IWE and IWL is specified in 10 CFR 50.55a. Thus, this change eliminates duplication of federal regulations and can be made without an impact on public health and safety. Removal of these details from the CTS and the incorporation of a containment tendon surveillance program in Section 5.0 of the ITS is consistent with NUREG-1432.

Palisades Nuclear Plant Page 5 of 6 09/04/98

. ATI'ACRMD4T 3

, , , , . . DISCUSSION 0F CHANGES

__,, CHAPTER 5.0, ADMINISTIMTIVE CONTROLS __

~

LESS RESTINCTIYE CHA'5GES - REMOVAL OF DETAILS TO LICENSEE CONTROLLED DOCUMENTS (LA) -

LA.2 CTS 6.5.7, Inservice Inspectio'n and Testing Program has been revised to delete the l phrase " including applicable supports." Requirements for inservice inspections of l ASME Code Class 1, 2, and 3 components are specificed in 10 CFR 50.55a(g). As l used in CTS 6.5.7, " applicable supports" is intended to apply to the inspection of l snubbers. Adaptation of this phrase in the CTS was consistent with the NRC's I approach to address concerns related to the relocation of the Snubber LCO from the l ISTS NUREGs. Subsequently, the ISTS NUREGs have been modified to delete this l phrase in recognition that it duplicates requirements specifed in the CFRs (See Section l 5.0, JFD 26 addressing TSTF-279). As such, the deletion of this phrase from the CTS l can be made without a significant impact on safety since the inspection of applicable I supports continues to be required by 10 CFR 50.55a(g). l LESS RESTRICTIVE CHANGES (L)

There were no "Less Restrictive" changes made to this chapter.

RELOCATED (R)

There were no " Relocated" changes made to this chapter.

Palisades Nuclear Plant Page 6 of 6 09/04/98

i Programs and Manuals 5.5 c.d ..

5.5 Programs and Manuals l

t,. s, g 5.5.1 Offsite Oose Calculation Manual (ODCM_). (continuad) i the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month l

and year) the change was implemented.

(,1 t 5.5.2 Primary Coolant Sources Outside Containment l .bd}

This program provides controls to minimize leakage from those portions of systems outside containment that could contain highly y

, WWS radioactive fluids during a serious transient or accident to

" "" )(

i

_ vels as low as oracticable. The systems include tFpcirculati'n 9

@wC~<@Soray, Safety injection 71Cpemical and VAlume control / qas /

c,4.--.er s-p f strtoper, and /Hydrocen Retombined< The program shall include u.,p the following:

a. Preventive maintenance and periodic visual inspection requirements; @

b. Integrated leak test requirements for each system at refueling cycle intervals or less; 4 Inut) !$

(. ,5.1 5.5.3 Post Accident Samolina _a.s.gg.-gk.n-m

,jg g,ga.. s .-J @

This program provides controls that ensure the capability to /

obtain and analyze reactor coolant, radioactive gases, and particulates in plant gaseous effluents and containment atmosphere samples under accident conditions. The program shall include the following:

a. Training of personnel;

b. Procedures for sampling and analysis; and

c. Provisions for maintenance of sampling and analysis equipment.

6.5.9 5.5.4 Radioactive Effluent Controls Proaram This program conforms to 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably

( (continued)

CEOG STS 5.0 8 Rev 1, 04/07/95

l Programs and Manuals ;

5.5 l l

l _. 5.5 Programs d Manuals

' 6,,s.9 5.5.4 Radioactive Effluent Controls Proaram (continued) 4h limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents from each unit to areas beyond the site boundary, conforming to 10 CFR 50, Appendix I; l g[8 Limitations on the annual and quarterly doses to a member of the public from iodine-131, iodine-133, tritium, and all I

radionuclides in particulate form with half lives > 8 days in gaseous effluents released from each unit to arets beyond l the site boundary, conforming to 10 CFR 50, Appendix 1; and h (( Limitations on the annual dose or dose commitment to any member of the public due to releases of radioactivity and to '

radiation from uranium fuel cycle sources, conforming to 40 l CFR 190.

5.5.5 Comoone t cyclic or Tra ient limit This rogram provides entrols to trapk the FSAR Secti n [ ]

cyc)tained within the/ design limits /ic and transient occurrences to jensure tha mayn nea

- lLo a . w .a 54< s .,4 L +.y:% s ,,,:n.,,m P 3,. ]

5.5. hPreStrestedConcreWContainm$nt'TendonSurhe111ancePfoaramj h

This program provides controls for monito ag any tendon degradation in pre stressed concrete containments, including effectiveness of its corrosion protection medium, to ensure a h

f containment structural integrity. The program shall includ L baseline measurements prior to initial operations. The h Surveillance Program, inspection frequencies, and acceptance criteria shall_be in accordance with.

(Ravision 3/. /1964 AW b.s v) mu{Eagui atory G2n de 1.3 A.mLGu,L,rm g 5)

S h w twd ced N L

( pge r> TheprovisionsofSR3.0.2andSR3.0.3areapplicabletothe$

4. ,. f M Surveillance Program inspection frequencies. @

& Q,' W hdiirTuutoeIIIIiir~M' ""

f, ,5. L, 5.5 @ RetetM Coolant Pumo Fivwhe~el Insoection proaram h

This prpgram sh M provi for th nspecti of eac reactor 7 coolapt pump wheel the r mmendat ns of rg ulatory posMion c.4 b of Reg atory de 1.14 Revistorv1, August 1975.

5.,s.twa f A e w< < 3 c..k.A p.~e Ft p ,,,13 s k a ,. u .i t o f <-

l t s a. . .h d , e . n s e,% .4 u - n << 5 \, s e 4 u eu s o ws . /]

N p ..: 3:..,3o?snu.t.c.cd,,):uur A e r,:m.,3 (continued)

?

C.o.u k 9-~ e F tJ < < \ r u a.6 a , r<.v.-

CE0G STS 6.0 10 Rev 1, 04/07/95 REVISED ewswes

f Programs and Manuals l l 5.5 l

l 5.5 Programs and Manuals (continued) l l

) (,,Q 5.5,$@ Inservice Testino Proaram This program provides control.s for inservice testing of ASME Code Class 1, 2, and 3 components Unciddina aoMicable sun 6ertd. The ' /',

program shall include the following:

a. Testing frequencies specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addendagas l

ASME iler d P e sure (B{ fV (en.) h F'Kew Vess Cod and j a_pp icabi Add nd_

terminology for Required Frequencies j inservice testing for performing inservice l activities testina activities i Weekly Monthly T <

T l~ ast At eas one per ce er 7 days 31 days .

l Quarterly or every l 3 months 6 1 st ce per 92 days l Semiannually or e every 6 months 6 At ea one per 184 days -

Every 9 months 6. A le st on per 276 days Yearly or annually f.!At 1 ast opce per,366 days Biennially or every 2 years j,Atleastj/ once_ pet 731 days

b. The provisions of SR 3.0.2 are applicable to the above required Frequencies for performing inservice testing activities;

c. The provisions of SR 3.0.3 are applicable to inservice testing activities; and bW

d. Nothing in the diIf Cciger/ancVPres re W :scljCode shall be @

construed to superside t~he requireirE6ti"~o~f'an'y Tgj h

[YEi,naic % <re c i ric ^ n ed 65.8 5.5.@h Steam Generator (SGI Tube Surveillance Proaram

~

Reviewer's tjotei ~TheTic~in1Eis curFbn~t Tife6Tiiig~Iiasis stWm l c

generatortubesurveillancerequirementssha'llberelocated/from 4 v

the t.C0 and included here. An appropriate / administrative controls; '

programfjrmatshouldbe sed. / / . _._. I (rMst.T SG G Lu<:\ % l'cr L'~l'G ,

l (continued)

CEOG STS 5.0-11 Rev 1, 04/07/95 RDASED te4&es

l ATTACIIMENT 6 l JUSTIFICATION FOR DEVIATIONS l SPECIFICATION 5.0, ADMINISTRATIVE CONTROLS Chanoe Discussion

23. NUREG-1432 5.5.6 specifies the requirements for the Tendon Surveillance Program.

The proposed ITS revises this title to the Containment Structural Integrity Surveillance Program and replaces the plant specific requirements which currently exists in CTS 4.5.4 and 4.5.5. This program and the associated report (ITS 5.6.7), include requirements relating to dome delamination in addition to tendon testing. The program and report names were changed accordingly. This change is acceptable because the NUREG-1432 5.5.6 is in brackets to indicate that the plant specific information is to be

provided if the report is applicable.

I

24. NUREG-1432 5.5.9 and 5.5.13 are revised to incorporate TSTF-118 which provides consistent application of SR 3.0.2 and SR 3.0.3 to the Programs referenced by ITS t

SRs.

i

25. NUREG-1432 5.6.1 and 5.6.3 are revised to incorporate TSTF-152 which reflects previous revisions to 10 CFR Part 20 and 10 CFR 50.36a.

26, Reference to the " applicable support" was deleted from the description of the Inservice I l

Testing (IST) Program. The IST Program provides control for testing Code Class 1,2, l and 3 components. The discussion of the IST Program in Section 5.5 of the ISTS was l revised by the NRC to include the " applicable supports" in February 1992 due to l concerns related to the relocation of the Snubber LCO from the ISTS NUREGs. l However, this is inappropriate; supports are addressed under the Inservice Inspection l Program not the IST Program. Thus, the reference to the " applicable supports" in the l IST Program description was deleted. This change is consistent with NUREG-1432 as l modified by TSTF-279. l l

l l

Palisades Nuclear Plant Page 6 of 6 09/04/98

ML20151Z811

Text

Navigation menu

Search