ML18066A252

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Refers to 980126 Licensee Request to Convert Palisades NPP Current TS to Improved TS (Its).Rai Re ITS Sections 3.8 & 5.0 Encl
ML18066A252
Person / Time
Site: Palisades Entergy icon.png
Issue date: 07/27/1998
From: Robert Schaaf
NRC (Affiliation Not Assigned)
To: Haskell N
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
TAC-MA0805, TAC-MA805, NUDOCS 9807300407
Download: ML18066A252 (24)
v • d • e


Text

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Mr. Nathan L. Haskell Director, Licensing Palisades Plant

  • 27780 Blue Star Memorial Highway Covert, Ml 49043 July 27, 1998

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE TECHNICAL SPECIFICATIONS CHANGE REQUEST TO CONVERT TO THE IMPROVED TECHNICAL SPECIFICATIONS FOR THE PALISADES PLANT (TAC NO.

MA0805)

Dear Mr. Haskell:

On January 26, 1998, Consumers Energy submitted its request to convert the Palisades Nuclear Plant current technical specifications (CTS) to improved technical specifications (ITS).

We have determined that we require additional information to complete our evaluation of ITS Sections 3.8 and 5.0. Please provide your response to the staff comments in the enclosure within 45 days of your receipt of this letter. The staff requests that you provide your response using the enclosed comment format, adding your responses Where indicated in the enclosure.

Should you have any questions, please do not hesitate to contact me at (301) 415-1312 or Mary Lynn Reardon of the Technical Specifications Branch at (301) 415-1177.

Docket No. 50-255

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION (w/encl):

Sincerely, ORIGINAL SIGNED BY Robert G. Schaaf, Project Manager Project Directorate 111-1 Division of Reactor Projects - 111/IV Office of Nuclear Reactor Regulation tDockefFileC!

PUBLIC PD#3.;1 Reading EAdensam (EGA 1)

OGC ACRS B. Burgess, Riii M. Reardon DOCUMENT NAME: G:\\WPDOCS\\PALISADE\\PALITS38.RAI.

To receive a copy of this document, indicate in the box C=Copy w/o attachment/enclosure E=Copy with attachment/enclosure N = No copy OFFICE PM:PD31 E

LA:PD31 NAME RSchaaf:db~ CJamerson DATE

. 71 2-1 /98 OFFICIAL RECORD COPY

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Mr. Nathan L. Haskell Consumers Energy Company cc:

Mr. Thomas J. Palmisano Site Vice President Palisades Plant 27780 Blue Star Memorial Highway Covert, Michigan 49043 Mr. Robert A. Fenech, Sr Vice Pres Nuclear, Fossil, and Hydro Operations Consumers Energy Company 212 West Michigan Avenue Jackson, Michigan 49201 M. I. Miller, Esquire Sidley & Austin 54th Floor One First National Plaza Chicago, Illinois 60603 Mr. Thomas A. McNish Vice President & Secretary Consumers Energy Company 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon; Esquire Consumers Energy Company 212 West Michigan Avenue Jackson, Michigan 49201 Regional Administrator, Region Ill U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Jerry Samo Township Supervisor Covert Township 36197 M-140 Highway Covert, Michigan 49043 Palisades Plant Office of the Governor P. 0. Box 30013 Lansing, Michigan 48909 U.S. Nuclear Regulatory Commission Resident Inspector's Office Palisades Plant 27782 Blue Star Memorial Highway Covert, Michigan 49043 Drinking Water and Radiological.

Protection Division Michigan Department of Environmental Quality 3423 N. Martin Luther King Jr Blvd P. 0. Box 30630 CPH Mailroom Lansing, Michigan 48909-8130 Gerald Chamoff, Esquire Shaw, Pittman, *Potts and Trowbridge 2300 N Street, N. W.

Washington DC 20037 Michigan Department of Attorney General Special Litigation Division 630 Law Building P.O. Box 30212 Lansing, Michigan 48909 June 1998

Palisades Improved TS Review Comments ITS Section 3.8, Electrical Power Systems*

3.8.1, AC Sources - Operating 3.8.1-01 JFD 10 STS 3.8.1 Required Action A.2 ITS 3.B.1 Condition A With one offsite circuit inoperable, STS 3.8.1 Required Action A.2 specifies to declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable. Th_is requirement has not been adopted in the Required Actions for Condition A in corresponding ITS 3.8.1. JFD 10 states that the Palisades design and requirements for

' operable offsite circuits ensures that each ESF bus will be energized if at least one circuit is operable.

Comment: JFD 10 does not explain how each ESF bus wou.ld be energized if only one offsite circuit is operable, or how long it would take fo accomplish. No requirement has been proposed to verify that each ESF bus is energized following the loss of an offsite circuit. Additionally, Required Action A.2 applies to required features with no offsite power available. If offsite power is available to a required feature, no action is required. Revise the submittal to adopt Required Action A.2, or provide appropriate technical justification for the difference.

Consumers Energy Response:

3.8.1-02 DOC M.1 JFD7 STS 3.8.1 Completion Time for Required Action A.3 ITS 3.8.1 Completion Time for Required Action A.2 Bases for ITS 3.8.1 Required Action A.2, CTS Bases markup page B 3.7.1-5, insert The Completion Time for Required Action A.3 for STS 3.8.1 is 6 days from discovery of failure to meet the LCO. The Completion Time for Required Action A.2 for ITS 3.8.1 is 10 days from discovery of failure to meet the LCO. JFD 7 considers successive inoperabilities of an offsite circuit and a diesel generator.

Comment: JFD 7 did not consider successive inoperabilities of the offsite circuits. Revise the submittal to conform to the STS, or provide appropriate technical justification for the difference.

Consumers Energy Response:

Palisades Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1-03 DOC L.1 JFD5 STS 3.8.1 Completion Time for Required Action B.4 ITS 3.8.1 Completion Time for Required Action B.4 Bases for ITS 3.8.1 Required Action B.4, CTS Bases markup page B 3.7.1.7 insert CTS 3. 7.1 Action B.4 With one diesel generator inoperable, CTS 3.7.1 Action B.4 provides 7 days (total for both DGs) in any calendar month to restore the diesel generator(s) to operable status. The Completion Time for Required Action B.4 for corresponding STS 3.8.1 is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The Completion Time that has been proposed' for Required Action B.4 for corresponding ITS 3.8.1 is 7 days. DOC L.1 states that this proposed change is not a significant impact on safety.

Comment: No technical justification has been provided to support the proposed change.

Additionally, DOC L.1 does not explain why this proposed change is not a significant impact on safety. Revise the submittal to provide the appropriate technical justification, and to explain why the proposed change is not a significant impact on safety, or conform to the STS.

Consumers Energy Response:

3.8.1-04 JFD 7 STS 3.8.1.1 Completion Time for Required Action B.4 ITS 3.8.1.1 Completion Time for Required Action B.4 Bases for ITS 3.8.1.1 Required Action B.4, CTS Bases markup page B 3.7.1.7 insert STS 3.8.1.1 Required Action B.4 has a Completion Time that limits the amount of time that the LCO is not met from the time of discovery to 6 days. ITS 3.8.1.1 Required Action B.4 has a Completion Time that limits the amount of time that the LCO is not met to 10 days. JFD 7 states that the 1 O day Completion Time is based in part on the 7 day Completion Time to restore the DG to operable status.

Comment: The 7 day Completion Time to restore the DG to operable status requires additional justification (see comment 3.8.1-03 above). If the 7 day Completion Time is not approved by the NRC, revise the Completion Time that limits the amount of time that the LCO is not met to conform to the STS.

Consumers Energy Response:

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Palisades Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1-05 DOC LA.1

  • JFD6 STS 3.8.1 Condition F and Required Action F.1 CTS 3. 7.1 Action F CTS 3.7.1 Action F addresses one or both load sequencers inoperable. This requirement has not been retained in Corresponding ITS 3.8.1. STS 3.8.1 Condition F and Required Action F.1 address one load sequencer inoperable. This requirement has not been adopted in corresponding ITS 3.8.1.

Comment: The Note with STS 3.8.1 Condition F states.that the Condition need not be adopted if a sequencer failure only affects the ability of the associated DG to power its safety loads.

Neither DOC LA.1 nor JFD 6 explain if the sequencers are shared by the diesels and the offsite circuits. If the sequencers are shared, revise the submittal to conform to the STS. If the sequencers are not shared, provide appropriate technical justification for the difference.

Consumers Energy Response:

3.8.1-06 JFD 6 STS LCO 3.8.1 item c STS LCO 3.8.1 c addresses automatic load sequencers. This portion of the LCO has not been adopted in corresponding ITS 3.8.1.

  • Comment: If the response to comment 3.8.1-05 is to propose a Condition and Required Action that address the sequencers, then revise the submittal to have ITS LCO 3.8.1 adopt STS LCO 3.8.1.c.

Consumers Energy Response:

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Palisades Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1-07 JFD 5 STS SR 3.8.1.5 STS SR 3.8.1.5 specifies checking for and removing accumulated water from each day tank.

This requirement has not been adopted in corresponding ITS 3.8.1.

Comment: A similar requirement has been retained from the CTS for the fuel oil storage tank as ITS SR 3.8.3.5. Provide the technical justification for not adopting STS SR 3.8.1.5, or conform to the STS.

Consumers Energy Response:

3.8.1-08 JFD 5 ITS SR 3.8.1.5 STS SR 3.8.1.9Note1 Bases for STS SR 3.8.1.9 Note 1 to STS SR 3.8.1.9 specifies that the Surveillance not be performed in Mode 1 or 2.

This Note has not been adopted in corresponding ITS SR 3.8.1.5. The Bases for STS SR 3.8.1.9 states that the reason for the Note is that during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challeng~ continued steady state operation and, as a result, unit safety systems.

Comment: JFD 5 did not address these issues. Revise the submittal to provide the technical justification for not adopting the Note or conform to the STS.

Consumers Energy Response:

4

Palisades Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1-09 JFD 5 ITS SR 3.8.1.6 STS SR 3.8.1.10 Note 1 Bases for Note 1 to STS SR 3.8.1.10 specifies that the Surveillance not be performed in Mode 1 or 2. This Note has not been adopted in corresponding ITS SR 3.8.1.6. The Bases for STS SR 3.8.1.10 states that the reason for the Note is that during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems.

Comment:. JFD 5 did not address these issues. Revise the submittal to provide the technical justification for not adopting the Note or conform to the STS.

Consumers Energy Response:

3.8.1-10 ITS SR 3.8.1.8 STS SR 3.8.1.14 Note 1 CTS 4.7.1.10 Note 1 to STS SR 3.8.1.14 states that momentary transients outside the load and power factor ranges do not invalidate this test. This Note has been adopted in corresponding ITS SR 3.8.1.8.

Comment: The CTS markup does not show this proposed change, and no justification has been provided for the proposed change. Revise the submittal to correct the CTS markup, and to provide the appropriate justification.

Consumers Energy Response:

5

Palisades Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1-11 Bases JFD 7 Bases for ITS SR 3.8.1.2, CTS Bases markup page B 3.7.1-12 Bases for CTS 4. 7.1.2 The Bases for CTS 4. 7.1.2 states that standby conditions for a DG mean the diesel engine is not running and its coolant and oil temperatures are being maintained consistent with the manufacturer's recommendations. This has been retained in the Bases for corresponding ITS SR 3.8.1.2 which also contains the stipulation that ~ 20 minutes have elapsed since the last DG air roll. Bases JFD 7 states that this is an existing procedural limitation.

Comment: No technical justification has been provided to support the proposed change.

Revise the submittal to provide the appropriate justification.

Consumers Energy Response:

6

Palisades Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.2, AC Sources - Shutdown 3.8.2-01 JFD2 Bases Applicability for ITS 3.8.2, CTS Bases markup page B 3.7.2-2 Bases Applicability for STS 3.8.2 The Bases Applicability for STS 3.8.2 refers to monitoring and maintaining the plant in a cold shutdown or refueling condition. The Bases Applicability for ITS 3.8.2 refers to monitoring and maintaining the plant in a shutdown condition. JFD 2 states that differences have been made for clarity, grammatical preference, or to establish consistency within the Improved Technical Specifications.

Comment: This is not a justifiable plant specific difference. Revise the submittal to conform to the STS.

Consumers Energy Response:

Palisades Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3-01 CTS LCO 3.7.3 ITS LCO 3.8.3 CTS LCO 3.7.3 states, 'The stored DG fuel oil and DG lube oil shall be within limits."

Corresponding ITS LCO 3.8.3 states, "The stored diesel fuel oil, lube oil, fuel oil transfer system, and starting air subsystem shall be within limits for each required Diesel Generator (DG)". This proposed change was not noted on the CTS markup, and no justification has been provided for this proposed change.

Comment: Revise the submittal to note this proposed change on the CTS markup and provide the appropriate justification.

Consumers Energy Response:

3.8.3-02 ITS LCO 3.8.3 ITS 3.8.3 Conditions C, D, and E ITS SR 3.8.3.6 Bases Applicability for ITS 3.8.3, CTS Bases markup pa.ge B 3.7.3-2 ITS LCO.. 3.8.3 and the associated Bases Applicability refer to the fuel oil transfer system being within limits. ITS 3.8.3 Conditions C, D, and E, and ITS SR 3.8.3.6 refer to the operability of the fuel oil transfer system, they do not refer to any limits.

Comment: The LCO and the Bases Applicability should refer to the operability of the fuel transfer system. Revise the submittal to have the LCO and the Bases Applicability refer to the.

operability of the fuel oil transfer system; Consumers Energy Response:

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Palisades Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.3-03 JFD 1 CTS 3.7.3 Action B ITS 3.8.3 Condition B CTS 3. 7.3 Action B refers to stored oil inventory < 175 and ~ 150 gallons. Corresponding ITS 3.8.3 Condition B refers to stored lube oil inventory < 200 gallons and > 160 gallons. JFD 1 states that the brackets have been removed and the proper plant specific information or value has been provided. No proposed change has been noted on the CTS markup. No specific justification has been provided for this proposed change.

Comment: Revise the submittal to note the proposed change on the CTS markup and provide the appropriate justification for the proposed change.

Consumers Energy Response:

3:8.3-04 JFD 4 ITS SR 3.7.3.2 CTS 4.7.3.1 Bases for ITS SR 3.8.3.2, CTS Bases markup page B 3.7.3-4 CTS 4.7.3.1 requires verifying the stored lube oil inventory is~ 175 gallons. ITS SR 3.7.3.2 requires verifying the stored lube oil inventory is ~ 200 gallons. JFD 4 states that changes have been made to reflect the facility analysis description. No proposed change has been noted on the CTS markup. No specific justification has been provided for this proposed change.

Comment: Revise the submittal to note the proposed change on the CTS markup and provide the appropriate justification for the proposed change.

Consumers Energy Response:

3.8.3-05 Bases Applicable Safety Analysis discussion for ITS 3.8.3, CTS Bases markup page B 3.7.3-1 Bases Applicable Safety Analysis discussion for STS 3.8.3 The Bases Applicable Safety Analysis discussion for STS 3.8.3 includes reference to the criteria of 1 O CFR 50.36. This material has not been adopted in the Bases for corresponding ITS 3.8.3.

Comment: This is not a justifiable plant specific difference. Revise the Bases to conform to the STS.

Consumers Energy Response:

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Palisades Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.3-06 Bases Background for ITS 3.8.3, CTS Bases markup page B 3.7.3-1 Bases Background for ITS 3.8.3, ITS Bases page B 3.8.3-1 The second paragraph of the Bases Background for ITS 3.8.3, CTS Bases markup page B 3.7.3-1 is different than the second paragraph of the Bases Background for ITS 3.8.3, ITS Bases page B 3.8.3-1.

Comment: Revise the submittal to resolve this discrepancy. Provide the appropriate justification for all proposed changes.

Consumers Energy Response:

3.8.3-07 Bases Background for ITS 3.8.3, CTS Bases markup page B 3.7.3-1 Bases Background for ITS 3.8.3, ITS Bases page B 3.8.3-1 The fourth paragraph of the Bases Background for ITS 3.8.3, CTS Bases markup page B 3.7.3-1 is different than the fourth paragraph of the Bases Background for ITS 3.8.3, ITS Bases page B 3.8.3-1.

Comment: Revise the submittal to resolve this discrepancy. Provide the appropriate justification for all proposed changes.

Consumers Energy Response:

3.8.3-08 ITS 3.8.3 Condition G Bases for ITS 3.8.3 Required Action G.1 ITS 3.8.3 Condition G addresses the starting air subsystem not within limits. The Bases for ITS 3.8.3 Required Action G.1 is silent regarding the starting air requirement.

Comment: Revise the submittal to expand the Bases for ITS 3.8.3 Required Action G.1 to address starting air.

Consumers Energy Response:

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Palisades Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.4, DC Sources - Operating 3.8.4-01 DOC L.1 ITS 3.8.4 Completion Time for Required Action C.1 Bases for ITS 3.8.4 Action C.1, CTS Bases markup page B 3. 7.4-3, insert ITS 3.8.4 Coridition C addresses one DC electrical power source inoperable for reasons other than Conditions A or B. The proposed Completion Time for associated Required Action C.1 is 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. In the event of this occurrence, the CTS requires entry into a shutdown action. The Completion Time for Required.Action A.1 for corresponding STS 3.8.4 is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

Comment: No JFD has been provided to justify this proposed difference with the STS. DOC L.1 does not provide a technical justification to support the proposed change. Revise the.

submittal to provide the technical justification for the proposed change, or conform to the STS.

Consumers Energy Response:

3.8.4-02 Bases Applicable Safety Analysis discussion for ITS 3.8.4, CTS Bases markup page B 3. 7.4-2 Bases Applicable Safety Analysis discussion for STS 3.8.4 The Bases Applicable Safety Analysis discussion for STS 3.8.4 includes reference to the criteria of 10 CFR 50.36. This materi_al has not been adopted in the Bases for corresponding ITS 3.8.4.

Comment: This is not a justifiable plant specific difference. Revise the Bases to conform to the STS.

Consumers Energy Response:

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Palisades Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.5, DC Sources - Shutdown 3.8.5-01 JFD5 ITS SR 3.8.5.1 Bases for ITS SR 3.8.5.1 STS SR 3.8.5.1 CTS 4.7.5.1 STS SR 3.8.5.1 states that SRs 3.8.4.7 and 3.8.4.8 are applicable. These requirements have not been adopted in corresponding ITS SR 3.8.5.1. JFD 5 states that this proposed difference reflects the current licensing basis/technical specifications.

Comment: The Notes to ITS SRs 3.8.4. 7 and 3.8.4.8 state that the surveillances shall not be performed in Modes 1, 2, 3, or 4. These SRs are required to be performed in Modes 5.or 6.

Provide the technical justification for not requiring these SRs to be applicable in Modes 5 and 6, or conform to the STS.

Consumers Energy Response:

3.8.5-02 Bases Applicable Safety Analysis discussion for ITS 3.8.5, CTS Bases markup page B 3.7.5-1 Bases Applicable Safety Analysis discussion for STS 3.8.4 The Bases Applicable Safety Analysis discussion for STS ~.8.5 includes reference to the criteria of 10 CFR 50.36. This material has not been adopted in the Bases for corresponding ITS 3.8.5.

Comment: This is not a justifiable plant specific difference. Revise the Bases to conform to the STS.

Consumers Energy Response:

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Palisades Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.5-03 JFD 2 Bases Applicability for ITS 3.8.5, CTS Bases markup page B 3.7.5-1 Bases Applicability for STS 3.8.5 The Bases Applicability for STS 3.8.5 refers to monitoring and maintaining the plant in a cold shutdown or refueling condition. The Bases Applicability for ITS 3.8.5 refers to monitoring and maintaining the plant in a shutdown condition. JFD 2 states that differences have been made for clarity, grammatical preference, or to establish consistency within the Improved Technical S pecincations. -

Comment: This is not a justifiable plant specific difference. Revise the submittal to conform to the STS.

Consumers Energy Response:

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Palisades Improved TS Review Comments

  • ITS Section 3.8, Electrical Power Systems 3.8.6, Battery Cell Parameters 3.8.6-01 Bases Applicable Safety Analysis discussion for ITS 3.8.6, CTS Bases markup page B 3.7.6-1 Bases Applicable Safety Analysis discussion for STS 3.8.6 The Bases Applicable Safety Analysis discussion for STS 3.8.6 includes reference to the criteria of 10 CFR 50.36. This material has not been adopted in the Bases Applicable Safety Analysis discussion for corresponding ITS 3.8.6.

Comment: This is not a justifiable plant specific difference. Revise the Bases to conform to the STS.

Consumers Energy Response:

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Palisades Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.7, Inverters - Operating 3.8.7-01 Bases Applicable Safety Analysis discussion for ITS 3.8.7, CTS Bases markup page B 3.7.7-1 Bases Applicable Safety Analysis discussion for STS 3.8.7 The Bases Applicable Safety Analysis discussion for STS 3.8.7 includes reference to the criteria of 10 CFR 50.36. This material has not been adopted in the Bases for corresponding ITS 3.8.7.

Comment: This is not a justifiable plant specific difference..Revise the Bases to conform to the STS.

Consumers Energy Response:

3.8.7-02 Bases for ITS SR 3.8.7.1, CTS Bases markup page B 3.. 7.7-3 The first sentence of the Bases for ITS SR 3.8.7.1 states, "This Surveillance verifies that the inverters are functioning properly and Preferred AC buses energized from the inverter."

Comment: This sentence is very awkward. Revise utilizing parallel structure.

Consumers Energy Response:

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Palisades Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.8, Inverters - Shutdown 3.8.8-01 Bases Applicable Safety Analysis discussion for ITS 3.8.8, CTS Bases markup page B 3.7.8-1 Bases Applicable Safety Analysis discussion for STS 3.8.8 The Bases Applicable Safety Analysis discussion for STS 3.8.8 includes reference to the criteria of 10 CFR 50.36. This material has not been adopted in the Bases for corresponding ITS 3.8.8.

Comment: This is not a justifiable plant specific difference. Revise the Bases to conform to the STS.

Consumers Energy Response:

3.8.08-02 JFD 2 Bases Applicability for ITS 3.8.8, CTS Bases markup page B 3.7.8-1 Bases Applicability for STS 3.8.8 The Bases Applicability for STS 3.8.8 refers to monitoring and maintaining the plant in a cold shutdown or refueling condition. The Bases Applicability for ITS 3.8.8 refers to monitoring and maintaining the plant in a shutdown condition. JFD 2 states that differences have been made for clarity, grammatical preference, or to establish consistency within the Improved Technical Specifications Comment: This is not a justifiable plant specific difference. Revise the submittal to conform to the STS.

Consumers Energy Response:

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Palisades Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.9, Distribution Systems - Operating 3.8.9-01 JFDS ITS 3.8.9 Condition A STS 3.8.9 Condition A CTS 3. 7. 9 Action A Bases for ITS 3.a.9 Required Action A.1, CTS Bases markup page B 3.7.9-3 Bases for STS 3.8.9 Required Action A.1 STS 3.8.9 Condition A addresses one AC electrical power distribution subsystem inoperable.

Condition A of corresponding ITS 3.8.9 addresses one or more AC electrical power distribution subsystems inoperable. JFD 5 states that this proposed difference reflects the current licensing basis/technical specifications. CTS 3.7.9 Action A addresses one or more subsystems of one AC electrical power distribution train inoperable.

Comment: The Bases for ITS 3.8.9 Required Action A.1 clearly explains the intent of ITS 3.8.9 Condition A, and is consistent with the Bases for corresponding STS 3.8.9 Required Action A.1.

The proposed change is not a justifiable plant specific difference. Revise the submittal to conform to the STS.

Consumers Energy Response:

3.8.9-02 JFD 5 ITS 3.8.9 Condition B STS 3.8.9 Condition B CTS 3.7.9 Action B STS 3.8.9 Condition B addresses one AC vital bus inoperabie. Condition B of corresponding ITS 3.8.9 addresses one or more Preferred AC buses inoperable. JFD 5 states that this proposed difference reflects the current licensing basis/technical specifications. CTS 3.7.9 Action B addresses one Preferred AC bus inoperable.

Comment: The proposed difference seems not to reflect the current licensing basis/technical specifications. This is not a justifiable plant specific difference. Revise the submittal to conform to the STS.

Consumers Energy Response:

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Palisades Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.9-03 JFD 5 ITS 3.8.9 Condition C STS 3.8.9 Condition C CTS 3.7.9 Action C STS 3.8.9 Condition C addresses one DC electrical power distribution subsystem inoperable.

Condition C of corresponding ITS 3.8.9 addresses one or more DC electrical power distribution subsystems inoperable. JFD 5 states that this proposed difference reflects the current licensing basis/technical specifications. CTS 3.7.9 Action C addresses one or more subsystems of one DC electrical power distribution train inoperable.

Comment: This is not a justifiable plant specific difference. Revise the submittal to conform to the STS.

Consumers Energy Response:

3.8.9-04 Bases for ITS 3.8.9 Required Action C.1, CTS Bases markup page B 3.7.9-4 Bases for ITS 3.8.9 Required Action C.1, STS Bases markup page B 3.7.9-7 The Bases for ITS 3.8.9 Required Action C.1 refers to a DC bus in one train inoperable. The Bases for ITS 3.8.9 Required Action C.1, STS Bases markup page B 3.7.9-7 refers to a DC bus or buses in one train inoperable.

Comment: Revise the submittal to resolve this discrepancy.

Consumers Energy Response:

3.8.9-05 Bases Applicability for ITS 3.8.9, CTS Bases markup page B 3.7.9-2 The Bases Applicability for ITS 3.8.9 states, "The AC source requirements for Modes 5 and 6 are addressed in LCO 3.8.2, AC Sources - Shutdown."

Comment: This statement seems out of context with the remainder of the Applicability discussion because these Bases address distribution systems and not AC sources. Revise the submittal to remove this statement from the Bases.

Consumers Energy Response:

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Palisades Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.9-06 CTS 3.7.9 Action E ITS 3.8.9 Condition E Bases for ITS 3.8.9 Required Action E.1, CTS Bases markup page B 3;7.9-4 Bases for STS 3.8.9 Required Action E.1 CTS 3.8.9 Condition E addresses two or more inoperable distribution subsystems that result in a loss of function. ITS 3.8.9 Condition E does not refer to other existing equipment failures, and the Bases for STS 3.8.9 Required Action E.1 does not contain this reference either.

Comment: ITS 3.8.9 Condition Eis a proposed change relative to the CTS. This proposed change has not been noted on the CTS markup, and justification for the proposed change has not been provided. Revise the submittal to note this proposed change on the CTS markup, and provide the appropriate justification. Revise the associated Bases to support ITS 3.8.9 Condition E.

Consumers Energy Response:

3.8.9-07 Bases for ITS SR 3.8.9.1, CTS Bases markup page B 3.7.9-5, third paragraph The third paragraph of the Bases for ITS SR 3.8.9.1 addresses buses which have only one possible power source.

Comment: There seems to be material missing from the sentence - the sentence is incomplete.

Revise the submittal to add the missing material to the Bases.

Consumers Energy Response:

3.8.9-08 Bases Applicable Safety Analysis discussion for ITS 3.8.9, CTS Bases markup page B 3.7.9-1 Bases Applicable Safety Analysis discussion for STS 3.8.9 The Bases Applicable Safety Analysis discussion for STS 3.8.9 includes reference to the criteria of 10 CFR 50.36. This material has not been adopted in the Bases for corresponding ITS 3.8.9.

Comment: This is not a justifiable plant specific difference. Revise the Bases to conform to the STS.

Consumers Energy Response:

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Palisades Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.10, Distribution Systems - Shutdown 3.8.10-01 ITS 3.8.1 Required Action A.2.5 CTS 3.7.10 Action A.2.5 ITS 3.8.10 Required Action A.2.5 states, "Declare associated required shutdown cooling train inoperable and not in operation," which is consistent with the STS. CTS 3.7.10 Action A.2.5 states, "Declare affected required shutdown cooling trains inoperable."

Comment: This proposed change was not noted on the CTS markup.

  • Revise the submittal to note the proposed change on the CTS markup, and provide the appropriate justification.

Consumers Energy Response:

3.8.10-02 Bases Applicable Safety Analysis discussion for ITS 3.8.10, CTS Bases markup page B 3.7.10.. 1 Bases Applicable Safety Analysis discussion for STS 3.8.10 The Bases Applicable Safety Analysis discussion for STS 3.8.10 includes reference to the criteria of 1 O CFR 50.36. This material has not been adopted in the Bases for corresponding ITS 3.8.10.

Comment: This is not a justifiable plant specific difference..Revise the Bases to conform' to the STS.

Consumers Energy Response:

. 3.8.10-03 JFD 2 Bases Applicability for ITS 3.8.10, CTS Bases markup page B 3. 7.10-1 Bases Applicability for STS 3.8.10 The Bases Applicability for STS 3.8.10 refers to monitoring and maintaining the plant in a cold shutdown or refueling condition. The Bases Applicability for ITS 3.8.10 refers to monitoring and maintaining the plant in a shutdown condition. JFD 2 states that differences have been made for clarity, grammatical preference, or to establish consistency within the Improved Technical Specifications.

Comment:. This is not a justifiable plant specific difference. Revise the submittal to conform to the STS.

Consumers Energy Response:

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Palisades Improved TS Review Comments Section 5.0, Administrative Controls 5.5, Programs and Manuals 5.5-01 ITS 5.5.2 CTS 6.5.2 The CTS markup for the first paragraph in this section contains the term "shutdown cooling system". Although the ITS has this term in it, the STS markup does not include it.

Comment: Revise the submittal to include this term in the STS markup.

Consumers Energy Response:

5.5-02 JFD 19 CTS 6.5.14 ITS 5.5.14 Information has been added or changed in the CTS for this section via "Insert 1" from the STS markup without any supporting DOCs.

Comment: Revise the submittal to address each change in CTS 6.5.14 as revised by "Insert 1" from the STS markup. Each of these changes or additions should be supported by an appropriate DOC.

Consumers Energy Response:

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Palisades Improved TS Review Comments Section 5.0, Administrative Controls 5.6, Reporting Requirements 5.6-01 CTS 6.6.1 ITS 5.6.1 The first paragraph of the CTS, ITS, and STS from this section has a bracketed item containing the term "describe maintenance". This term has not been edited to reflect plant specific maintenance items relating to the Occupational Radiation Exposure Report.

Comment: Revise the CTS, ITS, and STS markup bracketed item for this section to reflect plant specific maintenance items relating to the Occupational Radiation Exposure Report.

Consumers Energy *Response:.

  • 5.6-02 DOCA.8 CTS 6.6.5 b.1 ITS 5.6.5 b.1 DOC A.8 does not fully explain or support the removal of the term "LCO 3.10.1" from CTS 6.6.5 b.1.

Comment: Revise the CTS submittal DOC A.8 to substantiate removal of the term "LCO 3.10.1" from CTS 6.6.5 b.1.

Consumers Energy Response:

5.6-02 DOC A.10, LA.1 CTS 6.5.5, 6.6.8 (ref. 4.5.4, 4.5.5, 4.5.6)

ITS 5.5.5, 5.6. 7 DOC A.1 O and LA.1 are included in the Attachment 3 "Discussion of Change" portion of the CTS markup but are not referenced in the actual CTS markup. It appears that DOC A.10 should be referenced in CTS 6.6.8 and that DOC LA.1 should be referenced in CTS 6.5.5.

Comment: Revise the CTS submittal to reference DOC A.10 and LA.1.

Consumers Energy Response:

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