IR 05000255/1980015
| ML18046A320 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/09/1981 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Dewitt R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18046A321 | List: |
| References | |
| NUDOCS 8101220182 | |
| Preceding documents: |
|
| Download: ML18046A320 (2) | |
Text
..
~
'
, I l I *
Docket No. 50-255 Consumers Power Company ATTN:
Mr. R. B. DeWitt Vice President Nuclear Operations 212 West Michigan Avenue Jackson, MI 49201 Gentlemen:
CENTRAL F~LES 19~
.....
This is in response to your letter dated October 17, 1980, in which you took exception to the apparent items of noncompliance identified in our letter dated September 24, 198 Following a re-evaluation of our initial position, we believe our interpre-tation and reading of Technical Specification 3.20.1 as stated in our September 24, 1980 letter is correc All snubbers of Table 3.20.1 must be operable with the plant above cold shutdown; this being the most conserva-tive conditio All permissible exceptions to this requirement (subparagraphs
"a" through "d'), are addressed strictly in the singula One inoperable safety related snubber is the least conservative condition and constitutes a permitted degraded mode of operatio No provision is made for more than one safety related snubber to be inoperable while above cold shutdow Such a condition is less conservative than the least conservative aspect of this Specification, and constitutes a violation of the Specification requirements when the reactor is not placed in cold shutdown within 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Item 1 remains as initially issued:
The plant was operated above cold shut-down for more than 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> with more than one inoperable safety-related snubbe Operation of the plant with more than one safety-related snubber inoperable is clearly not permissible under your current technical specifications and would therefore also be contrary to the provisions of 10 CFR 50.3 Item 2.a will be withdrawn as an item of noncompliance since it is directly related to Item Consumers Power Company did not recognize Item 1 as a violation of technical specifications and therefore could not be expected to report the matte *
Consumers Power Company
- 2 -
Item 2.b remains as initially issue Our review concludes that changing from the cold shutdown mode to the hot shutdown mode with one safety-related snubber inoperable does constitute entry into a limiting condition for operation action statemen Thus, while entry into this action statement is permissible, it does require, per Technical Specification 6.9.2.b(2), that a 30-day report be issue Other aspects of your response are of concern to this offic While we agree with the practice of reviewing the bases of your technical specifications or reviewing standardized technical specifications to assist in clarifying areas where the intent is not clear, we do not agree with your position that an option exists to either ignore the specification if the bases does not clearly address the issue, or to adopt the less stringent requirement that may exist in a standardized technical specificatio Specifically, the facility technical specification requirements must be adhered to unless either a waiver is granted or the technical specification is change If you believe a relaxation of this requirement is possible, it is your responsibility to initiate the appropriate technical specifi-cation change reques In accordance with Section 2.201 of the NRC's "Rules of Practice", Part 2, Title 10, Code of Federal Regulations, you are requested to submit to this office within twenty days of your receipt of this notice, a written statement or explanation in reply, including for each item of noncompliance:
(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid furthei noncom-pliance; and (3) the date when full compliance work will be achieve Be sure to address each of these items in your respons We will gladly discuss any questions you have concerning this inspectio cc w/ltr dtd 10/17/80:
D. P. Hoffman, Nuclear Licensing Administrator R. W. Montross, Manager Central Files Reproduction Unit NRC 20b AEOD Resident Inspector, RIII PDR Local PDR NSIC TIC Ronald Callen, Michigan Public Service Commission Myron M. Cherry RIII
~
R~
Jorgensen/jp Heller
~\\. 12/31/80 (
Sincerely, James G. Keppler Director RIII uJ Boyd RI~L-H~hman
\\\\1\\q\\
RIII N~T*us{
1'1 ~