ML18046A287
| ML18046A287 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/08/1981 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8101120318 | |
| Download: ML18046A287 (2) | |
Text
consumers Power company General Offices: 212 West Michigan Avenue, Jackson, Michigan 49201 * (517) 788-0550 January 8, 1981 Director, Nuclear Reactor Regulation Att Mr Dennis M Crutchfield, Chief Operating Reactors Branch No 5 US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR LOSS OF OFF-SITE POWER SURVEY - PALISADES PLANT - REVISION 2
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. -.J Consumers Power Company was requested, by NRG letter dated September 25, 1979, to supply information concerning the loss of off-site power experiences at our Palisades Plant.
Our letter dated January 31*, 1980 supplied that information and identified that between June 6, 1971 and July 22, 1978 the Palisades Plant experienced 94 partial losses of off-site power and four total losses of off-site power.
The information obtained from our January 31, 1980 letter was taken and incor-porated into a Loss of Off-Site Power Survey which was distributed to the industry on Jl.µle 19, 1980.
The Loss of Off-Site Power Survey Status Report dated June 19, 19'30 was prepared by Mr Raymond Scholl, Jr from the Systematic Evaluation Program Branch of the Division of Licensing.
Mr R Scholl was con-tacted by telephone on August 20, 1980 by Mr M R Wade and Mr S R Frost of CP Co and discussed his steps in data reduction and analysis and his conclusions and recommendations.
Our comments to the Loss of Off-Site Power Survey were transmitted to the NRG by CP Co letter dated October 28, 1980.
During the final preparation of our response to the original Loss of Off-Site Power Survey (June 19, 1980), we received the NRC's latest Loss of Off-Site Power Survey Status Report issued October 10, 1080.
A review of the October 10, 1980 survey reveals that there are still some items that provide misleading information, such as Item 11 under "Discussion" still shows Palisades with four event rates greater than the target values.
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These four events were thoroughly discussed in our October 28, 1980 letter.
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Th3 latest report concludes and recommends that Palisades be further evaluated ~ '-;
to determine the causes for the relatively high frequency of trips caused by
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Director, Nuclear React.Regulation Palisades Plant January 8, 1981 2
lightning.
This was also discussed in our earlier submittal, but it deserves to be repeated here.
There is no way to reduce the number of lightning strikes on our transmission lines.
Our lightning protection and protective relaying system is doing exactly what it was designed to do and exactly what we want it to do.
We are not going to degrade our system by reducing our protection against lightning.
Our event rate is only 0.66 compared with a target of 0.63 for lightning.
This is not a significant deviation and the whole topic about lightning should be dropped unless more substantial concerns can be provided.
Also, future revisions of this status report should reflect the acceptability of this position.
By NRG letter dated December 4, 1980, we were informed that the staff has reviewed our comments contained in our October 28, 1980 submittal.
The letter stated that Revision 2 of the Loss of Off-Site Power Survey (NRG letter dated October 10, 1980) adequately addresses the comments raised in our October 28, 1980 submittal.
Based on our comments above, we still see some problems related to this survey.
Consumers Power Company is quite concerned that this data be correctly interpreted since this report gets wide circulation.
This is an important factor if this survey is to be a helpful tool.
The information provided by this survey should be accurate and not misleading as it is in the present form.
We are willing to provide any information/clarification of events at the Palisades Plant pertaining to this subject so the events can be properly incorporated into tnis Loss of Off-Site Power Survey.
David P Nuclear Licensing Administrator CC Director, Region III, USNRC NRG Resident Inspector-Palisades