ML18046A322
| ML18046A322 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/17/1980 |
| From: | Frost S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML18046A321 | List: |
| References | |
| NUDOCS 8101220186 | |
| Download: ML18046A322 (3) | |
Text
consumers Power company General Offices: 212 West Michigan Avenue, Jackson, Michigan 49201
- Area Code 517 788-0550 October 17, 1980 Mr James G Keppler Off ice of Inspection and Enforcement Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - RESPONSE TO IE INSPECTION REPORT 80-15
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Consumers Power Company's response to the apparent infractions noted in IE Inspection Report 80-15 dated September 24, 1980 are as follows:
Item 1 Technical Specification 3.20.1 permits operation up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with a single safety-related snubber inoperable; requiring the reactor be in cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> after these conditions cannot be met.
Contrary to the above, after two safety-related snubbers (No 5 and 9) were determined inoperable at 1400 on 12 May 1980, the licer1see neither restored at least one snubber to operability nor placed the reactor in cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
Response to Item 1 Consumers Power Company takes exception to the NRG interpretation of the Palisades Plant Technical Specification (TS) 3.20.1.
We do not find anywhere in the basis section of the TS or in the SER that states when a single safety-related snubber is inoperable for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> that the reactor is to be in cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> after these conditions cannot be met.
The standard Technical Specifications have also been reviewed to provide clarification of this problem.
They specifically state that with one or more hydraulic snubbers inoperable, replace or restore the inoperable snubber(s) to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Mr James G Keppler Palisades Plant October 17, 1980 2
Based on the above discussion and interpretation, we maintain the fact that we can operate with one or more snubber's being declared inoperable under Sec-tion 3.20.1.
Item 2 Technical Specification 6.9.2 contains requirements for reporting selected occurrences to NRC.
- a.
Paragraph 6.9.2.a(2) requires notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for operation with any parameter subject to a limiting condition for operation (LCO) less conservative than the least conservative aspect of the LCO.
Contrary to the above, notification was not made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after a least conservative aspect of TS 3.20.1, permitting operation above cold shutdown with a single safety-related snubber inoperable, was exceeded on 12 May 1980 by operation above cold shutdown with two inoperable safety-related snubbers.
Response to Item 2.a As stated in the discussion to Item 1, we were not in violation of the Palisades Plant TS 3.20.1. Therefore, we did not have to report this event under Section 6.9.2.a(2) of the Palisades TS.
Item 2.b Paragraph 6.9.2.b(2) requires a written report within 30 days for conditions leading to operation in a degraded mode permitted by an LCO.
Contrary to the above, no written report was submitted within 30 days after the Plant was heated above cold shutdown on 10 May 1980 with an inoperable safety-related snubber; a degraded mode permitted by TS 3.20.1.c.
Response to Item 2.b Palisades Technical Specification 3.20.1.c specifically states:
"If a snubber is determined to be inoperable while the reactor is in either cold shutdown or refueling mode, the snubber shall be made operable or replaced prior to the reactor being made critical."
As allowed by this TS, the Palisades Plant was heated above cold shutdown to hot shutdown on May 10, 1980 with a safety-related snubber inoperable.
This snubber was repaired and d~clared operable prior to going to a hot standby condition (ie, reactor critical).
Based on the above, it is our conclusion that no action statement was entered.
Therefore, we did not have to report this event under Section 6.9.2.b(2) of the Palisades TS.
Mr James G Keppler Palisades Plant October 17, 1980 Summary Consumers Power Company disagrees (based on past practice and comparison with the standard Technical Specifications) with the IE inspectors' interpretation of the Palisades Plant Technical Specifications and requests that these apparent items of noncompliance be withdrawn.
Steven R Frost (Signed)
Steven R Frost Palisades Nuclear Licensing Engineer CC. Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector-Palisades 3