ML18046A366

Responds to Conditions Specified in NRC 810114 Ltr Re Owners Group Program for Completing Sep.Topic Assessments,Reviews of Outstanding Draft Evaluation & Representative to Assist W/Resolution of Issues to Be Provided

ML18046A366
Person / Time
Site:	Palisades, Big Rock Point  File:Consumers Energy icon.png
Issue date:	02/04/1981
From:	Vincent R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Crutchfield D Office of Nuclear Reactor Regulation
References
NUDOCS 8102090227
Download: ML18046A366 (6)

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General Offices: 212 West Michigan Avenue, Jackson, Michigan 49201 * (517) 788-0650 February 4, 1981 Director, Nuclear Reactor Regulation Att ~.r Dennis M Crutchfield, Chief Operating Reactors Branch No 5 U S Nuclear Regulatory Commission Washington, D C 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT DOCKET 50-255 - LICENSE DPR PALIS.ADES PLANT -

SYSTEMATIC EVALUATION PROGRAM NRC letter dated January 14, 1981, specified seven (7) conditions to be met in order for the staff to consider the SEP Owner_s Group program for completing the SEP. The Owners Group program was developed in response to anticipated diffi-culties with the staff's proposal for redirecting the existing SEP; and has been discussed with the staff on several occasions over the past four months.

The SEP Owners Group program provides that:

1. Sixty percent (6ci%) of the aggregate total of topic assessment for all SEP plants be completed by June, 1981. *

2. Not all topics will be able to be completed by June, 1981, because of long lead times for some evaluations or lack of topic definition and criteria.

3. There will be a lead plant assigned for each topic- which is not complete.

This plant would work with staff reviewers to develop an SER for a topic which, in turn, would serve as a model for the assessments of that topic for the remaining SEP plants.

There is a possibility that some topics will not be addressed by June, 1981, but this should not preclude achieving the other staff goals by this date.

The nine (9) SEP Owners Group plants represent 1,233 SEP topics to be resolved.

As of January 9, 1981; 504 of these topics were either deferred because they were generic issues being addressed elsewhere, or were not applicable to particu-lar plants. Of the remainder, draft or final SERs have been is.sued for 207 topics.

The SEP Owners would review each SER completed for another plant and apply the findings, where possible, to-_development of an assessment of that topic to their own plant(s). Where a topic SER does not yet exist, the designated plant would

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Dennis M Crutchfield 2 Palisades & Big Rock Point Plants February 4, 1981 cooperate with and assist the NRC in developing the final SER for that topic.

These SERs, in turn, would be used by the other Owners to develop the remain-ing plant-specific assessments for that topic. For SERs which now exist in draft form, it is anticipated that Owner reviews would be completed expeditious-ly; and that resulting comments would be provided to the staff to allow SER finalization. It is expected that reviews of most draft SERs in existence prior to February 1, 1981, could be completed or at least major problems could be identified within approximately 30 days of formal NRC acceptance of the Owners Group program. For those draft SERs issued after February 1, 1981, efforts will be made to complete reviews and provide comments within the normally prescribed 30-day response period.

In order for these goals to be realized by the NRC and the Owners Group, it is expected that sufficient staff resources will be dedicated to clear and concise definition of topic req_uirerr.ents, prorc:pt issc;.ance of draft SERs, and 30-day review of and response to Owner topic assessments. Consistency of review criteria and reviewers also will be of great importance to the achievement of these goals.

The following provides individual responses to each of the seven (7) conditions specified. in your January 14, letter:

1. By June 30, 1981, we agree to provide for staff review a sufficient number of topic assessments, and complete reviews of outstanding draft assessments to meet the staff goal. Al though Palisades is already beyond the 6-0% level, additional topics will be addressed to support the SEP Owners Groun nrogra.m.

Lists of c~didate topics for Palisades and Big Rock Point a}e included as Attachments I and II.

2. We commit to actively support staff ::-eviews to permit June, 1981, completion of lead topic assessments for those topic.s assigned to Palisades and Big Rock Point. It must be recognized, however, that any long lead time analyses or lack of clear review criteria may preclude completion of some assigned topics by this date.

3, 4. We are concerned that the ninety-day trial period and the parallel continu-ation of the lead plant approach represents less than a full staff commitment to the success of a redirected SEP. We are concerned that these parallel efforts will dilute both the available staff resources and Consumers Power Company resources. It is expected that staff reviewers will be primarily oriented toward the Owners Group program, and that continuation cf the lead plant concept will not affect staff responsiveness to either the rest of the SEP plants, or to the Owners Group program topics assigned to Palisades and Big Rock Point Plants.

5. We agree to provide, at least on a part-time basis, a local representative to assist with the expeditious resolution of SEP issues for Palisades. This I

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Dennis M Crutchfield 3 Palisades & Big Rock Point Plants February 4, 1981 agreement shall be subject to the following considerations:

a. It is our understanding that this representative primarily would provide advance reviews of documents such as draft SERs which are nearing com-pletion, and generally would assist with and expedite communications for q_uick resolution of staff questions. This individual will not be provid-ed to research information which has previously been docketed or is other-wise readily available to the reviewers.

b. Consumers Power Company reserves the right to assign different individuals to act as our local representative; ie, the individual provided initially as the Consumers Power Company representative may not be assigned necessar-ily for the entire period; In addition, Consumers Power Company reserves the right to vary the schedu~e of our representati7e consistent 'N-ith t:i.e work load. Since greater efficiency can be realized through direct con-tact of our representative with both Consumers Power Company and NRC staff personnel, it is anticipated that he normally will not spend full time in Washington.

c. Again, in the interest of efficiency, it.is important that our local representative have a consistent office in close proximity to appropriate NRC personnel, and have a* consistent telephone number for rapid communica-tions with the Project Managers, reviewers and Consi,uners Power company personnel. Permanent office facilities within the Phillips Building seem. to.be the only reasonable alternative. Since the reason f9+/- assign-ment of a local representative is efficiency, it would b~ iliogical to simply rotate this individual from vacant desk to vacant desk, or provide no facilities at all.

6. W~ agree to the NRC request fa~ .periodic meetings between SEP plant Owner representatives and NRC SEP management representatives to discuss progress and program planning.

{. We agree to process draft SERs and advise the staff of comments, insofar as possible, within the normally specified 30 day response periods.

In light of the commitments that we and the remainder of the SEP plant Owners have made to the SEP program, we view the staff's present approach to the Bingham Amendment with great concern. This approach, detailed in SECY-81-13 and discuss-ed with the Commissioners on January 14, appears to go well beyond the intent of Representative Bingham, and certainly would have a major impact on SEP plant Owners. This approach to the Systematic Safety Evaluation (aka Bingham) would result in a reevaluation of most completed SEP topics to develop additional material and to rewrite existing material into a format amenable to direct comparison with the Standard Review Plan. If this program were imposed on SEP

Dennis M Crutchfield 4 Palisades & Big Rock Point Plants February 4, 1981 plants as stated in SECY-81-13, resource constraints would not allow completion of either SEP or the Systematic Safety Evaluation within the desired schedules.

Consumers Power Company will continue to monitor the progress of this issue with great interest.

Robert A Vincent Staff Licensing Engineer CC Director, Region III, USNRC

• NRC Resident Ins?ectors - Palisades & Big Rock Point Plants Attachments - 2

ATTACHMENT I TOPIC LI ST FOR EARLY RESOLUTION*

FOR PALISADES 1 II-3.A HYDROLOGIC DESCRIPrION 2 II-3.B FLOODillG POTENTIAL AND PROTECTION REQUIREMENTS 3 II-3.B.l CAPABILITIES OF OPERATING PLANTS TO COPE WITH DESIGN BASIS FLOODING CONDITION 4 II-3.C SAFETY-RELATED WATER SUPPLY (ULTIMATE HEAT srnK (UHS))

5 III-4.B TURBINE MISSILES 6 III-7.D CONTAINMENT STRUCTURAL INTEGRITY TESTS 7 V-5 REACTOR COOLANT PRESSURE BOillIDARY (RCPB) LEAKAGE DEI'ECTION 8 V-10.B RESIDUAL HEAT REMOVAL SY8TEM RELIABILITY 9(LP) VI-7 .A.3 ECCS ACTUATION SY8TEM 10 VI-7.F ACCUMULATOR ISOLATION VALVES POWER AND CO:NTROL SY8TEM 11 VII-3 SySTEMS REQUIRED FOR SAFE SHUTDOWN 12 IX-3 STATION SERVICE AND COOLrnG WATER SyS~..S 13 II-4.D STABILITY OF SLOPES 14 III-3.A EFFECTS OF HIGH WATER LEVEL ON STRUCTURES 15 VI-5 COMBUSTIBLE GAS CONTROL 16 VI-7-B ESF SWITCHOVER FROM INJECTION TO RECIRCULATION MODE (AUTOMATIC ECCS REALIGNMENT) 17(LP) VI-7 .C ECCS SINGLE FAILURE CRITERION AND REQUIREMENTS ]'OR LOCKING OUT POWER TO VALVES rncLUDING INDEPENDENCE OF INTERLOCKS ON ECCS VALVES 18 IX-l FUEL STORAGE 19(LP) III-7.C DELAMINATION OF PRESTRESSED CONCRETE CONTAINMENT STRUCTURES 20(LP) III-4.C INTERNALLY GENERATED MISSILES 21 (LP)thru xv-1* thru

• 40 XV-19 TRANSIENTS LP - Indicates Palisades is the chosen lead plant 1.lllder the Owners Group's lead topic concept.

• We have agreed under Item 5 of NRC's letter of January 14, 1981 to continue to support a Palisades lead plant approach. We, therefore believe NRC will set the schedule. and topic choices for Palisades. The above list contains topics which we feel can be resolved in a six-month period.

It is not necessarily implied that they can all be handled simultaneously but that a sufficient number of topics can be chosen to meet NRC's goals.

• ATTACHME.NT II TOPIC LIST FOR EARLY RESOLUTION*

BIG ROCK POINT PLANT

• 1 II-1.C POTENTIAL HAZABDS OR CHANGES m POTE~l'TIAL HAZARDS DUE TO TRANSPORTATION, INSTITUTIONAL, INDUSTRIAL, AND MILITARY FACILITIES 2 II-3.A HYDROLOGIC DESCRIPTION 3 II-3.B FLOODING POTENTIAL AND PROTECTION REQUL>\EMENTS.

4 II-3.B.l CAPABILITY OF OPERATING PLANTS TO COPE WITH DESIGN BASIS FLOODING CONDITIONS 5 II-3.C SAFETY-RELATED WATER SUPPLY (ULT!MATE HEAT SINK UHS))

6 III-7.D *CONTAINMENT STRUCTURAL INTEGRITY TESTS 7 V-5 REACTOR COOLANT PRESSURE BOUNDARY (RCPB) LEAKAGE DETECTION 8 VI-7.A.3 ECCS ACTUATION S'YSTEM 9 VII-2 ENGINEERED SAFETY FEATURES (ESF) SY8TEM CONTROL LOGIC 10 VII-3 SY8TE.i.\1S REQUIRED FOR SAFE ShLITDOWN ll IX-3 STATION SERVICE AND COOLING WATER SySTEMS 12 II-4.D STABILITY OF SLOPES 13 III ... 3.A EFFECTS OF HIGH WATER LEVEL ON STRUCTURES 14 VI-7.B ESF SWITCHOVER FROM INJECTION TO RECIRCULATION MODE (AUTOMATIC ECSS REALIGNMENT) 15 IX-1 FUEL STORAGE 16-34 XV-1 thru XV-19 TRANSIENTS 35(LP) VI-2D MASS AND ENERGY RELEASE FOR POSTULATED PIPE BREAKS INSIDE CONTAINMENT 36 (LP) VI-3 CONTAINMENT PRESSURE AND HEAT REMOVAL CAPABILITY 37(LP) VI-4 CONTAINMENT ISOLATION SySTEM *

• This list contains topics each of which we believe can be resolved in a six-month period. From this list sufficient topics will be chosen and com:pleteito meet NRC's target of having 6Cf/o of the SEP Topics resolved by June 1981.

(LP) Means Big Rock Point was chosen as lead plant under the Owners Group' s lead topic *concept.