ML18046A565

Forwards Descriptions of Plans to Support SEP Milestone Dates of 810430 & 810630 in Response to 810219 Request

ML18046A565
Person / Time
Site:	Palisades, Big Rock Point  File:Consumers Energy icon.png
Issue date:	04/09/1981
From:	Vincent R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Crutchfield D Office of Nuclear Reactor Regulation
References
NUDOCS 8104130382
Download: ML18046A565 (8)

Text

General Offices: 212 West Michigan Av11nue, Jackson, Michigan 49201 * (517) 788-0650 April 9, 1981 Director, Nuclear Reactor Regulation Att Mr Dennis M Crutchfield, Chief Operating Reactors Branch. No 5 US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT DOCKET 50-255 - LICENSE DPR PALISADES PLANT SYSTEMATIC EVALUATION'PROGRAM (SEP)

During a meeting between the SEP Owners Group and the NRC on February 19, 1981, each SEP plant owner was requested to provide a description of activities planned to support program milestone dates of April 30, 1981 and June 30, 1981.

Descriptions and schedules for both Big Rock and Palisades were telecopied to NRC on February 27, 1981. Subsequent discussions with the staff indicate that our plans provide an acceptable response to the staff's concerns. It was requested, however, that they be docketed.

The descriptions of our plans to support the SEP are, therefore, submitted as Attachments I and II. These attachments are identical to the doci.unents telecopied to the staff on February 27, 1981.

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R A incent Staff Engineer CC JGKeppler, USNRC NRC Resident Inspector - Palisades Enclosure (7 pages) 8- Jo 4-130 3&2-

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~ r? . ~ILLtF'S Bcb~ "E?ooP( ;o 5' 2 2 7./-ff..J a '-='69<1sp#:6b>> ~bet ({ict....~ALISADrn SEP SCHEDULE FOR JU?~ 30, 1981 EFFORT This program represents a significant effort for Consumers Power. While we wish to co-operate in every way with NRC to attain the goals set, it must be recog-.

nized that the schedule is extremely ambitious. We also feel that maintaining the quality of the reviews is of paramount importance. For these reasons we consider the below dates as target dates to assist NRC in scheduling their .

reviewers. We will make every effort to provide the material as soon as it becomes available in the event it is available early or to inform NRC as soon as we realize we can not meet the target dates.

The following relates directly to NRC status summary as of February 18, 1981, provided in the meeting on February 19, 1981.

1. Consumers is requested to complete one Topic (III-5.B)

Status: We analyzed this Topic beginning in 1972. The report

.(SR-6) Rev 2 is on the docket. Rev 3 of the report dated June 30, 1975 is available.

Proposed Ac1tion:

1. Perform a review of methodology used in Rev 3 of SR-6, NRC's lead Topic SER, and current standard review plan.

2 *.. Submit SR-6 Rev 3 along with methodology comments and any questions requiring NRC guidance by April l, 1981.

3. Obtain NRC.answers by April 15, 1981.

4. In parallel with l, 2 and 3 begin detailed review of SR-6 to compare it with currently accepted analysis.

Since the report uses the "mechanistic'~ approach and since stress analysis was, or will be, redone for IEB79-14 r.equirements this will take many man hours. Target is to submit this review incorporating the Item l, 2, 3 methodology comparison*results by June 30, 1981.

5. If the result is unfavorable and significant reanal-ysis of breaks is required this will extend beyond June 30, 1981, and is expected to take on the order of 6 months to complete.

2. As a result of NRC's acceleration of Palisades reviews and Consumers' preoccupation with the EEQ problem, post TMI problems, and the problems of I&E Region 3 we have a backlog of completed SER's for review and comment.

2.

We will accelerate our efforts and as a target will be up to date by June 30, 1981. NRC's status reports indicate that there may be as many as 36 Topics involved. More specifically:

a) By April 30, 1981, have 1/2 to 2/3 of these topics reviewed.

These will be those which are less man-hour intensive or on which we have less significant comments.

b) By June 30, 1981, have the remaining mc;ire difficult ToI>ics along with the Topics added to status 5 by NRC between now and then (potentially as many a.s 22) reviewed *.

3. NRC will be working on 22 Topics which are now status 3, 4 or have been given to contractors. Some of these will require that Consumers answer NRC on ques-tions to retain NRC's schedule.

a) By April 30, 1981, answer all questions which are now in our hands. Give incomplete or partial answers if necessary to meet this schedule.

b) Process new NRC questions within NRC's standard 30 days or provide alternate time schedules if this is not possible.

In the above schedule there is no time for second and third r0und questions. If quality and schedule are to be maintained management on both sides must agree to and. constantly enforce ways of communication that are significantly better than those typical. in the past

• Specifically both sides must:

. 1 *. Avoid artificial positioning questions and answers.

2. Questions and answers must be clearly worded, mean what the words say and be aimed at the engineering heart of the matter.

3. Frequently several levels of approval are required on both sides. The management of both sides will have to develop timely ways of obtaining these including reserving time, pre-publishing when those times are and not subordinating SEP in their priorities.

4. NRC should attempt to refrain from raising new short sched')lle issues for the term of this agreement so that it has a chance to work. The shielding of SEP Licensees and folding into SEP of new issues that was promised by NRC at .the inception of SEP has not.

• happened. Perhaps for this short time period a renewed effort could be made. *

.BIG ROCK POINT SEP SCHEDULE FOR JUNE 30, 1981 EFFORT .

This program represents a significant effort for Consumers Power. While we wist to co-operate in every way with NRC to attain the goals set, it must be recog-nized that the schedule is extremely ambitious. ~e also feel that maintaining the quality of the reviews is of paramount importance. For these reasons we consider the below dates as target dates to assist NRC in scheduling their

• reviewers. We will make every effort to provide the material as soon as it becomes available in the event it is available early or to infonn NRC as soon as we realize we can not meet the target dates.

The following relates directly to NRC status summary as of February 18, 1981, provided in the meeting on February 19, 1981.

NRC has asked that 1) topics be done for Big Rock Point. They a~e:

l. Topic II-2C Atmospheric Transport & Diffusion Status: We beli~ve that BRP essentially meets present criteria with the exc::-:::tion of

. the control room habitability aspect. Control room habitability is the direct ." 1 ~b~ ect of Topic VI-8, inter3.cts with Topic IT.-5 "Ventilation Systems", is a pn:rt of pc :t *.;:"I

• activities, and is being handled by NRC' s post._ TMI action plan rather thP..n in s::?.

• Proposed Action: Write up and document X/Q values used in calcula~ing dose to the public~ *Document that there are no significant B.molints of explosive or haz1rdous material on site. Consider NRC comments from the site visit o:i this topic.

Schedule : April 30, 1981

2. Topic II-4F Settlement of Foundation & Buried Equipment Status: During ::1. site visit NRC and Consumers engineers walked plant foundations and found them in excellent condition. None of the classic symptoms of foun1lation settlement could be found. We have looked for benchmark data f:!"Om which differential settleroent_between end of con-struction and. no*t could be determined.. The coristruction benchmark field notes, if *;hey ever existed, have been lost.

Proposed Action: Have a structural engineer with recognized foundation expertise inspec*~ the visible portions of the foundations and equipment and write a repol*t. If this report confirms our preliminary findings we will submit it as resolution of the topic.

Schedule: April 30, 1981

2.

3. Topic III-4.D Si~e Proximity Missiles (Including Air Craft)

Status: We are aware of no likely site proximity missiles other than aircraft. BRP has not been analyzed for the consequences of aircraft crash. We would argue that air crashes are improbable. Based on the site site visit we be:.ieve NRC will accept this app::-oach.

Proposed Action: Document aircraft density in the area. Write safety evaluation based on computed low probability o:~ air crash.

Schedule: June :\O, 1981

4. Topic III-5 .B HEJ..B Outside Containment Status: A repori~ of analysis performed in 197~! and 1973 is on the doc.ket. The report is mechanistic and includecL seismic stress per old BRP seismic 1:riteria which has been replac1?d by other criteria during SEP.

Proposed Action:. Determine from NRC whether s1.ress values in 1972 work are acceptal,le by March 15 ,1981. If not, completion of this topic by June 30:. 1981 is impossible. In that event we wish to replace the topiC! with Topic II-4.D stability c*f slopes. This topic

. can be completed 60 days after the lead topic ~*ER becomes available.

5. Topic III-6 Seisriic Design Considerations Status: We have analyzed BRP structures and tr e report is in final review. *Piping, mechanical equipment functione.lity, cable trays, and electrical equipment design adequacy and ftnctionality are longer term projE!cts as outlined in our Octobe1* 10, 1980 letter.

Proposed Action: It is not possible to compleie Topic III-6 by June 30, 1981. We therefcire 'Wish to replace it with T01ic IV-2. We have activity in progress on this topic as a result of NRC questions which we believe will E!Ssentially complete the topic. This assessment can .

be completed by Hay 30, 1981.

• 6. Topic VI-7 .C.2 l'ailure Mode Analysis ECCS Status: The BRP probabilistic risk assessment has considered this subject. We can excerpt the risk assessment, l:owever, it is not clear that this n1aterial will be in the proper forma. t to easily resolve this issue.

Proposed Action: By March 31, 1981 provide NRC with appropriate risk assessment J!laterial and obtain an answer en adequacy for this topic. If :!.t is not adequate we wish to replace this topic with Topic VI-1 ~*hi ch we. believe we can complete 60 days after the lead topic SER becomes available.

7. Topic VI-10.A RPS and ESF Trip Testing Status: Our surveillance program has been recently reviewed by NRC and essentially meets the criteria as we understand them.

The issue of respcnse time testing, however, has not been addressed in the SER review.

Proposed Action:* Compare present program with criteria in lead topic SER and doc~ment in an assessment. Argue that in a plant of BRP's age adequate response time has been demonstrated during operation.

Schedule: May 30, 1981

8.Section XV Transie*nts Status: Some wor~: has been done using the RErRJN code. The project was droppe:d 1 1/2 years ago due to post TMI worlt load.

Proposed Action: Reopen project and augmenting existing personnel with consultants ~.ttempt to complete transients on the May 18, 1981 list and perform 1.he minimum methods qualificat~ on study by June 30, 1981. Except :for 3 topics which involve reactor physics and radioactivity releases all Section XV topics on the list will be submitted together because of the commonality of the modeling.

Should sane to:pic~: become available earlier they will be submitted.

It is. anticipated that one meeting with NRC will be required before June l:>, 1981 to c1.iscuss the methodology and as~ timptions being

• eII1Ployed. * *

9. Big Rock has a backlong of NRC completed topics for review and comment.

We propose to remove this backlog and be up to date by April 30, 1981.

10. We have several S*!ts of questions from NRC on Bl:P topics. We propose to complete these answer.<> and be up to date by April 30, 1981, except for questions on topics we have agr1'!ed to handle outselves in 1 tl1rough 8 above. *Additionally, NRC proposes to compl*~te 2 more BRP topics by June '.iO, 1981, we will also supper~

this NRC effort by an.~wering the necessary question:;.

• In the above schedule there is no time for second aud third round questions. If quality and schedule a.re to be maintained management on both sides must.agree to and constantly enforc*~ ways of communication that are significantly better than those typical in the :?ast. Specifically both sides must:

l. Avoid artificial positioning quE1.stions and ll.nswers.

2. Questions and answers must be clearly wordecl, mean what the words say and be ;iiri:led at 'the engineering heart of *the matter.

4.

3. Frequently several levels of approval are required on both sides. The management of both sides Will have to develop timely ways of obtaining these including reserving time, pre-publishing when those times are and not subordinating SEP in their priorities.

4. NRC should attempt to refrain from raising new short schedule issues for the te1m of this agreenent so that it has a chance to work:. The shielding of SEP Licensees and folding into SEP of new issues that was p1omised by NRC at the *inception of SEP has not happened. Perhap~ for this short time period a renewed effort could be made.

ATI'N.

SUBJECT MESSAGE.

SIGNED IH~l'LY TO .

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