ML18051A592

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Requests Extension to Respond to Generic Ltr 83-28 Re Required Action Based on Generic Implications of Salem ATWS Events. Extension Needed Due to Scheduled Refueling Outage Which Began 830813
ML18051A592
Person / Time
Site: Palisades Entergy icon.png
Issue date: 09/06/1983
From: Vandewalle D
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To: Eisenhult D
Office of Nuclear Reactor Regulation
References
GL-83-28, NUDOCS 8309120016
Download: ML18051A592 (3)


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consumers Power company General Offices: 1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-0550 September 6, 1983 Darrell G Eisenhut, Director Division of Licensing Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50~255 - LICENSE DPR PALISADES PLANT - REQUEST FOR EXTENSION OF TIME TO RESPOND TO GENERIC LETTER 83-28 NRC Generic Letter 83-28 and its enclosure, "Required Action Based on Generic Implications of Salem ATWS Events," dated July 8, 1983 requires all licensees to furnish within 120 days a status report of current conformance with the positions contained in by the Generic Letter.

In addition, all licensees are to provide a plan and schedule for improvements needed to achieve conformance for those items that are found to not be in conformance with the positions stated in Generic Letter 83-28.

Generic Letter 83-28 also provides for licensees to request, within 60 days of the date of the letter, time extensions for submittal of the required information.

Consumers Power Company has examined the actions and information required by Generic Letter 83-28 and has determined that the required response cannot be provided on the schedule requested for the following issues:

Issue 1.1 - Post-Trip Review (Program Description and Procedure)

Issue 1.2 - Post-Trip Review - Data and Information Capability Issue 2.1 - Equipment Classification - Program Verification Issue 2.2 - Equipment Classification, Items 1.2 through 1.6 Issue 3. 1 - Post-Maintenance Testing (Reactor Trip System Components)

Issue 3.2 - Post-Maintenance Testing (All Other Safety-Related Modifications)

Issue 4.1 - Reactor Trip System Reliability (Vendor-Related Modifica-tions) 8309120016 830906 PDR ADOCK 05000255 P

PDR OC0983-0003A-NL02

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  • Darrell G Eisenhut, Director Palisades Plant REQUEST FOR EXTENSION OF TIME TO RESPOND TO GL 83-28 September 6, 1983 2

Issue 4.2.- Reactor Trip System Reliability (~reventative Maintenance and Surveillance Program for Reactor Trip Breakers), Items 3 and 4 (It is noted that issues 4.1 and 4.2 may not be applicable to the Palisades Plant because reactor trip breakers are not employed in the reactor trip system)*'

Issue 4.5 - Reactor Trip System Reliability (System Functional Testing)

Additional time is required due to the fact that the Palisades Plant began a scheduled refueling outage on August 13, 1983.

This refueling outage includes several projects and programs critical to the continued safe operation of the Palisades Plant including the 10-year Inservice Inspection (mechanized reactor vessel examinations, core barrel removal and associated examinations),

completion of the Systematic Evaluation Program modifications as previously committed to in the Integrated Assessment. In.addition, other significant activities scheduled for this outage are: installation of a third auxilliary feedwater pump, completion of the control room habitability modifications and upgrades, remedying the leaking safety bottle check valves, sipping of a majority of the nuclear fuel, steam generator inspections, major turbine inspections and main electrical generator availability improvement modif ica-tions.

All plant personnel are fully committed to supporting this outage and are therefore unavailable to perform activities required to adequately address the issues raised by Generic Letter 83-28.

In addition to the issues above, Consumers Power Company requests an extension for th~ Vendor Interface portion of Issues 2.1 and 2.2. *Issues 2.1 and 2.2 both require that licensees establish a vendor interface program to assure that vendor information related to the reactor trip system components specifically and all other safety-related components more generally is adequately controlled and reflected in plant programs and procedures.

Consumers Power Company is actively involved in supporting the INPO sponsored Nuclear Utility Task Action Committee (NUTAC) establish to address issue 2.2 for all safety-related components.

The NUTAC has determined that it can complete its efforts by February 1984. It is our intent to use the program guidance developed by the NUTAC as the basis for Consumers Power Company's vendor interface program.

A description of our vendor interface program and an implementation plan will be submitted following completion of the NUTAC's efforts.

Consumers Power Company will provide, as part of 120 day response required by the Generic letter, a report describing existing programs for*equipment classification for the reactor trip system and all other safety-related components (Issues 2.1 and 2.2.1.1) and for our preventative maintenance and surveillance program for the reactor trip breakers/devices (Issues 4.2.1 and 4.2.2).

Consumers Power Company will also provide at that time a detailed OC0983-0003A-NL02

  • Darrell G Eisenhut, Director Palisades Plant REQUEST FOR EXTENSION OF TIME TO RESPOND TO GL 83-28 September 6, 1983 program plan and schedule for addressing the remaining issues and a status report of our efforts on the vendor interface issue.

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Nuclear Licensing Administrator CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades OC0983-0003A-NL02 3