ML18052A846
| ML18052A846 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/28/1987 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CAL, NUDOCS 8702050370 | |
| Download: ML18052A846 (3) | |
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consumers Power POWERING MICHIGAN'S PROGRESS General Offices:
1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-1636 January 28, 1987 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO NRC ADDITIONAL INFORMATION REQUEST Kenneth W Berry Director Nuclear licensing NRC letter dated December 23, 1986, requested additional information with regard to Consumers Power Company's December 1, 1986 response to the NRC's Confirmatory Action Letter and Information Request Pursuant to 10CFR50.54(f).
This requested information falls into the following three broad areas where NRC questions still exist:
- 1.
The adequacy of the test program to assure that planned tests will demonstrate that systems function as designed.
- 2.
The basis for deferral of certain modifications and program implemen-tation beyond the plant restart *
- 3.
The specific technical basis for some of the requested Technical Specification Change Requests.
Specific qqestions to further clarify and address these areas were included in the NRC information request.
Response to the questions are individually I
aqdressed in the attachments to this letter.
- 1*o::s:: ;.
' l'O Attachments 1-3 respond to the first three questions specified in the
\\.~g-,, D~cember 23, 1986 letter. provides a description and schedule of
'.~!l~,}1 those corrective action programs that will be continuing through or that will
- ru *'*": be initiated following our restart.
These programs are designed to assure
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P,roper resolution of futui:e* emergent issues, to verify that the existing plant
~.,mo...~ hardware is operational, the material condition is maintained, and is
~,.{\\'.~:-;\\** ¢onfigured and tested to assure the design bases are met.
The programs
~.*~~, described in Attachment 1 are considered additions to those corrective action programs that remain in place as specified in our QA Topical Report.
The programs are identified in Attachment lA as follows:
- 1.
Configuration Management Program - This program is intended to consolidate the design basis in a format, which will be easier to OC0187-0007-NL~.. ~~.,..._, f\\~*. 1i\\~'M'('\\""" ~rJd..- 'lO *. ~LP
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Nuclear Regulatory Commission Palisades Plant Response to NRC Request for Add'l Information January 28, 1987 2
access, use, verify and*validate that the plant conforms to the functional design requir~ments, and that the related plant documenta-tion is correct.
The program responds to any final concern that may exist regarding our "plans for performing a detailed design review of systems important to safety."
- 2.
Valve Maintenance Program - This program provides added assurance that valves and operators will continue to perform their functions, failures are minimized, and repairs are done promptly and properly.
- 3.
INPO Accreditation - This program will lead to accreditation of our Electrical and Mechanical Maintenance Training Program.
A System Engineering Training Program also is under development.
- 4.
Improved Preventive Maintenance - Full implementation should lead to a net reduction in corrective maintenance and therefore should yield an improvement in plant availability, system reliability and a reduction in safety system challenges.
- 5.
Test Program - The objective of our improved Test Program is to assure proper operation of important systems in normal operating and post-accident modes.
The program addresses Technical Specification Surveillance Tests, Augmented Surveillance Tests and Post.Maintenance.
Testing.
- 6.
Five Year Plan - Our Five Year Plan addresses major modification projects and maintenance activities for improving long-term availa-bility and reliability.
The plan provides for capturing and prior-itizing emergent issues and incorporating them into the schedule.
Attachment lB addresses the specific issues and results of the Material Condition Task Force (MCTF).
It responds to the NRC request specified in the first question to identify all'MCTF items and significant emergent issues. contains a revised System Functional Evaluation (SFE).
The original SFE was included as Attachment 3 to our December 1, 1986 response.
This revised SFE has been expanded to include additional source documents and system input from the results of the Material Condition Task Force Report (MCTF) and System Emergency Operating Procedures (EOP's).
The criteria also has been increased to include additional parameters, such as Heat Exchanger flows and temperatures. summarizes our Test Program.
Summary descriptions for thirty-three plant systems are provided.
A description of our overall test program as well as our specific pump test program is included. responds to an additional NRC concern specified in the December 23, 1986 letter.
The letter requests a description of our "planned approach to resolve any future identified instances of plant system failure to meet design-basis requirements."
We believe the plans and programs described in response to the previous three questions provide assurance that Consumers OC0187-0007-NL02
Nuclear Regulatory Commission Palisades Plant Response to NRC Request for Add'l Information January 28, 1987 Power Company can deal effectively with future emergency issues.
However, describes our review process and administrative controls that we have in place as part of our normal administrative systems to assure appro-priate corrective actions are. identified and accomplished.
3 responds to the questions contained in Enclosure 1 to the December 23, 1986 NRC letter.
This attachment is incomplete pending further tests and analysis scheduled to be completed prior to startup.
The results of the tests and analysis will be provided as soon as they are available.
The information provided in this response to the individual comments and questions will support the Palisades Plant Readiness Inspection.
The Technical Specifi-cation Changes Requests we have submitted in support of plant restart are supported by our response contained in Attachment 5 plus the additional tests and analysis to be submitted upon availability.
Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, NRC NRC Resident Inspector - Palisades Attachments OC0187-0007-NL02