ML18052B405

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Advises That NRC Position Re Util Justifications for Deviation from Guidance of Reg Guide 1.97 Not Received & Requests That Response to NRC Be Extended to 45 Days After Receipt of Clarification of NRC Position
ML18052B405
Person / Time
Site: Palisades Entergy icon.png
Issue date: 12/04/1987
From: Berry K
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
RTR-REGGD-01.097, RTR-REGGD-1.097 GL-82-33, NUDOCS 8712090161
Download: ML18052B405 (2)


Text

consumers Power POWERING MICHIGAN'S PROGRESS General Offices:

1945 West Parriall Road, Jackson, M.1 49201 * (517) 788-1636 December 4, 1987 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

Kenneth W Berry Director Nuclear Licensing RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION -

CONFORMANCE TO REGULATORY GUIDE 1. 97 By a letter dated October 20, 1987, the NRC provided the staff's Safety Evaluation Report (SER) on Consumers Power Company's response to Generic Letter 82-33, Conformance to Regulatory Guide 1. 97.

A copy of t.he Technical Evaluation Report, prepared by EG&G, Idaho Inc. was also attached.

The SER stated that Consumers Power Company conforms to or had acceptably justified deviations from the guidance of R. G. 1.97 for each post-accident monitoring variable with the exception of the variables for accumulator tank level and pressure, quench tank temperature and pressure, steam generator pressure, and component cooling water flow to the ESF system.

The SER noted. that the acceptability of instrumentation for accumulator tank level and pressure was the subject of a generic review by the NRC staff and would remain open until t~e completion of that review.

However, for the remaining items for which the staff found that Consumers Power Company had not provided adequate justification, the SER requested that Consumers Power Company respond to the staff positions within 45 days.

The SER also noted, "An appropriate implementation schedule will be developed by the project manager via discussion with the licensee."

During a November 10, 1987 conference call between Consumers Power Company staff, the NRC Palisades Project Manager and other NRC staff personnel, Consumers Power Company noted that the SER merely stated that the Reg. Guide 1.97 variables for quench tank temperature and pressure, steam generator pressure, and component cooling water flow, "provided information that is valuable to an operator for monitoring proper equipment operation", and that Consumers Power Company should provide the necessary instrumentation to monitor these variables.

Neither the SER nor the TER addressed ~he adequacy of Consumers Power Company's justifications for not providing instrumentation to monitor these variables.

Consumers Power Company's technical staff was unable to determine the intended use of these expanded ranges.

OC1287-0030S-NL01

  • '*I.

? Nuclear Regulatory Palisades Plant Conformance to Reg December 4, 1987

  • Cominission 2

Guide 1.97 Consumers Power Company requested that the NRC staff provide clarification with regard to the rejection of our justifications.

Because the information requested by Consumers Power Company was not immediately available to the NRC staff, both the NRC and Consumers Power Company agreed, that the information requested would be collected by the NRC staff and made available to Consumers Power Company prior to the submittal date requested by the October 20, 1987 letter. It was further agreed that should the information requested by Consumers Power Company not be available prior to December 4, 1987, Consumers -

Power Company would request an extension of time to prepare the submittal.

Consumers Power Company has not received the clarification of the NRC staff position regarding our justifications, therefore, Consumers Power Company requests that our response to the October 20, 1987 letter be extended to 45 days after the receipt of the clarification of the NRC staff's position.

At that time, Consumers Power Company will respond to the NRC positions for quench tank temperature and pressure, steam generator level, and component cooling water flow.

An appropriate implementation schedule will also be developed through discussions with the NRC Palisades Project Manager.

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Director, Nuclear Licensing CC Administrator, Region III, NRC NRC Resident Inspector - Palisades OC1287-0030S-NL01