ML18054A236
| ML18054A236 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/19/1988 |
| From: | Kuemin J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| GL-88-02, GL-88-2, NUDOCS 8802230122 | |
| Download: ML18054A236 (2) | |
Text
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consumers Power POWERING MICHIGAN'S PROGRESS General Offices: 1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-0550 February 19, 1988 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
INTEGRATED SAFETY ASSESSMENT PROGRAM II (ISAP II) GENERIC LETTER 88-02
RESPONSE
In accordance with the NRC request in Generic Letter 88-02 dated January 20, 1988, we are providing the attached responses.
Although we support the ISAP effort, we have observed the implementation of other similar programs and have identified concerns with the process.
Typically, NRC Regional issues, which may be ranked as having low safety significance in a plant PRA model, require immediate resolution and this has caused delays in resolving other safety significant issues. If Palisades were to participate in the proposed process, we would seek assurances that the process would be universally applied to all regulatory and self-initiated issues.
However, we are interested in seeking additional information and meeting with the NRC to discuss the status of the Palisades Plant PRA and its applicability to the ISAP process.
~~
rKuemin Staff Licensing Engineer CC Administrator, Region III, NRC NRC Resident Inspector - Palisades Attachments OC0288-0053-NL04
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,FACILITY: Palisades Plant
.tr~iLi~Y7 Consumers Power Company CONTACT:
J J Fremeau, (517) 788-7041 RESPONSE TO GENERIC LETTER 88-02
- 1.
Would you be interested in participating in ISAP II? If so, in what time frame?
Palisades is interested in learning more about the ISAP II process before making a decision about participating.
We would not desire to participate before January 1989.
- 2.
Do you believe that an industry/NRG seminar consisting of a brief discus-sion by NRC followed by a question and answer period would be beneficial prior to making a decision?
Yes, Palisades would be interested in participating in such a seminar prior to making a decision concerning participation. *
- 3.
Would you be interested in a one-on-one meeting with the NRC to discuss your particular facility or facilities?
Yes, Palisades would be interested in such a meeting.
We would like to discuss the status of our Plant specific PRA and its applicability to the ISAP II process.
- 4. If you remain undecided regarding participating, what information do you need in order to make a decision?
Refer to response to Question 5.
- 5.
Do you have any potential concerns about participating in ISAP II?
Our concerns relate primarily to our observations of other similar programs.
The process appears to work very well for those issues included within the program scope.
However, regulatory issues that are pursued by the NRC Regional offices, which are not included in the program scope, generally require immediate resolution.
While these issues may be of relatively lower safety significance than program scope issues, when ranked by a plant PRA model, resources are often applied to these Regional issues at the expense of program scope issues.
Before Palisades participates, we would seek assurances that the process will be universally applied to all present and future issues, and that both regulatory, including Region III activities, and self~initiated issues, would be ranked based on their relative safety significance. It is understood such an agreement is not possible without active NRC participation in establishing safety significance.
We are also concerned that the schedule referenced in the Generic Letter is overly optimistic.
We would hope that NRC can dedicate a team of reviewers to each participating licensee in order to facilitate and expedite the review process and ensure that the knowledge acquired during the review period is retained long term.
- 6.
Do you have any suggestions for program improvements or changes?
See response to Question 5.
MI0288-0006A-NA01-NL04