ML18057A517
| ML18057A517 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/03/1990 |
| From: | Pierson R Office of Nuclear Reactor Regulation |
| To: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| REF-GTECI-A-47, REF-GTECI-SY, TASK-A-47, TASK-OR GL-89-19, TAC-74974, NUDOCS 9010160080 | |
| Download: ML18057A517 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, 0. C. 20555 Docket No. 50-255 Mr. Gerald B. Slade Plant General Manager Palisades Plant 27780 Blue Star Memorial Highway Covert, Michigan 49043
Dear Mr. Slade:
October 3, 1990
SUBJECT:
CONSUMERS POWER COMPANY RESPONSE TO GENERIC LETTER 89-19 REGARDING SAFETY IMPLICATIONS OF CONTROL SYSTEMS IN LWR NUCLEAR POWER PLANTS (TAC NO. 74974)
By letter dated March 20, 1990, Consumers Power Company responded to Generic Letter 89-19, "Request for Action Related to Resolution of Unresolved Safety Issue A-47, 'Safety Implication of Control Systems in LWR Nuclear Power Plants' pursuant to 10 CFR 50.54(f).
11 In your letter, you stated that more detailed design studies and safety assessments must be completed before a decision can be n1ade regarding implementation of a steam generator overfill protection system (SGOPS) at Palisades.
This conclusion is based upon Palisades' specific evaluation of the probabilistic risk assessment performed, whereby you conclude that steam generator overfill would not be a dominant contributor to the overall risk of plant operation. Moreover, your letter stated that the appropriate framework to evaluate steam generator overfill events and the safety impact of implementing a steam generator overfill protection system is the Individual Plant Examination (IPE).
We do not agree with your position that a more detailed design and safety assessment using the IPE is an appropriate framework to continue the eva hi at ion of steam generator overfi 11 safety impacts.
Previous NRC analyses performed to evaluate alternatives to resolve USI A-47, "Safety Implications of Control Systems", provided insight with respect to the safety benefits,.
impacts, and costs of modifications for overfill protection. Plant specific differences were considered in the development of NUREG-1218, "Regulatory Analysis for Resolution of USI A-47, 11 and in the preparation of the Generic Letter 89-19.
You had ample opportunity to provide comments on this issue when the Federal Register notice was published in May 1989.
Combustion Engineering (CE) plants, as a class, do not provide steam generator overfill protection. Overfill events have occurred at CE plants and other light water reactors.
The consequences resulting from such events depend largely on piping system integrity, are difficult to model accurately, and have large uncertainties. It is for these reasons that IPE evaluation will not add significant information to close this issue. Further, we believe that the potential negative impacts of inadvertent isolation of feedwater can be made insignificant through sound design, with reliable equipment, and with implementation of a reasonable test strategy.
Mr. Gerald In regard to the implementation schedule for Palisades the staff is of the opinion that implementation of the SGOPS prior to the startup following the Cycle 10 refueling outage, which commences about February 1, 1992, is feasible.
~le request your response within 45 days from receipt of this letter.
cc:
See next page Sincerely, Robert C. Pierson, Director Project Directorate III-1 Division of Reactor Projects - III, IV, V & Special Projects Office of Nuclear Reactor Regulation
Mr. Gerald B. Slade cc:
M. I. Miller, Esquire Sidley & Austin 54th Floor One First National Plaza Chicago, Illinois 60603 Mr. Thomas A. McNish, Secretary Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Jerry Sarno Township Supervisor Covert Township 36197 M-140 Highway Covert, Michigan 49043 Office of the Governor Room 1 - Capitol Building Lansing, Michigan 48913 Mr. David J. Vandewalle Director, Safety and Licensing Palisades Plant 27780 Blue Star Memorial Hwy.
Covert, Michigan 49043 Resident Inspector c/o U.S. Nuclear Regulatory Commission Palisades Plant 27782 Blue Star Memorial Hwy.
Covert, Michigan 49043 PALISADES Nuclear Facilities and Environmental Monitoring Section Office Division of Radiological Health P.O. Box 30035 Lansing, Michigan 48909 Gerald Charnoff, P.C.
Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W.
Washington, D.C.
20037 Mr. David L. Brannen Vice President Palisades Generating Plant c/o Bechtel Power Corporation 15740 Shady Grove Road Gaithersburg, Maryland 20877
Mr. Gerald In regard to the implementation schedule for Palisades the staff is of the opinior1 that implementation of the SGOPS prior to the startup following the Cycle 10 refueling outage, which commences about February 1, 1992, is feasible.
We request your response within 45 days from receipt of this letter.
cc:
See next page DISTRIBUTION DOCKET nn:-
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Mr. Gerald In regard to the implementation schedule for Palisades the staff is of the opinion that implementation of the SGOPS prior to the startup following the Cycle 10 refueling outage, which commences about February 1, 1992, is feasible.
We request your response within 45 days from receipt of this letter.
cc:
See next page DISTRIBUTION DOCKET FILE-NRC & LOCAL PDRs PD31 RIF DCRUTCHFIELD JZWOLINSKI RPIERSON SVARGA SMEADOR OGC EJORDAN ACRS (10)
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