ML18057A758
| ML18057A758 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/22/1991 |
| From: | Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| NUDOCS 9103040011 | |
| Download: ML18057A758 (3) | |
Text
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I Docket No. 50-255 Consumers Power Company ATTN:
Gerald B. Slade General Manager Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Gentlemen:
-0,_;<l FEB 2 2 1991 This is to acknowledge receipt of the following revisions to the Palisades Nuclear Plant Site Emergency Plan:
Revision 5, MRN-EP-90-001, to Section 6 dated August 24, 1990; Revision 10, MRN-EP-90-005, to Section 4 dated November 2, 1990; Revision 9 to Section 5 dated September 18, 1990; Revision 9, MRN-EP-90-004, to Section 5 dated October 12, 1990; Revision 9, MRN-EP-90-006, to Section 5 dated December 18, 1990; Revision 5, MRN-EP-90-007, to Section 6 dated December 19, 1990; Revision 6, MRN-EP-90-008, to Section 7 dated December 19, 1990; Revision 9, MRN-EP-91-001, to Section 8 dated January 14, 1991.
We have reviewed these changes to the Palisades Nuclear Plant Site Emergency Plan and made the following determinations:
Revision 5, MRN-EP-90-001, to Section 6 was determined to be consistent with the requirements of 10 CFR 50.54(q) and did not decrease the effectiveness of the emergency plan. Therefore, the changes implemented with this revision are acceptable.
Revision 10, MRN-EP-90-005, to Section 4 was determined to be consistent with the requirements of 10 CFR 50.54(q) and did not decrease the effectiveness of the emergency plan. Therefore, the changes implemented with this revision are acceptable. While reviewing the changes to Section 4 it was noted that the actions identified by numbers 1 through 36 in Table 4.3 are not explained in your emergency plan, nor is a reference provided to where these actions are explained.
You should consider adding an explanation or reference to clearly identify what these actions are. The reviewer also noted that in accordance with Step 4.1.c of your emergency implementing procedure EI-3, Revision 11, action number 36 could be added to each Unusual Event classification. These observations are provided for your consideration.
9103040011 910222 PDR ADOCK 05000255 F
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Consumers Power Company 2
FEB 2 2 1991 Revision 9 to Section 5 was considered to be a potential downgrading of your response capability. The level of on shift staffing addressed by this revision appears to be in conflict with existing NRC guidance.
As you are aware, we approved interim implementation of this change during the Steam Generator replacement project while the reactor was defueled (see letter dated September 21, 1990).
After a through review of Revision 9 to Section 5, we have determined that this revision does in fact downgrade your emergency response capabilities. However, the impact of the changes were determined to be minimal and therefore are acceptable. During the evaluation of this revision it was determined that you do not currently verify on a regular basis the actual response time capability for personnel on your callout roster. The very basis for your own justification of this change is your ability to call in emergency responders in a timely manner.
We consider it prudent that you test and demonstrate your ability to meet your response time commitments.
We would expect you to perform such a test in the near future, and to establish a programmatic requirement to verify on a regular basis that response time commitments continue to be achievable.
Revision 9, MRN-EP-90-004, to Section 5 was a change implemented by you to reflect our interim approval of Revision 9 to Section 5.
As such, this change was acceptable during the interim period while the reactor was defueled.
Because the reactor is no longer defueled, this interim change is no longer applicable.
Revision 9, MRN-EP-90-006, to Section 7; Revision 5, MRN-EP-90-007, to Section 6; Revision 6, MRN-EP-90-008, to Section 7; and Revision 9, MRN-EP-91-001, to Section 8 were determined to be consistent with the requirements of 10 CFR 50.54(q) and did not decrease the effectiveness of the emergency plan. Therefore, the changes implemented with these revisions are acceptable.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter will be placed in the NRC's Public Document Room.
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Consumers Power Company FEB 2 2 1991 3
Should you have any questions regarding this letter, please contact Mr. Daniel M. Barss of my staff at (708) 790-5298.
Sincerely,
~~~
cc:
David P. Hoffman, Vice President Nuclear Operations Mr. D. J. VandeWalle, Safety and Licensing Director DCD/DCB (RIDS)
OC/LFDCB Resident Inspector, RIII James R. Padgett, Michigan Public Service Commission Michigan Department of Public Health Palisades, LPM, NRR D. Bement, FEMA, RV R. LaFreniere, RIII L. Robert Greger, Chief Reactor Programs Branch
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