ML18057A915
| ML18057A915 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/13/1991 |
| From: | Brian Holian Office of Nuclear Reactor Regulation |
| To: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| TAC-79933, NUDOCS 9105220276 | |
| Download: ML18057A915 (4) | |
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+O Docket No. 50-255 Mr. Gerald B. Slade Plant General Manager Palisades Plant UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTO'N, D. C. 2'0555
. r.tiy 13, 1991 27780 Blue Star Memorial Highway Covert, Michigan 49043
Dear Mr. Slade:
SUBJECT:
PALISADES PLANT - INSTRUMENT AND CONTROLS TECHNICAL SPECIFICATION CHANGE (TAC NO. 79933)
By letter dated February 27, 1991, Consumers Power Company requested numerous changes to Section 3.17 of the Technical Specifications. The proposed changes would:
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0 expand the Applicability section of TS 3.17, clarify operability and bypass requirements of the associated instrumentation, and expand the Basis statements for the Reactor Protective System.
Some of the changes were submitted to resolve inconsistencies described in Licensee Event Report (LER)91-001.
The other changes were proposed in order to clarify the operating requirements for the Instrument and Control systems, which include Reactor Protective System (RPS) and Engineered Safety Features Actuation System (ESFAS) instrumentation.
This letter documents conversations I have had with your Licensing staff on April 17, May 2, and May 6, 1991 regarding this license application.
In summary, Sections II and III of your submittal (Discussion and Analysis of No Significant Hazards Consideration), do not contain adequate explanation and/or justification to facilitate a timely review.
One example which supports this determination is that your letter does not adequately describe the change in applicability for the instrumentation in Table 3.17.1-4. Additionally, this change in applicability is not adequately addressed in your analysis of no*
significant hazards consideration. Several additional examples were provided
.to your Licensing staff, who committed to supersede your February 27, 19~1 license application with a revised submittal.
There is one additional, related matter that was discussed with your staff on May,6, 1991.
The Palisades Senior Resident Inspector and myself have been re~je~ing your Technical Specifications and related licensing information to determine the acceptability of your practice of allowing long term operation of the *four channel Reactor Protective System and Engir1e~.red Safety Features Actuation System in a 2 out of 3 logic configuration (e~g., NI-005 was in bypass for a number of months last refueling cycle)
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Mly 13, 1991 On June 25, 1982 you submitted a Technical Specification change request which limited the length of time one channel of RPS and/or ESFAS could remain in the "bypass" mode.
Coincidentally, this license application also submitted a clarification to the instrument bypass conditions described in LER 91-001.
You requested to withdraw this license application by letter dated January 24, 1989, which committed to maintain the technical requirements of withdrawn Technical Specifications active through administrative controls until approval was obtained for Restructured Technical Specifications. The NRC staff requests that you evaluate your commitments as stated in the January 24, 1989 letter, ensuring that your administrative procedures for maintaining the requirements of the withdrawn technical specifications are being maintained.
We request that your discuss the results of this evaluation with myself and the Senior Resident Inspector.
Per my discussion with your Licensing staff it is my understanding that your resubmittal of the February 29, 1991 license application will address the RPS/ESFAS continuous bypass issue. The staff recognizes the need to clarify these instrument specifications and will support a timely review as requested in your original submittal.
cc:
See next page Sincerely, Brian E. Holian, Project Manager Project Directorate III-1 Division of Reactor Projects III/IV/V Office of N~clear Reacto~ Regulation
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.. Miy 13, 1991 On June 25, 1982 you submitted a Technical Specification change request which limited the length of time one channel of RPS and/or ESFAS could remain in the "bypass" mode.
Coincidentally, this license application also submitted a clarification to the instrument bypass conditions described in LER 91-001.
You requested to withdraw this license application by letter dated January 24, 1989, which committed to maintain the technical requirements of withdrawn Technical Specifications active through administrative controls until approval was obtained for Restructured Technical Specifications.
The NRC staff requests that you evaluate your commitments as stated in the January 24, 1989 letter, ensuring that your administrative procedures for maintaining the requirements of the withdrawn technical specifications are being maintained.
We request that your di_scuss the results of this evaluation with myself and the Senior Resident Inspector.
Per my discussion.with your Licensing staff it is my understanding that your resubmittal of the February 29, 1991 license application will address the RPS/ESFAS continuous bypass issue. The staff recognizes the need to clarify these instrument specifications and will support a timely review as requested in your original submittal.
cc: See next page Sincerely, priginal signed by Brian f-blian Brian E. Holian, Project Manager Project Directorate III-1 Division of.Reactor Projects III/IV/V Office of Nuclear Reactor Regulation DISTRIBUTION c--*-oockEf FILE ---r *
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Mr. Gerald B. Slade Consumers Power Company 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. Nucl~ar Regulatory Commission
- 799 Roosevtlt Road Glen Ellyn, Illinois 60137 Jerry Sarno Township Supervisor Covert Township 36197 M-140 Highway C.overt, 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 Mt::morial Hwy.
Cov~rt, Michigan 49043 Palisades Plant Nuclear Facilities and Environmental Monitoring Section Office Division of Radiological Health P.O. Box 30035 Lansing, Michigan 48.9_09 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 Roy W. Jones Manager, Strategic Program Development Westinghouse Electric Corporation 4350 Northern Pike Monroeville, Pennsylvania 15146