ML18057B364
| ML18057B364 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/05/1991 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-04, GL-89-4, NUDOCS 9111180161 | |
| Download: ML18057B364 (2) | |
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- MICHlliAN*s PROliRESS Palisades Nuclear Plant:
27780 Blue Star Memorial Highway, Covert. Ml 49043 November 5, 1991 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 GB Slade General Manager DOCKET 50-255 - LICENSE DPR PALISADES PLANT - RESPONSE TO GENERIC LETTER 89-04, "GUIDANCE ON DEVELOPING ACCEPTABLE INSERVICE TESTING PROGRAMS" -
CHANGE OF COMMITMENT The purpose of this letter is to inform the NRC of Consumers Power Company's intention to change a commitment previously conveyed to the NRC regarding the completion of what we had termed "insignificant procedure changes" to the Palisades Inservice Pump and Valve Test Program.
In our response, dated October 2, 1989, we stated that, because of the volume of effort required for revising procedures, we would not be completing the programmatic upgrade within the time table suggested in the generic letter.
Furthermore, we divided the procedure revisions into two categories; those which were required by expanded test scope or changed methodology (significant) and those which were not necessitated by change in test scope or methodology (insignificant).
In our response we committed to complete the insignificant procedure changes by October 9, 1991, in conjunction with each procedures biennial review date.
Palisades ha~ completed "insignificant procedure changes" for one hundred and ten (110) of one hundred and thirty-eight (138) valves. Twenty-two of the remaining twenty-eight valves are in the Chemical and Volume Control System (CVCS) and were not previously tested by the program.
Originally, we believed that testing of the eves valves could be incorporated into existing procedures and were therefore categorized as "insignificant procedure changes." However, we have since determined that the existing procedures would not adequately test the valves. Therefore, the twenty-two CVCS valves will be included in a new surveillance procedure which is currently being developed.
The six remaining valves affect four procedures.
Revisions to these procedures are currently in progress.
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A CMS ENERGY COMPANY
~-Based on the information presented, it is necessary to extend our previous commitment pertaining to the "insignificant procedure changes" to allow ample time to develop the new procedure and to develop efficient procedure changes for the remaining valves.
We believe that the new procedure and the remaining procedure revisions will be completed by December 31, 1991.
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Gerald B Slade General Manager CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades