ML18057B442
| ML18057B442 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/20/1991 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-88-20, NUDOCS 9201030258 | |
| Download: ML18057B442 (3) | |
Text
consumers Power POWERING MICHlliAN'S PIUllilU.SS Palisade& Nuclear Plant: 27780 Slue Stir Mert'IQl'ial HiQhW8y, Covert. Ml 49043 December 20, 1991 Nuclear Regulatory Co1m1ission Document Control Desk Washington, DC 20555 PAGE.002 G 8 Sl*de
~ru:rol Mgnage, DOCKET 50-255 - LICENSE DPR PALISADES PLANT - RESPONSE TO GENERIC LETTER 88-20, SUPPLEMENT 4, INDIVIDUAL PLANT EXAMINATION OF EXTERNAL EVENTS FOR SEVERE ACCIDENT VULNERABILITIES Generic Letter 88-20, Supplement 4, requests licensees to describe their proposed programs for completing the Individual Plant Examination of External Events for Severe Accident Vulnerabilities (IPEEEs) by December 26, 1991.
Also, this generic letter supplement encourages coordination of the seismic portion of the IPEEE with Unresolved Safety Issue (USI) A-46, ".*. so that the objectives of both activities may be accomplished with a single walkdown effort.~ As stated in NRC SECY-91-102, the procedures for the seismic walkdown portion of this program are "... one of the most important ingredients in the seismic IPEEE, [and] are similar to those that will be used in the implementation of Unresolved Safety Issue (USI) A-46 *..* "
Consumers Power Company agrees with NRC staff that the walkdowns of each program should be combined into a single walkdown.
Palisades Plant is a USI A-46 plant and a member of the Seismic Qualification Utility Group (SQUG).
Because of the similarities of the two programs, we intend to conduct seismic IPEEE and A-46 walkdown$ at the same time to avoid repetition of-essentially the same work within a short time span. However, the anticipated final Supplemental Safety Evaluation Report (SSER} on the SQUG's Generic Implementation Procedure (GIP) for resolution of USI A-46 has not been made available in sufficient time to permit finalization of a coordinated plan and schedule for the seismic portion of the IPEEE in this response.
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PAGE.003 CPCo's tentative plans for the seismic IPEEE program are described later in this letter. However, because of the delay in issuance of the GIP SSER, Consumers Power Company is not able to submit a firm schedule to complete the seismic portion of the IPEEE until after receipt and review of the SSER.
We will submit our final schedule within 120 days following receipt of the SSER.
Fo 11 owing rev1 ew of the SSER Consumers Power Company may modify its program for condu,ting the seismic IPEEE depending on the content of the SSER and resolution of open issues.
2 For the Palisades Plantt Consumers Power Company will develop a seismic PRA and utilize the FIVE methodology for fires to fulfill the requirements of Generic Letter 88-20, Supplement 4.
The seismic risk assessment will be coordinated with the actions taken to resolve USI A-46, hVerification of Seismic Adequacy of Equipment in Operating Plants,* using the SQUG Generic Implementation Procedure (GIP) when approved for use.
The risk assessment will be completed in a manner consistent with the guidance of NUREG/CR-2300, "PRA Procedures Guide,* the guidance provided in the generic letter (including enhancements identified in Appendix 1) and NUREG-1407, "Procedural and Submittal Guidance for the Individual P1ant Examination of External Events (IPEEE} for Severe Accident Vulnerabilities." The fire analysis will be completed using the FIVE.methodology to analyze fire propagation instead of the COHPBRN code.
The o1her external events will be evaluated consistent with the screenjng approach discussed in the generic letter.
The plant model developed in the Individual Plant Examination (IPE) process will be used as the basis for conducting the seismic risk assessment and fire analysis.
To the extent pos~ible internal resources will be utilized in conducting the assessment or as participants to acquire the necessary information and experience to maintain the analysis for possible future use.
Regarding other external evants programs, resolution of the Eastern United States Seismicity (The Charleston Earthquake) issue is assumed to be accomplished via completion of the IPEEE.
The reliability of the decay heat removal system given an external event wil 1 also be addressed as part of the IPEEE.
USI A-17, "Systems Interactions in Nuclear Power Plants,* and USI A-40, *seismic Design Criteria, A Short-Tenn Program,* are considered resolved by completion of the A-46 process.
The IPEEE process for the Palisades Plant will-be completed within a time frame ecn$iSt~t with the originally identified three years. Adjustments to the schedullt"-for action$ necessary to coordinate the walkdown and other app11cable portions of the process with the USl A*46 methodolo~y will be subm1tted no later than lZO days following issuance of the GIP SSER.
Principally, the availability of planned outages to complete the walkdown
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portion will be the critical path to completing the project. It is not considered prudent or justifiable to shut down the plant to complete the required walkdown activities. Therefore, the availability of an approved Generic Implementation Procedure may have a significant impact on the schedule.
Ongoing evaluations of shutdown risk and coordination of the use of risk assessment to support internal prioritization of plant issues may also necessitate other adjustments to the proposed schedule.
~/-!~
Gerald B Slade General Manager CC:
Administrator, Region III, USNRC Resident Inspector ~ Palisades i
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