ML18058B240

Responds to NRC 920930 Ltr Advising Util That NRC Deferred Further Review of TS Amend Request Re Shutdown Cooling Operations,Thereby Effectively Denying Request.Amend Request Complete & Accurate & Should Be Approved

ML18058B240
Person / Time
Site:	Palisades
Issue date:	11/23/1992
From:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Murley T Office of Nuclear Reactor Regulation
References
TAC-M73443, NUDOCS 9212010025
Download: ML18058B240 (3)

Text

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~ower David P Hoffman Vice President POWERING Nuclear Operations MICHIGAN'S PROGRESS General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0453 November 23, 1992 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - REPLY TO NRC DEFERMENT OF AMENDMENT REQUEST FOR SHUTDOWN COOLING (TAC No. M73443)

Your letter of September 30, 1992 states that you have deferred further review of our Technical Specifications amendment request regarding shutdown cooling operations, thereby effectively denying the request. We do not agree with the basis for your action.

A long standing NRC concern is the lack of Technical Specifications for shutdown cooling at Palisades. The amendment request proposed various requirements that incorporated input from CE Standard Technical Specifications, the Technical Specification Improvement Program, and Generic Letter 88-17. As you noted in your letter, we expended considerable effort in the preparation, review, and submittal of the amendment requests. The subject Technical Specifications amendment request was prepared and subsequently revised three times. We note that the NRC staff also expended considerable review and effort, and had, as we understood it, satisfactorily brought the review to a close except for the reason for the deferral described in your letter. Both our efforts have been in good faith and have been centered on a common goal of producing an acceptable technical specification compatible with the Palisades plant system configuration. During this iterative process, in addition to our time (over 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br />) and your time, we also have spent, through March 1992, approximately $9,000 in direct billing, and we expect the billing for the last 6 months to approximately equal this cost. Indirect cost associated with review of this task, conducted by the NRC Palisades Senior Resident Inspector, will also be charged to Consumers Power Company.

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2 We are concerned that much of the effort in these previous reviews by the NRC will be lost in the intervening time for us to resubmit another amendment application. Similar deferral of approval in the past has resulted in new NRC reviewers being assigned resulting in re-review and additional cost for the review. Furthermore, we have no basis to believe that the generic letter, that you indicated will be issued in early 1993, will be acceptable to us.

Our comments with respect to these issues are as follows:

• Our plant equipment configuration is not a standard configuration, so generic recommendations for a technical specifications amendment are not likely to adequately address our plant.

• Our present proposed amendment (that you have deferred) contains all the elements necessary to assure the availability of shutdown cooling during certain operations conditions as described in the proposal.

These elements have been incorporated into our operating procedures, and, therefore, we conclude that short of having a technical specification, we have adequately addressed the NRC concerns. A future option for us is to maintain this status quo.

• We do not believe the contents of the present application will be affected by the generic letter recommendations since, to our knowledge, the recommendations will be independent of, although related to, our present application.

• We will address the issues in the proposed generic letter when it is issued.

• Since generic letters are not regulation, the recommendations will not be mandatory. Therefore, we would submit an amendment request only if we believed it necessary and correct within our system configuration.

• The proposed generic letter is in preliminary stages and may not be issued as soon as predicted (early 1993).

In conclusion, we believe our shutdown cooling amendment request to be complete and accurate, thoroughly reviewed, and independent of a future generic letter. Therefore, we again request that you approve the proposed amendment in the form it was proposed and negotiated with the NRC staff in our June 28, 1989 letter and supplemented May 1 and September 26, 1991, and March 18, August 24, and August 28, 1992.

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Vice President Nuclear Operations CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Document Control Desk NUMARC

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. LICENSING CORRESPONDENCE\COMMITMENT TRACKING RECORD

SUMMARY

DATE: November 23, 1992 DOCKET 50-255 LICENSE DPR PALISADES PLANT - REPLY TO NRC DEFERMENT OF AMENDMENT REQUEST FOR SHUTDOWN COOLING (TAC No. M73443)

SUMMARY

Notifies the NRC of our reasons why the shutdown cooling conditions amendment request should be approved now instead of after the generic letter is approved and issued in 1993.

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