ML18058B822

Submits Mha Analysis Status & Updated Commitments,Per Util 920429 Ltr Supplementing 920110 Submittal,Providing Mha & Control Room Habitability Analysis to NRC for Review & Approval

ML18058B822
Person / Time
Site:	Palisades
Issue date:	05/17/1993
From:	Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TAC-M80402, NUDOCS 9305250112
Download: ML18058B822 (2)

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consumers Power GB Slade General Manager POWERINli NllCHlliAN'S PROliRESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 May 17, 1993 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - MHA ANALYSIS STATUS AND UPDATED COMMITMENTS (TAC No.MS0402)

In Consumers Power Company.letter on April 29, 1992, which supplemented a January 10, 1992 submittal, we provided a MHA and control room habitability analysis to the NRC for review and approval. In these letters we indicated that if the NRC could review and approve the methodology used in completing the analysis by November 1, 1992, we could complete all modifications needed to bring the plant into compliance with the analysis assumptions, by the end of the 1994 refueling -0utage.

On March 30, 1993 representatives from Consumers Power Company met with NRC staff from the Radiation Protection Branch to discuss our plans for deter~ining site specific atmospheric dispersion factors and control room damper leakage to further validate some of the inputs to our MHA analysis. At this meeting we also informed the NRC that because we had not received approval on the methodology for the final MHA analysis, we did not have,a calculation from-which we could decide whether or not the plant needed to be -

reconfigured to m~et the MHA analysis assumptions. Therefore, without an approved methodology at thts time we will not be able to complete modifications as originally proposed by the end of the 1994 refueling outage.

The key to determining whether or not changes will need to be made to comply with a final MHA analysis is reaching an agreement on the methodology we submitted for our final MHA analysis. Once the methodology is approved we can complete a calculation from which conclusions can be drawn regarding future actions we may need to take. Therefore, until the methodology is approved we cannot commit to a schedule for compliance to our final MHA analysis.

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2 Until we can reach agreement on the MHA methodology, we will continue to work on the analyses and some of the plant changes already identified as warranted.

For example, we will continue the ongoing validation work for the site specific atmospheric dispersion factors and with the plans for the installation of the containment tri-sodium phosphate for post accident sump pH control.

In letters dated June 14, 1991, January 10, 1992, April 21, 1992, and July 28, 1992, we provided justification for continued operation of the Palisades plant until the time that actions could be completed to come into compliance with an approved MHA analysis. In those letters we described the modifications we have completed to limit and measure actual leakage into the Safety Injection and Refueling Water Storage tank, procedure changes made to better assure prompt containment sump pH control and the verification we completed to assure that potassium iodide tablets are available to the control room operators.

Part of that justification contained the results of an interim MHA analysis we completed using plant specific dose terms derived from our 10 CFR 50, Appendix K, LOCA fuel failure analysis, that resulted in interim calculated control room operator and site boundary dose values well within established limits. In response to a later NRC request, we completed and submitted in our July 28, 1992 letter an MHA analysis using the Regulatory Guide 1.4 source terms and our final MHA methodology. The results of that analysis also resulted in calculated dose values within established limits.

We conclude that the justification for continued operation that we previously presented remains valid and provides an acceptable level of assurance for safe plant operation.

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Gerald B Slade General Manager CC: Administrator, Region III, USNRC NRC Resident Inspector - Palisades