ML18065B203
| ML18065B203 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/01/1998 |
| From: | Robert Schaaf NRC (Affiliation Not Assigned) |
| To: | Haskell N CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| TAC-MA0805, TAC-MA805, NUDOCS 9804070173 | |
| Download: ML18065B203 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555--0001 Mr. Nathan L. Haskell
_Director, Licensing Palisades Plant 27780 Blue Star Memorial Highway Covert, Ml 49043 April 1, 1998
SUBJECT:
PALISADES PLANT - INITIAL SCREENING REVIEW OF CONSUMERS ENERGY COMPANY'S REQUEST FOR CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS (TAC NO. MA080S)
Dear Mr. Haskell:
The NRC staff has completed its initial screening review of the Consumers Energy Company's January 26, 1998, request to convert the Palisades Plant custom technical specifications (CTS) to improved technical specifications (ITS) and has concluded that the submittal is acceptable for detailed staff review. The proposed ITS are similar in format and content to Revision 1 of NUREG-1432, "Standard Technical Specifications, Combustion Engineering Plants," (STS).
During the screening, the staff noted that beyond scope issues (i.e., technical changes to CTS requirements in addition to conversion to the corresponding ITS requirements) were not identified in the screening submittal or cover letter. In addition, the staff screening review identified the following issues that will need to be addressed in order to facilitate complete review of Consumers Energy's submittal..
The Palisades ITS Modes conform to the STS. However, in translating CTS operational conditions to ITS Modes, the staff is concerned that changes to CTS limits may have occurred that are unevaluated in the conversion evaluation which compares CTS operational conditions tables with the ITS Modes table.
The ITS proposes plant-specific values as replacements for STS bracketed numbers (e.g., [1025] psig). In some cases the plant-specific values are not currently specified
- limits in the Palisades CTS. Generic justifications should be replaced with references to staff approved methods or analyses to support the plant-specific values proposed in the ITS.
Some changes which were identified as administrative should have been identified as less restrictive or more restrictive. For example, Section 3.8.1, Discussion of Change (DOC) A3 and Section 3.8.2, DOC A2, should be more restrictive. A justification of "consistent with a reasonable interpretation of the CTS" is insufficient. The staff will identify specific changes of this type in future requests for additional information.
The ITS include Mode 4 as an operational Mode; however, the CTS do not include an operational condition equivalent to Mode 4. The impact of the addition of Mode 4 needs to be discussed.
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9804070173 980401 PDR ADOCK 05000255 p
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- Consumers Energy needs to provide a list of Technical Specifications Task Force (TSTF) changes that have been incorporated into the ITS but that differ from the approved version,of the TSTF.
A new model safety evaluation (SE) was developed for the H.B. Robinson Plant ITS conversion, issued on October 24, 1997. Prior to this model SE, conversion SEs were over 400 pages of text. With the model SE, the total volume was reduced to about 240 pages; 40 to 50 pages of text and about 200 pages of tables. In the model SE format, changes from the CTS to the ITS are categorized and tabulated as follows: (1) administrative changes, (2) technical changes - less restrictive (specific)-, (3) technical changes - less restrictive (generic),
. (4) technical changes - more restrictive, and (5) relocated specifications.
In order for the Palisades SE to conform with the model SE, we request that Consumers Energy prepare tables formatted in accordance with the model SE. These tables should be provided to the staff in WordPerfect, Version 6.1 for Windows, file format. A copy of the Robinson SE was provided to your staff in a meeting on November 5, 1997. The Robinson SE is also available through the NRC public document rooms (accession number 9711050147).
The NRC staff requests a meeting at your earliest convenience to discuss the content of your submittal package, the results of the staff screening, and the conversion review process, including discussion of the schedule for submlttal of the conversion tables discussed above. If you have any questions regarding this letter, please contact me at (301) 415-1312.
Docket No. 50-255 cc: See next page Sincerely,
. ORIGINAL SIGNED BY..
Robert G. Schaaf, Project Manager Project Directorate 111-1 Division of Reactor Projects - 111/IV Office of Nuclear Reactor Regulation DISTRIBUTION: See attached list DOCUMENT NAME: G:\\WPDOCS\\PALISADE\\PALA0805.L TR To receive a copy of this document, indicate in the box C=Copy w/o attachment/enclosure E=Copy with.
attachment/enclosure N = No copy OFFICE PM:PD31 NAME DATE L{ I f 198
/98 OFFICIAL RECORD COPY
Mr. Nathan L. Haskell Consumers Energy Company cc:
Mr. Thomas J. Palmisano Site Vice President Palisades Plant 27780 Blue Star Memorial Highway Covert, Michigan 49043 Mr. Robert A. Fenech, Sr Vice Pres Nuclear, Fossil, and Hydro Operations Consumers Energy Company 212 West Michigan Avenue Jackson, Michigan 49201 M. I. Miller, Esquire Sidley & Austin 54th Floor One First National Plaza Chicago, Illinois 60603 Mr. Thomas A. McNish Vice President & Secretary Consumers Energy Company 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consumers Energy Company 212 West Michigan Avenue Jackson, Michigan 49201 Regional Administrator, Region Ill U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Jerry Sarno Township Supervisor Covert Township 36197 M-140 Highway Covert, Michigan 49043 Office of the Governor Room 1 - Capitol Building Lansing, Michigan 48913 Palisades Plant U.S. Nuclear Regulatory Commission Resident Inspector's Office Palisades Plant 27782 Blue Star Memorial Highway Covert, Michigan 49043 Drinking Water and Radiological Protection Division Michigan Department of Environmental Quality 3423 N. Martin Luther King Jr Blvd P. 0. Box 30630 CPH Mailroom Lansing, Michigan 48909-8130 Gerald Charnoff, Esquire Shaw, Pittman, Potts and Trowbridge 2300 N Street, N. W.
Washington DC 20037 Michigan Department of Attorney General Special Litigation Division 630 Law Building P.O. Box 30212 Lansing, Michigan 48909 March 1998
Distribution for Letter to Consumers Energy Co.. Palisades Plant. dated: April 1, 1998 Docket File (50-255),
PUBLIC.
PD3-1 Rdg E. Adensam (EGA 1)
R. Schaaf C. Jamerson W. Beckner (WDB)
F. Reinhart (FMR)
M. Reardon (MLR2)