ML18067A498

Forwards FSAR Verification Project Scope & Schedule Which Meets Commitment Discussed in 970206 Response to 961009 RAI

ML18067A498
Person / Time
Site:	Palisades
Issue date:	04/22/1997
From:	Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9704290169
Download: ML18067A498 (6)

Text

'1 A CMS Energy Company 111amas C. Bardlns Manager Licensing April 22, 1997 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT DESCRIPTION OF FSAR VERIFICATION PROJECT AND SCHEDULE FOR COMPLETION On February 6, 1997, Consumers Energy Company submitted a response to the October 9, 1996, letter "Request for Information Pursuant to 10 CFR 50.54(f) Regarding Adequacy and Availability of Design Bases Information". That response included the following commitment:

Revise the scope of the current limited-scope FSAR Validation Project to an FSAR Verification Project designed to identify and correct discrepancies that are (

the subject of the NRC Policy Statement on Enforcement Actions; Departures from FSAR (61 FR54461 ). A description of the verification project with a schedule for completion will be submitted by May 1, 1997.

The attachment to this letter provides the FSAR Verification Project Scope and Schedule which meets the above commitment.

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Palisades Nuclear Plant

• 27780 Blue Star Memorial Highway

• Coveil, Ml 49043

• Tel: 616 764 2913

• Fax: 616 764 2490

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SUMMARY

OF COMMITMENTS This letter contains one new commitment and no revisions to existing commitments.

The commitment is:

If any significant changes are made to the schedule for the FSAR Verification Project, a revised schedule will be provided to the NRC.

Thomas C. Berdine Manager, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Attachment

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ATTACHMENT CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 FSAR VERIFICATION PROJECT SCOPE AND SCHEDULE 3 Pages

FSAR Verification Project Scope and Schedule

References:

(a) Response to NRC 1o*::CFR 50.54(f) Letter: Request for Information Pursuant to 10 CFR 50.54(f) Regarding Adequacy and Availability of Design Bases Information, dated February 6, 1997 (b) NRC Policy Statement on Enforcement Actions; Departures from the FSAR (61 FR54461)

In Reference (a) Consumers Energy committed to perform a verification of the Palisades FSAR and to provide the scope and schedule for this commitment by May 1, 1997. The scope of the FSAR Verification Project will include three major elements.

The first element will be a review of existing Palisades Safety Evaluation Reports (SERs) to identify Licensing and Design Bases information which is appropriate for inclusion in the FSAR. This will typically include commitments and structures, systems, and equipment (SSE) performance requirements and limitations. This element will not include SERs associated with Technical Specifications. These commitments and SSE requirements are already addressed in surveillance procedures and program requirements which require a matrix of Technical Specification surveillance requirements versus the implementing surveillance procedure.

The second element of the project will be a review of the FSAR to verify its completeness and accuracy. This review will be conducted by plant personnel who are subject matter experts in the areas being reviewed.

The third element will be a review of the FSAR to identify Licensing and Design Bases requirements. Again, this will typically include commitments and SSE performance requirements and limitations. This element will also verify proper inclusion of these requirements in plant implementing procedures and programs.

The project deliverables will include:

• A matrix of Licensing and Design Bases requirements contained in the FSAR/SERs versus the implementing procedures or programs.

• A FSAR which is verified for accuracy, completeness and inclusion of Licensing and Design Bases requirements included in SERs.

• Licensing and Design Bases requirements which are verified to be accurately implemented in plant procedures and programs.

The FSAR Verification Project will be performed under the supervision of a dedicated Consumers Energy Project Manager. Elements one and three will be performed by a vendor and reviewed by Palisades plant staff. As stated earlier, element two will be performed by plant staff. Issues identified during the project will be dispositioned per existing plant administrative procedures.

• 2 The FSAR Verification Project is very broad in scope and could result in a significant amount of work. For this reason, we are providing the attached schedule with target versus fixed dates. These target dates are presently based on a best estimate and could change during project implementation. If significant changes are made to the schedule a revised schedule will be provided to the NRC. The target end date of the project is predicated on the discretionary enforcement period discussed in reference (b). Consumers Energy plans to complete all reviews and the evaluation/resolution of major issues by October 18, 1998. Completion of FSAR and procedure/program revisions will extend beyond this date; however priority will be given to resolution of significant issues.

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FSAR Verification Project Schedule Page 1 of 1 4122197 1997 1998 1999 J----r----.----.--,--------,------,---.--+------r----,---.--,--------,------,---.---,.---,--,-------.-----+-------o-.-------.-----,.---,-----,---.--,---<i~--.-----t MJJASONDJFMAMJJASONDJFMAMJJASOMD Element 1 SER review Ji IL

/15 10/28 Element 2 FSAR review for completeness &

accuracy Ji

/15 12/31 Element 3 FSAR review to identify Licensing &

Design bases Ji 6/1 6/1 Element 3 Identify implementing procedures and programs Ji 7/3 12/15 FSAR revisions 8/1 6/29 Pr~c~dure & program rev1s1ons 8/1 6/29 All major issues evaluated & resolved

• 10/18