ML19350C991

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Responds to Noncompliance Noted in IE Insp Rept 50-155/80-15.Util Position Differs from NRC Re Tech Specs for Snubber Operation.Requests Formal NRC Review.Tech Spec Mods Re Clarification Will Be Requested,If Necessary
ML19350C991
Person / Time
Site: Palisades Entergy icon.png
Issue date: 02/02/1981
From: Hoffman D
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19350C988 List:
References
NUDOCS 8104130037
Download: ML19350C991 (1)


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power Company Generel Offices: 212 West Michleen Avenue, Jeckson, Michleen 49201 + (517) 708-0650 February 2, 1981

~r James G Keppler Office of Inspection and Enforcement Region III U S Nuclear Regulatcry Co==ission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISALES PLidiT - RESPONSE TO IE INSPECTIO:; REPO..T 80-15 IE Inspecticn Report 80-15 dated September 2h,1960, identifiec. two items of noncompliance.

Consumers Power Company's respense to those items of noncompli-ance was submitted to you on October 17, 1930.

In our response to Ite: 1, we took exception to the NRC interpretation of the Palisades Plant Technical Speci-fications for snubber operation.

Your letter dated January 9,1951, stated that following a reevaluation of your initial position, the interpretation and reading of the Palisades Technical Specification 3.20.1, as stated in your September 2L,1980, letter, was ccrrect.

Telephone conversations between Mr D C Scyd 3;RC) and Mr S R Frost (CPCo) on January 16, and 27, 1981, failed to resolve the snubber interpretation probles.

Censumers Power Company's position is that the Palisades Technical Specifications 3.20.1-Amendment No 23, L.16-for Amendment No 23 and its basis secticn of the Technical Specification, or in the Safety Evaluation Report Amendment No 23 does not say that when a sincle safety-related snubber is inoperable for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that the reactor is to be in cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> after these ecnditions can-not te net.

The Combustion Engineering Standard Technical Specifications also have been reviewed to provide clarification of this problem.

They specifically state that with cne or more hydraulic snubbers inoperable, replace or restore the inoper-able snutterisTto operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least hot standty within the next six hours and in cold shutdown within the next 30 hcurs.

Since this probles cannot be resolved between Region III and Consumers Power Company, we request that this matter be formally reviewed with the Office of Nuclear Reactor Regulations (NhR).

Consumers Power Company is willing to modify the Palisades Plant Technical Specifice.tions if NER determines that clarification is ecessary c sf.'

r-David P Hoffman Nuclear Licensing Administrator CC D! rector, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Palisades Plant fEB 5W 8ie4 2 3 g o d 7