ML20002C432
| ML20002C432 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 02/05/1975 |
| From: | Sewell R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20002C427 | List: |
| References | |
| NUDOCS 8101100297 | |
| Download: ML20002C432 (4) | |
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L General Offices: 212 West M chegan Avenue, Jackson. Mechigan 49201
- Area Code S17 7HH OSSO February 5, 1975 Division of Reactor Licensing Re: Docket 50-1.5 US Nuclear Regulatory Commission License DPR-6 Washington, DC 20555 Big Rock Point Plant Gentlemen:
On November 1, 1974, Consumers Power Company submitted a request for change to the Technical Specifications of License DPR-6 and requested permission to conduct a special test. The special test was requested to obtain additional information necessary to support the application for the Technical Specifications Change. The change requested deletion of the mini-mum withdrawal time of 23 seconds for control rod drives.
Permission to perform the special test was requested not because the test was deemed to involve an unreviewed safety question as defined in 10 CFR 50 59, but rather because cf a question with regard to interpreta-tion of the Technical Specifications.
In fact, as stated at the bottom of Page 2, both the SARB and PRC, by review and approval of the proposed Tecb-nical Specifications Change submitted November 1, 1974 agreed with the con-clusion that "The perfoace of this test would constitute neither an unreviewed safety question nor a significant hazards consideration." The request for permission to perform the special test was submitted because several members of our staff argued that the definitions provided in the Technical Specifications for " shutdown," " cold shutdown" and " power opera-tion" implied that performance of the test would constitute deliberate vio-lation of a Technical "pecifications limit (23-second withdrawal time) during power operation. The conditions of " shutdown" and " cold shutdown" are defined in the Technical Specifications as being shutdown conditions at less than 212 F.
The definition of power operation is anything other than "shetdown" or " cold shutdown." These members of the staff well understood that the plant could be and often is in a shutdown condition with primary coolant tem-peratures with greater than 212 F but nonetheless were concerned of the strict literal interpretation of the definition of " power operation."
Since submittal of the proposed Technical Specifications Change Request and the request to perform the teat, discussions with members of your staff have revealed that we are needlessly concerned with the " strict literal interpretation" of the definition of " power operation." The NRC staff recognizes that the reactor can be in a shutdown condition above 212 F, I\\
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A Division of Recctor Liesnaing 2
US Nuclear Regulatory Commission Big Rock Point Plant
', February 5, 1975 even with one rod fully withdrawn to perform such a test.
Consumers r
Company also recognizes this as evidenced by our conclusion that an unre-viewed safety question would not exist. Further, similar tests are per-formed with the exception of the maximum withdrawal rate at six-month intervals when the drives are timed individually in a hot condition.
It is interesting to note that at the present time more shutdown margin exists with one rod fully withdrawn in a hot condition than existed with one rod fully withdrawn in is cold condition at the time the maximum withdrawal rate in the cold condition was measured.
As discussed with members of the NRC staff, it has been concluded that special permission to perform the test is not required and, therefore, i
ve withdraw our November 1,197h request for permission to perform the test.
l The test will be performed in the hot condition with all rods excepting the one being tested fully inserted. A second licensed operator will be sta-i tioned to observe the rod withdrawal and ensure that test procedures are being followed.
The data obtain d from this tesc sill be submitted in support of our request for deletion of the 23-second withdrawal time limit.
Yours very truly, i
Ralph B. Sewell (Signed)
RBS/ map Ralph B. Sewell Nuclear Licensing Administrator CC: JGKeppler, USNRC l
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i NRC DISTRIBUTION FOR PART 50 DOCKET MATERIAL (TEMPORARY FORM) 2G CONTROL NO:
FILE:
FROM onsaxra Fover Co.
DATE OF DOC DATE REC'D LTR TWX RPT OTHER C
Jackson, Michigan 2-28-75 3-5-75 xxxx Ralph B. Sewell TO:
ORIG CC OTHER SENT AEC PDR_ xxxxx Division of Reactor Licnesing 1-signed SENT LOCAL PDR ****
CLASS UNCLASS PROPINFO INPUT NO CYS REC'D DOCKET NO:
xxxx 1
50-155 DESCRIPTION:
ENCLOSURES:
Ltr ref their 2-5-75 Itr trans the followlo:::
Ltr dated Feb. 5, 1975 requesting withdrawal of there Nov 1,1974 request for change of Tech-Specs.....
Big Rock Point
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