ML20023D912
| ML20023D912 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 05/31/1983 |
| From: | Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8306060144 | |
| Download: ML20023D912 (2) | |
Text
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9 O Consumers Power Company General offices: 1945 West Parnall Road, Jackson, MI 49201 * (517) 788-0550 May 31, 1983 Dennis M Crutchfield, Chief Operating Reactor Branch No 5 Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT - TECHNICAL SPECIFICATION DEFINITION - OPERABLE NRC letter dated April 10, 1980 requested review and incorporation of the model Technical Specification definition for " operable-operability." In as much as Big Rock Point does not have Standard Technical Specifications considerable review and discussion with the NRC staff has resulted. The efforts were necessary to determine the impact of the requested revisions in light of the existing Specifications. Consumers Power Company has concluded that incorporation of the "model" definition within the Big Rock Point Plant Technical Specification is not appropriate.
The staff has expressed concern that because the Big Rock Point Plant Technical Specifications do not address the operability of auxiliary systems in Limiting Conditions for Operation, a large number of equipment outage combinations could exist in which the plant might not be fully protected. We believe provisions necessary for declaration of operability are defined within the applicable sections of the plant manual as well as other nuclear operation departments procedures. These provisions specify numerous conditions and prerequisites to assure plant protection under the various possible combinations of equipment failures. They include identifications of equipment l
status; system line-ups; return to service releases; jumper, link, and bypass control; switching and tagging order; walk downs; and status boards. These administrative controls have been established to assure the applicable system, subsystem, train, component or auxiliary system is capable of performing its og Q
intended function prior its declaration of operability.
m kj It is Consumers Power Companys position that our existing administrative L
controls do meet the intent of the "model" technical specification definition, U
i e Implicit within our procedures, as within the model definition, is "the Y
assumption that all necessary attendant instrumentation, controls, normal and C'
emergency electrical power sources, cooling or seal water, lubrication or o<
other auxiliary equipment that are required for the system, subsystem, train, l3 geol EL OC0583-0025A-NLO2 l
DMCrutchfield, Chief 2
Big Rock Point Plant TECH SPEC DEFINITION - OPERABLE May 31, 1983 component or device to perform its functions (s) are also capable of performing their related support function (s)."
However, it is also our position that incorporation of the definition within Big Rock Point Plant Technical Specifications would require an extensive rewrite of the Technical Specifications. This is due to the fact that our Technical Specifications do not contain the detailed Action Statements as are found in the Standard Technical Specifications with their progressive stages of actions. In conclusion, Consumers Power Company believes that our existing administrative controls meet the intent of the Model Technical Specification definition and therefore the requested change to our Technical Specification is unwarranted.
Thomas C Bordine Staff Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point OC0583-0025A-NLO2
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