ML20127F395
| ML20127F395 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Big Rock Point, 05000000 |
| Issue date: | 06/21/1985 |
| From: | Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| GL-85-07, GL-85-7, NUDOCS 8506250144 | |
| Download: ML20127F395 (6) | |
Text
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Consumers power Company I
oeneren off'ese: 1946 West Parnell Moed, Jo.hoon. MI 49201 e (817119e 0660 t
June 21, 1985
- Director, Nuclear Reactor Regulation US Nuclear Regulatory Comminaion Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -
DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO CENERIC LETTER 85 IMPLEMENTATION OF INTEGRATED SCllEDULES NRC Generic Letter 85-07, dated May 2, 1985, requested information regarding our views on the Integrated Living Schedule (ILS) concept and in particular our intentions for using an ILS. The Generic Letter requented that the information be completed on the attached enclosure. We have completed the applicable sections of the enclosure for our Palisades and Big Rock Point Planta. The following additional reference information in also provided.
I Consumers Power Company han developed an ILS for Big Rock Point.
In a March 18, 1983 letter to the NRC, we committed to conduct an integrated assensment of all regulatory and non-regulatory open issues. Our letters dated June 1, 1983: February 2, 1984: August 14, 19843 and February 12, 1985 submitted a description of the integrated assenament and scheduling approach, and the resulting schedule updates for issue resolution. On June 7, 1985, we submitted a Proposed Operating License Change Request to incorporate the method by which the NRC and Consumers Power Company will implement the Big Rock Point Integrated Annenoment into our license. The request is currently under NRC review.
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da Thoman C Bordine l
Staff Licensing Engineer CC Administrator, Region !!!, USNRC j
NRC Resident Inspector - Big Rock Point & Palinnden bg Attachment
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PDM OC0685-0006D-NLO2
7 ATTACHMENT g
Consumers Power Company Big Rock Point & Palisades Plants Dockets 50-155 & 50-255 ENCLOSURE 2 - RESPONSE F010 TAT -
CENERIC LETTER 85-07 June 21, 1985 2 Pages f
l IC0685-0006A-NI,02
!O f
ENCLOSURE 2 RESPONSE FORMAT - GENERIC LETTER 85-n7 PLANT NAME:
Pic Rock Point t
UTILITY:
connumern Pcwor company I.
INTENTIONS A.
Intend to work with the staff to develop an I
ILS x
B.
Have reservations that must be resolved before developinq ILS I
C.
Do not presently intend to negotiate an l
ILS with the staff 4
0.
Plan to implement an informal ILS only J
STATUS f
A.
If you answered I.A above:
1.
Have you settled on a method for prioritizing the work at your plant (s)?
Ranked on basis of L factors i
- 1. Ability to Achieve Cafe Oes No chutdown
[
Circle Onet
- 2. ?!!nimi:stion of Radienuelide If yes, select best description:
Pelease
- 3. Enhancement of !!ucienr Cafety l Engineering judgement
- b. Imtrovement of Plant Analytic Hiearchy process Availability & manhouro nnd Risk based analysis cost-benefit nnnlysis used at Cost benefit analysis times to Justiry work tased Other(pleasedescribe) on $1000/ man rem ruidelines.
[
y t
If no, provide estimated date l
i I
for selecting a methodology:
{
Date i
f or i
If not presently available, provide estimated date for scheduling the selection of a methodology 2.
What.is your estimated date for making a i
submittal to the NRC.
License Aman 4 rent Pc3uest vna i
sutmitted June 7, 19c5 l
or l
If not presently available, planned date for r
scheduling a submittal to the NRC t
O B.
If you answered I.B above:
8 1.
P1.ase explain your reservations on separate sheet (s) or provide your schedule for supplying an explanation See separate sheet (s) or Separate submittal scheduled for (Date) 2.
If available to meet with the staff to discuss your concerns, propose a time frame for such a meeting and provide a contact that can make arrangements Contact / Time Frame Phone Number C.
!/ you answered I.C 1.
Would you he willino to meet with the staff to discuss the rievelooment of an IL$ for your facility 417 Circio One:
Yes No j
If yes, propose a tire frame for such a meeting and provide a contact that can rike arrangements.
Contact fire Frame Phore Number If no, any constructive coments you have would be appreciated.
ADDITIONAL ITEMS Please nahe any suogestions you may have as to how a utt11ty sponsored availability / reliability pro.iect might be credited for plant safety enhancement.
Provide additional constructive coments as appropriate.
7
<3 1
ENCLOSURE 2 RESPONSE FORMAT - GENERIC LETTER 85 o7 PLANT NAME:
Pallanden r
UTILITY:
consumers Power Comrany l
INTENTIONS A.
Intend to work with the staff to develop an i
ILS 8.
Have reservations that must be resn1ved i
before developinq ILS I
C.
Do not presently intend to negotiate an ILS with :he staff i
__ x D.
Plan to implement an informal ILS only x
l STATUS l
A.
If you answered !.A above:
1.
Have you settled on a method for prioritizing i
the work at your plant (s)?
l Circle One:
Yes No If yes, select best description:
l Engineering judgement x
Analytic Hiearchy process Risk based analysis x
(if avnilabic) l Cost benefit analysis i
Other(pleasedescribe)
If no, provide estimated date for selecting a methodology:
Date i
or r
If not presently available, orovide estimated date for scheduling the selection of a methodology i
2.
Uhat.is your estimated date for making a submittal to the NRC-l or If not presently available, planned date for Scheduling a submittal to the NRC
O 8.
If you answered !.8 above:
)
1.
Please exclain your reservations on separate sheet (s) or provide your ichedule for supplying an explanation Seesepartteshettis) or separate submittal scheduled 'or (cate) 2.
If available to meet with the staff to discuss your concerns, propose a time frame for such a meeting and provide a contact that can make arrangements Contact / Time Frame Phone Number C.
If you answered !.C 1.
Would you he willine to meet with the staff to discuss the development of an !Ls for your facility (si?
Circle One:
M No If yes, propose a time frame for such a meeting and provide a contact that can rekt arrangements.
Contact envia vnnanwnti.
Tire Frame oran Phone Number 517-7A8-1636 ff no, any constructive comments you have would be appreciated.
A00!T!0NAL !TEMS Please make any suagestions you ray have as to how a utility sponsored availability / reliability pro.iect might be credited for plant safety enhancement.
Provide additional constructive comments as appropriate.
Any improvement in pinnt nyallnbility/ reliability performed in comformance with !!BC requistions regnrding pinnt changes (to 10CFR50.59) in likely to also enhance plant safety.
In many ways pinnt safety nnd nyntinbility are inserarable. For examplet nn improvement in safety system nyntinbility should result in improved plant nynilability (fever forced outages) und safety (lower core melt frequency.)
Our experience with the Big Hock point probabilistic risk assessment (pBA) and integrated.,
living schedule (ILO) confirms the close association of availnbility and safety.
Many of the
)
pinnt tetterments incorporated in the Big Hock point ILO have cost-bonefit ration (from a plant /
screty perspective) that nre more favornble than those of the safety improvements indentified in ths Dystematic Evaluntion program and other NHC initiatives. The priorities given such plant betterments in the ILO should and do reflect their more favorable cost-benefit ratios.
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