ML20149J389

Forwards Response to Generic Ltr 88-02,per 880120 Request. Plant Has Implemented Process Similar to Isap II Defined as Integrated Assessment Plan (Living Schedule) Subsequently Adopted in Amend 82.Process Has Proven Beneficial

ML20149J389
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	02/19/1988
From:	Frisch R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
GL-88-02, GL-88-2, NUDOCS 8802230029
Download: ML20149J389 (2)

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Consumers

@eswsums AHUNEAN5 PROENE55 Power oeneral officos: 1945 West Parnall Road, Jackson, MI 49201 * (517) 788cO550 February 19, 1988 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

INTEGRATED SAFETY ASSESSMENT PROGRAM II (ISAP II) GENERIC LETTER 88-02

RESPONSE

In accordance with the NRC request in Generic Letter 88-02 dated January 20, 1988, we are providing the attached responses. Big Rock Point has implemented a similar process called the Integrated Assessment Plan (Living Schsdule) and adopted in Amendment 82 to the Big Rock Point Licence. Our experience to date has shown this process to be beneficial. Although NRC Regional inspection activities / issue resolutions are not included in the Integrated Assessment Plan, at times this results in issues of relatively high safety significance being forced to lower priority due to the shifting of the resources required to complete these items. An improvement to the proposed process would be to universally apply the process to all regulatory and self-initiated issues, sa Ralph R risch Senior Licensing Analyst CC Administrator, Region III, NRC NRC Resident Inspector - Big Rock Point Plant Attachment 8802230029 DR 880219 p ADOCK 05000155 PDR \\

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FACILITY: Big Rock Point UTILITY: Consumers Power Company CONTACT: R R Frisch (517) 788-2353 RESPONSE TO GENERIC LETTER 88-02

1. Would you be interested in participating in ISAP II?_ If so, in what time frame?

No, current Integrated Assessment Plan, which is a license conditien, meets the intent of the proposed ISAP process.

2. Do you believe that an industry /NRC seminar consisting of a brief discus-sion by NRC followed by a question and answer period would be beneficial prior to making a decision?

No, our current program is adequate, however, we would gladly participate in such a seminar to gain insight to improving our process and to lend our experience to others.

3. Would you be interested in a one-on-one meeting with the NRC to discuss your particular factitty or facilities?

No, we already have a similar process in place and there is an on-going dialogue.

4. If you remain undecided regarding participar uat information do you need in order to make a decision?

None, please see response to question 1 and 3.

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5. Do you have any potential concerns about participating in ISAP II?

No concerns. As stated in response to question 1, current process meets intent of ISAP process.

6. Do you have any suggestions for program improvements or changes?

NRC Regional inspection activities / issue resolutions are not addressed in l our process nor do they appear to be covered in the ISAP process.

i Inclusion of these items would enhance the ISAP process and scheduling / utilization of utility and NRC resources.

MIO288-0006A-NA01-NLO2-NLO4