ML20195H007

Requests Extension of Schedular Exemption for 1 Yr from Submittal of Requirements for Updated Final Hazards Summary Rept Due to Util Expanding Scope to Include Provisions from NRC SRP & Reg Guide 1.70.Fee Paid

ML20195H007
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	11/22/1988
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
RTR-REGGD-01.070, RTR-REGGD-1.070 NUDOCS 8811300178
Download: ML20195H007 (3)

Text

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November 22, 1988 l

Nuclear Regulatory Coneission Document Control Desk Washington, DC 20555 1

DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

l REQUEST TOR EXTENSION OF EXEMPTIOh TROM THE SCHEDULAR REQUIREMENTS TOR SUBMITTAL OT UPDATED TINAL HAZARDS

SUMMARY

REPORT l

l This letter requests an extension of the schedular exemption from the l submittal requirements for the Updated Tinal Hazards Susanary Report (THSR).

3 By letter dated March 2, 1987 from the Office of Nuclear Reactor Regulation j the NRC granted an exemption from the schedular requirements of 10CTR50.71(e)(3)(ii) for the submittal of the Updated THSR until December 31, i 1988. An extension is needed because Consumers Power Company cannot meet the December 31, 1988 date. Discussions with the NRC Big Rock Point Project i

Manager have indicated that a partial submittal is not adequate to meet the intent of 50.71(e). The TBSR Update has been carried as Integrated Plan Issue A-035B.

l Consumers Power Company continues to make a good faith effort toward completion of the Updated THSR. The previous schedular exemption was based upon the dedication of one person plus typing / clerical support toward this effort until coepletion. Peyond this, we have additionally dedicated one

Department Head to provide management review and approval of all coepleted THSR sections utilized the support of the Consucers Power Company General Office and Palisades Accident and Transient Analysis staff in the development

! and completion of Chapter 15 - Accident Analysest utilfred the onsite Resetor Engineering Staff to provide Chapter 4 - Nucles* Thermal Hydraulic Design subsectionst and ut111:ed other Big Rock Point Plant. Consumers Power Company General Offies, and Palisades Plant staff in performance of Technical and Informational Review of coupleted chapters. Even with this eFlensive additional support. Consuners Power Company finds that it vill be unable to i submit a complete Updated THSR of satisfactory quality by December 31, 1988.

Accorditigly. ve request an extension of the exemption of the schedular requirenents of 10 CTR 50.71(e)(3)(11) until December 31. 1989. The need for

! this extension was discussed with the NRC Project Manager in August, 1988 agaan by conference call on Novembet 7, 1988, and finally in a reeting at '

j Region III headquartsrs on November 16, 1966.

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, ^ Big Rock Point Plant Request for Extension of Exemption November *2, 1988 Consumers Power Company letter dated December 3, 1986 addressed the scope and coepletion date for this project. Subsequent to that letter. Consumers Power l Company expanded the acope to include provisions for completion of the Updated l WSR using the NRC Standard Review Plan and i datory Guide 1.70 Tormat and l Numbering System in the rewrite effort. Ba, , n this format, the l'pdated l THSR will centain eighteen (18) chapters, n.. f qich should be available by the end of 1986 I

Discussions with the NRC Project Manager indicates his desire to fave these l completed chapters availabic for use by both Big Rock Point (BRP) and NRC l personnel and to make the additional chs.pters available for use upon completion, until such time as the entire Updated THSR is completed and suomitted as an integrated volume. Because the RJ l'pdated THSR is an integrated /ceerdinated dccueent, changes to these coepleted chapters may be required as the remaining chapte-s are completed.

Based upon the premise that the completed chapters may requira additional l'

chanFes before the entire document is completed, Consumers Power Company agrees to submittal of the corpletti chapters as they are published. These chaptero vill be identified as "Interim l'pdated THSR" and vill be provided to the NRC Project Manager, BRP Resident Inspector, and cade available for BRP Plant staff use until the entire doctment is available. These "Interim l'pdated THSR" copies will be provided on an "Interim" basis until such time that the complete l'pdated THSR is submitted. The templete l'pdated WSR will j then be "Certified" to reflect all changes up t, s maxinum of six months prior to tha date of filing and the Interim Copies ray then be discarded.

l J

Basis For The Extension of the Schedular Exemption

1. An extension vill not present undue risk to the public health and safety because:

- The original THSR, as amended, is still considered to be the licensing

! basis for the plant.

1 i - Consurers Fever Company, by letter dated August 27. 1986, submitted the BRP TESR "Cross Index" as an alternative to an l'pdated THSR.

- The NRC previously canted an exet. tion for PRP from the schedular I

requirenents of 10 W R 71(e). The asis for granting thie extension to the exemption request essentially re'esins unchanged from that l considesed in the March 2, 1987 NRC letter.

2. The following "special circumstances" are submitted for consideration:

. Big Rock Point is the holder os HEC 1.icents No. DPR-6, dated May 1, 1964 The plant is the oldest operating General Electrh hoiling water reactor and one of the oldest operating corrercial nucit.n generating plants in the l'nited States. Big Rock Point's operating licensa expires on May 31, 2000. Because of Big Rock Point's age, nany of the OC1198-0205-h104

r e jf Nuclear Regulatory Commission 3

• Big Rock Point Plant Request for Extension of Exemption November 22, 1988 Final Hazard Summary Report sections have required the research, compilation, and review of over 26 years of correspondence, design, and at.alyses information in order to provide a quality document.

In addition to being one of the oldest commercial reactors, Big Rock Point is the smara operating commercial nuclear generating plant in l the United Stater sig Rock Point's output is 67 MWe net. This output is more than one order of magnitude less than the average modern vintage commercial generating plant. The NRC recognizes the problem that licensees of smaller reactors may have in applying the finite personnel and financial resources available towards resolution of those issues for which completion offers the greatest return on investment in an effort to ensure safe and economical future operation of BRP. ,

- Because of Big Rock Point Plant's age, time and effort involved in the completion of the Updated FHSR are significantly in excess of those incurred by other never facilities because these newer facilities were designed, built, and analyzed to more recent NRC requirements and the documentation is more readily available. Because BRP was built prior to the promulgation of the General Design Criteria, the evaluations conducted as part of the Systematic Evaluation Program which compared i BRP to these critetia were in most cases protracted, and resulted in a significant volume of material to be compiled, collated, summarized, .

and included in the Updated FHSR. [

l

3. The extension to the exemption previously granted will provide only l temporary relief from 10 CFR 71(e) (additional year) and Consumers Power Company and the BRP staff continue to make a good faith effort to comply with the regulation and to provide a quality document that contains ,

sufficient detail to assure acceptable review and approval of future plant changes by both NRC and Consumers Power Company. '

l Pursuant to 10CFR170.12(c) a check in the amount of $150.00 is remitted with l this application. [

t Q Y Abj Kenneth W Berry f Director, Nuclear Licensing }

l CC Administrator, Region III, NRC ,

NRC Resident Inspector - Big Rock Point '

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l OC1188-0205-NLO4 I

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