ML20235A967
| ML20235A967 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Big Rock Point, 05000000 |
| Issue date: | 07/03/1987 |
| From: | Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8707080592 | |
| Download: ML20235A967 (2) | |
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I Consumers POWar i
S$NU MIEMSAN'S PROGRE55 j
General. Offices: 1945 West Parnell Reed, Jacksora, MI 49201 * ($17) 788-0550
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'l July 3, 1987 J
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i Nuclear Regulatory Commission i
Document Control Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -
DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
INTERPRETATION - PROCEDURAL IMPLEMENTATION OF TECHNICAL SPECIFICATION AMENDMENTS This interpretation is provided in response to concerns raised by the Senior-Resident Inspector at our Palisades Plant regarding the period of time permitted to make procedure changes to implement technical specification changes. The Palisades Plant Administrative Procedures specify that all procedure changes must be completed and implemented within thirty days of the date of a technical specifications amendment. This practice has also been used at our Big Rock Point Plant. A period of time is necessary to not only j
assure the appropriate procedural changes are in order, but to permit adequate time to coordinate essential activities, of which many are safety related.
This interpretation does not apply to those changes which we have committed to in the change request submitted.
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Technical specifications changes committed to at the time of submittal, are implemented by Standing Order until issuance of the license amendment by NRC.
Committed changes are generally those that relate to significant safety or NRC concerns. Plant procedure changes related to these type of change requests are reviewed, approved and implemented as specified by our docketed commitment letter.
However, there are proposed technical specifications that address changes of a controversial, contradictory or administrative nature that cannot or need not i
be implemented until NRC approval in the form of the license amendment has been received. Changes of this type may take from sixty days to years for NRC approval, and Consumers Power Company has little or no control over the issuance date of the amendment. Frequently, the amendments are not received by Consumers Power Company for periods of one to two weeks following NRC issuance. Following receipt of an amendment by Consumers Power Company,_
appropriate procedures are routed for final approval and, are scheduled for implementation to assure a smooth transfer or change over from one procedural of OC0687-0094-NLO4 8707080592 870703 h0.p PDR ADDCK 050 5
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Nuclear Regulatory Commission 2
Big Rock Point & Palisades Plants Interpretation July 3, 1987 requirement to another. Some period of time is necessary in order to cecom-
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plish the revisions and it is in these instances we find thirty days as an i
eppropriate period of time to implement the requirements of the amendment.
l The results of an inf ormal survey of other utilities conducted to determine industry norms has established no standard industry practice.
Implementation of technical specifications amendmente. by the industry ranges from no estab-11shed procedures to describe the process, to immediate iraplementation_ or to a
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negotiated implementation period for each submittal.
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Consumers Power Company thetefore concludes that our existing Plant Administrative Procedures requirement that reflects a period of up to thirty days for implementation is appropriate and abould remain as specified.
Specific effective dates other than the thirty days after the date of the amendment will be negotiated on a case by case basis with the NRC Project Manager end the results specified in our request. Typically the effective date for negotiated submittals will be upon issuance of the amendment, however, others will be following future events such as completion of a j
project or the end of an outage.
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Thomas C Bordine Staff Licensing Engineer CC Administrator, Region III, NRC NRC Resident Inspectors - Big Rock Point & Palisades OC0687-0094-NLO4