U-602066, Responds to NRC 921014 Request That Util Reconsider Submittal Schedule & Complete IPE of External Events,Per Suppl 4 to GL 88-20 Earlier than Requested Date of June 1994.Schedule Should Not Be Accelerated
| ML20127M516 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 11/23/1992 |
| From: | Spangenberg F ILLINOIS POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-88-20, U-602066, NUDOCS 9211300256 | |
| Download: ML20127M516 (2) | |
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llhnois Power Company Clinton Power Stanon P.O. Box 678 Clinton. IL 61727 Tel217 935 8881 U-602066 L30-92(11-23)LP ILLEN91$
8. 20 P(WWER November 23, 1992 10CFR50.54(f)
Docket No. 50 461 Document Control Desk Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Clinton Power Station's Response to Generic Lottet 88-20, Supplement 4, " Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities - 10CFR50. 54 ( f)"
Dear Sir:
On June 28, 1991, the Nuclear Regulatory Commission (NRC) issued Ceneric Letter (CL) 88-20, Supplement 4, " individual-Plant Examination of External Events-(IPEEE) for Severe Accident Vulnerabilities". The NRC requested a response to the letter by December 25, 1991, describing the propose:i programs for completing the IPEEEs. The NRC requested that the response include the methods and approach selected for perferming the-IPEEE, a description of the method to.be used, and the milestones and schedule for performing the IPEEE.
Illinois Power's (IP) letter U-601911, dated December 1.8,- 1991 fulfilled that request.
It identified the methods that IP intends to employ to complete the IPEEE, as well as the 'xpec.ed submittal date of September 1995.
e Your Ic.tter of October 14, 1992, requested that IP reconsider the I
submittal schedule end complete the IPEEE earlier, since the current schedul.e la 'oeyund the NRC's requested' submittal date of June U94 We have reviewed the IPEEE schedule and re-affirm that the initial schedule for completion should not be accelerated.
This decision is based on using IP personnel as much as possible, rather.than consultants, in order to gain the most benefit from the IPEEE. The people who are performing the IPEEE l~
are, for the most part, the same individuals who completed the IPE, and,.
therefore, could not start on the'IPEEE ratil the.PE was essentially complete.
In order to gain some benefit from the 1FE, some of the same team is involved in apr eing the IPE to plant situations and priorities, including implementing the intenance rule.
IP does not feel that reducing the application of the IPE results to plant operations is appropriate considering the ecsts involved in its preparation. Additionally, since IP had not received a response to the n 11ef requested elevec. months ago, the proposed.
schedule was used for both long range planning and budgeting.
To accelerate the schedule solely. to meet your recent request at -this time would entail l
additional 1993/1994 costs in the form of increased 1. manhour expenditures and the unnecessary and unplanned increased involvemen of.cortractors during 9211'300256 921123
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to U-602066 i
i those years.
It should be noted that in reviewing the schedules of other 4
licensees IP recognized that several schedules extended beyond the June 1994 period.
IP has reasse sed the schedule and determined that it is still valid for the reasons stated.
The scheduled submittal date will rema!-.tptember 1995.
IP int..is to apply the same methods identified in letter U-601911, except that a reference was made to the current Standard Review Plan (SRP)
(NUREG-0800, July 1981).
However, tlUREG-1407, " Procedural and Submittal Guidance for the Individual Plant I.xamination of External. vents (IPEEE) for Severe Ac.idant Vulnerabilities", specifically references the 1975 SRP (NUREG-75/087).
IP will ensure the IPEEE submittal is consistent with the guidance of NUREC-1407.
I Sincerely yours, 1
F. A. Spangenbe III Manager, Licensing and Safety WTD/msh cc:
NRC Clinton Licensing Project Manager i
hRC Resident Office Regional Administrator, Region III, USNRC Illinois D?partment of Nuclear Safety NUMARC 4
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