|
---|
Category:CORRESPONDENCE-LETTERS
MONTHYEARML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML20217G4111999-10-12012 October 1999 Informs of Changes to Big Rock Point Defueled Emergency Plan, That Meet Requirements of 10CFR50.54(q) & Can Be Made Without NRC Approval.Changes to Plan Are Listed ML20212L9051999-10-0404 October 1999 Forwards Environ Assessment & Finding of No Significant Impact Re 990511 Application for Amend,As Supplemented on 990603 & 0728.Proposed Amend Would Make Changes to TSs by Deleting Definition,Site Boundary & Use ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML20212K7561999-09-30030 September 1999 Forwards Insp Rept 50-155/99-05 on 990731-0921,site Insp & 990929 Public Meeting.No Violations Noted ML20217C5111999-09-30030 September 1999 Forwards Info Re Management & Funding of Irradiated Fuel Notification,Per 10CFR50.54(bb),in Response to NRC Telcon Rai.Revs to Original 990811 Submittal Are Indicated by Redline/Strikeout Method ML20217C2761999-09-30030 September 1999 Forwards Big Rock Point Plant Annual Rept of Facility Changes,Tests & Experiments,Iaw 10CFR50.59(b)(2).Rept Provides Summary of Changes to Facility Performed Since 981001.No Activities Classified as Tests or Experiments ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211G1011999-08-25025 August 1999 Confirms Discussions & Agreement to Have Mgt Meeting in Region III Office on 990929.Purpose of Meeting to Discuss Decommissioning Activities,Priorities,Challenges & Successes & to Preview Plans & Schedules for Next Year ML20210V0561999-08-17017 August 1999 Advises of Plan to Stop Using Ofc Complex at Plant,Which Consumers Energy Co Had Provided for NRC Resident Inspectors Under 10CFR50.70(b)(1) ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML20210S6961999-08-12012 August 1999 Forwards Insp Rept 50-155/99-04 on 990609-0730.No Violations Noted.No Safety Issues or Enforcement Items Were Identified During Insp ML20210S6291999-08-11011 August 1999 Forwards Notification to NRC for Review & Approval of Program Intending to Manage & Provide Funding for Mgt of All Irradiated Fuel at Big Rock Point Until Title of Fuel Is Transferred to Secretary of Energy for Disposal ML20210L0321999-08-0303 August 1999 Final Response to FOIA Request for Documents.Documents Listed in App a Being Released in Entirety & Documents Listed in App B Being Released in Part (Ref FOIA Exemption 6) ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML20210G8351999-07-29029 July 1999 Final Response to FOIA Request for Documents.Records in App a Encl & Will Be Available in PDR ML20210H2701999-07-28028 July 1999 Informs That Big Rock Point Commits to Listed Actions with Regard to 990511 Amend Request to Delete Definition of Site Boundary & Remove Site Map,Based on Discussion with NRC on 990728 ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML20209D6951999-07-0707 July 1999 Ack Receipt of Which Requested That NRC Reconsider Decision to Move NRC Resident Inspector from Big Rock Point Plant.Determined Decision to Be Correct One ML20210L0491999-06-30030 June 1999 Partially Deleted Request for FOIA Documents Re Source of High Alarms Generated by Radiation Effluent Detector or Detectors in Discharge Canal at Big Rock Point on 980314,15 & 25.Partially Deleted Info Encl ML20209B2081999-06-29029 June 1999 Discusses Closure of Response to RAI Re GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity. Rvid,Version 2 Issued as Result of Review of Responses.Info Should Be Reviewed & Comments Submitted by 990901 ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML20196E1601999-06-21021 June 1999 Forwards Insp Rept 50-155/99-03 on 990416-0608.No Violations Noted.Overall,Reactor Decommissioning Activities Performed Satisfactorily ML20209D7011999-06-21021 June 1999 Requests That NRC Reconsider Decision to Move Resident Inspector from Big Rock Point NPP ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML20195D0371999-06-0303 June 1999 Forwards Revised Defueled Ts,Per 990511 Util Request.Page Format in Attachments 1 & 2 of Submittal Do Not Agree with Current Facility Defueled TS Format.Replacement of Encl Pages Requested ML20207F6631999-06-0303 June 1999 Forwards Rev 33 of Big Rock Point Plant Security Plan,Which Incorporates Exemption from Certain Requirements of 10CFR73 That Reflect Permanent Shutdown & Defueled Condition of Facility.Encl Withheld IAW 10CFR73.21(c) ML20207D1151999-05-27027 May 1999 Informs That Effective 990328,NRC Ofc of NRR Underwent Reorganization.Within Reorganization,Division of Licensing Project Management Created ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML20206P4501999-05-11011 May 1999 Requests Transcript of 990413 Public Meeting in Rockville,Md Re Decommissioning of Big Rock ML20206P0921999-05-0707 May 1999 Responds to Discussing Impact That Delays to Wesflex Sys Approval Would Have on Big Rock Point Decommissioning Cost & Schedule ML20206H1011999-05-0404 May 1999 Forwards Safety Evaluation for Exemption from Certain Physical Protection Requirements.Enclosure Contains Safeguards Info & Being Withheld 1999-09-30
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML20217G4111999-10-12012 October 1999 Informs of Changes to Big Rock Point Defueled Emergency Plan, That Meet Requirements of 10CFR50.54(q) & Can Be Made Without NRC Approval.Changes to Plan Are Listed ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML20217C5111999-09-30030 September 1999 Forwards Info Re Management & Funding of Irradiated Fuel Notification,Per 10CFR50.54(bb),in Response to NRC Telcon Rai.Revs to Original 990811 Submittal Are Indicated by Redline/Strikeout Method ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML20217C2761999-09-30030 September 1999 Forwards Big Rock Point Plant Annual Rept of Facility Changes,Tests & Experiments,Iaw 10CFR50.59(b)(2).Rept Provides Summary of Changes to Facility Performed Since 981001.No Activities Classified as Tests or Experiments ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML20210S6291999-08-11011 August 1999 Forwards Notification to NRC for Review & Approval of Program Intending to Manage & Provide Funding for Mgt of All Irradiated Fuel at Big Rock Point Until Title of Fuel Is Transferred to Secretary of Energy for Disposal ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML20210H2701999-07-28028 July 1999 Informs That Big Rock Point Commits to Listed Actions with Regard to 990511 Amend Request to Delete Definition of Site Boundary & Remove Site Map,Based on Discussion with NRC on 990728 ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML20210L0491999-06-30030 June 1999 Partially Deleted Request for FOIA Documents Re Source of High Alarms Generated by Radiation Effluent Detector or Detectors in Discharge Canal at Big Rock Point on 980314,15 & 25.Partially Deleted Info Encl ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML20209D7011999-06-21021 June 1999 Requests That NRC Reconsider Decision to Move Resident Inspector from Big Rock Point NPP ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML20195D0371999-06-0303 June 1999 Forwards Revised Defueled Ts,Per 990511 Util Request.Page Format in Attachments 1 & 2 of Submittal Do Not Agree with Current Facility Defueled TS Format.Replacement of Encl Pages Requested ML20207F6631999-06-0303 June 1999 Forwards Rev 33 of Big Rock Point Plant Security Plan,Which Incorporates Exemption from Certain Requirements of 10CFR73 That Reflect Permanent Shutdown & Defueled Condition of Facility.Encl Withheld IAW 10CFR73.21(c) ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML20206P4501999-05-11011 May 1999 Requests Transcript of 990413 Public Meeting in Rockville,Md Re Decommissioning of Big Rock ML18068A5831999-05-0303 May 1999 Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432 ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20217A8191999-04-29029 April 1999 Forwards Listed Matls Related to Palisades Plant June 1999 Initial License Exam ML20206E7821999-04-29029 April 1999 Forwards Annual Radioactive Environ Rept for 1998 for Big Rock Point Plant. Rept Includes Summaries,Interpretations & Statistical Evaluation of Results of Radiological Environ Monitoring Program ML20206E8271999-04-28028 April 1999 Forwards Palisades Plant Annual Radiological Environ Operating Rept for 1998. There Were No Reportable Events During This Period 05000155/LER-1992-008, Advises That Util Terminated Corrective Actions Re LER 92-008 of Loss of Station Power 125 Volt Dc sys.SOP-28 Has Been Deleted in Entirety.Commitments No Longer Applicable1999-04-26026 April 1999 Advises That Util Terminated Corrective Actions Re LER 92-008 of Loss of Station Power 125 Volt Dc sys.SOP-28 Has Been Deleted in Entirety.Commitments No Longer Applicable ML20207B4661999-04-23023 April 1999 Forwards Copy of Final Exercise Rept for Biennial Radiological Emergency Preparedness Exercise Conducted on 981201 for Palisades Npp.No Deficiencies Noted.Seven New Arcas Identified ML18066A4531999-04-0707 April 1999 Forwards ITS Pages 3.1.4-2 & 3.1.4-8,revising Completion Time for Action D.1,as Requested by NRC 990406 Telcon,Per TS Change Request Submitted 980126.Change Submitted Does Not Alter Conclusions of No Signficant Hazards Considerations ML18066A4481999-04-0202 April 1999 Responds to Violations Noted in Insp Rept 50-255/98-06. Corrective Actions:Nuclear Performance Assessment Dept Has Reviewed Observations & Agrees That Field Observations by Qualified Personnel Are Important Aspect of Program ML18066A4471999-03-30030 March 1999 Confirms Completion of Util Review of Design Engineering Contractor Cable Ampacity Evaluation.Evaluation Available at Plant for NRC Review ML18066A4411999-03-30030 March 1999 Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review ML20196K7881999-03-29029 March 1999 Forwards Rept on Certification of Financial Assurance for Decommissioning for Big Rock Plant,Per 10CFR50.75(f)(1).Copy of Trust Agreement Between Consumers Energy & State Bank & Trust Co,Included in Rept ML18066A4441999-03-26026 March 1999 Submits Certification of Financial Assurance for Decommissioning of Palisades Nuclear Plant.Certified Rept of Status of Consumers Energy Co Decommissioning Funding & Trust Agreement Encl as Attachments 1 & 2 1999-09-30
[Table view] Category:UTILITY TO NRC
MONTHYEARML20059L0161990-09-18018 September 1990 Forwards Corrected Monthly Operating Rept for Aug 1990 for Big Rock Point Plant,Consisting of Corrections to Grey Book ML18057A4811990-09-17017 September 1990 Confirms 900718 Telcon Notification Re Westinghouse Agreement to Join Utils as Equity Investor in Plant ML20059K2381990-09-0707 September 1990 Forwards Info in Response to Request for fitness-for-duty Policy & Procedures,Per NRC ML18057A4551990-09-0606 September 1990 Forwards Proprietary Info Re Dept of Labor Decision on Discharge of Former Employee of Util,Per NRC 900809 Request. No 10CFR50.7 Violation Occurred Since Job Performance Was Reason for Discharge.Encl Withheld (Ref 10CFR2.790(a)(6)) ML20059F5031990-09-0505 September 1990 Forwards Description of Scope & Objectives for 1990 Emergency Exercise Scheduled for 901204.Region III Will Participate IR 05000255/19900101990-09-0404 September 1990 Submits Addl Info Re Circuit & Raceway Schedule Enhancement Project,Per Insp Rept 50-255/90-10.Electrical Cable Separation & Channelization Anomalies Identified During Review of Physical Raceway Installations Will Be Evaluated ML18057A4521990-09-0404 September 1990 Submits Addl Info Re Circuit & Raceway Schedule Enhancement Project,Per Insp Rept 50-255/90-10.Electrical Cable Separation & Channelization Anomalies Identified During Review of Physical Raceway Installations Will Be Evaluated ML18057A4381990-08-31031 August 1990 Forwards Info Re Contamination of South Radwaste Area,Per 10CFR20.302,in Response to NRC 900112 Request.Approval Requested to Dispose of Low Level Radwaste in Place ML18057A4371990-08-31031 August 1990 Forwards Analysis Concluding That Plant Reactor Beltline Matl Upper Shelf Energy Will Remain Greater than 50ft-lbs Until Yr 2032,per 900716 Commitment ML20059E0001990-08-29029 August 1990 Forwards Semiannual fitness-for-duty Program Performance Rept for Jan-June 1990 ML18057A4201990-08-24024 August 1990 Forwards Revised Application for Amend to License DPR-20, Changing Tech Specs Re Incore Analysis Program.Request Revised Per NRC Comments During 900709 Meeting ML20059B6221990-08-22022 August 1990 Forwards Missing Pages 25 & 26 Omitted from Facility Decommissioning Funding Rept,Consisting of Attachment a to Exhibit E ML20059B6321990-08-22022 August 1990 Forwards Revised Engineering Analysis of Generic Ltr 88-01 on Plant Temp Pressure Limits in Support of Licensee 900110 Tech Spec Change Request,Per NRC Request ML20059B6371990-08-22022 August 1990 Forwards Correction to 900628 Response to Generic Ltr 90-04 Re Status of Generic Safety Issues (Gsis).Response Contained Some Errors in That Some Palisades Plant Related Info Inadvertently Substituted Into GSI Table for Big Rock Point ML18057A4021990-08-22022 August 1990 Forwards Missing Pages from Decommissioning Funding Rept, Consisting of Pages 25 & 26 of Attachment a to Exhibit E ML18057A4241990-08-21021 August 1990 Forwards Application for Amend to License DPR-20,changing Tech Spec 4.5.1 Re Statement on Integrated Leak Rate Test ML18057A4181990-08-21021 August 1990 Forwards Description of Changes Being Made to Plant Site Emergency Plan & Emergency Plan Changes.Change Allows Reduction in Shift Staffing During Cold Shutdown for Stated Staff ML18057A4121990-08-21021 August 1990 Forwards Application for Amend to License DPR-20,changing Tech Specs to Revise Wording for Reactor Protective Sys Trip Setting Limits for Steam Generator Low Water Level ML18057A4071990-08-21021 August 1990 Forwards Tech Specs Change Request to License DPR-20,to Remove Redundant Requirements & Change Basis Statements No Longer Applicable ML18057A3911990-08-17017 August 1990 Forwards Replacement Pages,To Palisades Second 10-Yr Interval Inservice Insp Program. ML18057A3851990-08-17017 August 1990 Forwards Addl Info in Support of NRC Development of SER for full-term OL for Plant,Including Date of SER Providing Provisional OL to Plant & Summary of Valid Exemptions from 10CFR Regulations,Per Telcon ML18057A3841990-08-17017 August 1990 Provides Addl Info Re Transfer of Plant Ownership to Palisades Generating Co,Per NRC 900725 Ltr ML18057A3821990-08-14014 August 1990 Requests That Bechtel-KWU Rept 128901/MJS, Full Flow Testing of Motor-Operated Valve MO-1042A, Be Withheld (Ref 10CFR2.790(b)(1)) ML18057A3721990-08-0808 August 1990 Forwards Addl Info Re Util Request for Exemption from Separation Criteria of 10CFR50,App R,Section III.G.2 Re Containment Air Room ML20058L9891990-08-0606 August 1990 Provides Util Comments Re SALP 9 Board Rept.Declining Trend in Radiological Controls Noted in Cover Ltr Needs to Be Reevaluated ML20056A3491990-08-0303 August 1990 Updates Response to NRC Bulletin 90-002, Loss of Thermal Margin Due to Channel Bow 05000155/LER-1990-002, Requests Extension of Due Date for Radiation on-the-job Training to 901101,per 900518 LER-90-002 Describing Violation Involving Unqualified Technician Assigned to Shift Compliment.Delay Due to Forced Outage1990-08-0101 August 1990 Requests Extension of Due Date for Radiation on-the-job Training to 901101,per 900518 LER-90-002 Describing Violation Involving Unqualified Technician Assigned to Shift Compliment.Delay Due to Forced Outage ML20055J3841990-07-26026 July 1990 Forwards Certification of Financial Assurances for Decommissioning ML20055J1421990-07-26026 July 1990 Responds to Commitment Oversight Issue Resulting from Insp Rept 50-255/90-08.Commitment Mgt Seminar Training Will Be Complete Prior to 901001 ML18057A3561990-07-26026 July 1990 Forwards Certification of Financial Assurance for Decommissioning ML18057A3411990-07-18018 July 1990 Forwards Revised Proposed Tech Spec Page 6-3,now Designated as Page 6-1b,adding Section 6.3.4,now Designated as Section 6.3.5 to Remove Organization Charts,Per Generic Ltr 88-06 ML18057A3381990-07-16016 July 1990 Advises That Util Does Not Foresee Need to Rely on Section V.C of App G to Remain in Compliance W/Upper Shelf Energy (Use) Requirements Re Use of Matl in Reactor Beltline ML18057A3281990-07-13013 July 1990 Responds to Request for Addl Info Re Second 10-yr Interval Insp Program,Per 900418 Telcon.Util 900329 Response Revised to Reflect That Certain Components in Class 2 Sys Should Not Be Exempted,Per IWC-1220 of 1974 ASME Code Section XI ML18057A3191990-07-0909 July 1990 Forwards Performance Indicator Trend Graphs for Jan 1989 - May 1990 ML18057A3201990-07-0606 July 1990 Discusses Reassessment of Control Room Temp Following Station Blackout Event.Results of Analysis Indicate That Control Room Temp Will Remain Below 112 F for 4 H After Onset of Blackout ML18057A3171990-07-0303 July 1990 Provides Summary of Upgrades Made to Plant Electrical Distribution Sys,Per 870714 Loss of Offsite Power Event When Inadvertent Actuation of Water Deluge Spray Sys for 1-2 Startup Transformer Resulted in Bus to Ground Fault ML20058K3771990-07-0202 July 1990 Forwards Rev 26 to Security Plan.Rev Withheld (Ref 10CFR73.21(c)) ML20055E0211990-06-29029 June 1990 Requests NRC Approval of Encl Simulation Facility Application for Plant,Per 10CFR55.45(b) ML18057A3111990-06-25025 June 1990 Forwards Endorsements 116 & 117 to Nelia Policy NF-179 & Endorsements 102 & 103 to Maelu Policy MF-50 ML18057A3101990-06-25025 June 1990 Responds to Generic Ltr 90-04, Request for Info on Status of Licensee Implementation of Generic Safety Issues Resolved W/Imposition of Requirements on Corrective Actions. ML18057A3031990-06-22022 June 1990 Provides Addl Info Re Environ Qualification of Instrument Circuit Associated W/Steam Generator Pressure Channel PT-0752D,per Insp Rept 50-255/90-05.Circuits Spliced Directly to Pigtail from Electrical Penetration Connector ML18057A3001990-06-21021 June 1990 Concurs W/Nrc Change in Terminology & Submits Revised Proposed Section 4.14 of Tech Specs ML18057A2771990-06-15015 June 1990 Forwards Corrected NRC Form 474 Re Simulation Facility Certification,Indicating Exceptions to Ansi/Ans 3.5 ML18057A2901990-06-13013 June 1990 Forwards Application for Amend to License DPR-20,revising Tech Spec 3.3.1.b Re Safety Injection Tank Min Level ML18057A2941990-06-12012 June 1990 Advises That Submittal of Second Interval Inservice Insp Program Delayed from 900615 to 900715,per 900418 Telcon ML18057A2591990-06-11011 June 1990 Forwards Palisades Simulator Certification Submittal. ML18057A2641990-06-11011 June 1990 Provides Response to NRC Requalification Exam Rept Dtd 900410 on NRC Concerns Re Facility & Training Ctr Staffing. Adequate Staffing Will Be Maintained to Ensure Operator Requalification Program Successful ML18057A2711990-06-11011 June 1990 Requests Temporary Waiver of Compliance from Tech Spec 3.1.1i in Order to Maintain Plant in Hot Shutdown While Repair Made to Pressurizer Heater Power Supply.Request Based on 900608 Failure of Heater Transformer 15 ML18057A2631990-06-10010 June 1990 Requests Temporary Waiver of Compliance from Tech Spec 3.1.1i to Enable Plant to Be Maintained in Hot Shutdown While Repair Made to Pressurizer Heater Power Supply.Waiver Requested for 900611-18 ML18057A2571990-06-0808 June 1990 Responds to NRC 900509 Ltr Re Violations Noted in Insp Rept 50-255/90-12.Corrective Actions:Continuing Training Program Will Be Developed for Supervisors That Will Discuss Fire Protection Program Implementation Topics 1990-09-07
[Table view] |
Text
"'**** ------***-
!b -
J.
consumers Power 1 company ~I General Offices: 212 West Michigan Avenue, Jackson, Michigan 49201
- Area Code 517 788-0550 ©@[p)W June 27, 1980
-j Secretary of the Commission Att Docketing and Service Branch US Nuclear Regulatory Commission Washington, DC 20555 FIRE PROTECTION PROGRAM FOR NUCLEAR POWER PLANTS OPERATING PRIOR TO JANUARY 1, 1979 - PROPOSED CHANGE TO 10 CFR 50: COMMENTS CONCERNING.
On May 29, 1980, the NRG published in the Federal Register (45 FR 36082) a proposed change to 10 CFR Part 50. The proposed change would add a requirement for a fire protection plan at each facility and would add to 10 CFR 50 a new Appendix R specifying certain elements of this required plan.
The requirements of Appendix R would apply to nuclear power plants operating prior to January 1, 1979. Consumers Power Company operates two nuclear power plants, Big Rock Point and Palisades,. which would be subject .to these new requirements. In addition, members of the NRC staff have informed us that the requirements of Appendix R would form* a starting point for review of fire protection at Midland, currently under construction. *Accordingly, Consumers Power Company would be directly affected by the proposed rule.
Consumers Power Company is a member of a group of utilities combining efforts to ensure a satisfactory resolution of the fire protection issue. This group has engaged KMC, Inc as a consultant. In this capacity, KMC, Inc will be submitting comments on the proposed fire protection rule. Consumers Power
---~_ompany has participated. in preparing the comments to be. so submitted and endorses them fully. In recognitiOn of the importance of this proposed action, however, Consumers Power Company hereby submits additional detailed comments which may have a slightly different perspective from those developed by the utility group.
Notwithstanding the detailed comments herein or to be subm_itted by KMC, Inc regarding the form and content of the proposed rule, Consumers Power Company questions the appropriateness of any rule in this area. In discussing the proposed rule, the Commission notes that detailed reviews of fire protection have been conducted at all operating nuclear power plants. The Commission
- states, "Most of the licensees have accepted most of the staff positions and interpretations .... However, 17 generic issues exist ... where agreement has not been reached between the staff and some licensees .... Because of the above-mentioned differences between the staff and licensees in the oc0680-0343a-48
,800'7010 1/13
2 interpretation of the staff's guidelines, it is timely and necessary for the Commission to state what the minimilm fire protection requirements will be in each of these contested areas of concern" (45 FR 36083). The proposed Appe~dix R provides these requirements; areas important to fire protection where the staff and all licensees have reached agreement are not addressed.
Other, and better, means exist for the Commission to close out this long-standing debate. For example, individual orders could be issued to each licensee in disagreement. Such an approach would have the advantage of ending the current debate while not reopening issues accepted in good faith and considered closed by "most of the licensees."
If a rule _is determined necessary, the rule should not reopen issues which have been previously resolved. Fire protection is not an exact science. In many i~stances, differing means of addressing fire protection concerns can be used which are each technically defensible. Resolution of issues during the aforementioned site specific reviews to the mutual satisfaction of the licensee and the staff indicates such a technically defensible solution has been reached. Reopening such is.sues is unnecessary. In those instances where changes to plant systems are required to meet the rule requirements, such changes and their expense are totally without justification. Accordingly; any rule concerning fire protection should specifically exempt those issues which have been successfully resolved at each plant as indicated by NRC Safety.'*
Evaluation Reports issued before the effective date of the rule.
- Proposed Appendix R contains detailed requirements specifying the precise means t.o be used to address issues of concern. The degree of specificity contained therein is unprecedented in.the. Commission's regulation,s.
Regulations generally specify the degree of protection to be provided and leave to the staff and licensees the detailed methods to be used to provide such protection. The issue of fire protection.is no more important than issues of nuclear safety addressed elsewhere in the*Commission's regulations and does not justify treatment in a manner far more prescriptive than used for other issues. The detailed comments attached identify the most glaring instances of overspecificity; however, it should be recognized that a predilection to a specific method of providing the desired protection pervades all of Appendix R.
- The proposed rule specifies that most of the proposed requirements be imple-mented by November 1, 1980. The apparent impetus for this date is commitments made by the Commission after the Browns Ferry fire. Specifying a date five years in the future for accomplishing major upgrading was appropriate;
- however, it was not envisioned at that time that the vast majority of the intervening period would be taken up in agreeing on the changes to be implemented;_ In view pf the unresolved issues remaining at this late date, attempting to adhere to an arbitrary implementation deadline only four months after.the earliest possible effective date of the rule is inappropriate. In this regard, Consumers Power Company supports the separate comments of Commissioners Hendrie and Kennedy.
Detailed comments on the proposed rule are provided in the attachinent.
Consumers Power Company appreciates the opportunity to provide such comments; oc0680-0343a-48
3 however, as previously mentioned, it is our conclusion that closure of this long-standing debate can best be served by promulgating no rule at all.
D P Hoffman Nuclear Licensing Administrator CC HRDenton, USNR~
MPlesset, ACRS, USNRC oc0680-0343a-48
-~
1* * \
DETAILED COMMENTS CONCERNING PROPOSED RULE ON FIRE PROTECTION
S
- 1. The proposed rule incorporates Appendix A to Branch Technical Position .,
(BTP) 9.5-1 by footnote reference. Branch Technical Positions are not prepared with the same degree of attention and public involvement as regulations. It is, therefore, inappropriate to give them the weight of a regulation by referencing them therein. If specific areas within BTP 9.5-1 are appropriate for inclusion in the regulations, they should be separately identified, included. in the proposed regulation and subjected to public scrutiny and comment in the same manner as other parts of .the regulation. The footnote reference in t~e proposed rule should be deleted.
- 2. The proposed rule states, at various places, that requirements are applicable to components and systems important to safety. This repre-sents a large escalation over previous fire protection requirements.
Heretofore, the simultaneous. oc.currence of a fire and a plant accident was judged to be sufficiently improbable as to not require consideration; previous staff reviews concentrated instead on equipment important to assure safe shutdown. No new evidence has been presented which would indicate a need to expand consideration to simultaneous improbable events. The proposed rule should be limited in applicability to equipment; systems and components important to ensure safe shutdown.
- 3. The proposed rule appears to incorporate consider.at ion of multiple failures in fire detection and suppression equipment. This departure from the single failure criterion as applied to plant safety systems, is.
not justified by the probable consequences of a fire or by any other evidence. The proposed rule should be revised to delete all requirements which result from an arbitrary assumption of multiple, independent failures.
- 4. The proposed rule contains large numbers of ambiguous arid undefined terms. Terms such as approved, visually indicating, transient fire, alternate or dedicated shutdown system, exposure fire, good and poor are used throughout. Use of such terms leaves room for countless varying interpretations of the requirements which is counter to the stated intention of ending debate on this issue. The proposed rule should be carefully reviewed to eliminate ambiguity and to precisely define terms unique to fire protection.
SPECIFIC COMMENTS ON APPENDIX R
- 1.Section II.A specifies that the fire protection program be under the direction of a person knowledgeable in both fire protection and nuclear safety. Such a combination of expertise is unnecessary, Facility design, as specified during staff reviews of each operating plant, ensures that no fire can prevent safe shutdown. The fire protection oc0680-0343a-48
2 program, thus, must address considerations of fire only; the person responsible for this program does not need a detailed knowledge of nuclear safety. In fact, specifying expertise in both areas is likely to reduce the quality of fire protection by eliminating fire protection experts who are not experienced in nuclear safety.
- 2.Section II.A specifies that structures, systems and components be arranged to facilitate fire protection. This appendix applies only to operating plants. The arrangement of structures, systems and components is fixed in these units and.would require very expensive efforts to change (where change is even practicable). Such is the case even for units in the latter stages of construction. Accordingly, this appendix should recognize the existent nature of the facilities it affects; wording related to basic facility design requirements should be deleted.
- 3.Section II.A.2.h requires that fire detection and suppression systems shall be designed, installed and maintained by personnel properly qualified by experience and training in fire protection systems. The standards by which such qualificatton is to be judged are not specified.
While it may be necessary that detailed fire protection knowledge be *.;
applied in the design of such systems, such knowledge is not necessary *~
for installation of the system as designed. Furthermore, pumps, valves *,
and other components used in fire protection systems are no d'ifferent than similar components used in other plant applications; these components can be maintained by personnel not knowledgeable of the systems in which the components are utilized. Since system design is reviewed by NRC as a result of other regulations and that review
\.
- evaluates the appropriate application of fire protection knowledge in the .j design phase,Section II.A.2.h is unnecessary and should be deleted. l..
-~
- 4.Section II.E specifies that physical separation of redundant systems must r~
be by fire barriers or 50 feet both horizontal and vertical of clear air *~
- ,J space. The requirement for SO-feet separation is arbitrary and without technical basis. This requirement, in effect, eliminates use of physical separation as a tool in fire protection since such open spaces do not exist in nuclear power plants. This could actually reduce fire safety by discouraging use of physical separation which is realistically achievable. IEEE Standard 384 should be used as the basis for evaluating separation.
- 5. Section III:A i.Ilcludes a requirement that plants using a large body of fresh water as their source of fire water have separate, redundant suctions for this purpose. This implies consideration of an accident
- affecting one suction concurrent with a fire. Such consideration is not within the current design basis and is not justified by the probability of such simultaneous occurrences. In addition, the entire section is far too specific. with its delineation of numbers and types *of tanks, pumps and delivery systems. The section should be deleted and replaced with a requirement that a reliable water source be provided capable of supplying maximum expected water demands for a specified period.
oc0680-0343a-48
3 6~ Section III.E requires that hoses be hydrostatically tested at 50 psi above maximum.service pressure. This is inconsistent with NFPA 198.
Testing requirements should be limited to 50 psi above actual operating pressure. In addition, frequencies for hose testing need not be specified in this section, but should be left to the discretion of the person responsible for the fire protection program who can evaluate past experience and unique circumstances in establishing an appropriate frequency.
- 7.Section III.G specifies considerations to be used in the design of pro-tection features. This section is far too specific. In addition, it is totally inappropriate for inclusion in this regulation. Each of these considerations has already been addressed in a specific fire hazards analysis for each facility to which this appendix will apply. Inclusion J
of this level of detail serves no purpose other than to bring into question completed fire hazards analyses at all operating plants. I Table 1 of this section in particular is very specific; this table is also extremely confusing and ambiguous. I
- 8.Section III.H specifies that the fire brigade leader and at least two brigade members be Operations personnel and that the Shift Supervisor not ,;,
be a member of the brigade. This requirement is overly specific. There . ,;
is.no reason why persons from plant departments other than Operations cannot adequatly fill all fire brigade positions. With respect to the requirement affecting the Shift Supervisor, it should be noted that this title is not defined in the regulations and does not have the univ~rsally accepted definition implied. For example, the person responsible for overall plant operations at our Midland Plant will be the Plant Supervisor; the Shift Supervisor will, in fact, serve as the .brigade leader. .,.'
9~ Seetion III.i specifies in great detail the training which must be gl.ven ii to fire brigade members. This section is far too specific and is wholly inappropriate for inclusion in the regulations. Instructional content should be left to the discretion of licensees. NRC should evaluate training by observing whether fire brigade members can adequately perform their duties. Such observation of the end product is far more appropri-ate and can be readily accomplished by the resident inspectors assigned to each operating plant.
- 10.Section III.J specifies that battery powered emergency lighting h.ave an eight-hour power supply. This requirement is without basis. While provision of emergency lighting is appropriate, it will not be needed for such a lengthy period. Within a short time of the outbreak of a fire, large numbers of support personnel will be available ori site. These personnel can take.actions to restore/provide lighting to areas not otherwise affected by the.fire .. The emergency lighting, thus, is only needed for the period before such backup assistance might be available.
A two-hour power supply should be more than sufficient. In: addition, the emergency lighting requirements of Section III.H.3 are redundant with III.J and should be deleted.
oc0680-0343a-48
4
- 11.Section III.K specifies administrative controls to be imposed to reduce fire hazards. The requirements of this section are far too specific.
For example, III.K.5 specifies that a flame permit system be used and specifies how that system is to work. It should be sufficient to specify merely that operations which use ignition sources be administratively controlled. In addition, the requirement of III.K.8 that combustible material not be left unattended during lunch breaks, shift changes or similar periods is unnecessarily burdensome; personal attendance of such materials is merely a backup to installed fire detection equipment and operations likely to cause a fire are also highly likely to be curtailed during such periods.
- 12.
- Section III.K.12 specifies that detailed strategies be defined for
. fighting fires in all safety-related areas. Because of the many potential types of fires in each area, many different strategies would .
have to be developed. The large quantity of paperwork so generated could not be easily memorized or referenced during a fire. General fire fighting strategies and thorough training of fire brigade members is a far more manageable and effective means of addressing the concern.
- 13.Section III.M specifies that penetrations for ventilation systems be protected by a "fire door damper." The correct terminology should be "fire damper."
- 14.Section III.O includes requirements applicable to fire doors. It is not clear whether each fire door in a given facility must be provided with the same specified protection or i f each door individually must meet one*
of the four options .. :s..
- 15.Section III.N specifies detailed testing requirements for fire barrier penetration seal qualifications. The detail included in this section* is inappropriate. Testing of all possible penetration seal designs to the proposed requirements would be cost prohibitive and would require several years of testing.
- 16.Section III.P specifies design requirements for reactor coolant pump lubrication system protection. With respect to an oil collection system, these requirements are unnecessarily restrictive. For example, reactor coolant pumps cannot be operated with a significant loss of lubricating oil. Pump systems are designed to prevent such loss and to alarm in the event it should occur. Accordingly, it is inappropriate to specify that the oil collection system be capable of containing the entire lube oil system inventory. In addition, while it may be appropriate to specify that the collection container withstand a safe shutdown earthquake, it should not be required that all components of the oil collection system be fully functional following such an event.
- 17.Section III.Q specifies requirements applicable to "associated circuits."
These requirements are inappropriate for this regulation for several reasons. First, this appendix is applicable to operating plants; the concept of associated circuits was not considered in the design of most of these plants. Determining which are associated circuits would be a oc0680-0343a-48
-"* ... ....-::tw e ** 5 very expensive project with little benefit. Second, the requirements regarding associated circuits have no effect on fire prevention, detec-tion and suppression. Third, the concerns behind these requirements are largely addressed by other requirements for alternate or dedicated shut-down systems.
oc0680-0343a-48