ML18065A746
| ML18065A746 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/31/1996 |
| From: | Smedley R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9606040087 | |
| Download: ML18065A746 (2) | |
Text
consumers Power*
PDWERINli MICHlliAN'S PROliRESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 May 31, 1996 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555
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DOCKET 50-255 - LICENSE DPR PALISADES PLANT TECHNICAL SPECIFICATION CHANGE REQUEST - CONVERSION TO STANDARD TECHNICAL SPECIFICATIONS - WITHDRAWAL On March 29, 1996, CPC submitted a request to convert the Palisades Current Technical Specifications (CTS) to Improved Technical Specifications (ITS) which emulate the Combustion Engineering Standard Technical Specifications (STS). After initial preliminary review, the staff informed us that our March 29, 1996, submittal did not contain some of the desired explanation and cross-referencing necessary to facilitate staff review within their planned six month review period.
After making our March 29 submittal, we requested initial preliminary staff evaluation of the acceptability of the format used and the information we had included to facilitate staff review since no official guidance for staff accepted conversion format exists. This resulted in the May 10, 1996, NRG letter which summarized telephone conversations held subsequent to our March 29 submittal and discussion during a meeting held on April 16, 1996, at NRG Headquarters during which the staff informed us of their detailed expectations concerning the format and content of CTS to ITS conversion requests.
What our submittal did not include is the level of detail the staff requires to facilitate their review process. Since the Palisades CTS do not resemble STS, a complete (100%) change is necessary. We believed that mere wording changes that do not change the requirement or intent of the CTS would not require detailed description and justification. We now fully understand the staff's expectation that every change, including wording changes, should be described and justified. Thus, in comparison to
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the number of changes required for a plant that is merely converting from one form of
-STS to ITS, the number of changes that must be addressed for the Palisades CTS to ITS conversion is much greater.
In consideration of the foregoing and:
(1) the number of required additions to our March 29, 1996, submittal which will allow it to meet the staff review format and content standards; and (2) our determination that the most desirable time, in consideration of the Palisades Operating Plan and effective Palisades staff utilization,-to implement the ITS will be around our planned April 1998 refueling outage; we have decided, after consultation with the NRC staff, to withdraw our March 29, 1996, Technical Specifications Change Request and submit an upgraded version no later than March 1, 1997.
Then, assuming a six month staff review period and an additional six month implementation window, the ITS can be implemented at Palisades either just prior to or immediately after the 1998 refueling outage. We, therefore, hereby withdraw our March 29, 1996, Technical Specifications Change Request and thank the staff for the constructive dialog which has helped us to fully understand the details required for our submittal.
Summary of Commitments
- 1.
Submit an updated version of our (withdrawn) March 29, 1996, request to convert the Current Palisades Technical Specifications (CTS) to Improved Technical Specifications (ITS) no later than March 1, 1997.
The May 10, 1996, NRC letter referred to several "commitments " Consumers Power Company made at the April 16, 1996, meeting. These were not intended as "commitments" as the word is used in docketed licensing correspondence, but were planned actions resulting from discussion during the April 16, 1996, meeting. These actions are now considered unnecessary in view of our withdrawal of our March 29, 1996, submittal. Therefore, to the extent they were considered "commitments", they are hereby withdrawn.
CC Administrator, Region Ill, USNRC Project Manager, NRR; USNRC NRC Resident Inspector - Palisades