ML18155A260

Informs NRC of Revised Installation Schedule of Radcal Gamma Thermometer Probe Per Generic Ltr 82-28.Schedule Delay Due to Technology for Probe Sys Still Unproven & Unacceptable to NRC

ML18155A260
Person / Time
Site:	Palisades
Issue date:	10/19/1984
From:	Johnson B CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Office of Nuclear Reactor Regulation
References
GL-82-28, NUDOCS 8410260082
Download: ML18155A260 (2)

Text

consumers Power company General Offices: 1945 West Parnall Ro.ad, *Jackson, Ml 49201 *.1517}_ 7138-0550 October 19, 1984

Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOC.KET 50-255 - LICENSE DPR PALISADES PLANT -

INADEQUATE CORE COOLING INSTRUMENTATION SYSTEM (GENERIC L.ETTER 82-28 DATED 12/ 10/82)

Consumers Power Company letter dated May 31, 1984 provided an update to our response to NRC Generic Letter 82-28.

The May 31, 1984 letter supplied information reflecting our final choice of the Radcal Gamma Thermometer (RGT) probe application for reactor vessel water level indication and also stated that our schedule shows completion of the Inadequate Core Cooling Instrumenta-tion (ICC!) installation at the Palisades Plant during the next refueling outage.

The purpose of *this letter is to inform the NRC of our decision to revise the installation schedule of the RGT probes to the second refueling outage from now.

This revision effects only the RGT probes.

The enhanced subcooled margin monitor (SMM) and the qualified core exit thermocouples (CET's) will still be installed during the next refueling outage.

The reasons for this schedule delay are as follows:

First, the technology for*

• the. RGT probe system has still not been proven and formally accepted by the NRC.

This proof of acceptability should be forthcoming following installation of this system in another operating reactor in the spring of 1985.

Whereas we consider the RGT probe to be the best available, and most economical,.

technology for reactor water level measurement at Palisades, we believe that it would be prudent to wait to in.stall the device until* it has been proven through actual use in an operating PWR.

This will permit any identified improvements to be factored into the design for Palisades and minimize the need for expensive system backfits after installation.

Second, we are planning for a considerable amount of other work in 1985 including completion of the Electrical Equipment Qualification program; upgrade of the Safety Injection and Refueling Water (SIRW) Tank support structure; upgrade of the reactor protection system; and, various other improvements relating to plant availability.

Extensive Company resources

($15m) are committed for completing the above-m~ntioned work and we consider OC1084-0009A-NL02

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Director, NRR Palisades Plant ICCI (Gen Ltr 82-28)

October 19, 1984 this work (when a direct comparison is made) to be of a greater safety significance than the installation of the RGT probes which will cost an additional $3.3m.

The previous statement regarding relative safety significance is predicated upon the following facts:

First, other instrumentation will be available to the operators to detect ICCI.

This includes the SMM, which will be enhanced in the next refueling outage to meet NUREG-0737 requirements, and the CET's which will be upgraded to meet NUREG-0737 requirements during the next refueling outage.

Existing readouts will remain on the datalogger until moved to the new Reactor Vessel Level Monitor System (RVLMS) display panel during the following refueling outage.

These upgrades are described in detail in our submittal dated May 31, 1984.

Second, Consumers Power Company has made excellent progress in meeting other NUREG-0737 requirements.

This includes installation of a third auxiliary feedwater pump (NUREG-0737, Item I.E.1.1);

complete replacement of the HVAC system for the control room and Technical Support Center (Item III.D.3.4); installation of reactor coolant system high point vents (Item II.B.l); and, installation of various accident monitoring equipment (Items II.B.l and II.F.l). Third, we have installed a plant specific simulator in our new training facility in Midland, Michigan; substan-tially increased our operating staff and improved the training of our nuclear plant operators; partially completed a detailed control room design review; and we are in the process of upgrading our emergency operating procedures for the second time since the TMI-2 accident.

Fourth and finally, we have completed the upgrade of our plant emergency response facilities to conform with Supplement 1 to NUREG-0737.

Taken together, these improvements are very substantial and lead us to conclude that the plant can be operated safely during the period prior to installation of RGT probes.

Brian D Johnson Staff Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades OC1084-0009A-NL02 2