ML18051A387
| ML18051A387 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/11/1983 |
| From: | CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML18051A386 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 MI041183-NL01, MI41183-NL1, NUDOCS 8304210220 | |
| Download: ML18051A387 (22) | |
Text
CONSUMERS POWER COMPANY PALISADES PLANT INTEGRATED PROGRAM PLAN FOR SUPPLEMENT 1 TO NUREG 0737 April 11, 1983
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8304210220 830414 PDR ADOCK 05000255 F PDR MI041183-NL01
1.0 Introduction This report describes Consumers Power Company's Program Plan for completing the requirements to the emergency response capability initiatives identified in Supplement 1 to NUREG 0737.
There are several generic assumptions that apply to the Program Plan as described herein. They are:
- 1. Priority for completion of initiatives is dependent upon the integrated sequence of all initiative tasks.
As described in Section 3.8 of Supplement 1 to NUREG 0737, alterna-tive methods of phasing and integrating emergency response activities exist. Consumers Power Company's program plan has been designed to integrate the activities of several Company departments and the Plant in the completion of NUREG 0737, Supplement 1 - Emergency Response Capability initiatives. Though one initiative, eg Safety Parameter Display System, may have a higher implementing priority than the others, its completion may depend on precursor activities residing in other initiatives, eg. Detailed Control Room Design Review.
- 2. The program plan includes good faith efforts by the Company that are in progress or complete to meet initiative requirements, Section 3.7 of Supplement 1 to NUREG 0737 clearly establishes the NRG intent regarding good faith effort on the part of licensees.
Consumers Power company has initiated work in each of the initiatives except the application of Regulatory Guide 1.97 to emergency response facilities. Our Program Plan takes credit for work completed to date.
- 3. Consumers Power Company's Program Plan is based on a specific work scope. Any changes to that scope may result in changes to the integrated schedule.
Work scope and plan determine durations and hence, schedule. Should a change occur in work scope for these initiatives either during negotiation with the NRG project manager or post program implemen-tation then the potential exists for a change to occur in the integrated schedule for all the emergency response capability initia-tives covered under NUREG 0737, Supplement 1.
- 4. Future definitive schedule commitments can be submitted for those activities for which dates cannot be established by the submittal date of this program plan.
When Consumers Power Company can confidently identify a firm date for milestone activities that date is included in the milestone schedule.
Where available information is not complete for an activity, the milestone schedule will contain the date Consumers Power Company anticipates it 'will be able to determine the actual expected date for MI041183-NL01
the activity to take place. If insufficient information is available to establish any activity date, the Program Plan milestone schedule will reflect the plan for date determination.
- 5. Stated schedule and commitment dates downstream of NRC activities are predicated on the NRC supporting the integrated schedule.
In developing its program plan, Consumers Power Company used the descriptions for NRC activities provided at the regional informational meeting on Supplement 1 to NUREG 0737. The dates identified in the integrated schedule reflect the NRC provided durations.
- 6. Schedule commitment dates reflect identifiable critical resources within Consumers Power Company.
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2.0 Current Status - Emergency Response Capability Initiatives Consumers Power Company's December 19, 1980 letter to the NRC provided our initial response for Palisades Plant to NUREG 0737, Clarification of TMI Action Plan Requirements. Our response to NUREG 0737 was a description of intended actions with respect to the items of NUREG 0737 which included all of the initiatives of Supplement 1 to NUREG 0737 except the requirements for application of Regulatory Guide 1.97.
Our update to our initial response to NUREG 0737 for the Palisades Plant in which the status of the Consumers Power Company's continuing effort to address various NUREG 0737 items was submitted on September 28, 1981.
As a result of the Consumers Power Company's efforts since our December 18, 1980 submittal, substantial progress has been made in each of the emergency response capability initiatives covered by Supplement 1 to NUREG 0737 with the exception of Regulatory Guide 1.97. Below is a description of the current status of each initiative.
Safety Parameter Display System Consumers Power Company has recently completed the installation of a Combustion Engineering (C-E) designed Critical Functions Monitoring Systems (CFMS) at Palisades Plant.
We are in the process of conducting pre-operational testing on the system. Approximately 400 inputs have been identified and included as the data base for the CFMS. These inputs are obtained from existing plant signals available in the Control Room. The CFMS is proposed as the Palisades SPDS.
Detailed Control Room Design Review Consumers Power Company's Control Room Design Review (CRDR) Program Plan was submitted to the NRC on March 16, 1982. The control room survey and a review of the main control room panels and consoles have been completed. Surface enhancement modifications have been identified for installation during the 1983 refueling outage.
Regulatory Guide 1.97 - Application to Emergency Response Facilities Because this initiative is new to NUREG 0737, Consumers Power Company has not initiated any work on this initiative to date except that required to support our efforts in response to NRC Generic Letter 82-28 on Inadequate Core Cooling Instrumentation (ICCI) and to develop the program plan as required by NRC Generic Letter 82-33. We have submitted our proposed program to provide an ICCI system for Palisades Plant. The integrated summary schedule contains the plan for the final design, procedure and installation of the proposed ICCI system.
Upgrade Emergency Operating Procedures MI041183-NL01
Consumers Power Company has participated in C-E Owners Group activities conducted since the Three Mile Island accident to develop improved emergency procedure guidelines and associated supporting analyses. The C-E Owners Group analyses of transients and accidents (non-LOCA) are documented in Report CEN-128, "Response of Combustion Engineering Nuclear Steam Supply System to Transients and Accidents." The C-E Owners Group emergency procedure guidelines are documented in CEN-128 also. The NRC has reviewed CEN-128 and all NRC questions and comments have been addressed by the Owners Group.
The NRC's February 8, 1983 letter to the C-E Owners Group indicated preliminary acceptability of CEN-152, "Generic Technical Guidelines for the Preparation of Emergency Operating Procedures" and directed utilities to proceed with the development of Plant Specific Technical Guidelines.
Consumers Power Company has initiated work on the preparation of a writer's guide and the development of plant specific technical guidelines for revising the existing Palisades Plant Emergency Operating Procedures.
Emergency Response Facilities Consumers Power Company has completed its Site Emergency Plan (SEP) for Palisades Plant and it is in the process of being reviewed by the NRC Staff. Emergency Procedures have been prepared and training conducted.
Emergency Drills have been conducted for the Palisades Plant including walkthroughs of various scenarios. An exercise drill is scheduled for May 24 and 25, 1983 to demonstrate the effectiveness of the SEP.
The Palisades Plant TSC is located in the present Shift Supervisor's Office and control room viewing* areas just outside the control room.
Consumers Power Company has completed an expansion of the TSC to meet the size criteria of NUREG 0696. In addition, the TSC will have the same radiological habitability as the control room under accident conditions. The TSC's ventilation system is part of the control room's HVAC System and is being installed as part of the control room habitability modifications (See NUREG 0737 Item III.D.3.4 - Control Room Habitability Requirements).
- 2. Operational Support Center (OSC)
The Palisades Plant OSC has been established in the Plant Technical Services Building Lunchroom. The necessary communication equipment and other emergency equipment are available in the OSC.
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- 3. Emergency Operations Facility (EOF)
The Palisades Plant Emergency Operations Facility has been established at Consumers Power Company's South Haven Conference Center.
Our letter dated January 4, 1982 to NRC Region submitted its plans to use the General Office Control Center (GOCC) as a temporary EOF during the period in which the EOF staff would be in transit to the Palisades EOF at the South Haven Conference Center. The GOCC has the same communication equipment, data display, etc. as the EOF.
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3.0 Program Plan For Supplement 1 To NUREG 0737 Consumers Power Company's Program Plan for Supplement 1 to NUREG 0737 is designed to integrate the activities of several Nuclear Operation Depart-
- ments to complete the emergency response capability initiatives.
To achieve scope, schedule and cost. integration, a top down scoping and subscoping approach was used where total scope is represented as the top element of the breakdown with discrete activities as sub-elements. After identifying the total scope of work associated with Supplement 1 to NUREG 0737, performing organizations were assigned responsibility for the work scope and individuals designated for providing input into the Plan and schedule development. Each performing organization broke down the workscope to a level that was manageable and reconcilable between depart-ments working on a single initiative and between initiatives. (See CPCo Palisades Plant NUREG 0737 Supplement 1, Work Breakdown Structures.)
Following the breakdown of the workscope, all work tasks were sequenced
- and ordered in a logical fashion by work package (ie. each individual work scope) and by initiative. The work tasks were then integrated within initiatives and between initiatives and the necessary logic adjustments made to yield final integrated logic networks which identified all remaining work associated with the initiatives of Supple-ment 1 to NuREG 0737.
Once the final logic networks were established, critical resources were identified along with cost requirements and durations were assigned to each task activity on the integrated logic networks.
The duration determined for each work task were then used to develop the program schedule.
It is important to note that the schedule for completing the remaining work for each of the emergency response initiatives is directly established through assessment of scope of work associated with each initiative. Changes in work scope for any initiative may modify the schedule.
Consumers Power Company intends that this Program Plan for the emergency response capability initiatives will be a living plan, flexible enough to accomodate future definition of work scope for those activities for which sufficient detail is lacking at the time of this submittal.
Following is a description of the Program Plan by initiative which identifies the required remaining workscope.
Consumers Power Company will conduct a technical assessment of the C-E designed Critical Functions Monitoring System (CFMS) that has been installed at Palisades Plant against the NUREG criteria established for an SPDS. Should it be determined that MI041183-NL01
non-justifiable deviations exist, we will initiate a modification program to upgrade the CFMS.
- 2. Detailed Control Room Design Review (DCRDR)
Consumers Power Company will continue its DCRDR as outlined in its Control Room Design Review Program Plan with input to the planrted task analysis from the events analysis performed for the Safety Parameter Display System assessment. Control panel and console modifications in the form of surface enhancements already identified from work on this initiative will be completed during the 1983 refueling outage.
- 3. Application of Regulatory Guide 1.97 to Emergency Response Facilities Work on this initiative will start by conducting a comparison of the instrumentation and associated criteria defined in Regulatory Guide 1.97 with that existing in the Palisades Plant control room, technical support center and emergency operations facility.
Deviations from the requirements of Reg Guide 1.97 will be identified and a justification provided for submittal to the NRC. Should it be determined that non-justifiable deviations exist, we will initiate a program to procure and install instrumentation as required. Any control room instrumentation output required in the technical support center or the emergency operations facility will be made by modifying the Critical Functions Monitoring System data displays. Should instrumentation be added to the control room, the appropriate human factors principles will be applied in the selection of location, display, etc.
Our program plan also reflects the work required to design, procure, install, test, train and validate our proposed Inadequate Core Cooling Instrumentation System as described in our response to Generic Letter 82-28.
- 4. Emergency Operating Procedure (EOP) Upgrade Plant specific Technical Guidelines will be prepared along with a Writer's Guide, Verification and Validation Program and Training Plan will be submitted to the NRC. The Technical Guidelines and Writer's Guide will be used to upgrade plant emergency operating procedures.
Verification and validation will be achieved by auditing the upgraded procedures against the Writer's Guide and Plant Specific Technical Guidelines; by conducting control room walkthrough; by training and testing the operators to the procedures; and by use of the Palisades Plant simulator recently installed at our Nuclear Training Center at Midland.
- 5. Emergency Response Facilities (ERFs)
Consumers Power Company has the required Technical Support Center (TSC), Operational Support Center (OSC) and Emergency Operations MI041183-NL01
Facility in place for Palisades Plant. In addition, the Site Emergency Plan is complete. As a result, Consumers Power Company's Plan for the ERF's is to continue training to procedures, conduct practice drills and run periodic full scale exercises. In addition, we will review applicable guidance documents to assure the adequacy of the existing facilities for emergency response.
- 6. Training Consumers Power Company's requalification training plan which was submitted to the NRC on May 11, 1982 describes the training program for assuring that operators are appropriately trained on procedures.
In addition, the appropriate personnel will be trained on new equipment operating procedures, interfacing procedures and emergency operating procedures as required before implementation of approved procedure changes. Training will be on-going as required throughout Consumers Power Company's Program to complete the emergency response initiatives.
- 7. Verification and Validation Consumers Power Company's verification and validation plan consists of second level design review for required design verification.
Turnover tagging, component testing, system functional testing and preoperational testing will also serve to verify the design bases.
In addition, walkthroughs, audits, procedures training examinations and simulator exercises will be used to validate various initiative programs.
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CPCO PALISADES PLANT NUREG-0737 SUPPLEMENT-1 WORK BREAKDOWN STRUCTURE 1
CPCO'S PROGRAM PLAN 12 PALISADES PLANT I 121 I* 122 I 123 124 I 12s I 12a UPGRADE SAFETY DETAIL REG. GUIDE 1.97 EMERGENCY EMERGENCY PARAMETER CONTROL ROOtJ APPLICATION RESPONSE INDIRECTS OPERATING DISPLAY DESIGN REVIEW TO ERF'S FACILITIES PROCEDURES SYSTEM REV.
DATE SHEET 1 OF 7
CPCO PALISADES PLANT NUREG-0737 SUPPLEMENT-1 WORK BREAKDOWN STRUCTURE FROM SHEET 1 OF 7
... ~
121 UPGRADE EMERGENCY OPERATING PROCEDURES I 1210 I 1211 I 1214 I 1215 I 1218 I 1219 NRC SCOPE PLANT SCOPE NLD SCOPE RED SCOPE NOTO SCOPE QA SCOPE REV.
DATE SHEET 2 OF 7
CPCO PALISADES PLANT NUREG-0737 SUPPLEMENT-1 WORK BREAKDOWN STRUCTURE FROM SHEET 1 OF 7
~-
122 CONTROL ROOM DESIGN REVIEW I 1220 I 1221 1223 I 1224 I 1228 I 1229 NRC SCOPE PLANT SCOPE NPP SCOPE NLD *SCOPE NOTO SCOPE QA SCOPE
~ ' .
REV.
DATE SHEET 3 OF 7
CPCO PALISADES PLANT NUREG-0737 SUPPLEMENT - 1 WORK BREAKDOWN STRUCTURE FROM SHEET 1 OF 7
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123 REG. GUIDE 1.97 APPLICATION TO ERF'S I 1230 I 1231 I 1232 1233 I 1234 I 1236 NRC SCOPE PLANT SCOPE NPS SCOPE NPP SCOPE NLD SCOPE RSD SCOPE I I I I I 12331 I 12332 I 12341 I 12342 I 12343 I 12344 CONTROL CONTROL ROOM ICCI TSC EOF ICCI ROOM VARIABLES REV.
DATE SHEET 4 OF 7
CPCO PALISADES PLANT NUREG-0737 SUPPLEMENT-1 WORK BREAKDOWN STRUCTURE FROM SHEET 1 OF 7
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124 SAFETY PARAMETER DISPLAY SYSTEM I
11240 11241 I 1243 '1244 I 1245 I 1248 I 1249 NRC PLANT NPP NLD RED NOTO QA SCOPE SCOPE SCOPE SCOPE SCOPE SCOPE SCOPE I I I I 12451 112452 112481 I 124 RARE SAFETY RARE TRAINING EVENTS ANALYSIS EVENTS REV.
DATE SHEET 5 OF 1
CPCO PALISADES PLANT NUREG-0737 SUPPLEMENT-1 WORK BREAKDOWN STRUCTURE FROM SHEET 1 OF 7
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125 EMERGENCY
RESPONSE
FACILITIES I 1250 I 1251 I 1253 I 1254 I 1256 1258 PLANT SCOPE NLD SCOPE RSD SCOPE NRC SCOPE NPP SCOPE NOTO SCOPE (OSC)
I I I I 12531 12532 12533 12561 12562 12563 12581 12582 125 83 TSC osc EOF TSC osc EOF TSC osc EOF REV.
DATE SHEET 6 OF 7
CPCO PALISADES PLANT NUREG-0737 SUPPLEMENT-1 WORK BREAKDOWN STRUCTURE FROM SHEET 1 OF 7 126 INDIRECTS l12e 1 l12e2 11263 l12e4 11265 l12ee 11267 l12ea I1269 PLANT NPS NPP NLD RED RSD NPA NOTO QA Lf' REV.
DATE SHEET 7 OF 7
4.0 Integrated Schedule At the end of this Section is the Consumers Power Company Integrated Summary Schedule on which milestone activity dates are identified. Where anticipated completion dates for milestone activities were identifiable at the time of this submittal, they are so noted on the integrated schedule. (See legend on Integrated Summary Schedule for symbol definition.) For those milestone activities for which we could not determine a completion date, we have shown a date by which a completion date will determined. Milestones for which anticipated completion dates or dates for determination of anticipated completion dates are not known at the time of this submittal are so designated on the integrated schedule.
The attached table is a summary of milestone events that the NRC requested in Generic Letter 82-33 as clarified in the Regional Information Meetings and our meeting on March 24, 1983.
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PALISADES NRC - NUREG-0737 DATE CPCO CPCO WILL ISSUE CROSS MILESTONE COMMITMENT A COMMITMENT REFERENCE TO INITIATIVE DESCRIPTION DATE DATE COMMENTS DETAILED PLANS EOP's Generic Tech A08FEB83 NRC Authorization 941210011 121 Guidelines CEN-152 To Proceed (See LEGEND)
Procedures 01MAY84 941214035 Generation Package Operation Trn 31AUG84 941214072 Date Implementation 01MAY86 941211079 Complete DCRDR Submit Initial A16MAR82 (See LEGEND) 122 DCRDR Program Plan Update of 13JUN83 941224045 DCRDR Program Plan DCRDR Interim 31AUG84 Report will contain 941224014 Status Report Work Complete to datE and detail work to Ge DCRDR Final Plan will show 941224077 Report show sequence to arrive at a date MI041483AA-NL01
PAGE 2 ot' .3 PALISADES NRC - NUREG 0737 (Cont'd)
DATE CPCO CPCO WILL ISSUE CROSS MILESTONE COMMITMENT A COMMITMENT REFERENCE TO INITIATIVE DESCRIPTION DATE DATE COMMENTS DETAILED PLANS Reg Guide RVLS Concept Al5MAR83 (See LEGEND) 941234435 1.97 to NRC For ICCI 123 Interim Report 13SEP83 941234136 of Deviations ICCI By end of 941234085 Operational 1987 Refueling Date Outage Implementation Plan will 941231036 of 1. 97 show sequence to arrive at a date SPDS Update SPDS/CFMS 25JUL84 941244031 Comparison Report 124 Submit SAR Plan will show 941244073 sequence to arrive at date Operating Trn Plan will show 941248224 Date to NRC sequence to arrive at date System Fully Plan will show 941241075 Implemented sequence to arrive at date MI041483AA-NL01
PAGE 3 of '3..
PALISADES NRC - NUREG 0737 (Cont'd)
DATE CPCO CPCO WILL ISSUE CROSS MILESTONE COMMITMENT A COMMITMENT REFERENCE TO INITIATIVE DESCRIPTION DATE DATE COMMENTS DETAILED PLANS ERF's Integrated 25MAY83 941251022 125 ERF Exercise Interim Report 13SEP83 941254061 Report on (see 1. 97 Deviations same date)
TSC Fully 31AUG84 941254081 Functional OSC Fully 31AUG84 941254081 Functional EOF Fully 31AUG84 941254081 Functional GOCC Fully 31AUG84 941254081 Functional '
LEGEND An "A" in Front of A Date connotates an actual date MI041483AA-NL01
CONSUMERS POWER COMPANY DATA DATE 11 APR 83 PALISADES PLANT ISSUE NUREG 0737 DATE 15 APR 83 SUPPLEMENT-1 REV o INTEGRATED
SUMMARY
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- 5 0 1 2 !3 4 5 , s, 1' a 9 1011112113 14 15 1s*1118 19120 2122:2a2425,2s121128129:30*31132.33 34'35i36 37'38 39:40 4142 14314445 46!47 48'49 50,51,52 53;54 55 56 51585960s1's2 s3 s4,s5:ss s1686910111721314151s1111019 00 81 LEGEND INITIATIVE 1983 1984 1985 1986 1987 1988 1989 QINTEOACTIVITVNOOe
5.0 Conclusion In the development of our Program Plan, Consumers Power Company has determined that many milestone activities can be assigned specific completion dates. In addition, we have assigned for other milestone activities a date for which a completion date will be determined.
For those initiatives that may require future design procurement and installation activity of safety related hardware, the potential exists for considerable extension of the applicable initiative completion (e.g.
Safety Parameter Display System). In these cases, the Integrated Summary Schedule illustrates the Plan to complete the initiative in lieu of defining completion dates.
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