ML18051A666
| ML18051A666 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/07/1983 |
| From: | Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| GL-83-28, NUDOCS 8311110121 | |
| Download: ML18051A666 (20) | |
Text
consumers Power company General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0550 November 7, 1983 Mr Darrell G Eisenhut, Director Division of Licensing Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO GENERIC LETTER 83-28, REQUIRED ACTIONS BASED ON GENERIC IMPLICATIONS OF SALEM ATWS EVENTS NRC Generic Letter 83-28 and its enclosure, "Required Actions Based on Generic Implications of Salem ATWS Events," dated July 8, 1983, required all licensees to furnish within 120 days a status report showing conformance to the posi-tions contained in the Generic Letter.
Consumers Power Company's letter, dated September 6, 1983, requested an extension of time for providing a response to certain issues of Generic Letter 83-28 and stated that we would provide a detailed plan and schedule for those issues, a status report of our efforts on the vendor interface issue as well as a description of our present programs for:
- 1) the classification of the reactor trip system components (Issue 2.1) and all safety-related components (Issue 2.2) and 2) the preventa-tive maintenance and surveillance program for the reactor trip breakers (Issue 4.2, Items 1 and 2). provides our response to a portion of Issue 2.1, all of Issue 2.2 and Issue 4.2, Items 1 and 2. contains a status report on the vendor interface issue. contains a detailed description of our plan and schedule for the remaining GL 83-28 issues.
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David J VandeWalle
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Director of Nuclear Licensing CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement Administrator, Region III, USNRC NRC Resident Inspector - Pa*lisades Attachments OC1083-0007A-NLOO 8311110i2i 83ffij7 -
PDR ADOCK 05000255 P
RESPONSE TO GENERIC LETTER 83-28 At the request of the Commission and pursuant to the Atomic Energy Act of 1954 and the Energy Reorganization Act of 1974, as amended, and the Commission's Rule and Regulations thereunder, Consumers Power Company submits our response to Generic Letter 83-28 dated July 8, 1983, entitled, "Required Actions Based on Generic Implications of Salem ATWS Events."
Consumers Power Company's response is dated November 7, 1983.
CONSUMERS POWER COMPANY By R B DeWitt, Vice President Nuclear Operations Sworn and subscribed to before me this 3rd day of November 1983.
Sherry L Du ey, Notary Jackson County, Michigan My commission expires November 5, 1986.
SHERRY LYNN DURFEY Notary Public, facl{son County, Micl1.
r~'iy Ccn~m~ssion Exr:Ires Nov, 5, 1986 OC1083-0007BB-NLOO
ATTACHMENT 1 Consumers Power Company Palisades Plant Docket 50-255 CONSUMERS POWER COMPANY'S RESPONSE TO GENERIC LETTER 83-28 ISSUES 2.1, 2.2, 4.2.1 AND 4.2.2 November 7, 1983 10 Pages OC1083-0007C-NLOO (1)
ATTACHMENT 1 ISSUE 2.1 EQUIPMENT CLASSIFICATION AND VENDOR INTERFACE (REACTOR TRIP SYSTEM COMPONENTS)
NRC Position (Equipment Classification)
Licensee and applicants shall confirm that all components whose functioning is required to trip the reactor are identified as safety-related on documents, procedures, and information handling system(s) used in the plant to control safety-related activities, including maintenance, work orders and parts replacement.
Consumers Power Company Response Consumers Power Company's letter dated September 6, 1983 stated in part that Consumers Power Company would provide a report describing the present program for classification of the components of the reactor trip system.
That letter, however, requested an extension of time for review and verification that all components of the reactor trip system were specifically identified as being safety-related.
In addition, our letter of September 6, 1983 indicated that the Vendor Interface portion of the Equipment Classification Issues would be treated as a separate item.
Therefore, this section of Consumers Power Company's response to Generic Letter 83-28 provides a description of the present program for controlling safety-related activities on the reactor trip system and for ensuring that the reactor trip system components are classified as safety-related on all documents, procedures and information handling systems.
Palisades Nuclear Plant Administrative Procedure 10.08, "Q-List/Equipment Data Base," is the controlling procedure for the determination of the classifica-tion of all systems and equipment in the plapt.
This procedure identifies the plant Q-List and provides guidelines for the quality classification of plant equipment, material, services, and activities. It is the responsibility of the Plant Manager to maintain and implement this procedure and to maintain the approved Q-List.
The Palisades Plant Q-List consists of the Equipment Data Base (EDB), and the appendices of Procedure 10.08.
The Q-List delineates those structures, systems and components that are important-to-safety and require the applica-tion of the QA program.
Section 8.1 specifically includes as part of the Q-List; "the system, portions of systems or component (that) is designed to provide reactor shutdown."
Administrative procedures at the Palisades Plant requires that prior to any normal maintenance, including preventative maintenance, on systems or equip-ment at the plant, that a Maintenance Order (MO) be processed.
Administrative Procedure 2.01, "Processing of Maintenance Orders," describes the procedure for the processing of maintenance orders at the Palisades Plant.
This proce-dure applies to all maintenance and specifically requires that the safety status, ie, Q or non-Q, of the system or equipment be determined prior to the OC1083-0007D-NLOO Page 2 of 10 maintenance activity.
In addition, this procedure requires that if the safety status of the component or system cannot be determined from the Q-List that the equipment be designated as Q on the maintenance order and that a Q-List Interpretation Form be initiated.
This step ensures that all equipment, unless it is specifically listed as non-Q, is treated as if it were Q for all maintenance activities.
In addition, the administrative procedures that control major and minor modifications and minor field changes to equipment at the Palisades Plant require that the safety status of the equipment or system being modified be determined and that a safety evaluation be completed and reviewed prior to any work being performed.
For the procurement of replacement parts for safety-related systems or equip-ment, Procedure 10.03, Procurement of Materials, requires that the originator of the procurement documentation determine the safety-related status of the system, material, or part using the Q-List as a reference.
Subsequent review by the individual's functional superintendent and a Quality Assurance repre-sentative assures adequate control when procuring replacement parts.
In addition to the procurement of replacement parts, Procedure 10.08 states that vendor-supplied services are deemed to be Q-listed if that service involves activities which may affect Q-listed components, structures, or systems.
The existing procedures, as described above, are adequate as to ensure that the components of the reactor trip system are identified and controlled as safety-related during the performance of maintenance activities and when procuring replacement parts.
Verification that the components of the reactor trip system are specifically identified as being safety-related will be performed as part of the program plan for response to Generic Letter 83-28.
(See Attachment 3.)
OC1083-0007D-NLOO
NRC Position ISSUE 2.2 EQUIPMENT CLASSIFICATION AND VENDOR INTERFACE (Programs for All Safety-Related Components)
Page 3 of 10 For equipment classification, licensees and applicants shall describe their program for ensuring that all components of safety-related systems necessary for accomplishing required safety functions are identified as safety-related on documents, procedures and information handling systems used in the plant to control safety-related activities, including maintenance, work orders and replacement parts.
This description shall include:
- 1.
The criteria for identifying components as safety-related within systems currently classified as safety-related.
This shall not be interpreted to require changes in safety classification at the systems level.
- 2.
A description of the information handling system used to identify safety-related components and the methods used for its development and validation.
- 3.
A description of the process by which station personnel use this informa-tion handling system to determine that an activity is safety-related and what procedures for maintenance, surveillance, parts replacement and other activities defined in the introduction to 10 CFR 50, Appendix B, apply to.
safety-related components.
- 4.
A description of the management controls utilized to verify that the procedures for preparation, validation and routine utilization of the information handling system have been followed.
- 5.
A demonstration that appropriate design verification and qualification testing is specified for procurement of safety-related components.
The specifications shall include qualification testing for expected safety service conditions and provide support for the licensees' receipt of testing documentation to support the limits of life recommended by the supplier.
- 6.
Licensees and applicants need only to submit for staff review the equip-ment classification program for safety-related components.
Although not required to be submitted for staff review, your equipment classification program should also include the broader class of structures, systems and components important to safety required by GDC-1.
Consumers Power Company Response
- 1.
Safety-related structures, systems, components and related consumables are identified in a Q-List, which was developed and is maintained in accor-dance with the criteria of Regulatory Guide 1.29 as clarified by Item
- OC1083-0007E-NLOO Page 4 of 10 No 20a, Appendix A, Part 2 of Topical Report CPC-2A.
Nuclear Operation Department Standard (NODS) A21 which is based on the above Reg Guide, provides further detail, namely, that the following systems and components and their supports are to be included in the Q-List:
- a.
The reactor.coolant pressure boundary.
- b.
The reactor core and reactor vessel internals.
- c.
Systems* or portions of systems that are required for:
- 1) emergency core cooling; 2) post-accident containment heat removal; or
- 3) post-accident containment atmosphere cleanup (eg, hydrogen removal system).
- d.
Systems* or portions of systems that are required for:
- 1) reactor shutdown; 2) residual heat removal; or 3) cooling the spent fuel storage pool.
- e.
Those portions of the steam systems of boiling water reactors extend-ing from the outermost containment isolation valve up to but not including the turbine stop valve, and connected piping up to and including the first valve that is either normally closed or capable of automatic closure during all modes of normal reactor operation.
- f.
Those portions of the steam and feedwater systems of pressurized water reactors extending from and including the secondary side of steam generators up to and including the outermost containment isolation valves, up to and including the first valve (including a safety or relief valve) that is either normally closed or capable of automatic closure during all modes of normal reactor operation.
- g.
Cooling water, component cooling and auxiliary feedwater system* or portions of these systems, including the intake structures, that are required for:
- 1) emergency core cooling; 2) post-accident containment heat removal; 3) post-accident containment atmosphere cleanup;
- 4) residual heat removal from the reactor; or 5) cooling the spent fuel storage pool.
- h.
Cooling water and seal water systems* or portions of these systems that are required for functioning of reactor coolant system components important to safety, such as reactor coolant pumps.
- i.
Systems* or portions of systems that are required to supply fuel for emergency equipment.
- j. All electric and mechanical devices and circuitry between the process and the input terminals of the actuator.systems involved in generating signals that initiate protective action.
- k.
Systems* or portions of systems that are required for:
- 1) monitoring of systems important to safety and 2) actuation of systems important to safety.
OC1083-0007E-NLOO
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Page 5 of 10
- 1.
The reactivity control systems, eg, control rods, control rod drives and boron injection system.
- m.
The Control Room, including its associated equipment and all equipment needed to maintain Control Room within safe habitability limits for personnel and safe environmental limits for vital equipment.
- n.
Primary reactor containment
- o.
Systems*, other than radioactive waste management systems, not covered by Items a through n above that contain or may contain radioactive material, and whose postulated failure would result in conservatively calculated potential offsite doses that are more than 0.5 rem to the whole body or its equivalent to any part of the body.
- p.
The Class lE electrical systems, including the auxiliary systems for onsite electric power supplies, that provide the emergency electric power needed for functioning of Plant features included in Items a through o above.
- NOTE:
The piping system boundary includes those portions of the system required to accomplish the specified safety function and connected piping up to and including the first valve (including a safety or relief valve) that is either normally closed or capable of automatic closure when the safety function is required.
- 2.
The Palisades Plant Q-List is composed of the Equipment Data Base (EDB) and the Appendices to Palisades Administrative Procedure 10.08 and classi-fies plant structures, systems, components, chemicals and consumables as*
safety-related or non-safety-related in accordance with the requirements of NODS-A21 and Consumers Power Company's Quality Assurance Program.
When the Q status of an item cannot be determined from the Q-List or an apparent discrepancy exists, a Q-List Interpretation Form is initiated.
This form, along with an EDB Data Form if the item is new, is forwarded to the Technical Superintendent.
The Technical Superintendent assigns an individual to perform the interpretation.
Upon completion, the interpretation is given a technical review by a knowledgeable individual, a review by QA-NO and an administrative review by the Technical Superintendent.
- 3.
Nuclear Operations Department Standards (NODS) specify the standard corporate methods of accomplishing plant operating phase activities.
Because the Quality Assurance Program is an integral part of the opera-tional phase activities, the methods for implementing Quality Assurance Program controls are integrated into the NODS.
QA - Nuclear Operatio~s (QA-NO) reviews the NODS for compliance with QA Program requirements and Corporate QA policy.
In addition, QA-NO reviews station procedures, written to control plant activities, to ensure compliance with the NODS.
OC1083-0007E-NLOO
Parts Replacement Page 6 of 10 Administrative Procedure 10.02 establishes the general requirements for the procurement of replacement parts, equipment, materials, supplies and services to be used at the Palisades Plant.
The initiator for a procure-ment document utilizes the Q-List for classifying the procurement as either Q or non-Q (NQ).
An individual is then assigned to perform a tech-nical review of the procurement documents.
A quality assurance review is also performed for Q and CQ purchases.
All Q-listed equipment is pur-chased from a supplier listed on the Nuclear Operations Department ap-proved suppliers list (NODASL); suppliers of CQ and NQ items are not re-quired to be on the NODASL.
Upon receipt of a Q and CQ items, receipt inspection and review must be done by certified quality control personnel per existing QA procedures.
Receipt and Storage of Material By Administrative procedure 10.01, material received is delivered to stockroom receiving areas for receipt processing.
In receipt processing, verification is performed by the stockmen for correctness and physical acceptability on all items procured by a plant procurement document.
Material that cannot be accepted or identified by the stockkeeper is held pending resolution of the problem by the buyer in the Company's purchasing department.
After completion of receipt processing the stockkeeper places the material in the QC hold area.
A receipt inspector, under the direction of the Quality Assurance Superintendent, is responsible for the receipt inspec-tion of Q-listed materials.
Approved departmental procedures and check-lists are used to verify conformity with the procurement document.
The stockkeeper, upon satisfactory completion of the receipt processing and receipt inspection (if applicable), utilizes the Storage of Materials procedure to determine the applicable storage level requirements.
The stockkeeper also considers the manufacturer's standard storage require-ments in determining the level of storage.
Care of items in storage is exercised by the material services supervisor in accordance with requirements in the Material Control procedure, 10.01.
Maintenance The Maintenance Order (MO) is the fundamental element controlling mainte-nance activities and is used by all plant personnel to report equipment problems and request needed maintenance activities.
The Q-List block on the MO must be marked "yes" if any portion of the requested maintenance activity affects Q-listed equipment or systems.
Palisades Administrative Procedure 2.01 requires that maintenance which can affect the performance of Q-listed equipment, structures or systems be OC1083-0007E-NLOO Page 7 of 10 pre-planned and performed in accordance with written procedures, instruc-tions or drawings appropriate to the circumstances.
This includes mainte-nance on non-Q equipment which affects surrounding Q-listed equipment or non-Q equipment which can have a significant affect on plant reliability.
This planning effort ensures that adequate controls are maintained for Q-listed maintenance activities.
Modification/Testing Modifications to the Plant are controlled by Administrative Procedures 9.02, 9.03 and 9.04.
These procedures require that the modifi-cation be evaluated to determine its effect on Q-listed equipment, sys-tems, or activities.
Modifications identified as safety-related require reviews and approvals including Quality Assurance, Plant Review Connnittee, Technical Superintendent and Plant General Manger.
As a result, all safety-related interfaces are identified during the preliminary and detailed engineering prior to initiating implementation of a modification through maintenance orders and/or contracts for outside construction.
Testing of modifications is controlled by procedures which provide in-structions for identifying test requirements, preparing test procedures and controlling test activities.
Administrative Procedures 9.02, 9.03 and 9.04 require the notification of the appropriate personnel of neces-sary changes to permanent testing programs as a result of the modification (eg, training required, plant simulator modifications, Technical Specifi-cation Surveillance Program changes, changes to operating procedure, etc).
Surveillance Administrative Procedure 9.20, Surveillance Program Overview, summarizes the Technical Specifications Surveillance Program as defined in Adminis-trative Procedures 9.21, 9.22. 9.23 and 9.25.
Collectively these Adminis-trative Procedures, Surveillance Procedures and required records provide assurance that failures or substandard performance do not remain undetect-ed and that the reliability of safety-related systems is maintained.
- 4.
All plant procedures receive a technical and administrative review.
Those procedures which affect safety-related equipment also receive a PRC and QA review.
All procedures are then approved by the Plant Manager prior to implementation.
By plant Administrative Procedures, all maintenance orders, modifications and contracts are subject to review/approval prior to implementation.
Periodic surveillances and audits of maintenance, procurement, and modifi-cation procedures, conducted by the Quality Assurance Department, verify that the Q-List information is being properly utilized in these activities.
OC1083-0007E-NLOO
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Page 8 of 10
- 5.
Palisades administrative procedures 10.02, "Procurement Process-General,"
and 10.03, "Procurement of Materials," establish the requirements, respon-sibilities and method of procurement for all stock and non-stock equip-ment, materials and supplies.
These procedures provide instructions for preparing the Material Request/Authorization to Purchase (MR/ATP) Form.
These procedures include detailed statements for inclusion with the MR/ATP specifying design, manufacturer testing, shipment, and storage require-ments.
The MR/ATP Form and associated documentation receive technical, QA and Administrative reviews to ensure the adequacy of technical/quality requirements specified by the originator of the MR/ATP Form.
- 6.
Consumers Power Company's nuclear generating plants were built with a two-tier quality system.
These two tiers are "safety-related" and "non-safety-related."
Equipment which was judged to be important to safety has been upgraded to "safety-related," thus avoiding a third quality group such as "important to safety."
Equipment which has been determined to be important to safety from an operations and maintenance standpoint is addressed by NOD Standard A21 and the QA Topical Report CPC-2A.
Structures, systems, components and chemi-cals considered important to safety from operability/maintainability perspectives and not already on the Q-List as a design/construction requirement are added to the Q-List and are subject to the applicable elements of the operational QA program.
This occurs regardless of whether they were described as "safety-related" or "important to safety."
While Consumers Power Company's philosophy has been to define components, systems, and structures that are important to safety as safety-related, we are participating in the Utility Safety Classification Group and are seeking a generic resolution to the staff's concern in this regard through the efforts of this Group.
As described above, we nevertheless believe that all plant structures, systems, and components have been designed, and are maintained in a manner commensurate with their importance to the safety and operation of the plant.
NRC Position ISSUES 4.2.1 AND 4.2.2 REACTOR TRIP SYSTEM RELIABILITY (PREVENTATIVE MAINTENANCE AND SURVEILLANCE PROGRAM FOR REACTOR TRIP BREAKERS)
Page 9 of 10 Licensees and applicants shall describe their preventative maintenance program to ensure reliable reactor trip breaker operation.
The program shall include the following:
- 1.
A planned program of periodic maintenance, including lubrication house-keeping, and other items recommended by the equipment supplier.
- 2.
Trending of parameters affecting operation and measured during testing to forecast degradation of operability.
- 3.
Life cycle testing of the breakers (including the trip attachments) on an acceptable sample size.
- 4.
Periodic replacement of breakers or components consistent with demonstrat-ed life cycles.
Consumers Power Company Response Consumers Power Company's letter dated September 6, 1983 stated in part that Consumers Power Company would provide a report describing the existing preven-tative maintenance and surveillance program for the reactor trip breakers/devices.
This section of Consumers Power Company's response to Generic Letter 83-28 provides that report.
The Reactor Protection System (RPS) at the Palisades Plant consists of a General Electric relay in series with an Allen Bradley contactor in each of the four RPS channels.
Both GE and Allen Bradley were contacted subsequent to Consumers Power Company's receipt of Generic Letter 83-28 regarding their recommendations for preventative maintenance for these components.
The General Electric response indicated that there are no recommendations for maintenance on their relays.
Allen Bradley, however, referenced their latest preventative maintenance recommendations.
Those recommendations call for the contactors to be inspected and cleaned on a frequency based on past experience.
Following a review of the Allen Bradley recommendations, a preventative maintenance program was established to implement the Allen Bradley recommenda-tions for contactors.
No problems were noted during the initial inspection which was conducted during the present refueling outage.
Preventative mainte-nance will be repeated during each refueling outage.
OC1083-0007F-NLOO Page 10 of 10 Completed maintenance activities are reviewed to identify trends in equipment and system performance and to adjust the preventative maintenance frequency as appropriate.
The Technical Department performs this review per Palisades Administrative Procedure 5.03, Section 5.5.
Two Westinghouse supplied power supply circuit breakers (042-lRPS and 42-2RPS) are used at the Palisades Plant to provide manual initiation of the RPS.
These breakers do not affect the automatic initiation of the RPS.
Their functioning is required, however, when the reactor is manually scrammed from the C-06 Panel since they contain the undervoltage relays that interrupt power to the clutch power supplies.
Westinghouse was contacted regarding preventa-tive maintenance for these breakers.
No preventative maintenance was recom-mended; however, a visual inspection of the breakers has been performed.
Based on the above information, and the lack of previous problems associated with the Palisades reactor trip system, the current programs of planned preventative maintenance along with the trending of preventative maintenance results are adequate to satisfactorily address the concerns raised by the NRC in Issue 4.2.l and 4.2.2 of Generic Letter 83-28.
The remaining items of Issue 4.2 (life testing and periodic replacement) are being addressed as part of the program plan for response to Generic Letter 83-28.
(See Attachment 3.)
OC1083-0007F-NLOO
ATTACHMENT 2 Consumers Power Company Palisades Plant Docket 50-255 CONSUMERS POWER COMPANY'S RESPONSE TO GENERIC LETTER 83-28 ISSUE 2.1 AND 2.2 VENDOR INTERFACE November 7, 1983 2 Pages OC1083-0007C-NLOO (2)
NRC Position ATTACHMENT 2 ISSUE 2.1 AND 2.2 VENDOR INTERFACE For vendor interface, licensees and applicants shall establish, implement and maintain a continuing program to ensure that vendor information for safety-related components is complete, current and controlled throughout the life of their plants, and appropriately referenced or incorporated in plant instructions and procedures.
Vendors of safety-related equipment should be contacted and an interface established.
Where vendors cannot be identified1 have gone out of business, or will not supply information, the licensee or applicant shall assure that sufficient attention is paid to equipment mainte-nance, replacement, and repair, to compensate for the lack of vendor backup, to assure reliability commensurate with its safety function (GDC-1).
The program shall be closely coupled with action 2.2.1 above (equipment qualifi-cation).
The program shall include periodic communication with vendors to assure that all applicable information has been received.
The program should use a system of positive feedback with vendors for mailings containing techni-cal information.
This could be accomplished by licensee acknowledgment for receipt of technical mailings.
It shall also define the interface and divi-sion of responsibilities among the licensee and the nuclear and nonnuclear divisions of their vendors that provide service on safety-related equipment to assure that requisite control of and applicable instructions for maintenance work on safety-related equipment are provided.
Consumers Power Company Response Consumers Power Company's letter of September 6, 1983 stated that we were participating in the Nuclear Utility Task Action Committee (NUTAC) established to address the Vendor Interface portion of Issue 2.2 and that we would provide a status report of the NUTAC progress on this issue with our 120-day response to the Generic Letter.
It is the intent of the NUTAC to develop guidance for member utilities to use in establishing a proactive vendor interface program.
The NUTAC is examining alternatives for vendor/utility interface and the expansion of the INPO SEE-IN and NPRDS programs to provide additional support.
The NUTAC is also develop-ing guidance documents for use by individual utilities in addressing internal handling and control of vendor information.
The NUTAC has committed to present its recommendations to INPO for distribution by February 1, 1984.
In addition to active participation in the NUTAC, Consumers Power Company has reviewed our current handling and control of vendor manuals and vendor manual updates.
This review has shown that adequate mechanisms do exist to form the basis for meeting the intent of the vendor interface program defined in Generic Letter 83-28.
Specifically, the plant Document Control Centers do control and distribute changes to vendor manuals when received and the plant technical departments do review manual changes and technical bulletins for applicability.
However, these activities are not controlled by well-defined OC1083-0007G-NLOO Page 2 of 2 working-level procedures.
In addition, our NSSS vendors supply technical information letters (CE ADP Infobulletins and GE SILs) which are reviewed for technical applicability to our plants as part of Our Operating Experience review program.
However, most vendors do not provide revisions to manuals unless specifically requested.
Consumers Power Company will develop a plan and schedule for establishing a vendor interface program that meets the intent of Generic Letter 83-28.
Our program will utilize the results of the INPO/NUTAC program as guidance for the development of procedures to assure the receipt, control and incorporation of relevant vendor information into plant activities.
The plan and schedule will be submitted to the NRC for review sixty days after the NUTAC issues its final report.
OC1083-0007G-NLOO
9*
ATTACHMENT 3 Consumers Power Company Palisades Plant Docket 50-255 CONSUMERS POWER COMPANY'S PROGRAM PLAN AND SCHEDULE IN RESPONSE TO GENERIC LETTER 83-28 November 7, 1983 3 Pages OC1083-0007C-NLOO (3)
ATTACHMENT.3 PROGRAM PLAN AND SCHEDULE This section describes Consumers Power Company's Program Plan for completing the requirements of Generic Letter 83-28.
Consumers Power Company has made several assumptions in developing this Program Plan (Plan).
Those assumptions are listed below:
- 1.
Completion of the activities described by the Plan is dependent upon the integrated sequence of ali activities described by the Plan.
- 2.
The Plan includes those good faith efforts demonstrated by Consumers Power Company in this submittal and our September 6, 1983 letter in response to Generic Letter 83-28.
- 3.
The activities, and hence the Plan, are based on specific work scope.
Changes to the identified scope may result in changes to the integrated schedule.
- 4.
Submittal dates reflect identifiable critical resources with Consumers Power Company.
- 5.
The earliest start date for the activities described by the Plan is 60 days after the end of the current refueling outage.
- 6.
The completion dates for the activities described by the Plan are based on a completion date of January 10, 1984 for this refueling outage.
- 7.
A separate submittal will be made for each issue of Generic Letter 83-28 as the activities required by that issue are cqmpleted.
Post Trip Review (Program Description and Procedure)
A report will be prepared and submitted to the NRC by August 31, 1984 that describes the program and procedures used by Consumers Power Company's Palisades Plant for analyzing unscheduled reactor shutdowns.
That report shall describe:
- 1.
the criteria used to determine that the plant can be safely restarted;
- 2.
the qualifications, training, responsibility and authority of the plant personnel who will analyze reactor trips and authorize restart;
- 3.
the sources of plant data reviewed;
- 4.
the methods for comparing the event data with the expected behavior of the plant;
- 5.
the criteria for determining the need for independent assessment of the event.
OC1083-0007H-NLOO
Post Trip Review (Data and Information Capability)
Page 2 of 3
- A report will be prepared and submitted to the NRG by August 31, 1984 that describes and justifies the adequacy of plant equipment used to diagnose unscheduled.reactor shutdowns.
This report shall describe:
- 1.
the capability for assessing the sequence of events during the trip;
- 2.
the capability for determining the functioning of safety-related equipment;
- 3.
the capability for determining the time history of events during the reactor trip.
Equipment Classification (Reactor Trip System Components - Program Verification)
A report will be prepared and submitted to the NRG by November 30, 1984 confirming that the components of the reactor trip system are identified as safety-related on documents, procedures and information handling systems used to control safety-related activities.
Post-Maintenance Testing (Reactor Trip System Components)
A report will be prepared and submitted to the NRG by December 4, 1984 that describes the program for post-maintenance testing for the reactor trip system components.
That report will describe the operability requirements for the reactor trip system, vendor-recommended test guidance included in the test and maintenance procedures, and any Technical Specifications changes that may be required.
Post-Maintenance Testing (All Other Safety-Related Components)
A report will be prepared and submitted to the NRG by December 4, 1984 that describes the program for post-maintenance operability testing of safety-related testable equipment other than reactor trip system components.
That report will describe vendor-recommended test guidance included in the testing program and will identify required changes. to the Technical Specifications, if any.
Reactor Trip System Reliability (Vendor-Related Modifications)
A report will be prepared and submitted to the NRG by May 22, 1984 that describes vendor-recommended modifications to the reactor trip system, which vendor-recommended modifications have been implemented and a justification, if necessary, of recommended modifications that have have not been made.
OC1083-0007H-NLOO Page 3 of 3 Reactor Trip System Reliability (Preventative Maintenance and Surveillance Program for Reactor Trip Breakers)
A report will be prepared and submitted to the NRC by February 3, 1984 that describes and justifies Consumers Power Company's program for life cycle testing of the reactor trip breakers and for periodic replacement of the breakers based on the testing program.
Reactor Trip System Reliability (System Functional Testing)
A report will be prepared and submitted to the NRC by October 10, 1984 that describes and justifies the program for.on-line functional testing of the reactor trip system.
Conclusion Consumers Power Company has developed, as described above, a plan and schedule for addressing the requirements of Generic Letter 83-28.
That plan and schedule addresses those issues of Generic Letter 83-28 that are applicable to the Palisades Plant.
The plan includes good faith efforts already made by Consumers Power Company in response to the Generic Letter and reflects identi-fiable resource constraints within Consumers Power Company.
OC1083-0007H-NLOO