ML18051B005
| ML18051B005 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/17/1984 |
| From: | Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8407200168 | |
| Download: ML18051B005 (3) | |
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consumers Power company General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0550 July 17, 1984 Dennis M Crutchfield, Chief Operating Reactor Branch No 5 Nuclear Reactor Regulation US Nuclear Regulatory Connnission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - SUPPLEMENT 1 TO NUREG-0737 -
EMERGENCY OPERATING PROCEDURE REGULATORY GUIDE 1.97 MILESTONE ACTIVITY SCHEDULES -
SUPPLEMENTARY INFORMATION Consumers Power Company letter dated June 29, 1984 provided implementation schedules for certain Supplement 1 to NUREG - 0737 projects.
NRC Staff reviewers requested supplementary information concerning Emergency Operating Procedure (EOP) Upgrade and Regulatory Guide 1.97 project schedules proposed by Consumers Power Company.
This submittal provides the supplementary information.
Emergency Operating Procedure Upgrade Consumer Power Company's commitment of June 29, 1984 to implement the upgraded EOPs by February 1986, supercedes our September 13, 1983 commitment to implement the upgraded EOPs by December 1985.
The most recent commitment allows for an incresed work scope for function and task analysis in accordance with staff guidance.
Regulatory Guide 1.97 Consumers Power Company has reevaluated the relationship between the various Supplement 1 Projects.
This relationship is illustrated by flow chart (Attachment 2 of our June 29, 1984 submittal).
The flow chart represents a major rearrangement of work activities to utilize information being provided by our function and task analysis effort in the EOP and Detailed Control Room Design Review Programs.
The following list of activities summarizes the "critical path" of the current schedule.
8407200168 840717 PDR ADOCK 05000255 F
PDR OC0784-0020B-NL02
DMCrutchfield, Chief Palisades Plant SUPPLEMENT TO 0737 July 17, 1984
- Activity Description Complete function and task analysis Finalize plant specific technical guidelines Finalize draft emergency operating procedures Simulator validation and Plant Review Committee approval RG 1.97 draft report for internal use RG 1.97 submittal to NRC including a schedule for any necessary plant modifications Estimated Completion October 1984 November 1984 June 1985 December 1985 April 1986 May 1986 (Commitment) 2 A review by Consumers Power Company of other Supplement 1 Confirmatory Orders issued by NRC confirms that our proposed schedule for RG 1.97 is consistent with schedules previously accepted by the NRC.
The schedule is also consis-tent with a proper sequence of activities which considers guidance provided by the NRC Staff at our May 2, 1984 meeting.
NRC Staff representatives at the May 2, 1984 meeting advised the following:
- a. NRC Staff does not recommend adding instrumentation to satisfy RG 1.97 without first performing a function and task analysis and giving adequate consideration to human factors criteria.
- b. The function and task analysis may demonstrate that certain RG 1.97 variables are not essential for a particular plant.
(Each RG 1.97 variable must be addressed, however.)
- c. The function and task analysis should be an input to identify RG 1.97 Type A variables.
Consumers Power Company submittal dated September 13, 1984 concludes that 73 of the 80 RG 1.97 variables satisfy Reg Guide 1.97 guidelines.
The seven OC0784-0020B-NL02
DMCrutchfield, Chief Palisades Plant SUPPLEMENT TO 0737 July 17, 1984
- 3 remaining open items will be resolved according to the above schedule.
The open items are:
RCS Cold Leg Temperature - range and power source; RCS Pressure - range and power source; Containment Isolation Valve Position -not available for 4 valves; Radioactive Concentration in Circulating Primary -
redundancy and range; Quench Tank Pressure - range; Condensate Storage Tank Water Level - one of two transmitters not recorded; Component Cooling Water Flow to ESF System - no indication.
Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades OC0784-0020B-NL02