ML18051B348
| ML18051B348 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/22/1985 |
| From: | Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8504250146 | |
| Download: ML18051B348 (5) | |
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consumers Power company General Offices:
1945 West Parnall Road, Jackson. Ml 49201 * (517) 788-1636 April 22, 1985
- Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR
- PALISADES PLANT -
SUPPLEMENT 1 TO NUREG-0737 - REQUEST FOR MODIFICATION TO COMMISSION ORDER DATED JUNE 12, 1984 -
EMERGENCY RESPONSE CAPABILITIES David J VandeWalle Director of Nuclear Licensing The Nuclear Regulatory Commission, by letter dated June 12, 1984 issued an Order describing the schedular commitments made by Consumers Power Company with regard to the requirements of Supplement 1 to NUREG-0737.
Subsequently, by a letter dated August 23, 1984, the Commission modified this Order based on a major revision of the work activities planned by Consumers Power Company.
The purpose of this letter is to request that an extension of time be granted for completing the items listed below.
SPDS fully operational and operators trained by December 1985.
- 2. Detailed Control Room Design Review (DCRDR)
Submit a summary report to the NRC including a proposed schedule for implementation by May 1985.
- 3. Regulatory Guide 1.97 - Application to Emergency Response Facilities Submit a report to the NRC describing how the requirements of Supplement 1 to NUREG-0737 have been or will be met by May 1986.
- 4. Upgrade Emergency Operating Procedures'(EbPs)
Implement the upgraded EOPs by Feb~uary 1986
- 8504250146 850422
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OC0485-0045S-NL01
Director, Nuclear Reactor Regulation
'Palisades Plant Supplement 1 to NUREG-0737 April 22, 1985
- 5. Emergency Response Facilities This item is complete.
2 The Commission's Order and subsequent revision were based Consumers Power Company's plan and schedule for completion of the required activities of Supplement 1 to NUREG-0737.
That plan and schedule was based in turn on two major assumptions: 1) the early completion of a function and task analysis for the events described in "Combustion Engineering Emergency Procedure Guidelines" (CEN-152) and, 2) availability of qualified plant personnel, specifically a Control Operator, Shift Supervisor, or Shift Engineer, to assist in the completion of the function and task analysis and portions of the SPDS, DCRDR, Reg Guide 1.97, and EOP Upgrade activities.
As described in attachment 2 to Consumers Power Company's submittal dated June 29, 1984, the function and task analysis results serve as direct input to the EOP Upgrade, DCRDR, and SPDS activities and indirectly to the Reg. Guide 1.97 activities.
Therefore, any delay in the completion of the function and task analysis results in an equal delay in the completion of the other activities.
Accordingly, the explanation provided below describes the circumstances which led to a delay in the completion of the function and task analysis.
The function and task analysis was begun dur~ng the latter part of June 1984 with General Office personnel and a Control Operator supplied by the plant.
In August 1984, this Control Operator left the company.
Control Operators at the Palisades Plant are members of the union and may not be assigned duties other than that of a Control Operator without their consent.
Since no other Control Operator accepted this assignment, a Shift Supervisor was assigned to support the function and task analysis.
However, in October 1984, two Shift Supervisors at the Palisades Plant resigned reducing the number of Shift Supervisors available for on-shift duty to five rather than the normal complement of six.
Therefore, in order to maintain full coverage of shift operations and thereby ensure that the Plant was safely managed, the Shift Supervisor assigned to the function and task analysis was withdrawn by the Operations Department and reassigned to shift work.
During the latter part of 1984 the Palisades plant was attempting to start up from the 1983 refueling outage and experienced a series of problems including failure of a primary coolant pump and auxiliary feedwater piping.
Palisades Plant Administrative Procedures require that the Shift Supervisor authorize and ensure proper control of all maintenance and/or testing act.ivities during the shift, in addition to his other duties.
Accordingly, the Shift Supervisors were required to devote attention to issuing needed switching and I
tagging orders even though the Plant was shutdown during most of this time.
Thus, since a management decision was made to give highest priority to ensuring that critical maintenance was properly initiated and performed, no Shift Supervisor was available to assist in the function and task analysis until late February, 1985 when a group of hot license candidates received their licenses.
From February, 1985 until March, 1985 the Shift Supervisor originally assigned to the function and task analysis project was involved in turning over shift activities to a newly licensed Shift Supervisor.
Also, due OC0485-0045S-NL01
Direc~or, Nuclear Reactor Regulation
'Palisades Plant Supplement 1 to NUREG-0737 April 22, 1985 3
to the reorganization of the Nuclear Operations Department, new General Office personnel were assigned to the project during this same period.
This resulted in further delaying the restart of the function and task analysis project to April 1, 1985.
Consumers Power Company requests, for the reasons explained above, that the milestone/completion schedule for activities required by Supplement 1 to NUREG-0737 be modified as shown below:
TITLE
- 2. Detailed Control Room Design Review (DCRDR)
- 3. Regulatory Guide 1.97 - Application to Emergency Response Facilities
- 4. Upgrade Emergency Operating Procedures (EOPs)
REQUIREMENT lb. SPDS fully operational and operators trained.
2b. Submit a summary report to 3a.
3b.
4b.
the NRC including a proposed schedule for implementation of any additional enhancements identified since the pre-liminary assessment.
(ref. CPCo letters dated 3/16/1982 & 6/7/1983)
Submit a report to the NRC describing how the require-ments of Supplement 1 to NUREG-0737 have been or will be met.
Implement (installation or upgrade) requirements Implement the upgraded EOPs.
COMPLETION SCHEDULE December 1986 August 1986 January 1987 Plan and schedule to be provided with report.
December 1986 Consumers Power Company's current plan for completing the EOP Upgrade project consists of several subactivities. Initially the current Palisades Plant EOPs will be compared to CEN-152 and to the results of the function and task analysis.
The results of the function and task analysis are expected to be available by July, 1985.
This compairsion will generate a set of plant specific technical guidelines to be used in generating the upgraded EOPs. The Plant specific EOPs will then be written in the following order; 1) Standard Post Trip Actions, 2) Reactor Trip, 3) Loss of Fprced Flow, 4) Loss of All Feedwater, 5) Excess Steam Demand, 6) Loss of Coolant Accident, 7) Steam Generator Tube Rupture, and 8) Functional Recovery.
This specific order is required since the first two EOPs provide input to the following EOPs and all seven EOPs provide input to the Fuctional Recovery EOP. As each EOP is written OC0485-0045S-NL01
-.,/
0 Direc~or, Nuclear Reactor Regulation
'l>alisades Plant Supplement 1 to NUREG-0737 April 22, 1985 4
it will be verified on the Palisades simulator at our Nuclear Training Center.
In addition to validation on the simulator, each EOP will be compared to the results of the DCRDR to ensure that the information and control needs identified in the EOP are available to the operator.
After verification, any comments or corrections will be added to the new EOP.
After all the EOPs have been written and comments incorporated, the Plant operators will be trained in the use of the upgraded EOPs.
The milestone/completion dates proposed above are based on the projected availability of resources within Consumers Power Company to work on these high priority tasks and include, in the case of the SPDS and DCRDR activities, approximately six months additional time to account for unforeseen contingencies.
Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades OC0485-0045S-NL01
CONSUMERS POWER COMPANY Palisades Plant Docket 50-255 License DPR-20 Supplement 1 to NUREG-0737 Request for Modification to Commission Order Dated June 12, 1984 Emergency Response Capabilities 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 Rules and Regulations thereunder, Consumers Power Company requests an extension of time be granted on the deadline imposed under NRC Commission Order dated June 12, 1984 for completion of certain items.
Consumers Power Company's response is dated April 22, 1985.
CONSUMERS POWER COMPANY BiJi/66~
RB DeWitt, Vice President Nuclear Operations Sworn and subscribed to before me this 22nd day of April, 1985.
Sherry L Du y,
y P
- Jackson County My commission expires Novem SHERRY LYNN DURFEY Notary Public, Jackson County, Micll.
My Commission Ei:plre3 Nov. 5, 1986 NU0485-0027B-NL04