ML18052A229
| ML18052A229 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/13/1986 |
| From: | Bondine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8601170308 | |
| Download: ML18052A229 (3) | |
Text
consumers Power company General Offices: 1945 West* Parnell Road, Jackson, Ml 49201*:{517)788-0550 January 13, 1986
- Director, Nucle~r Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
ADDITIONAL INFORMATION TO SUPPORT HPSI FLOW INSTRUMENTS TECHNICAL SPECIFICATION CHANGE REQUEST -
PROGRAMS FOR PLANT INSTRUMENTATION Consumers Power Company submitted a Technical Specification Change Request to delete the operability requirements for the high pressure safety inj,ection (HPSI) flow instruments on July 30, 1985.
Subsequent telephone conversations with the NRC Project Manager (PM) established that we would have to commit to adopting the administrative controls reflected in a proposed Standard Technica.l Specification (STS) which was telecopied to us from NRR prior t6 NRC acceptance of our Technical Specification Change Request.
The proposed.STS provide resolution to Regulatory Guide 1.97 for Category 2 and 3 instrumenta-tion.
The proposed STS would require establishing an administrative control program for instruments that indicate system operating status.
The.program includes the following:
(i) preventive maintenance and periodic surveillance of instrumentation.
(ii) pre-planned operating procedures and back-up instrumentation to be used if one or more monitoring instruments become inoperable.
(iii) administrative procedures for ret 1urning inoperable instruments to OPERABLE status as soon as practicable.
Regt1latory Guide 1. 97 is not cons.idered a basis document of Consumers Power Company Administrative Control Program.
It is not specified by our Topical Report CPC-2A nor referenced as a commitment document.
However, our Nuclear Operations Department Standards (NODS) and Plant Administrative Procedures
. addr.ess several of the applicable...,- e+ements described above.
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OC1285-0353-NL04 EB (W. JOHNSTON)
RSB (THOMAS)
EICSB (PARR)
- FOB.*(W. REGAN)
Director, Nuclear Reactor Regulation 2
Palisades Plant Additional Information -
TSCR January 13, 1986 In response to item (i), our NODS - P07 specifies that procedures "shall be prepared, controlled and maintained by the plants for calibration of IPI" (Installed Plant Instrumentation).
It further requires "the Maintenance Department shall ensure that all Q-Listed IPI are placed in the Periodic Activity Control, (PAC) system for scheduling recalibration or maintenance."
A description of the PAC Program is found in Plant Administrative Procedure No. 2.02.
The Palisades Preventive Maintenance program (reference Plant Administrative Procedure No. 5.03) specifies that activities identified as Preventive Maintenance should be sufficient to include all plant equipment and instrumentation necessary for operability and safety.
The following criteria is taken from Procedure No. 5.03:
"a.
Equipment affecting personnel safety.
- b.
Equipment used to perform or satisfy a regulatory requirement.
- c.
Equipment required for operator control of plant systems or equipment.
- d.
Equipment that affects power generation.
Periodic Installed Plant Instrumentation (IPI) calibration controlled by Reference 3.2.4 (Control of Installed Plant Instrumentation) is included in the Plant Preventive Maintenance Program.
Periodic calibration is not limited to calibration alone, but includes other maintenance (eg, cleaning) to assure proper operation of IPI.
- a.
IPI includes all instrumentation as shown on Piping and Instrumentation Drawings (P&IDs).
- b.
IPI also includes instrumentation that has been supplied as part of larger system, (eg, skid mounted assemblies).
This instrumentation is included according to the criteria of 5.2.1 above.
Additional equipment which is considered important to the plant for other than the above criteria may be included in the program."
Plant Administrative procedures establish instrumentation as a component and define components as supporting equipment which is necessary to maintain operability of the major equipment group.
Furthermore, by definition, systems or portions of systems that are required for monitoring of systems important to safety are included in the Q-List.
In response to item (ii), our pre-planned operations administrative procedure for Equipment Control (reference Plant Administrative Procedure No. 4.03) specifies actions for inoperable equipment, redundant equipment testing OC1285-0353-NL04
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Director, Nuclear Reactor Regulation Palisades Plant Additional Information - TSCR January 13, 1986 3
requirements, removal of equipment from service, tagging control, LCOs, returning equipment*to service, operability testing, equipment clearance procedures and numerous other equipment control items.
Our preplanned maintenance administrative procedures for Processing Work Request/Work Orders (reference Plant Administrative Procedure No. 5.01) establish controls for corrective maintenance, determinations of affect on plant operations, priority scheduling requirements, determination if equipment can be released, and determination that equipment can be returned to service (among numerous other controls).
In response to item (iii) Consumers Power Company does not have a specific procedure for instruments that indicate system operating status to "ensure the capability to monitor plant variables and systems ** ~".
Our instruments are treated as supporting equipment in the same manner as the equipment, commensurate with it's importance to safety.
Our programs and procedures do however provide fqr preventive maintenance, periodi~ surveillance, use of redundant equipment, and establishing priorities in order to assure priority equipment is returned to operable status as soon as practicable.
Therefore, we believe the intent of your concern is satisfied by our existing program and procedural controls and request that.review of our July 30, 1985 Technical Specification Change Request be expedited.
Thomas C Bordine Staff Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades OC1285-0353-NL04