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Category:CORRESPONDENCE-LETTERS
MONTHYEARML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML20210G8351999-07-29029 July 1999 Final Response to FOIA Request for Documents.Records in App a Encl & Will Be Available in PDR ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20209B2081999-06-29029 June 1999 Discusses Closure of Response to RAI Re GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity. Rvid,Version 2 Issued as Result of Review of Responses.Info Should Be Reviewed & Comments Submitted by 990901 ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML18068A5831999-05-0303 May 1999 Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432 ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20217A8191999-04-29029 April 1999 Forwards Listed Matls Related to Palisades Plant June 1999 Initial License Exam ML20206E8271999-04-28028 April 1999 Forwards Palisades Plant Annual Radiological Environ Operating Rept for 1998. There Were No Reportable Events During This Period ML20207B4661999-04-23023 April 1999 Forwards Copy of Final Exercise Rept for Biennial Radiological Emergency Preparedness Exercise Conducted on 981201 for Palisades Npp.No Deficiencies Noted.Seven New Arcas Identified ML18066A4531999-04-0707 April 1999 Forwards ITS Pages 3.1.4-2 & 3.1.4-8,revising Completion Time for Action D.1,as Requested by NRC 990406 Telcon,Per TS Change Request Submitted 980126.Change Submitted Does Not Alter Conclusions of No Signficant Hazards Considerations ML18066A4481999-04-0202 April 1999 Responds to Violations Noted in Insp Rept 50-255/98-06. Corrective Actions:Nuclear Performance Assessment Dept Has Reviewed Observations & Agrees That Field Observations by Qualified Personnel Are Important Aspect of Program ML18066A4471999-03-30030 March 1999 Confirms Completion of Util Review of Design Engineering Contractor Cable Ampacity Evaluation.Evaluation Available at Plant for NRC Review ML18066A4411999-03-30030 March 1999 Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review ML18066A4441999-03-26026 March 1999 Submits Certification of Financial Assurance for Decommissioning of Palisades Nuclear Plant.Certified Rept of Status of Consumers Energy Co Decommissioning Funding & Trust Agreement Encl as Attachments 1 & 2 ML18066A4401999-03-25025 March 1999 Forwards Revised Best Estimate Fluence Evaluation Using Industry Data, Providing Justification for Using Industry Data to Determine Best Estimate Fluence.Review of Info & SE Requested ML18066A4191999-03-23023 March 1999 Forwards 1998 Annual Radioactive Effluent Release & Disposal Rept, for Palisades Plant,Providing Summary of Quantities of Radioactive Liquid & Gaseous Effluent Releases & Solid Radioactive Waste Processed During 1998 ML18066A4231999-03-22022 March 1999 Forwards Answers to 990311 Telcon Request for Addl Clarification & Revs Re ITS Section 3.4.Markups of Previously Submitted TS Pages & Revised Pages for Section 3.4 Also Encl ML20204F2091999-03-18018 March 1999 Requests That Listed TS Change Requests (Tscrs) Be Issued with Allowance That Tscrs Be Fully Implemented within Sixty Days of Issuance.Request Will Allow Time for Completion of Final Training & Procedure Changes Associated with Amend ML18066A4121999-03-18018 March 1999 Concludes That Mod to Provide Automatic Switchover of Control Room Heating,Ventilation & Air Conditioning (CRHVAC) Sys to Emergency Mode Is Not Needed to Meet Regulatory Requirements.Mod Commitment Cancelled ML18066A4141999-03-18018 March 1999 Forwards Rev 4 to COLR, Containing Limits for Fuel Cycle 14 & Future Cycles ML20204E5861999-03-16016 March 1999 Submits Current Limits of Property Insurance Maintained at Consumers Energy Co Operating Nuclear Power Plants ML18066A4131999-03-11011 March 1999 Responds to NRC 990210 Ltr Re Violations Noted in Insp Rept 50-255/98-22.Corrective Actions:Analytical Evaluation, EA-C-PAL-98-1067-01, P-50A Case to Cover Stud Evaluation, Was Submitted to NRC on 981220 ML18068A5241999-02-12012 February 1999 Resubmits Relief Request 12,with Addl Info That Includes Specific Locations Where Relief Request Would Be Applied,Per 10CFR50.55a(g)(5)(iii) ML18068A5211999-02-11011 February 1999 Informs NRC That Implementation of Formal Industry Position on Severe Accident Mgt at Palisades Plant Was Completed on 981217 ML20203F2541999-02-10010 February 1999 Informs That Beginning 990216,DE Hills Will Be Chief of Operations Branch Which Includes Operator Licensing Function 1999-09-30
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML18068A5831999-05-0303 May 1999 Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432 ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20217A8191999-04-29029 April 1999 Forwards Listed Matls Related to Palisades Plant June 1999 Initial License Exam ML20206E8271999-04-28028 April 1999 Forwards Palisades Plant Annual Radiological Environ Operating Rept for 1998. There Were No Reportable Events During This Period ML20207B4661999-04-23023 April 1999 Forwards Copy of Final Exercise Rept for Biennial Radiological Emergency Preparedness Exercise Conducted on 981201 for Palisades Npp.No Deficiencies Noted.Seven New Arcas Identified ML18066A4531999-04-0707 April 1999 Forwards ITS Pages 3.1.4-2 & 3.1.4-8,revising Completion Time for Action D.1,as Requested by NRC 990406 Telcon,Per TS Change Request Submitted 980126.Change Submitted Does Not Alter Conclusions of No Signficant Hazards Considerations ML18066A4481999-04-0202 April 1999 Responds to Violations Noted in Insp Rept 50-255/98-06. Corrective Actions:Nuclear Performance Assessment Dept Has Reviewed Observations & Agrees That Field Observations by Qualified Personnel Are Important Aspect of Program ML18066A4471999-03-30030 March 1999 Confirms Completion of Util Review of Design Engineering Contractor Cable Ampacity Evaluation.Evaluation Available at Plant for NRC Review ML18066A4411999-03-30030 March 1999 Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review ML18066A4441999-03-26026 March 1999 Submits Certification of Financial Assurance for Decommissioning of Palisades Nuclear Plant.Certified Rept of Status of Consumers Energy Co Decommissioning Funding & Trust Agreement Encl as Attachments 1 & 2 ML18066A4401999-03-25025 March 1999 Forwards Revised Best Estimate Fluence Evaluation Using Industry Data, Providing Justification for Using Industry Data to Determine Best Estimate Fluence.Review of Info & SE Requested ML18066A4191999-03-23023 March 1999 Forwards 1998 Annual Radioactive Effluent Release & Disposal Rept, for Palisades Plant,Providing Summary of Quantities of Radioactive Liquid & Gaseous Effluent Releases & Solid Radioactive Waste Processed During 1998 ML18066A4231999-03-22022 March 1999 Forwards Answers to 990311 Telcon Request for Addl Clarification & Revs Re ITS Section 3.4.Markups of Previously Submitted TS Pages & Revised Pages for Section 3.4 Also Encl ML20204F2091999-03-18018 March 1999 Requests That Listed TS Change Requests (Tscrs) Be Issued with Allowance That Tscrs Be Fully Implemented within Sixty Days of Issuance.Request Will Allow Time for Completion of Final Training & Procedure Changes Associated with Amend ML18066A4141999-03-18018 March 1999 Forwards Rev 4 to COLR, Containing Limits for Fuel Cycle 14 & Future Cycles ML18066A4121999-03-18018 March 1999 Concludes That Mod to Provide Automatic Switchover of Control Room Heating,Ventilation & Air Conditioning (CRHVAC) Sys to Emergency Mode Is Not Needed to Meet Regulatory Requirements.Mod Commitment Cancelled ML20204E5861999-03-16016 March 1999 Submits Current Limits of Property Insurance Maintained at Consumers Energy Co Operating Nuclear Power Plants ML18066A4131999-03-11011 March 1999 Responds to NRC 990210 Ltr Re Violations Noted in Insp Rept 50-255/98-22.Corrective Actions:Analytical Evaluation, EA-C-PAL-98-1067-01, P-50A Case to Cover Stud Evaluation, Was Submitted to NRC on 981220 ML18068A5241999-02-12012 February 1999 Resubmits Relief Request 12,with Addl Info That Includes Specific Locations Where Relief Request Would Be Applied,Per 10CFR50.55a(g)(5)(iii) ML18068A5211999-02-11011 February 1999 Informs NRC That Implementation of Formal Industry Position on Severe Accident Mgt at Palisades Plant Was Completed on 981217 ML18066A4051999-02-10010 February 1999 Requests Copy of Consumers Energy (Palisades) Formal Response to RAI Dtd 990512 (USI A-46) ML18066A3921999-01-29029 January 1999 Forwards Licensee Interpretation of TS Requirements for Performance of SRs as Applied to Instrumentation Channel Calibr.Ltr Established No New Commitments ML18066A3891999-01-28028 January 1999 Submits Response to Concern Expressed in Insp Rept 50-255/98-06 Re Whether Palisades ISI Program Was Being Conducted IAW Applicable Requirements 1999-09-30
[Table view] Category:UTILITY TO NRC
MONTHYEARML18057A4811990-09-17017 September 1990 Confirms 900718 Telcon Notification Re Westinghouse Agreement to Join Utils as Equity Investor in Plant ML18057A4551990-09-0606 September 1990 Forwards Proprietary Info Re Dept of Labor Decision on Discharge of Former Employee of Util,Per NRC 900809 Request. No 10CFR50.7 Violation Occurred Since Job Performance Was Reason for Discharge.Encl Withheld (Ref 10CFR2.790(a)(6)) ML18057A4521990-09-0404 September 1990 Submits Addl Info Re Circuit & Raceway Schedule Enhancement Project,Per Insp Rept 50-255/90-10.Electrical Cable Separation & Channelization Anomalies Identified During Review of Physical Raceway Installations Will Be Evaluated IR 05000255/19900101990-09-0404 September 1990 Submits Addl Info Re Circuit & Raceway Schedule Enhancement Project,Per Insp Rept 50-255/90-10.Electrical Cable Separation & Channelization Anomalies Identified During Review of Physical Raceway Installations Will Be Evaluated ML18057A4371990-08-31031 August 1990 Forwards Analysis Concluding That Plant Reactor Beltline Matl Upper Shelf Energy Will Remain Greater than 50ft-lbs Until Yr 2032,per 900716 Commitment ML18057A4381990-08-31031 August 1990 Forwards Info Re Contamination of South Radwaste Area,Per 10CFR20.302,in Response to NRC 900112 Request.Approval Requested to Dispose of Low Level Radwaste in Place ML20059E0001990-08-29029 August 1990 Forwards Semiannual fitness-for-duty Program Performance Rept for Jan-June 1990 ML18057A4201990-08-24024 August 1990 Forwards Revised Application for Amend to License DPR-20, Changing Tech Specs Re Incore Analysis Program.Request Revised Per NRC Comments During 900709 Meeting ML18057A4021990-08-22022 August 1990 Forwards Missing Pages from Decommissioning Funding Rept, Consisting of Pages 25 & 26 of Attachment a to Exhibit E ML18057A4241990-08-21021 August 1990 Forwards Application for Amend to License DPR-20,changing Tech Spec 4.5.1 Re Statement on Integrated Leak Rate Test ML18057A4071990-08-21021 August 1990 Forwards Tech Specs Change Request to License DPR-20,to Remove Redundant Requirements & Change Basis Statements No Longer Applicable ML18057A4121990-08-21021 August 1990 Forwards Application for Amend to License DPR-20,changing Tech Specs to Revise Wording for Reactor Protective Sys Trip Setting Limits for Steam Generator Low Water Level ML18057A4181990-08-21021 August 1990 Forwards Description of Changes Being Made to Plant Site Emergency Plan & Emergency Plan Changes.Change Allows Reduction in Shift Staffing During Cold Shutdown for Stated Staff ML18057A3911990-08-17017 August 1990 Forwards Replacement Pages,To Palisades Second 10-Yr Interval Inservice Insp Program. ML18057A3851990-08-17017 August 1990 Forwards Addl Info in Support of NRC Development of SER for full-term OL for Plant,Including Date of SER Providing Provisional OL to Plant & Summary of Valid Exemptions from 10CFR Regulations,Per Telcon ML18057A3841990-08-17017 August 1990 Provides Addl Info Re Transfer of Plant Ownership to Palisades Generating Co,Per NRC 900725 Ltr ML18057A3821990-08-14014 August 1990 Requests That Bechtel-KWU Rept 128901/MJS, Full Flow Testing of Motor-Operated Valve MO-1042A, Be Withheld (Ref 10CFR2.790(b)(1)) ML18057A3721990-08-0808 August 1990 Forwards Addl Info Re Util Request for Exemption from Separation Criteria of 10CFR50,App R,Section III.G.2 Re Containment Air Room ML20055J1421990-07-26026 July 1990 Responds to Commitment Oversight Issue Resulting from Insp Rept 50-255/90-08.Commitment Mgt Seminar Training Will Be Complete Prior to 901001 ML18057A3561990-07-26026 July 1990 Forwards Certification of Financial Assurance for Decommissioning ML18057A3411990-07-18018 July 1990 Forwards Revised Proposed Tech Spec Page 6-3,now Designated as Page 6-1b,adding Section 6.3.4,now Designated as Section 6.3.5 to Remove Organization Charts,Per Generic Ltr 88-06 ML18057A3381990-07-16016 July 1990 Advises That Util Does Not Foresee Need to Rely on Section V.C of App G to Remain in Compliance W/Upper Shelf Energy (Use) Requirements Re Use of Matl in Reactor Beltline ML18057A3281990-07-13013 July 1990 Responds to Request for Addl Info Re Second 10-yr Interval Insp Program,Per 900418 Telcon.Util 900329 Response Revised to Reflect That Certain Components in Class 2 Sys Should Not Be Exempted,Per IWC-1220 of 1974 ASME Code Section XI ML18057A3191990-07-0909 July 1990 Forwards Performance Indicator Trend Graphs for Jan 1989 - May 1990 ML18057A3201990-07-0606 July 1990 Discusses Reassessment of Control Room Temp Following Station Blackout Event.Results of Analysis Indicate That Control Room Temp Will Remain Below 112 F for 4 H After Onset of Blackout ML18057A3171990-07-0303 July 1990 Provides Summary of Upgrades Made to Plant Electrical Distribution Sys,Per 870714 Loss of Offsite Power Event When Inadvertent Actuation of Water Deluge Spray Sys for 1-2 Startup Transformer Resulted in Bus to Ground Fault ML20058K3771990-07-0202 July 1990 Forwards Rev 26 to Security Plan.Rev Withheld (Ref 10CFR73.21(c)) ML18057A3111990-06-25025 June 1990 Forwards Endorsements 116 & 117 to Nelia Policy NF-179 & Endorsements 102 & 103 to Maelu Policy MF-50 ML18057A3101990-06-25025 June 1990 Responds to Generic Ltr 90-04, Request for Info on Status of Licensee Implementation of Generic Safety Issues Resolved W/Imposition of Requirements on Corrective Actions. ML18057A3031990-06-22022 June 1990 Provides Addl Info Re Environ Qualification of Instrument Circuit Associated W/Steam Generator Pressure Channel PT-0752D,per Insp Rept 50-255/90-05.Circuits Spliced Directly to Pigtail from Electrical Penetration Connector ML18057A3001990-06-21021 June 1990 Concurs W/Nrc Change in Terminology & Submits Revised Proposed Section 4.14 of Tech Specs ML18057A2771990-06-15015 June 1990 Forwards Corrected NRC Form 474 Re Simulation Facility Certification,Indicating Exceptions to Ansi/Ans 3.5 ML18057A2901990-06-13013 June 1990 Forwards Application for Amend to License DPR-20,revising Tech Spec 3.3.1.b Re Safety Injection Tank Min Level ML18057A2941990-06-12012 June 1990 Advises That Submittal of Second Interval Inservice Insp Program Delayed from 900615 to 900715,per 900418 Telcon ML18057A2711990-06-11011 June 1990 Requests Temporary Waiver of Compliance from Tech Spec 3.1.1i in Order to Maintain Plant in Hot Shutdown While Repair Made to Pressurizer Heater Power Supply.Request Based on 900608 Failure of Heater Transformer 15 ML18057A2641990-06-11011 June 1990 Provides Response to NRC Requalification Exam Rept Dtd 900410 on NRC Concerns Re Facility & Training Ctr Staffing. Adequate Staffing Will Be Maintained to Ensure Operator Requalification Program Successful ML18057A2591990-06-11011 June 1990 Forwards Palisades Simulator Certification Submittal. ML18057A2631990-06-10010 June 1990 Requests Temporary Waiver of Compliance from Tech Spec 3.1.1i to Enable Plant to Be Maintained in Hot Shutdown While Repair Made to Pressurizer Heater Power Supply.Waiver Requested for 900611-18 ML18057A2571990-06-0808 June 1990 Responds to NRC 900509 Ltr Re Violations Noted in Insp Rept 50-255/90-12.Corrective Actions:Continuing Training Program Will Be Developed for Supervisors That Will Discuss Fire Protection Program Implementation Topics ML20043D0601990-06-0404 June 1990 Forwards Rev 25 to Security Plan,Including Changes to Security Plan Drawings to Clarify Protected Area Boundary within Plant Security Bldg & Vital Area Boundaries in Other Specific Vital Areas of Plant.Rev Withheld (Ref 10CFR73.21) ML18057A2581990-06-0101 June 1990 Forwards Revised Response to Violations Noted in Insp Rept 50-255/89-26.Concurs That Tests Performed Using Instrumented Insp Technique During 1988 Refueling Outage Considered Invalid ML18057A2561990-05-31031 May 1990 Advises That No NPDES Notifications Required Nor Any Repts of Oil or Salt Occurred During Nov 1989 - Apr 1990 ML18057A2541990-05-30030 May 1990 Forwards Response to Technical Evaluation Rept EGG-NTA-8333 Which Evaluated Plant Compliance w/NUREG-0737,Item II.D.1 & Requested Addl Info Re New PORVs & Block Valves No Later than Jan 1990 ML18057A2511990-05-30030 May 1990 Forwards Final Response to Concerns Re Porv/Block Valve Mod, Per 900308 Meeting.Bechtel Technical Rept Withheld ML18057A2501990-05-29029 May 1990 Forwards Investigation Rept Re Unsatisfactory Performance Testing of Fitness for Duty Program Blind Performance Test Samples ML18057A2411990-05-24024 May 1990 Forwards Revised Application to Amend License DPR-20, Consisting of Revised Attachments 1 & 5 to 890227 Amend Request,Reflecting Transfer of Plant Ownership ML18057A2311990-05-17017 May 1990 Forwards Analysis of Reactor Pressure Vessel Fast Neutron Fluence & PTS Ref Temps for Palisades Nuclear Plant. Rept Concludes That PTS Screening Criteria Will Be Exceeded at Axial Welds in Sept 2001 as Opposed to Mar 2002 ML18054B5861990-05-0707 May 1990 Forwards Monthly Trend Graph Rept for Jan 1989 - Mar 1990 Covering Safety Status Performance Indicators for HPSI, Auxiliary Feedwater,Emergency Ac Power,Lpsi,Containment Spray & Svc Water Sys ML18054B5801990-04-30030 April 1990 Responds to Request for Addl Info on Proposed Administrative Changes to Tech Spec Section 3.0.4,per Generic Ltr 87-09. Licensee Will Implement Program to Assure Appropriate Level of Mgt Approval Required When Operating Conditions Changed ML18054B5741990-04-25025 April 1990 Requests That Correspondence Re 890227 Application for Amend to License DPR-20 to Permit Transfer of Ownership of Plant Be Sent to Listed Address 1990-09-06
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. *41, consumers Power Kenneth W Berry Director POWERINli Nuclear LJcensing
/llllCHlliAN'S PROliRESS General Offices: 1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-1636 August 29, 1986
.... *. ).
Director, Nuclear Reac_tor Regu:lat;ion.,
US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION - PALISADES PLANT SAFETY PARAMETER DISPLAY SYSTEM DISPLAY CLUTTER AND VALIDATION AND VERIFICATION Generic Letter 82-33 entitled, "Supplement 1 to NUREG-0737 - Requirements for Emergency Response Capabilities", was issued by the Nuclear Regulatory Commis-sion on December 17, 1982. Item 4 of Supplement 1 required, in part, that each licensee develop and implement a Safety Parameter Display System (SPDS) that would aid the plant operators in rapidly and reliably determining the safety status of the plant.
By letter dated July 31, 1984, Consumers Power Company submitted a preliminary design description of the Safety Parameter Display System proposed for the Palisades Plant. Subsequently, by letter dated August 21, 1985, Consumers Power Company submitted a revised design description and preliminary Safety Analysis Report (SAR) for the Palisades Plant Safety Parameter Display System.
The NRC, by letter dated March 17, 1986, requested that Consumers Power Company provide additional information regarding the Palisades SPDS in order for the NRC to complete its review of the SAR. A portion of the additional information requested was provided to the NRC by our letter dated May 19, 1986. In our May 19, 1986 submittal, Consumers Power Company stated that the additional information requested concerning "Display Clutter," and "Verifica-tion and Validation" would be submitted by August 29, 1986. Attachment 1 to this report provides the additional information concerning these two subjects.
In conference calls with the NRC staff on July 10, and July 16, 1986, addi-tional clarification of certain information provided in our May 19, 1986 submittal was requested. Specifically, clarifications in the following four 8609osoo0s 860029 i ,*
~DR . ADOCK osooo25'.5 I
. PDR' I OC0886-0037S-NL01
Director, NRR 2 Palisades Plant Response to Request for Additional Information August 29, 1986 areas were requested; safety function parameter selection,_ trending of neutron flux, validation of safety function parameter input data, and the use of containment sump level to indicate the viability of the recirculation mode of operation. The report provided in Attachment 1 includes the information necessary to clarify these items.
Appendix A to Attachment 1 provides an executive summary of the results of the experimental validation of the c*ombustion Engineering designed CFMS carried out by the Halden Project in co-operation with Combustion Engineering.
This report is being submitted as a portion of Consumers Power Company's response to the NRC question concerning the validation and verification of the Palisades CFMS. Further discussion of the results of this experimental program and its application to the Palisades CFMS is provided in Attachment 1.
Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades OC0886-0037S-NL01
ATTACHMENT 1 Consumers Power Company Palisades Plant Docket 50-255 Response to Request for Additional Information Palisades Plant Safety *Parameter Display System Display Clutter and Validation and Verification August 29, 1986 9 Pages OC0886-0037S-NL01
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Director, NRR 1 Palisades Plant Attachment 1 August 29, 1986 I. DISPLAY CLUTTER The March 17, 1986 NRC request for additional information asked for information on the human factors guidelines used to design the Palisades CRT display formats. This sec.tion provides the requested information.
The Critical Function Monitoring System (CFMS) methodology utilized at the Palisades Plant evolved from Combustion Engineering's (CE) design efforts on the NUPLEX 80 advanced control center for nuclear power plants. This effort, which commenced prior to requirements for an SPDS, developed human engineering principles to be used in designing color graphic displays. The basic guidelines developed for designing displays are summarized below. These guidelines were extracted from References 1 and 2.
To adapt the displays to the human operator, some basic human engineer-ing principles had to be developed. These principles were a color convention, a basic symbology (component configuration coding), alarm identification (color and blink), display of variables (alphanumerics, bars, thermometers), and display sector/page information. The C-E color convention is summarized in Table 1.
TABLE 1 RECOMMENDED COLOR CODES Color Use Black Display Background Blue Nonessential or Non-Information Bearing Data Cyan Essential or Information Bearing Numeric Data or Text Green Off, De-Energized, Closed, Normal Red On, Energized, Open, Bypassed White Intermediate Between Green and Red Yellow Cautionary, Attention Required Magenta Danger, Immediate Attention Required
\
I OC0886-0037S~NL01
Director, NRR 2 Palisades Plant Draft Black is the unactivated screen color and serves as a logical background. Blue lies far below the eye's spectral sensitivity peak and may be difficult to perceive when the eye is stimulated by other colors on the CRT. This may be used as an advantage for labels and other static items which are purely advisory in nature. If the operator wishes to read the label associated with a variable it becomes informa-tion, otherwise it is noise. The poor contrast of blue on black reduces the impact of the noise but still allows the label to serve as inf orma-tion when focused upon. Cyan has a contrast ratio close to white but avoids the greater stimulus from the longer wavelength components of
. white. The corresponding legibility of cyan makes it applicable for numerics and test which always contain information.
Red and green have traditionally been used throughout the power industry to indicate ON and OFF respectively. The conventional use of red and green were retained, white is used as an intermediary state. Thus a valve used for throttling would be red when fully open, white when partly open, and green when fully closed. Yellow and magenta provide logical alarm colors as well as excellent contrast with black for portrayal of necessary alarm information. Additionally, their unique-ness aids the search task.
The choice of symbols utilized for the video displays is based on an experimental analysis of a plant operator preferred symbology research project. Many operators from different utilities contributed to this project.
Shape coding of the symbols is used in conjunction with color coding as a redundant indication of component status. By altering the configura-tion of a symbol, component operating status information is displayed to the operator. For example, a hollow red valve symbol is used to repre-sent an open valve, and a filled-in green valve symbol is used to -
represent*a closed valve. The hollow and filled-in shape coding allows proper interpretation of non-color hard copies of the displays. Table 2 shows examples of the use of shape coding for displaying component status.
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Director, NRR 3 Palisades Plant Attachment 1 Draft TABLE 2 NUPLEX 80 SHAPE CODING FOR COMPONENT STATUS Symbol Component Status Configuration Color Pump On Hollow Red Pump Off Solid Green Circuit Breaker Current Closed Red (Energized)
Circuit Breaker No current Open Green (De-energized)
Switch Current Closed Red (Energized)
Switch No current Open Green (De-energized)
Valve Open Hollow Red Valve Closed Solid Green Valve Throttled Combination White The standard flow direction used on the graphical displays is from the top of the screen to the bottom of the screen and from left to right.
These flow directions have been selected to be consistent with the operator's standard reading direction (left to right, top to bottom).
Wherever possible in the design of a particular display, these flow direction conventions have been followed. The use of the standard flow method allows the displays to incorporate a success path structure where the source, inlet control, driving force, processing, outlet control, and sink are displayed from left to right. The use of a consistent flow direction allows the users to be trained in the generic interpretation of the display set rather than the specific nuances of display (such as some displays flowing the opposite direction). The ability to utilize the consistent flow direction is especially important when the users in the Technical Support Center (TSC) and the Emergency Operation Facility (EOF) may not be familiar with the displays.
All "standard" methods are subject to exceptions and,. at times, a more effective means of presentation might require a different flow pattern.
Examples of an exception are looped systems such as the Primary Coolant OC0886-0037S-NL01
Direct~r, NRR 4 Palisades Plant Draft System and the Chemical Volume Control System. In these cases, a looped flow is utilized.
It is understood that on occasion the flow direction o~ the display system may be different from existing engineering drawings. The problem of whether this difference warrants an exception then arises~ In general, the use of a standard flow direction on the displays is still valid. The engineering drawings were not laid out for plant operation but rather for plant construction, and often reflect the whims and spatial limitations of the draftsman rather than an effective presenta-tion of information. The success path format utilized on the CFMS displays is designed to allow the operator to rapidly access the status of a system and plan remedial action if required. It is usually not effective to change the flow direction within the context of the display set. As in the use of color codes, the consistent use of a direction code is very important within a context. Consumers Power Company has concluded that maintaining consistency within the display set and making the directional change between contexts (eg, between drawings and displays) would be more effective and less error prone than having the change in flow direction between two display pages.
Recommended values for information density used in the design of the Palisades CFMS are summarized in Table 3. Obviously, these are general in nature and should not be used unquestioningly. The display designer must balance them against his experience for each and every display.
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Director, NRR 5 Palisades Plant Draft TABLE 3 RECOMMENDED VALUES FOR INFORMATION DENSITY Total display loading, maximum 25%
Dynamic display loading, maximum 18.75%
Text word size, -maximum 12 characters Recommended 6 characters or less Numeric word size, maximum 12 characters Recommended 4 characters or less Symbol size, maximum 2 inches (5.08 cm)
Recommended
Word orientation Horizontal Word spacing 2 inches (5.08 cm)
Preferred quadrant Upper right (in.order of preference) Upper left, lower left, lower right Several of the hard copy displays submitted with our August 21, 1985 response do appear somewhat cluttered. These copies contained a grid surrounding the display which is used for display development, these grids are not included in displays presented to the operator thus reducing the apparent clutter. Further, the black and white hard copies of the displays do not fully represent the screen as actually viewed by an operator. Nonessential information, such as labels and other static items, is colored dark blue. The poor contrast of dark blue on black redu~es the impact of the noise while still allowing the label to serve as information when focused on. However, because the copying process does not provide an effective demonstration of these contrast differ-ences, the CRT displays do not appear as cluttered to an operator as might be inferred from the hard copies provided with our response.
OC0886-0037S-NL01
Direct9r, NRR 6 Palisades Plant Attachment 1 Draft II VERIFICATION AND VALIDATION The March 17, 1986 NRC letter also requested information on the verifi-cation and validation effort performed on the design and development of the Palisades SPDS display system. Consumers Power Company's response of May 19, 1986 noted that the Palisades CFMS was procured prior to the formal requirements for verification and validation being issued by the NRC and therefore, no formal validation and verification plan ~as used in the design of the Palisades CFMS. However, Consumers Power Company noted that an experimental validation test program of the CFMS design philosophy had been conducted and committed to providing information on this program of man-in-the-loop validation testing. This section provides that additional information.
An experimental validation of the Critical Function Monitoring System (CFMS) was carried out as part of the Halden Project as a joint effort among Combustion Engineering, the Technical Research Center of Finland (VTT) and Imatran Noima Oy (IVO). The experiments took place at the PWR training simulator situated at the Loviisa Nuclear Power Plant in Finland. The overall objective of the test program was to determine the impact of the CFMS on operator performance and hence, on operational safety. The experiment was designed to record and measure operator performance both with and without the use of the CFMS, to assess the correspondence between the expected and actual effects of operator use of the CFMS, to develop predictions about operator performance when using the CFMS, and to determine what problems might be expected from introducing the CFMS into an existing control room.
Two specific hypotheses were investigated: (1) that operators using the CFMS would maintain plant critical functions more effectively, and (2) that effective maintenance of plant critical functions was equivalent to improved plant safety. The results of the experiment indicated that overall, the operating crews used the CFMS to obtain useful information on critical safety function, and that the CFMS proved useful to the operating crews in providing an overview of plant conditions and assis-tance in early identification of process transients.
The Critical Functions Monitoring System implemented in this experimen-tal program contained the seven critical functions identified in the CE Emergency Procedure Guidelines (CEN-152): Core Reactivity Control, Reactor Coolant System (RCS) Inventory Control, RCS Pressure Control, Core Heat Removal, RCS Heat Removal, Containment Isolation, Containment Temperature/Pressure Control. The CFMS implemented at the Palisades Plant uses the same seven critical functions plus an eighth critical function, Environmental, which was not implemented in the experimental system. The experimental CFMS employed in the Loviisa experiments operated with the same top down hierarchy employed by the Palisades CFMS, wherein the top level displays consist of status indicators providing the operator with an overview of the condition of the plant safety systems and quick access to lower level displays which provide greater detail on specific parameters and systems. The hardware used by the operators to interface with the CFMS at the Loviisa test consisted OC0886-0037S-NL01
DirectQr, NRR 7 Palisades Plant Attachment 1 Draft of the same type of equipment as that installed in the Palisades system, a keypad for requesting different displays .and acknowledging alarms, and a color graphic video display terminal (CRT). The CFMS display format used in the Loviisa experiment was essentially the same as the format of the CFMS displays in use at the Palisades Plant in that the display shows a mimic diagram of major plant systems, important system parameter values, and the status of major components in the system.
Although there are differences between the experimental system tested at Loviisa and the Palisades CFMS, the differences are primarly in the CRT display format and are attributable to differences between plant designs and in the selection of specific plant process parameters monitored, not in the basic structure or design philosophy of the CFMS. Thus, these differences do not invalidate the conclusions of the Loviisa test program when the test results are applied to the Palisades CFMS.
Therefore, based on the similarities of design and operating philosophy between the experimental CFMS tested at Loviisa and the Palisades* CFMS, Consumers Power Company has concluded that the results of the Loviisa man-in-the-loop validation experiment are applicable to the Palisades CFMS.
III. ADDITIONAL CLARIFICATION OF MAY 19, 1986 RESPONSE In a telephone conversation on July 10, 1986, the NRC reviewer requested additional clarification of information submitted by Consumers Power Company letter dated May 19, 1986. The clarifications requested were i~
four areas; safety function parameter selection, use of containment sump level indication, trending of neutron flux and validation of safety function input data. This section provides the requested clarifications.
A. Safety Function Parameter Selection
- 1. Hot and Cold Leg Temperatures, Core Exit Temperatures Our May 19, 1986 response on parameters monitored for each safety function did not explicitly state that hot and cold leg temperatures were monitored as part of the "Reactor Core Cooling and Heat Removal From the Primary System" critical safety function. Our response did state that subcooled margin based on hot and cold leg temperatures and core exit temperatures are monitored. This use of hot and cold leg temperatures was meant to indicate that hot and cold leg temperatures were parameters included to assess the "Core Cooling and Heat Removal" safety function. These parameters are monitored for this function and are displayed on page 211. Core exit temperatures were noted as being parameters required to monitor core heat removal in Section 1.1.4 of our May 19, 1986 submittal.
OC0886-0037S-NL01
Direct~r, NRR 8 Palisades Plant Attachment 1 Draft
- 2. Containment Sump Level The choice of parameters monitored for each critical safety function was based on the safety function status checks identified in the Combustion Engineering Emergency Procedure
- Guidelines (CEN-152). Containment sump level is not included as a parameter monitored for the "PCS Integrity" critical safety function for the following reasons:
- a. Containment sump level is not a direct measure of PCS integrity. Sump level can increase as a result of steam line breaks inside of containment which do not effect PCS integrity. Further, sump levels will remain constant for steam generator tube ruptures which do violate PCS integri-ty. Thus, sump level changes do not correlate directly to violations of PCS integrity.
- b. Parameters selected for monitoring the critical safety functions are those required to be controlled within appro-priate limits in order to assure that critical safety functions are being maintained. The operator has no control over the containment sump level.
Containment sump level is considered in the CEN-152 Emergency Procedure Guidelines as a diagnostic parameter. Sump level is used*
in conjunction with other parameters to determine the type event *in progress to allow selecting the optimal recovery guideline. Fur-ther, sump level is used to confirm that the safety injection pumps have adequate NPSH following the automatic switchover of the suction of these pumps to the containment sump.
Containment sump level is considered to be an important parameter and, as such, is included in the CFMS and is displayed on CRT pages 244 and 321 *. Sump level is not, however, considered to be a neces-sary parameter for determination of challenges to the critical safety functions and thus is not included as information required to assess "Reactor Coolant System Integrity."
B. Neutron Flux Trending Consumers Power Company's May 19, 1986 submittal provided informa-tion on the one second update rate utilized by the SPDS for display-ing trends of plant parameters. This response did not explicitly state that this update rate is acceptable for monitoring expected neutron flux oscillations. Consumers Power Company has reviewed the Palisades Plant Final Safety Analysis and determined that no neutron flux oscillations which might be indicative of a severe accident are discussed in this analysis. Further, no mechanism for rapid oscil-lations of reactivity has been identified which could result in rapid neutron flux oscillations. Changes in neutron flux which approximate step changes, such as following a reactor trip, have been identified, however, the one second update rate is sufficient OC0886-0037S-NL01
Director, NRR 9 Palisades Plant Attachment 1 Draft for an operator to clearly resolve the time such a step change in power occurs. Based on the above, we have concluded that the one second update rate is sufficient to provide operators the informa-tion necessary to trend neutron flux under all conditions.
C. Validation of Safety Function Input Data The May 19, 1986 submittal provided a description of the parameters monitored by the SPDS for each critical safety function. Of the parameters described, approximately 80% are provided with redundant inputs. Validation of these inputs is performed by a combination of input range checks and validity checks of .the redundant inputs.
All analog inputs to the SPDS are checked for out of range condi-tions prior to display. Inputs found to be out of range are indi-cated on the out-of-range display page and indicated on operational displays by question marks "????" in the value field. An input quality flag is also carried by the signal and utilized in safety function algorithms which require the input. For parameters having redundant inputs, the safety function algorithms determine the best estimate value to be utilized by evaluating the quality flag of each input. If there are no good quality inputs for a particular parame-ter, the color of the top level display matrix box and alarm leg name associated with that parameter are changed to yellow to indi-cate to the operator that the input data is questionable.
For some parameters, consistency checks against other input parame-ters are performed to further validate the input. For example, the source range nuclear instruments are turned off automatically when the wide range nuclear instruments exceed a certain value. To prevent this from indicating an invalid source range signal, the source range validity check determines if the wide range nuclear instruments are on scale above a certain value prior to tagging the source range instruments as invalid. A similar check is performed for the wide range nuclear instruments which can go off scale low when neutron level is in the source range. For this case, the status of the source range instruments is determined prior to flagging the wide range nuclear instrumentation invalid.
Parameters utilized in the critical safety function algorithms which do not have redundant inputs include the following:
- a. Shutdown cooling flow
- b. Shutdown cooling heat exchanger inlet temperature
- c. Condenser off-gas radiation
- d. Steam line radiation (one monitor/steam generator)
- e. Containment temperature OC0886-0037S-NL01
Direct9r, NRR 10 Palisades Plant Attachment 1 Draft Of these items, a through d have only one transmitter available in the plant and thus redundancy is not provided in the computer.
Items c and d taken together provide for redundancy in determining secondary steam radiation. Item e, containment temperature, is redundant in its usage with containment pressure. Items a and b, which monitor shutdown cooling, are backed up by other parameters such as subcooled margin which would also indicate inadequate shutdown cooling. Thus, the combination of redundant inputs and functional redundancy provided for parameters having only a single input are adequate to provide the operator with valid safety func-
, tion data.
IV. REFERENCES
- 1. C H Meijer, J L Pucak and T J O'Connell, "Applied Human Engineering to Improve the Man-Process Interaction in a Nuclear Power Plant,"
Presented at IEEE 1980 Symposium on Nuclear Power Systems, November 5-7, 1980, Orland6, Florida, TIS-6047.
- 2. MM Danchak, "Effective CRT Display Creation for Power Plant Appli-cations," Presented at Instrument Society of American Power Instru-mentation Symposium, May 10-12, 1976, San Francisco, California, TIS-4868.
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Appendix A Consumers Power Company Palisades Plant Docket 50-255 Addendum to Response to Request for Additional Information Safety Parameter Display System OECD HALDEN REACTOR PROJECT August 1986 24 Pages OC0886-0037S-NL01
Appendix A Consumers Power Company Palisades Plant Docket 50-255 Addendum to Response to Request for Additional Information Safety Parameter Display System OECD HALDEN REACTOR PROJECT August 1986 24 Pages OC0886-0037S-NL01