ML18057A491
| ML18057A491 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/24/1990 |
| From: | Brian Holian Office of Nuclear Reactor Regulation |
| To: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| PAL-90-034, PAL-90-34, NUDOCS 9010040285 | |
| Download: ML18057A491 (6) | |
Text
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September 24, 1990
'l' Docket No. 50-255 PAL-90-034 Gerald B. Slade Plant General Manager Palisades Plant 27780 Blue Star Memorial Highway Covert, Michigan 49043
Dear Mr. Slade:
SUBJECT:
SIMULATOR CERTIFICATION FOR 10 CFR 55.45(b)(2), PALISADES NUCLEAR PLANT The staff has completed its review of your initial Simulator Certification submittal, dated June 11, 1990, for the Palisades Nuclear Plant simulator.
This review has identified several areas in which there is, as yet, inadequate information and data to ensure complete documentation of your certification.
These areas are described in the enclosure.
You are requested to provide the additional data no later than December 15, 1990 so that this information may be promptly incorporated in the staff's records.
If you cannot meet this schedule, please contact me as soon as possible.
Our review is only to ensure completeness of documentation.
It is not intended to verify the accuracy of the data or statements made in the certification, nor does it provide NRC approval of the acceptability of a particular simulator for use in administering operating tests.
If you require additional information or clarification about this letter or its enclosure, please contact me at (301) 492-1344.
Enclosure:
As stated cc wlenclosure:
DISTRIBUTION:
Sincerely, Isl Brian Holian, Project Manager Project Directorate III-1 Division of Reactor Projects III, IV, V and Special Projects Office of Nuclear Reactor Regulation See next pag~
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r Docket No. 50-255 PAL-90-034 Gerald B. Slade Plant General Manager Palisades Plant 27780 Blue Star Memorial Highway Covert, Michigan 49043
Dear Mr. Slade:
September 24, 1990
SUBJECT:
SIMULATOR CERTIFICATION FOR 10 CFR 55.45(b)(2), PALISADES NUCLEAR PLANT The staff has completed its review of your initial Simulator Certification submittal, dated June 11, 1990, for the Palisades Nuclear Plant simulator.
This review has identified several areas in which there is, as yet, inadequate information and data to ensure complete documentation of your certification.
These areas are described in the enclosure.
You are requested to provide the additional data no.later than December 15, 1990 so that this information may be promptly incorporated in the staff's records.
If you cannot meet this schedule, please contact me as soon as possible.
Our review is only to ensure completeness of documentation.
It is not intended to verify the accuracy of the data or statements made in the certification, nor does it provide NRC approval of the acceptability of a particular simulator for use ir1 administering operating tests.
If you require additional information or clarification about this letter or its enclosure, please contact me at (301) 492-1344.
Enclosure:
As stated cc w/enclosure:
See next page DISTRIBUTION:
ooci<Ii'FTIE PD31 R/F NRC & LOCAL PORS LA/PD31:D8~
SMEADOR piY 911)190 EJORDAN ACRS(lO)
BHOLIAN Sincerely, Isl Brian Holian, Project Manager Project Directorate III-1 Division of Reactor Projects III, IV, V and Special Projects Office of Nuclear Reactor Regulation JZWOLINSKI OGC SMEADm!
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91~r1 9 PALISADES SIMULATOR CERT.
Docket No. 50-255 PAL-90-034 Gerald B. Slade Plant General Manager Palisades Plant UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 September 24, 1990 27780 Blue Star Memorial Highway Covert, Michigan 49043
Dear Mr. Slade:
SUBJECT:
SIMULATOR CERTIFICATION FOR 10 CFR 55.45(b)(2), PALISADES NUCLEAR PLANT The staff has completed it~ review of your initial Simulator Certification submittal, dated June 11, 1990, for the Palisades Nuclear Plant simulator.
This review has identified several areas in which there is, as yet, inadequate information arid data to ensure complete documentation of your certification.
These areas are described in the enclosure.
You are requested to provide the additior;al data no later than December 15, 1990 so that this information may be promptly incorporated in the staff's records.
If you cannot meet this schedule, please contact me as soon as possible.
Our review is only to ensure completeness of documentation.
It is not intended tc, verify the accuracy of the data or statements made in the certification, rior does it provide NRC approval of the acceptability of a particular simulator for use in administering operating tests.
If you require additional information or clarification about this letter or its enclosure, please contact me at (301) 492-1344.
Enclosure:
As stated cc w/enclosure:
See next page Sincerely, Brian Holian, Project Manager Project Directorate III-1 Division of Reactor Projects III, IV, V and Special Projects Office of Nuclear Reactor Regulation
Mr. Gerald B. Slade Palisades Plant cc:
M. I. Miller, Esquire Sidley & Austin 54th Floor One First National Plaza Chicago, Illinois 60603 Mr. Thomas A. McNish, Secretary Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consumers Power Company 212 West Michigan Avenue Llackson, Michigan 49201 Regional Adnii11istrator, Region III U.S. Nuclear Regulatory Comrnissio11 799 Roosevelt Road Glen Ellyr,, Illiriois 60137 Llerry Sarno Township Supervisor Covert Township 36197 M-140 Highway Covert, Michigan 49043 Office of the Governor Room 1 - Capitol Building Lansi11g, Michigar1 48913 Mr. David J. Vandewalle Director, Safety and Licensing Palisades Plant 27780 Blue Star Memorial Hwy.
Covert, Michigan 49043 Resident Inspector c/o U.S. Nuclear Regulatory Commission Palisades Plant 27782 Blue Star Memorial Hwy.
Covert, Michigan 49043 Palisades Plant Nuclear Facilities and Environmental Monitoring Section Office Division of Radiological Health P.O. Box 30035 Lansing, Michigan 48909 Gerald Charnoff, P.C.
Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W.
Washington, D.C.
20037 Mr. David L. Brannen Vice President Palisades Generating Plant c/o Bechtel Power Corporation 15740 Shady Grove Road Gaithersburg, Maryland 20877
~ "
Enclosure
- 1.
This comment pertains to exceptions 2 and 5.
Exception 2, regarding surveillance testing, states that "Only the surveillance tests that are conducted entirel in the control room..* " were included in the performance test emphasis added].
"Simulator Test N008 Abstract" indicates that only two surveillances were actually included.
ANSI/ANS-3.5-1985, in Section 3.1.1, requires the simulator to be capable of perf arming "Operator conducted survei 11 ance testing on safety-re lated equipment or systems.
11 Furthermore, Section 3.:j.2 requires the simulator to have the remote functions necessary to support these evolutions such that trainees can respond as they would in the plant.
Exception 5 states that 11 not all systems operated outside the control room, that are necessary to perform surveillance tests, are simulated."
The only justification provided for these two exceptior1s is that the surveillances that have data taken remotely are covered in training according to your Systematic Approach to Training (SAT) program. This justification is insufficiert because it does not address the means by which the ability to perform the remaining surveillances can be demonstrated in an operating test in accordance with 10 CFR 55.45(a).
Please provide additional justification for these exceptions.
- 2.
In many of the simulator test abstracts the description of the baseline data used to determine fidelity to the reference plant includes the review cf subject mc.itter experts.
However, no documentation of their review was provided. Additional documentation should be provided, such as the qualifications of these experts and any differing professional opinions as to the outcome of the tests.
- 3.
ANSI/ANS-3.5-1985, Section 3.2.1, requires the simulator to contain sufficient operational panels to coriduct the evolutions described in 3.1.1 (Normal Plant Evolutions), and the malfunctions described in 3.1.2 (Plant Malfunctions).
In section C of the attachment to Form 474~ it is stated that panels C47, C47A, and C115 are not simulated, arid that these deviations have minimal impact on training. There is no description of the controls and indications not modeled because of these deviations.
No exceptions were requested. Please confirm that the Palisades simulator meets the guidance of ANSI/ANS-3.5-1985, Section 3.2.1 or provide justification for exception.
- 4.
In section C of the attachment to Form 474, under "Required Systems,"
numerous systems are noted as only partially simulated.
No exceptions were requested. ANSI/ANS-3.5-1985, Section 3.3.1, requires the degree of system simulation to be to the extent necessary to perform the evolutions in 3.1.1 (Normal Plant Evolutions) and the malfunctions in 3.1.2 (Plant Malfunctions). Please confirm that the Palisades simulator meets this guidance or provide justification for exception.
- 5.
The list of recorded parameters identified in "Simulator Test N007 Abstract" for the steady state tests does not include all of the parameters required by ANSI/ANS-3.5-1985, Appendix B, Section B2.1.
Specifically, boron concentration, control rod positions, and steam generator secondary side temperature are missing. Please confirm that these parameters were recorded or provide justification for exception.
- 6.
Test TOlO, involving a failed pressurizer relief valve, was performed with "no initial input from the high pressure safety injection pumps."
Appendix B of ANSI/ANS-3.5-1985 specifies that activation of high pressure Emergency Core Cooling Systems (ECCS) should be inhibited during this test, vice initially inhibited.
No exceptions were requested. Please confirm that high pressure ECCS activation was inhibited for the duration of the test or provide justification for exception.
Also, the list of recorded parameters identified in "Simulator Test TOlO Abstract" did not include loop flow rates or surge line temperature as.
required by section 82.2.4. Please confirm that these parameters were recorded or provide justification for exception.
- 7.
In section F of the attachment to Form 474, under "Simulator Open Items Report (Paltrack Listing)," there are many items which appear to have significant detrimental impact upon the simulator 1s ability to represer1t the reference plant and tu meet certification requirements.
Under the column entitled "Simulator Impact Description" are the following descriptions:
Simulator Impact Description 0 Negative Training 0 Misleading to Trainees 0 Simulator Certification
° Complicates Trainees Diagnoses of Transients
° Fails Test of Real Time Simulation 0 Does Not Meet Cert Test Requirements 0 Inadequate Training Number of Items with this Description 2
4 19 12 1
]
1 10 CFR 55.45(b){5) requires a certified simulator to meet the definition of a "plant-referenced simulator" given in 10 CFR 55.4 which states:
"Plant-referenced simulator" means a simulator modeling the systems of the reference plant with which the operator interfaces in the control room, including oper.ating consoles, and which permits use of the reference plant 1s procedures. A plant-referenced simulator demonstrates expected plant response to operator input, and to normal, transient, and accident conditions to which the simulator has been designed to respond." Please provide additional information describing these open items and showing that they are not contrary to the definition of a plant-referenced simulator. Also, please confirm that no additional exceptions to the guidance of ANS/ANS-3.5-1985 as endorsed by Regulatory Guide 1.149 are required or provide justifications for any additional except ions.