ML18057A768
| ML18057A768 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/27/1991 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9103110097 | |
| Download: ML18057A768 (9) | |
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consumers Power POW ERi Nii MICHlliAN'S PRDliRESS Palisades Nuclear Plant:
27780 Blue Star Memorial Highway, Covert, Ml 49043 February 27, 1991 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
GB Slade General Manager RESPONSE TO QUESTIONS REGARDING PALISADES SIMULATOR CERTIFICATION - ADDITIONAL INFORMATION Comment No 1 in the NRC letter dated September 24, 1990 asked that Consumers Power Company provide additional justification for the exceptions included in our June 11, 1990 submittal requesting certification of the Palisades simulator.
In CPC's December 17, 1990 response to comment No 1, we stated that an additional 22 surveillances should be included in our certification submittal and that a preliminary evaluation indicates 16 of the 22 tests can be conducted on the simulator in its present state and the remaining 6 would require the addition of several remote functions to the simulator.
CPC committed to conduct the 16 tests in January 1991 and submit the results in a new test abstract in February 1991.
During January 1991, we were able to conduct 21 of the 22 additional tests. A revised response to the NRC's September 24, 1991 comment No 1, along with Simulator Test N008 Abstract Addendum 1, is attached.
~r/
r Gerald B Slade General Manager CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades A CMS ENERGY COMPANY
ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 PALISADES SIMULATOR CERTIFICATION - ADDITIONAL INFORMATION REVISED RESPONSE TO THE NRC SEPTEMBER 24, 1990 COMMENT NO. 1 February 28, 1991 7 Pages
2/20/91 Revision 2 1
RESPONSE TO NRC QUESTIONS REGARDING PALISADES SIMULATOR CERTIFICATION
- 1.
NRC Comment This conment pertains to Exceptions 2 and 5.
Exception 2, regarding surveillanc*e testing, states that "Only the surveillance tests that are conducted entirely 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 performing "Operator conducted surveillance testing on safety-related equipment or systems."
Furthermore, Section 3.3.2 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 "not all systems operated outside the control room, that are necessary to perform surveillance tests, are simulated."
The only justification provided for the~e two exceptions 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 insufficient 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 SS.45(a).
Please provide additional justification for these exceptions.
RESPONSE
The Consumers Power Company Palisades simulator certification submittal only included those surveillances that could be done entirely in or from the control room.
Howe.ver, the Palisades simulator has the ability to conduct many other surveillance tests the operators are required to perform.
We evaluated each of our Technical Specification Surveillance
.tests for operations and determined that an additional 22 surveillances should be included in our certification submittal.
These surveillance tests were selected because they thoroughly test the safety-related equipment and systems that are sybject to surveillance testing at the Palisades plant.
Including these additional surveillances will address the means by which the ability to perform surveillance testing on remaining safety-related equipment and systems can be demonstrated in an operating test.
A preliminary evaluation of these additional 22 surveillances indicated that 16 of the surveillance tests could be conducted on the simulator in its present state. The six rema1n1ng surveillances were to be done at a I later date after modifications to the simulator were completed.
After
~
further evaluation, we found we could perform 21 of the 22 surveillance tests.
Following is a list of the surveillance tests that have been selected for addition to the Palisades simulator certification submittal.
Except for l Q021, all tests were conducted on the simulator during January 1991.
The results are documented on the test abstract addendum attached.
MI0291-0002A-MC01
2/20/91 Revision 2 2
The addendum test abstract documents that we are taking an exception on only one test (Q021) until we modify the simulator.
Q021 is scheduled to be conducted by 12/31/91.
The remainder of the additional surveillance tests were adequately performed.
Some simulator deficiencies were identified and are documented in the abstract.
These deficiencies did not prevent the acceptable performance of the tests.
Surveillance ID
- 1.
QOl
- 2.
Q08C
- 3.
Q013
- 4.
QOS
- 5.
Q06
- 6.
MCllB
- 7.
- 8.
- 9.
M025
- 10. M029
- 11. M033
- 12. M037
- 13. R021
- 14. R065
- 15. R0112
- 16. SH0-1
- 17. D/WOl MI0291-0002A-MC01 Title Safety Injection System
- Safety Injection Tank Check Valve Test (Hot Shutdown)
Iodine Removal Valves Stroke Test Valve Test Procedure (Includes Containment Isolation Valves)
Cold Shutdown Valve Test Procedure (Includes Containment Isolation Valves)
Safeguards Boron Sample, Safety Injection Tanks Emergency Diesel Generator K6A Emergency Diesel Generator K6B Iodine Removal Equipment Surveillances Engineered Safety System Alignment Control Room Ventilation Emergency Operation Fuel Handling Area Ventilation System Control Rod Drive System Interlocks High Pressure Safety Injection (HPSI)
Trains 1 and 2, and Hot Leg Injection (HLI) Check Valve Test Reactor Head/Pressurizer Vent Flow Check Operators Shift Items Operators Daily/Weekly/Biweekly Items
Surveillance ID
- 18. Q08B
- 19. Q021
- 20. Q023
- 21. ROll
- 22. R012 MI0291-0002A-MC01 Title 2/20/91 Revision 2 3
ESS Check Valve Operability Test (Cold Shutdown)
Auxiliary Feedwater System Valves, Inservice Test Procedure Auxiliary Hot Shutdown Panel Instrumentation Checks Containment High Radiation Test Containment High Pressure (CHP) and Spray System Tests
- 1.
e e
SIMULATOR TEST N008 ABSTRACT ADDENDUM 1 NAME AND DESCRIPTION OF TEST N008 addendum 1 is a simulator performance test that involves technical specification surveillance tests normally conducted by the control room operators. However, all steps of these tests are not performed from the control room.
Certain steps are performed locally at the valves, controls, tanks, etc.
The steps that are performed out of the control room but have indicators in the control are simulated using remote functions, malfunctions, or by an instructor's response.
The steps that are performed out _of the control room but have no indicators in the control room were not conducted on the simulator.
These tests were accomplished following applicable Palisades' Technical Specification Surveillance Procedures and Standard Operating Procedures as required.
The additional tests that were conducted are as follows:
- 1.
SAFETY INJECTION SYSTEM (QOl)
- 2.
SAFETY INJECTION TANK CHECK VALVE TEST (HOT SHUTDOWN)
(Q08C)
- 3.
IODINE REMOVAL VALVES STROKE TEST (Q013)
- 4.
VALVE TEST PROCEDURE (INCLUDES CONTAINMENT ISOLATION VALVES)
(Q05)
- 5.
COLD SHUTDOWN VALVE TEST PROCEDURE (INCLUDES CONTAINMENT ISOLATION VALVES)
(Q06)
- 6.
SAFEGUARDS BORON SAMPLE, SAFETY INJECTION TANKS (MCllB)
- 7.
EMERGENCY DIESEL GENERATOR K6A (M07A-l)
- 8.
EMERGENCY DIESEL GENERATOR K6B (M07A-2)
- 9.
IODINE REMOVAL EQUIPMENT SURVEILLANCES (M025)
- 10. ENGINEERED SAFETY SYSTEM ALIGNMENT (M029)
- 11. CONTROL ROOM.VENTILATION EMERGENCY OPERATION (M033)
- 12. FUEL HANDLING AREA VENTILATION SYSTEM (M037)
- 13. CONTROL ROD DRIVE SYSTEM INTERLOCKS (R021)
- 14. HIGH PRESSURE SAFETY INJECTION (HPSI) TRAINS 1 AND 2, AND HOT LEG INJECTION (HLI) CHECK VALVE TEST (R065)
- 15. REACTOR HEAD/PRESSURIZER VENT FLOW CHECK (R0112)
- 16. OPERATORS SHIFT ITEMS (SH0-1)
- 17. OPERATORS DAILY/WEEKLY/BIWEEKLY ITEMS (D/WOl)
- 18. ESS CHECK VALVE OPERABILITY TEST (COLD SHUTDOWN)
(Q08B)
- 19. AUXILIARY HOT SHUTDOWN PANEL INSTRUMENTATION CHECKS (Q023)
- 20. CONTAINMENT HIGH RADIATION TEST (ROll)
- 21. CONTAINMENT HIGH PRESSURE (CHP) AND SPRAY SYSTEM TESTS (R012)
- 2.
ANSI/ANS-3.5-1985 RELATIONSHIP 3.1.1 (10)
- 3.
TEST DATES N008 addendum 1 was conducted in January, 1991.
E.24.1
SIMULATOR TEST N008 ABSTRACT ADDENDUM 1
- 4.
TESTED PARAMETERS The parameters tested were those parameters that each Technical Specification Surveillance Procedure requested, that were o~servable on instrumentation or indicators in the control room.
- 5.
INITIAL CONDITIONS The initial condition for e~ch Technical Specification Surveillance procedure was set up per the individual procedure.
Following is a list and description of the initial conditions used for the procedure indicated:
ICl - Plant at Cold Shutdown (Q06, Q013, ROll, R065, R012, QOSB)
IC4 - Plant at Hot Shutdown (QOSC)
IC13 - Plant at Hot Shutdown (R021)
IC2 -
Plant on Shutdown Cooling (R0112)
IClO - Plant at 75% Full Power (D/WOl, Q023, M029, M037, M033, M025, M07A-2, M07A-1, SH0-1, MCllB, Q05, QOl)
- 6.
FINAL CONDITIONS/DURATION OF TEST
- 7.
In all the Technical Specification Surveillance procedures, the initial condition was maintained throughout the test.
Each surveillance procedure was conducted through its specified completion.
Following is a list of the Technical Specification Surveillance procedures conducted and the approximate completion time required for each.
PROCEDURE HOURS PROCEDURE HOURS PROCEDURE HOURS QOl
- 1. 50 M07A-1
- 1. 00 R021
- 1. 50 QOSC
.75 M07A-2
- 1. 00 R065
- 1. 50 Q013
.25 M025
.25 R0112
.50 Q05
- 1. 50 M029
.75 SH0-1 1~00 Q06
- 1. 00 M033
.50 D/WOl 2.00 MCllB 3.33 M037
.25 QOSB
- 1. 00 R012 3.50 Q023
.50 ROll 2.00 BASELINE DATA The baseline data is actual plant data from the surveillance test p~ocedures conducted.
E.24.2
SIMULATOR TEST N008 ABSTRACT ADDENDUM 1
- 8.
DEFICIENCIES The following simulator deficiencies were noted during performance of these tests.
A. LPSI PUMP DISCHARGE PRESSURE TOO LOW B. FI-0315 SHOWS NO FLOW WHEN CV3069 IS OPEN C. CV0867 WILL NOT OPERATE FROM C33 PANEL D. CV1102 VALVE STROKE TIME IS NOT CORRECT E. VARIOUS VALVE STROKE TIMES ARE NOT CORRECT IN THE SERVICE WATER SYSTEM F. VARIOUS VALVE STROKE TIMES ARE NOT CORRECT IN THE CONTAINMENT AND HVAC SYSTEM G. VARIOUS VALVE STROKE TIMES ARE NOT CORRECT IN THE COMPONENT COOLING WATER SYSTEM H. SAFETY INJECTION TANKS LOW LEVEL SWITCHES DO NOT CAUSE LOW ALARM I. D/G FREQUENCY METER READS APPROXIMATELY
.5 HERTZ OFF J. PIA-0438 PRESSURE READING IS ABOVE ACCEPTABLE LEVEL K. CV3037 AND 3036 DO NOT CHANGE TO PROPER POSITIONS WHEN SWITCHES ARE MOVED L. RIA-2327 HI ALARM BUTTON SHOULD MOVE METER INDICATION UPSCALE M. ELAPSED TIME INDICATORS FOR D/W0-1 STEPS 21 & 22 ARE NOT SIMULATED N. PANEL EC-302, FOR BORIC ACID HEAT TRACE CHECKS, IS NOT SIMULATED
- 0. WITH ONLY P55C ON, OPENING HPSI VALVE DOUBLES FLOW -
SHOULD REMAIN AT 40 GPM P. CV-0939 SHOULD REMAIN CLOSED FOLLOWING CHR RESET Q. FOLLOWING RESET OF CHP, CV-0501 & CV0510 REOPENED R. VARIOUS VALVES DO NOT PROPERLY ACTUATE ON CHP S. WITH ZERO CONDENSATE FLOW AVAILABLE, S/G LEVEL INCREASED WHEN CV0734 OR 35 OPENED T. DPIC-1659 AND DPIC-1660 FOR M0-33 STEPS 5.1.12 AND 5.2.12 ARE NOT SIMULATED U. A REMOTE FUNCTION TO LINE UP HOT LEG INJECTION TO THE PSDT IS NEEDED TO ACCURATELY PERFORM Q08B; SECTION 5.3 SDR-91-015 SDR-91-026 SDR-91-014 SDR-91-035 SDR-9;1.-004 SDR-91-032 SpR-91-033 SDR-91-013 SDR-91-011 SDR-91-010 SDR-91-007 SDR-91-012 SDR-91-005 SDR-91-006 SDR-91-019 SDR-91-016 SDR-91-017 SDR-91-018 SDR-91-020 SDR-91-036 SDR-91-037 QOl Q08C Q05 Q05 Q06 Q06 Q06 MCllB M07A-l M07A-2 M025 M029~
SH0-1 D/WOl D/WOl Q08B ROll R012 R012 R012 M033 Q08B These simulator deficiency reports (SDRs) are scheduled to be resolved in 1992.
E.24.3
SIMULATOR TEST N008 ABSTRACT ADDENDUM 1
- 9.
EXCEPTIONS TO ANSI/ANS-3.5-1985 Technical Specification Surveillance Procedure Q021 "Auxiliary Feedwater System Valves, Inservice Test Procedures could not be entirely conducted at this time due to the unavailability of required simulator functions.
Q021 is scheduled to be conducted by 12/31/91 following resolution of the following simulator deficiencies.
A. AUX FEEDWATER TEST STATION (SS-3/P-SA/B)
IS NOT MODELED B. VARIOUS VALVE STROKE TIMES ARE NOT CORRECT IN THE AUX FEEDWATER SYSTEM E.24.4 SDR-91-009 Q021 SDR-91-034 Q021