ML18065A076

Comment on Draft Rg DG-1043 Re Proposed Rev 2 to Rg 1.149. New Malfunction Tests Required by Revised Rg Can Be Tested at Required 25% Per Year & Reported in Next 4-yr Testing Rept W/O Rev to Test Plan

ML18065A076
Person / Time
Site:	Palisades
Issue date:	09/13/1995
From:	Vincent R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-60FR36833, RTR-REGGD-01.149, RTR-REGGD-1.149, TASK-*****, TASK-RE 60FR36833-00005, 60FR36833-5, NUDOCS 9509200070
Download: ML18065A076 (2)

Text

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MICHlliAN'S PROliRESS t !(" ~ !Df' Palisades Nuclear Plant: 27760 Blue Star Memorial Highway, Covert, ~I '49043-'

September 13, 1995 Rules Review and Directives Branch DFIPS, Office of Administration U S Nuclear Regulatory Commission Washington, DC 20555 RE: COMMENTS ON DRAFT REGULATORY GUIDE DG-1043, PROPOSED REVISION 2 TO REGULATORY GUIDE 1.149 Please consider the following comments on the proposed Revision 2 to Regulatory Guide 1.149.

1. Consumers Power Company's Palisades control room simulation facility has indicators installed which are identical to those installed in the Palisades plant. In many cases, the plant indicators have one or more internal alarm relays that are used as inputs to alarms and controls, to cause annunciators to alarm, valves to open/close, pumps to start/stop, etc. These alarm relays are also used as digital inputs to the simulator and cause the same responses.

It is Consumers Power Company's position that the overrides for these indicators do not " ... affect or alter the normal operation of simulated instrumentation or components within the model ... " and, therefore, are not considered malfunctions under the third sentence of paragraph 1.4.

Based on Palisades' use of the alarm flags on indicators as digital inputs to the simulation model, is the Palisades' position a correct interpretation of paragraph 1.4?

It is requested that the second sentence of paragraph 1.4 be changed to clarify this position.

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2. Will the increase in the scope of simulator testing constitute a "Performance Testing Plan Change" as noted on NRC Form 474, "Simulation Facility Certification"; thus requiring the submission of revised test abstracts, a revised test plan, and test schedule?

It is Consumers Power Company's position that the new malfunction tests required by the revised Regulatory Guide can be tested at the required 25% per year and reported in the next four-year testing report without a revision to our test plan and submission of a new NRC Form 474.

Is the Palisades' position a correct interpretation of the implementation requirements for the revised Regulatory Guide 1.149?

3. Cost of implementation based on Consumers Power Company's positions in paragraphs 1 and 2:

It is estimated that the Palisades Plant simulation facility will have an additional 250 malfunctions that will require testing during each four~

year period. These tests will require 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> of one-time development effort and will require approximately 500 yours of effort during each four-year period. Additionally, the performance of the tests will require 125 hours0.00145 days <br />0.0347 hours <br />2.066799e-4 weeks <br />4.75625e-5 months <br /> of the dedicated use of the simulator each four-year period, at an estimated cost of $300 per hour of simulator time.

$17,000 Test Development Labor Cost (one-time)

$ 9,400 Annual Increased Simulator Usage

$ 4,200 Annual Increased Labor Cost

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Licensing Administrator