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| | issue date = 09/13/1995 | | | issue date = 09/13/1995 |
| | title = 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 | | | title = 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 |
| | author name = VINCENT R A | | | author name = Vincent R |
| | author affiliation = CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), | | | author affiliation = CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), |
| | addressee name = | | | addressee name = |
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| {{#Wiki_filter:consumers Power | | {{#Wiki_filter:* (oOFR~~33 9/1'6/°fS consumers Power POWERiNii |
| * 9/1'6/°fS SEP ! !3 PM I : 5 2 POW ERi Nii MICHlliAN'S PROliRESS t !(" !Df' Palisades Nuclear Plant: 27760 Blue Star Memorial Highway, Covert, '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. | | ~ SEP ! !3 PM I: 52 @ |
| 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 | | 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. |
| ===1.4. Based===
| | : 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. |
| 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. | | 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. |
| -----9509200070 950913 PDR REGGD 01. 149 C PDR I 0 | | 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. |
| * 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? | | 9509200070 950913 PDR REGGD |
| 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. 2 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 year period. These tests will require 500 hours 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 hours 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) | | : 01. 149 C PDR I 0 ACM!ff~COMPANY |
| $ 9,400 Annual Increased Simulator Usage $ 4,200 Annual Increased Labor Cost Licensing Administrator}} | | * 2 |
| | : 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 hours 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 hours 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 |
| | ~~~n6}Q~\ |
| | Licensing Administrator}} |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217N7201998-03-31031 March 1998 Comment on Proposed Rule 10CFR50 Re Proposed Changes to 10CFR50.55a,inservice Inspection & Inservice Testing of Nuclear Power Plant Components ML20203J9661998-02-27027 February 1998 Comment on GL 98-XX, Yr 2000 Readiness of Computer Sys at Npps ML18067A6301997-07-0707 July 1997 Comment Supporting NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Charges,Tests or Experiments). DD-97-15, Director'S Decision DD-97-15 Re Petitioners Request That NRC Prohibit Loading of VSC-24 Until Coc,Sar & SER Amended Following Independent third-party Review of VSC-24 Design. No Adequate Basis Exists for Granting Petitioners Request1997-06-18018 June 1997 Director'S Decision DD-97-15 Re Petitioners Request That NRC Prohibit Loading of VSC-24 Until Coc,Sar & SER Amended Following Independent third-party Review of VSC-24 Design. No Adequate Basis Exists for Granting Petitioners Request ML20115H7061996-06-0404 June 1996 Submits Addl Info to Support Petition for Rulemaking PRM-72-3 Re Amend to SAR ML18065A0761995-09-13013 September 1995 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 ML20086D9031995-06-29029 June 1995 Comments on Proposed Generic Ltr Re Process for Changes to Security Plans W/O Prior NRC Approval.Proposed GL Also Avoids Unnecessary Expense for Requirements That Provide No Benefit ML18064A8201995-06-27027 June 1995 Comment on Proposed GL Re Relocation of Pressure Temperature Limit Curves & Low Temperature Overpressure Protection Sys Limits.Supports Issuance of Ltr ML20085E6541995-06-13013 June 1995 Comment Re Draft NUREG/BR-0199, Responsiveness to Public. Expresses Concern on Dry Cask Storage W/Exemption Given to VSC-24 Cask & Procedures for Unloading & Transport at Plant ML18064A7681995-05-26026 May 1995 Comment on Proposed GL, Pressure Locking & Thermal Binding of Safety-Related Power Operated Gate Valves. ML20073M0621994-09-29029 September 1994 Comment Opposing Proposed Rule 10CFR72 Re Addition of NUHOMS 52B Dry Casks to List of Approved Spent Fuel Storage Casks. Objects to Proposed Rule Because of Substantial Differences Between Fuel Rods & Assemblies at Different Plant ML20056E5101993-08-11011 August 1993 Comment Opposing Proposed Rule 10CFR20 Re Radiological Criteria for Decommissioning ML20012G5301993-02-26026 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Suggests That NRC Conduct Formal Hearing ML20012G5311993-02-24024 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20012G5331993-02-23023 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20012G5341993-02-23023 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20012G5321993-02-23023 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20012G5231993-02-20020 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20012G5251993-02-15015 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20128L9531993-02-10010 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127E8851993-01-15015 January 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127E8631993-01-14014 January 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127F0561993-01-0808 January 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116N9171992-11-12012 November 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116K9591992-11-0909 November 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Concerns Noted ML20116L4651992-11-0606 November 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116L0501992-11-0303 November 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Concerns Noted ML20116K7851992-11-0303 November 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116L1811992-11-0202 November 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116L2051992-11-0202 November 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116L3341992-10-30030 October 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule.Waste Can Not Be Stored Safely.Doe Will Not Be Liable for Wastes If Interim Site Not Built by 1998 ML20116L2881992-10-26026 October 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116L1311992-10-22022 October 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule.Waste Cannot Be Stored Safely.Doe Will Not Be Liable for Wastes If Interim Site Not Built by 1998 ML20116L2841992-10-22022 October 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116L2681992-10-22022 October 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule.Waste Can Not Be Stored Safely.Doe Will Not Be Liable for Wastes If Interim Site Not Built by 1998 ML20116K9861992-10-22022 October 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule.Deadly Waste Cannot Be Stored Safely.Doe Stated Will Not Be Liable for Wastes If Interim Site Not Built by 1998 ML20127E1371992-09-16016 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A4721992-09-14014 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A4081992-09-14014 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A4011992-09-14014 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A3981992-09-11011 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127D6611992-09-0909 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A3831992-09-0909 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A4521992-09-0909 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127D6241992-09-0909 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127D9421992-09-0909 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127D6331992-09-0909 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A4111992-09-0808 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A3671992-09-0808 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127D7191992-09-0606 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule 1998-03-31
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20217N7201998-03-31031 March 1998 Comment on Proposed Rule 10CFR50 Re Proposed Changes to 10CFR50.55a,inservice Inspection & Inservice Testing of Nuclear Power Plant Components ML20203J9661998-02-27027 February 1998 Comment on GL 98-XX, Yr 2000 Readiness of Computer Sys at Npps ML18067A6301997-07-0707 July 1997 Comment Supporting NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Charges,Tests or Experiments). ML20115H7061996-06-0404 June 1996 Submits Addl Info to Support Petition for Rulemaking PRM-72-3 Re Amend to SAR ML18065A0761995-09-13013 September 1995 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 ML20086D9031995-06-29029 June 1995 Comments on Proposed Generic Ltr Re Process for Changes to Security Plans W/O Prior NRC Approval.Proposed GL Also Avoids Unnecessary Expense for Requirements That Provide No Benefit ML18064A8201995-06-27027 June 1995 Comment on Proposed GL Re Relocation of Pressure Temperature Limit Curves & Low Temperature Overpressure Protection Sys Limits.Supports Issuance of Ltr ML20085E6541995-06-13013 June 1995 Comment Re Draft NUREG/BR-0199, Responsiveness to Public. Expresses Concern on Dry Cask Storage W/Exemption Given to VSC-24 Cask & Procedures for Unloading & Transport at Plant ML18064A7681995-05-26026 May 1995 Comment on Proposed GL, Pressure Locking & Thermal Binding of Safety-Related Power Operated Gate Valves. ML20073M0621994-09-29029 September 1994 Comment Opposing Proposed Rule 10CFR72 Re Addition of NUHOMS 52B Dry Casks to List of Approved Spent Fuel Storage Casks. Objects to Proposed Rule Because of Substantial Differences Between Fuel Rods & Assemblies at Different Plant ML20056E5101993-08-11011 August 1993 Comment Opposing Proposed Rule 10CFR20 Re Radiological Criteria for Decommissioning ML20012G5301993-02-26026 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Suggests That NRC Conduct Formal Hearing ML20012G5311993-02-24024 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20012G5331993-02-23023 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20012G5341993-02-23023 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20012G5321993-02-23023 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20012G5231993-02-20020 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20012G5251993-02-15015 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20128L9531993-02-10010 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127E8851993-01-15015 January 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127E8631993-01-14014 January 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127F0561993-01-0808 January 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116N9171992-11-12012 November 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116K9591992-11-0909 November 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Concerns Noted ML20116L4651992-11-0606 November 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116K7851992-11-0303 November 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116L0501992-11-0303 November 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Concerns Noted ML20116L1811992-11-0202 November 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116L2051992-11-0202 November 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116L3341992-10-30030 October 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule.Waste Can Not Be Stored Safely.Doe Will Not Be Liable for Wastes If Interim Site Not Built by 1998 ML20116L2881992-10-26026 October 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116L2681992-10-22022 October 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule.Waste Can Not Be Stored Safely.Doe Will Not Be Liable for Wastes If Interim Site Not Built by 1998 ML20116L2841992-10-22022 October 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116K9861992-10-22022 October 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule.Deadly Waste Cannot Be Stored Safely.Doe Stated Will Not Be Liable for Wastes If Interim Site Not Built by 1998 ML20116L1311992-10-22022 October 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule.Waste Cannot Be Stored Safely.Doe Will Not Be Liable for Wastes If Interim Site Not Built by 1998 ML20127E1371992-09-16016 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A4011992-09-14014 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A4081992-09-14014 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A4721992-09-14014 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A3981992-09-11011 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A4521992-09-0909 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127D6241992-09-0909 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127D9421992-09-0909 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127D6331992-09-0909 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127D6611992-09-0909 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A3831992-09-0909 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A4111992-09-0808 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A3671992-09-0808 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127D7191992-09-0606 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A4401992-09-0606 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule 1998-03-31
[Table view] |
Text
- (oOFR~~33 9/1'6/°fS consumers Power POWERiNii
~ SEP ! !3 PM I: 52 @
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.
---~----- -----
9509200070 950913 PDR REGGD
- 01. 149 C PDR I 0 ACM!ff~COMPANY
- 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
~~~n6}Q~\
Licensing Administrator