ML18051A872
| ML18051A872 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/02/1984 |
| From: | Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8405020183 | |
| Download: ML18051A872 (7) | |
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'. *. ') ',TI Wu-v General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0550 April 2, 1984 Dennis M Crutchfield, Chief Operating Reactor Branch No 5 Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
SUPPLEMENT 1 TO NVREG-0737 - MILESTONE ACTIVITY SCHEDULE CHANGES - DETAILED CONTROL ROOM DESIGN REVIEW AND EMERGENCY OPERATING PROCEDURE PROJECTS The NRC Staff provided comments December 22, 1983 regarding the Detailed Control Room Design Review (DCRDR) program and requested that Consumers Power Company representatives meet with the NRC Staff to resolve the comments.
A meeting was held February 9, 1984.
NRC meeting minutes were issued February 29, 1984.
The meeting resolved all of the NRC Staff's comments with the exception of the use of "function and task analysis."
The February 29, 1984 letter provides NRC Staff guidance on an acceptable method for conducting the task analysis.
The guidance offered by the NRC Staff is quite prescriptive.
In order to incorporate the guidance into Consumers Power Company's integrated schedule for Supplement 1 to NUREG-0737, it is necessary to modify the milestone commitment schedule for the Detailed Control Room Design Review (DCRDR) and Emergency Operating Procedure (EOP) projects.
The milestone commitments were submitted September 16, 1983.
The revised milestone commitment schedule is provided by Attachment 1.
Consumers Power Company is working to address the NRC Staff's guidance regarding function and task analysis as per the schedule provided by.
It is requested that the NRC arrange a meeting in Washington, DC the week of April 16, 1984.
The purpose of the meeting is to discuss Consumers Power Company's new plan and schedule which will address the NRC Staff's guidance. It is requested that the NRC reviewers for the DCRDR and EOF projects be present at the meeting. Our original integrated plan and schedule included the use of function and task analysis. It is our understand-ing that the NRC Staff finds our original plan unacceptable because the Emergency Procedure Guidelines (CEN-152) were not developed independent of the Palisades Plant Control Room.
This shortcoming was not discussed in the NRC letter dated July 29, 1983 where it is stated, "the guidelines are acceptable for implementation and will provide improved guidance for emergency procedure OC0484-0001A-NL02
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DMCrutchfield, Chief Palisades Plant SUPPLEMENT 1 NUREG-0737 April 2, 1984 2
development." It is requested that the NRC clarify the extent to which the Emergency Procedure Guidelines are unacceptable for the DCRDR and EOP projects.
Our integrated plan and schedule includes a review of the Palisades Plant against the guidelines of Regulatory Guide 1.97, Revision 3, "Instrumentation for Light-Water-Cooled Nuclear Power Plants and Environs Conditions During and Following an Accident."
The Regulatory Guide states the following, "this guide provides a method acceptable to the NRC Staff for complying with the Commission's regulations to provide instrumentation to monitor plant variables and systems during and following an accident in a light-water-cooled nuclear power plant."
Consumers Power Company submitted a detailed report September 13, 1983 which addressed each of the eighty variables in Regulatory Guide 1.97 and provided an implementation schedule for closing out open items resulting from the review.
It is our understanding that the NRC Staff does not consider Regulatory Guide 1.97 adequate in defining the Control Room Operator's instrumentation needs following an accident.
Further, it is our understanding that the NRC Staff prefers that Consumers Power Company perform a detailed engineering evaluation of operator information and control needs for each function maintained by the operator under emergency conditions.
If this level of effort is necessary to revise the EOPs and complete the DCRDR it is not clear why it was necessary to perform a detailed review against Regulatory Guide 1.97 variables.
It is therefore requested that the NRC Staff clarify their position regarding the relationship between the Regulatory Guide 1.97, DCRDR and EOP projects.
David J VandeWalle (Signed)
David J VandeWalle Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachments OC0484-0001A-NL02
OC0484-0001B-NL02 ATTACHMENT 1 Consumers Power Company Palisades Plant - Docket 50-255 CONMITMENTS ON SUPPLEMENT 1 TO NUREG-0737 REVISION 1 2 Pages
TITLE
- 1.
Emergency Operating Procedures (EOP)
- 2.
Detailed Control Room Design Review
- 3.
Regulatory Guide 1.97 Application to Emergency Response Facilities OC0484-0001C-NL02 CONSUMERS POWER COMPANY PALISADES PLANT COMMITMENTS ON SUPPLEMENT 1 TO NUREG-0737 REVISION l la.
lb.
le.
2a.
2b.
3a.
MILESTONE DESCRIPTION NRC acceptance of Combustion Engineering Owners' Group Emergency Procedures Guidelines Program Submit a Procedures Generation Package to the NRC Implement the upgraded EOPs Submit a program plan to the NRC Submit an interim report to the NRC including a proposed schedule for implementation Submit a report to the NRC describing how the requirements of Supplement l to NUREG-0737 have been or will be met; include a proposed schedule for implementation.
COMPLETION SCHEDULE (Or Status)
Complete (NRC_letter February 8, 1983)
June 1984 Date to be provided by June 1984 Complete (Consumers Power Company letters March 16, 1982 and June 7, 1983)
Date to be provided by June 1984 May 1985
TITLE
- 4.
Safety Parameter Display System (SPDS)
- 5.
Emergency Response Facilities CONSUMERS POWER COMPANY PALISADES PLANT COMMITMENTS ON SUPPLEMENT 1 TO NUREG-0737 REVISION 1 4a.
5a.
5b.
5c.
MILESTONE DESCRIPTION Submit a comparison report of the Critical Functions Monitoring System to the SPDS criteria, a preliminary safety analysis report and an implementation plan to the NRC.
Technical Support Center (TSC) fully functional.*
Open Item - complete TSC habitability modifications Operational Support Center fully functional.*
Emergency Operations Facility fully functional.*
COMPLETION SCHEDULE (Or Status)
July 1984 End of 1983 Refueling Outage (Open item is currently addressed by NRC Conf irrnatory Order dated March 14, 1983, Item III.D.3.4 "Control Room Habitability")
Complete Complete
- Except for any additional changes that may be required as a result of completion of the other initiatives (i.e., items 1 through 4)
OC0484-0001C-NL02 2
OC0484-0001B-NL02 ATTACHMENT 2 Consumers Power Company Palisades Plant - Docket 50-255 SCHEDULE TO ADDRESS NRG STAFF'S GUIDANCE REGARDING TASK ANALYSIS 1 Page
ATTACHMENT 2 SCHEDULE TO ADDRESS NRC STAFF'S GUIDANCE REGAHDING TASK ANALYSIS DESCRIPTION Develop process to address task analysis described by NRC letter dated February 29, 1984.
Discuss process with NRC Staff reviewers Resolve comments resulting from meeting with NRC Staff reviewers Revise Scope and Schedule for EOP and DCRDR projects OC0484-0001D-NL02 ESTIMATED COMPLETION April 13, 1984 Week of April 16, 1984 Week of April 23, 1984 June 1984 J