ML17320A329

Requests Working Group Meeting W/Nrc,American Electric Power Svc Corp & Franklin Research Ctr to Review Technical Evaluation Rept on Environ Equipment Qualification Findings

ML17320A329
Person / Time
Site:	Cook
Issue date:	01/24/1983
From:	Hunter R INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Harold Denton Office of Nuclear Reactor Regulation
References
AEP:NRC:0775, AEP:NRC:775, NUDOCS 8301310088
Download: ML17320A329 (7)

Text

REGULA Y INFORMATION DISTRIBUTI SYSTEM (RIDS)

ACCESSION NBR:8301310088 DOC.DATE: 83/01/2'OTARIZED:

NO DOCKET ¹ FACIL:50 315 Donald C,

Cook Nuclear Power Plantr Unit 1~ Indiana 8

05000315 50 316 Donald C,

Cook Nuclear Power Plantr Unit 2~ Indiana 8

05000316 AUTH,NAME AUTHOR AFFILIATION HUNTERIR ~ ST Indiana 8 Michigan Electric Co+

, REC IP, NAME RECIPIENT AFFILIATION OENTONr HeRe Of fice of Nuclear Reactor Regulationz Director

SUBJECT:

Requests, working gl'oup meeting w/NRCiAmerican Electric Power Svc Corp 8 Franklin Research Ctr to review Technical Evaluation Rept on environ equipment qualification finding

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INDIANA IIt MICHIGAN ELECTRIC COMPANY P. O. BOX 18 BOWLING GREEH STATION HEW YORK, H. Y. 10004 January 24, 1983 AEP:NRC:0775 Donald C. Cook Nuclear Plant Unit Nos.

1 and 2

Docket Nos. 50-315 and 50-316 License Nos.

DPR-58 and DPR-74 REQUEST FOR NRC/FRC/AEPSC ENVIRONMENTAL EQUIPMENT QUALIFICATION (EQ) MEETING Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.

20555

Dear Mr. Denton:

By letter dated December 30, 1982, Mr. S. A. Varga (NRC) transmitted to Indiana

& Michigan Electric Co.

(I&MECo.) the Safety Evaluation Report (SER) for the Environmental Qualification of Safety-Related Electrical Equipment at the D. C. Cook Nuclear Plant Unit Nos.

1 and 2.

This letter and its Attachment acknowledge the receipt of the SER and request that a working group meeting be held to discuss several points of concern in the TER prepared by your consultant.

We expect the meeting to be attended by members of your staff, American Electric Power Service Corporation (AEPSC) personnel and/or AEPSC's consultants, and the NRC's consultant on Equipment Qualification (EQ) for the D. C.

Cook Nuclear Plant, i.e., the Franklin Research Center (FRC).

Furthermore, for the reasons presented in the Attachment, we are requesting extensions on the response deadlines noted in Mr. S.

A.

Varga's letter referenced above.

This document has been prepared following Corporate Procedures which incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned.

Very truly yours, RSH/os

~

cc:

(attached)

R. S. Hunter Vice President SS01Slooaa Saoia4 PDR ADOCK 05000315 P

PDR

f l

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Mr. Harold R.

on AE

. C:0775 cc:

John E. Dolan Columbus M. P. Alexich R.

W. Jurgensen W. G. Smith, Jr.

Bridgman R.

C. Callen G. Charnoff NRC Resident inspector at Cook Plant Bridgman

Attachment to AEP:NRC:0775 As stated in the SER attached to Mr. S.

A. Varga's letter of December 30,

1982, we are being requested to review FRC's Technical Evaluation Report (TER) on EQ issues at the D. C. Cook Plant, and inform the NRC within seven (7) days of receipt of the SER whether any portions of certain identified TER pages still require proprietary protection.

We first want to state for the record that we did not receive the entire TER (4 volumes) along with Mr. S. A. Varga's letter.

We did not receive the two Volumes 2 of 2 (one for each Unit) until January 17, 1983, after having placed a request with our NRC Project Manager on January 14 to complete the transmittal.

In response to the NRC request identified above we note that most, if not all, of the proprietary information in FRC's TER has been obtained from manufacturers'nd vendors'quipment descriptions and test reports.

Thus, at present, we believe that any proprietary material used in FRC's review has been deemed so by the manufacturers and vendors, and is unlikely to be reclassified.

We are pursuing this matter further and will, as requested by the SER, specifically identify the proprietary information and the specific rationale and justification for protection from public disclosure, consistent with the criteria of 10 CFR 2.790(b).

Our initial review of the TER has indicated that a working group meeting to be attended by NRC,

FRC, and AEPSC personnel would be beneficial to our understanding of FRC's findings and NRC expectations regarding the format and specificity of our future responses to the SER.

We are thus requesting that arrangements be made for such a

meeting.

We trust that this meeting could be held within the next two

weeks, due to the time frame in which our SER responses are required.

We expect that three (3) to six (6) members of the AEPSC staff and/or its consultants would attend this meeting.

The agenda for such a meeting should include an item-by-item review of the TER findings, and a discussion of potential responses to each item.

We believe that a complete review will require a two-day meeting.

Other topics to be discussed during the meeting include, but are not limited to, the following:

1)

Various equipment item reviews in the TER include pages reproduced from our AEP:NRC:0578 submittal dated September 23, 1981.

These pages have, in certain cases, been revised via our June 11, 1982 submittal (AEP:NRC:0578B).

FRC's review does not reflect this fact.

2)

We do not understand FRC's rejection of arguments for equivalence between tested equipment and installed plant equipment.

3)'t is our understanding that the Arrhenius technique was acceptable for extending operating time qualifications.

This technique does not appear to have been accepted by FRC during their review.

4)

The qualification of greases and lubricants was accepted by a previous SER dated May 26, 1981.

The recent TER has rejected the qualification.

What is the new information on which this change of opinion has been based?

5)

Some of the test reports cited in our AEP:NRC:0578 submittal were superceded and/or supplemented by test reports referenced in our AEP:NRC:0578B submittal.

The TER appears to reference, for various items, only -the earlier reports.

We trust that a working group meeting would clear up these points and lead to a common understanding of the NRC's concerns regarding Eg.

Finally, due to the extent of the material to be reviewed and the numerous items to be responded to, we are hereby requesting that the deadlines presented in Mr. S. A. Varga's letter of December 30,

1982, be extended for our SER responses.

In particular, we request.

that our required response regarding justification for continued operation be extended from thirty (30) days after receipt of the SER to thirty (30) days after the above requested meeting is held.

We also request that the response deadline for th'e schedule of proposed corrective actions be extended from ninety (90) days after receipt of the SER to one hundred twenty (120) days after the working meeting date.

We believe these proposed schedules to be realistic and representative of the time required to, hold the meeting, assimilate the views of NRC and FRC, review each item, and prepare the submittals.

Lastly, we request that the deadline for our response regarding justification of proprietary material in the TER be extended by two (2) additional weeks, i.e. until February 18, 1983.

We are presently reviewing the material contained in the FRC assessment, but require more time to contact and receive responses from the equipment manufacturers and vendors.