ML18045A349
| ML18045A349 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/07/1980 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| TASK-03-12, TASK-3-12, TASK-RR NUDOCS 8007110358 | |
| Download: ML18045A349 (2) | |
Text
consumers Power
. company General Offices: 212 West Michigan Avenue, Jackson, Michigan 49201
- Area Code 517 71:~8-0550 July 7, 1980 Director, Nuclear Rea<;:.tor Regulation Att Mr Dennis M Crutchfield, Chief Operating Re~ctors Branch No 5 US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLAi.'IT -
RESPONSE TO THE FRANKLIN RESEARCH CENTER "DRAFT INTERIM TECH.t\\IICAL EVALUATION" REPORT ON EQUIPMENT ENVIRONMZNTALQUALIFICATION FOR PALISADES
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NRC letter dated June 19, 1980 requested our comments on a "Draft Interim Technical Evaluation Report on Equip~ent Environmental Qualificati~n for the Palisades Station." Since we only had seven days to review this document, a detailed ev:lluation was not performed.
However, some of our ccrru:ne.nts on this draft report 9.re as follows:*
The Franklin Research Center (FRC) takes a* very rigid, narrow and :rastric.tive
- interpretation. of the* qual"if ication of electric* equipment rules'.
T'r..:i.s seems unwarranted and excessive since the NRC entitled them. "Guideli.:'.les" when they w~re issued.
In addition, FRC, in some instanc~s, has gone beiond ri~id in-terpretation o.f NRC Guideli:ne.s to include requirements not maationed by the*
NRG.
A Consumers Power Company report was writt~n two years prior to issuance of the NRC Guideiines and the site visit occurred.four-weeks prior to issu~nce of the Guidelines.
It ii urilikely.that our report and ~ite visit response would meet all of the many 'requirements put forth S;r FRC' s im:erpretation of. the Guidelines.
As requested by the NRG, Consumers Power Company intends to submit a new report which,* to tl:_e extent possible, -;.;ill_ address more closely the -HRC Guidelines, 'answer questions. posed by FRC and correct any errors which we have discovered.
Most of the equipment being evaluated. was purchased in 1968.
At that time, no
- Aoo /
requiremerits for equipment q~alification existed beyond what prudent engineer-ing judgment might require to insure the equipment could perform its desigr.
.s 1/0 80071103~*
2 function.
QA documentation requirements did not exist nor did the General Design Criteria (GDC).
Therefore, the NRC should accept qualification documentation more in line with standard industrial practice such as certificates of compli-ance, similarity to tested equipment, engineering analysis and experience as valid qualification unless specific technical reasons to suspect the validity of them can be given.
Since many of the qualification reports being evaluated were written by Franklin Institute and since Franklin seems to stand to gain the majority of any independent requalification work required by the NRC, we feel that NRC personnel should more closely follow and supervise the Franklin work than they appear to have done in the past.
In conclusion, we believe that our report and the work performed to date do provide reasonable assurance that the important equipment in which the safety of the plant relies upon is capable of providing its design function and that resolution of this issue can proceed on a reasonable and normal schedule and that the overall quality of the work will be improved by doing so.
David P Hoffman Nuclear Licensing Administrator CC JGKeppler, USNRC NRC Resident Inspector-Palisades