ML18045A563

Notifies of Procedural Problem in Complying W/Nrc 800523 Memorandum & Order Re Electrical Equipment Qualification. Emergency Radiation Assessment Sys Cannot Invoke IEEE 323-1974.Best Components Consistent W/Order Will Be Used

ML18045A563
Person / Time
Site:	Palisades, Big Rock Point  File:Consumers Energy icon.png
Issue date:	09/02/1980
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 8009040423
Download: ML18045A563 (3)

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• 3eneral Offices: :;:12 Weu Mlchlqan Avenue, Jac1C1on, i*.11chlgan 49201

• io17) 788-0550 September 2, 1980 Director, Nuc.2..ear Reactor Regulation At;t Mr Dennis i*I Crutchfie.j.d, Chief Operating Reactors Branch No 5 U S Nuclear Regulatory Commission Washington, D C 20555 DOCKETS 50-155 & 50-255 - LICENSES DPR-6 & 20 -

BIG ROCK POINT AND PALISADES PLANTS -

QUALIFICATION OF ELECTRICAL EQUIPMENT ny letter dated June 25, 1980, the NRC transmitted the Commission's Memorandum and Order (CLI-80-21) dated May 23, 1980. One part of the Memorandum and Order described the Commission's revised position with respect to electrical e~uip ment qualification. The Memorandum and Order (page 7) also states that t:::i.e requirements for replacement parts need not apply if there are "sound reasons to the contrary.

The expressed implementation schedule for NRC staff Safety Evaluation Reports (February l, 1981) and qualification of all safety-related electrical equipment (June 30, 1982)are in conflict with other imposed NRC requirements (eg, TN.I Lessons Learned Implementation schedules). NRC guidance provided to date has not been sufficient to resolve this conflict. Consumers Power Company has attempted to procure electrical equipment to the requirements established in the Commission's Memorandum and Order and has been unable to obtain delivery schedules that are consistent with the required implementation dates for NRC requested modifications. In addition, many suppliers have been unwilling to bid when specifications require conformance with IEEE 323-1974 (see attached examples).

Consumers ?ewer Company has determined that to complete certain NRC requested plant modifications (eg, Palisades Long-Term Cooling, Big Rock Point Modifica-tions to Reduce Personnel Exposure, Big Rock Point Emergency Radiation Assess-

~ent System), our specifications cannot automatically invoke IEEE 323-1974.

Instead, we will use the best_ ~vail~~le __c_ompope~ts wl:!ich _'!'ill_ b~ _at least COI),$i:?-

tent with-originai plant sp~cifications arid meet the intent of the Memorandum a~d Crder to the extent permissible with respect to schedular restraints. The upgrad-ing, if necessar-y, of any equipment so purchased will be addressed when the NRC

~inalizes its position on environmental qualification for Palisades and Big ?oc~

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• Director, Nuclear Reactor Regulation September 2, 1980

?alisad.es Zt Big Rock Point Plants Point. Consumers Power Company must emphasize that delays in the development of final NRC positions will dictate the schedule for qualification of electri-cal equipment.

David P Hoffman Nuclear Licensing Administrator CC Director, Region III, USNRC URC Resident Inspector - Palisades NRC Resident Inspector - Big ROck Point Attachment

ATTACHMENT Examples of Procurement Problems Class lE Electrical Equipment Qualification to IEEE 323-19711 Prospective Did Outcome Plant Project Equipment Bidders Schedule Impact Big Rock Point TMI Modifications to Motor Control Center/ No bids-critical Reduce Personnel Circuit Breaker path equipment Exposure Palisades Long Term Cooling Motor Control Center 9 No bids-critical patl1 equipment Pi;..lisades Long Term Cooling Valves with Actuators On order Qualification of actuators makes delivery schedule critical path Pulisades Long Term Cooling Panel Mounted Indicators Similar problerns DC Power Supplies as indicated above expected when bid