ML18046A194

Discusses NRC 801024 Orders for Mod of Environ Qualification of safety-related Electrical Equipment.Advises That Mod for Facilities Is Governed by SEP Topic III-12.All safety- Related Electrical Equipment Shall Be Qualified by 820630

ML18046A194
Person / Time
Site:	Palisades, Big Rock Point  File:Consumers Energy icon.png
Issue date:	11/26/1980
From:	Vincent R 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 8012020479
Download: ML18046A194 (2)

Text

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General Offices:* 212 West Michigan Avenu_a, Jackson, Michigan* 4920_1 * *(517) 788-0850 November 26, 1980 Director, Nuclear Reactor. Regulation *

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At_t Mr Dennis M Crutchfield, Chief ' --

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Operating Projects Branch No 5 U S Nuclear Regulatory Commission .;>

• .A Washington, DC 20555 DOCKET 50-255 LICENSE DPR-20 &

DOCKET 50-155 - LICENSE DPR PALISADES AND BIG ROCK POINT PLANTS -

CLARIFICATION OF OCTOBER 24, 1980, ORDERS . CONCERNING ELECTRICAL EQUIPMENT QUALIFICATION On.October 24, 1980, the NRC issued Orders for Modification of the Palisades and Big Rock Point licenses whi°ch cencerned the environmental qualification of.

safety-related electrical equipment. This issue for Palisades. and Big Rock Point Plants is . governed by the Systematic Evaluation Program as Topic III..:12.

In summary~ these Orders require that:

• a.. All safety-related electrical equipment shall .be qualified for the expected operating qr accident environment by June 30, 1982,: and b . . Complete and audi table records which document the degree of compliance with qualification requirements shall b.e a-.railable at a* c.entral

• location by December*1, 1980, and thereafter maintained carrent.

Because of some.confusion between the implementation letters for SEP Topic III-i2.

• IE Btllletin 79-0lB. and supplements. (not applicable to SEP. plants), the various public meetings on thi.s subject, and the. wording of the Orders which included Technical Specification changes, *it was considered necessary to document our

. understanding of .these. requirements.

First, the requirement to have centrally located complete and auditable electri~

• cal equipment qualification (EEQ) records by_ December 1, 1980, will initially pertain to only those specific safety-related compbnents*for which reports were req11ired to be submitted to the NRC by November 1,. 1980. The equipment scope .

. fer these reports (submitted October 7, 1980, and Oct.ob er 30, 1980, for Palisades and October 3i., 1980, for Big Rock* Point) . was defined in the September 19, 1980, Orders. modifying Palisades. and Big Rock Point licenses, and included only that.

safety-related equipment identified in accordance with NRC letters of March 6, '

-.1980, and March 28; i980~ and subsequent discussions with the staff. These. files I, .

presently exist a.:d wi:l be maintai~ed. on an int~r:im basis in the Consumers . ~"?. ~

Power* Company o~fices .in Jackson, Michigan. Ultimately these files may. be X' " W transferred* to the. plant*. sites. * . \.

Mr Dennis November 26, 1980 MCrutchfield

• 2 Second, as equipment is modified; additional qualification information .is receiv-ed, or additional equipment .is. installed (including that resulting from TMI Action*

Plan requirement's) , the EEQ files must be updated and maintained current. To this end, appropriate quaj.ifiCation information will be added to these files as it becomes available. We recognize the requirement to have all safety-related electrical equipment qualified for the appropriate environments by June 30, 1982, and to have proper supporting documentation.* Since no additional requirements now exist for us to .submit EEQ information beyond that addressed by the September 19, 1980, Orders, this approach will fully comply with present requirements.

Third; the .term "all safety-relate.d electrical equipment" as used in the October 2~,

1980, Orders is as defined,in Section 3.0 of the NRC staff "Guidelines for Evaluat-ing Environmental Qualification of Class lE Electrical Equipment in Operating Reactors". As stated in these Guidelines, transmitted as attachments to the Orders, this includes "all electrical equipment needed to achieve emergency reactor shut-down~* containment isolation, reactor core. cooling, containment and reactor heat removal, and prevention of significant release of radioactive material to the environment.

Fourth~ .for that safety-related electrical equipment which is located in non-hostile environments., and was .therefore not included in the scope of the Septem-ber 19, 1980, Orders, appropriate qualifications and any supporting documentation must be. obtained by June 30, 1982. This documentation w:lll be added to the EEQ.

files as it becomes available. However.~ it is not presently required that this.

additional information be submitted to the NRC.

Consumers Power company believes that the above discussion accurately states the*

requirements now' applicable to the Palisades and Big Rock Point Plants. Several of the above points were discussed with the NRC' s Mr DiBenedetto on November 25.,

1980, and do reflect our understanding of the NRC staff's intent as derived from.

that discussion.

• Robert A Vincent.

St.aff Licensing Engineer CC Director, USNRC,

• Re.gion III NRC Resident Inspectors - Palisades &: Big Rock Point Plants

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