ML20011A714
| ML20011A714 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 09/11/1981 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20011A711 | List: |
| References | |
| NUDOCS 8110290327 | |
| Download: ML20011A714 (2) | |
Text
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James W Cook rH 3 Vsce President - Projects, Engineering and Construction General Offices: 1945 West Parnell Road, Jackson, MI 49201 * (517) 788-0453 September 11, 1981 Mr J G Keppler, Regional Director Office of Incpection & Enforcement US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND PROJECT -
FURTHER RESPONSE 'IO INSPECTION REPORT NO 50-329/81-11 AND 50-330/81-11 FILE:
0.4.2 SERIAL
13667
References:
1.
Consumers Power Company letter, J W Cook to J G Keppler, dated July 16, 1981 (Serial 12046).
2.
NRC letter, C E Norelius to J W Cook, dated August 12, 1981.
This letter is in response to Item 4 of Reference 1.
Reference 2 raquested a further response regarding Item 4 of Appendix A from NRC Inspectiac Report No 50-329/81-11 and 50-330/81-11. The requested response is given in of this letter.
Consumers Power Company hdf[9 By Jam W Cook Sworn and subscribed to before me on is lith day of September, 1981.
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ATTACHMENT 1 Serial 13667 Item 1 "With respect to Item 4, we disagree with your position that the instrument impulse lines are not required to be identified distinctively as being in the protection system.
This requirement, as stated in Appendix A of the report, is delineated in IEEE 279-1971, Section 4.22.
It is our position that the impulse lines constitute part of an instrument component and thus shall be distinctively identified as indicated in the subject standard."
Consumers Power Response Reference 2 states the NRC's position that the instrument impult a lines of the Reactor Protection System (RPS) constitute part of the inst ument compo-nent and shall be distinctively identified in accordance with 74EE Standard 279-1971.
The Midland Project's position interprets the scope of the IEEE Standard 279-1971 as being from the transmitter to the actuating device. The Project also interprets that the instrument impulse line is beyond the scope of IEEE Standard 279-1971 and does not require distinct identification. The impulse lines are basically an extension of the process line and would conform to ASME criteria.
The basis for the Midland Project's position is as follows:
1.
IEEE Standard 279-1971, Section 1, defines its scope as "...from sensors to actuation device input terminals... "
2.
IEEE Standard 603-1980, Section 2, defines the sensor as "the por-tion of a channel which responds to changes in a plant variable or conditions and converts the measured process variable into the elec-tric or pneumatic signal." This definition clearly indicates the sensor as the transmitter.
3.
The title of Section 5.8 of IEEE Standard 384-1974 clearly indicates that the impulse line is not part of the sensor by stating that both
"... sensor and the connections to the process line... " shall meet the separation criteria.
4.
IEEE Standard 323-1974, Section 3, defines Class IE in part as "the safety classification of electric equipment and systems." The dis-tinction here is " electric. " The standard does not provide any lan-guage which would cause the inclusion of instrument impulse lines within the definition of " electric" equipment and systems.
Based on the above four points, Consumers Power Company believes the Midland Project's position to be correct, justified and in conformance with IEEE Standard 279-1971.
MJS/JWC/da L
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